[Pharmwaste] Unwanted med collection event--Boy Scout Eagleproject

Elizabeth Toot-Levy Toot-LevyE at neorsd.org
Thu Apr 29 14:46:00 EDT 2010


In addition, in Ohio you must have written permission from the Ohio DEA
to hold a pharmaceutical collection even.  We have worked in Northeast
Ohio (Cleveland area) for a number of years trying to come up with fully
legal collection events and have run into roadblock after roadblock. 
Late last year, Ohio EPA put out a guidance document on how to do a
legal collection event in Ohio.  As we are learning this guidance
document also contains a number of problems (as an example, the guidance
indicates that it is possible for sewage sludge incinerators to
incinerate collected pharmaceuticals without permit modifications,
however the federal, regional and local air pollution authorities will
not allow this to happen).  Ohio DEA also has strict requirements for
the law enforcement officials involved in any collection events.
 
Here is a link to the Ohio Guidance document
http://www.epa.ohio.gov/LinkClick.aspx?fileticket=69l3sgdFwdw%3D&tabid=1763

 
While, I applaud the ideas of this Eagle Scout and the amount of work
he has obviously already put into this project, I think that he has a
long way to go before he could actually have a legal project in Ohio.  I
will be more than happy to provide as much information as I can, but
before he can move forward, he needs to get permission from the Ohio
DEA.  
 
Please feel free to contact me.
 
Elizabeth Toot-Levy
Environmental Specialist 
Regulatory Compliance
Northeast Ohio Regional Sewer District
toot-levye at neorsd.org 
216-641-6000
 

>>> "Charlotte A. Smith" <csmith at pharmecology.com> 4/21/2010 9:45 AM
>>>
Because prescription drugs are involved, even though non-controlled,
some state agencies have required law enforcement to be in control of
all drugs. Each program must check with their state board of pharmacy,
and any additional agencies that have jurisdiction, including controlled
substances boards, etc. 

Best regards, 

Charlotte A. Smith, R. Ph., M.S., HEM
Director, PharmEcology Services
WM Healthcare Solutions, Inc.
12229 W. North Ave., Suite 2
Wauwatosa, WI 53226
414-292-3959
713-725-6363 (cell)
414-479-9941 (fax)
csmith at pharmecology.com 

Waste Management’s renewable energy projects create enough energy to
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-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
Matthew C. Mireles
Sent: Monday, April 19, 2010 5:38 PM
To: Nancy Busen; Susan Zabo; sfmeier at aol.com;
pharmwaste at lists.dep.state.fl.us 
Subject: RE: [Pharmwaste] Unwanted med collection event--Boy Scout
Eagleproject

Law enforcement is required ONLY for controlled substances.  The chain
of custody (including completion of FORM DEA-41) applies to ONLY
controlled substances.  DEA provides an exemption to all law enforcement
(sheriff, state trooper, constable, US Custom, FBI, deputized citizens,
etc...NOT firemen, EMS, non-law enforcement security guards, etc.) to
receive and destroy controlled substances.  Refer to 21 CFR Part 1300,
Section 1301.24: Exemption of Law Enforcement Officials.  Consider
collecting ONLY non-controlled drugs.

One important issue about unused and expired medicines is "pharming"
among teens.  I highly recommend the Eagle Scout candidate to consider
adding a health education/health promotion about the dangers of
"pharming".  The National Center for Patient Education and Information
(NCPIE at www.ncpie.org) has materials for young leaders (influencers)
to increase awareness of the dangers of pharming.  Just an added value
idea for Eagle Scout badge.

We had an unfortunate near-fatal case with a Boy Scout who was
experimenting (pharming) his parents' medicines.  


Matthew Mireles


-----Original Message-----
>From: Nancy  Busen <NBusen at bentonvillear.com>
>Sent: Apr 19, 2010 10:56 AM
>To: Susan Zabo <SusanZ at ohanet.org>, sfmeier at aol.com,
pharmwaste at lists.dep.state.fl.us 
>Subject: RE: [Pharmwaste] Unwanted med collection event--Boy Scout
Eagleproject
>
>This is what we were told when starting our Pharm Waste program.
>
>The pharmaceutical waste must be accompanied by law enforcement to
the
>destination for destruction and a chain of custody signed indicating
>that the officer observed the contents were put into the incinerator.
>
>I assume that an off duty officer could volunteer his/her time to
reduce
>costs. 
>
>Nancy Busen
>Bentonville, AR
> 
>
>-----Original Message-----
>From: pharmwaste-bounces at lists.dep.state.fl.us 
>[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Susan
>Zabo
>Sent: Monday, April 19, 2010 9:45 AM
>To: sfmeier at aol.com; pharmwaste at lists.dep.state.fl.us 
>Subject: RE: [Pharmwaste] Unwanted med collection event--Boy Scout
>Eagleproject
>
>I am not sure, but I have been trying to come up with away to help
this
>Scout, but was advised by an attorney on staff to ask this, does
anyone
>have any opinions.
>
>I suggest you alert the assistant SM to the DEA requirement,
hazardous
>waste regulatory aspects (fines and prison), and probably other
>obstacles to his proposal.  E.g., if he or the troop rents a truck,
my
>legal opinion is that he/they have taken possession of the hazardous
>waste and will be illegally managing it including transporting it
>without proper manifest, container, etc.
>
>Susan Zabo
>Ohio Hospital Association
>Pollution Prevention Coordinator Consultant
>614.738.2186
>
>http://www.ohanet.org/Issue/Environmental%20Protection 
>________________________________
>From: pharmwaste-bounces at lists.dep.state.fl.us 
>[pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
sfmeier at aol.com 
>[sfmeier at aol.com] 
>Sent: Saturday, April 17, 2010 6:35 AM
>To: pharmwaste at lists.dep.state.fl.us 
>Subject: [Pharmwaste] Unwanted med collection event--Boy Scout Eagle
>project
>
>We have a Boy Scout that would like to hold an unwanted med.
collection
>event in the fall in Ashtabula County in Northeast Ohio for his Eagle
>project.  He has recruited pharmacists, law enforcement officials, a
>troop full of volunteers, and has found a host of "how to hold an
event"
>guidelines online but has run into one roadblock -- disposing of the
>meds.  A local hospital told us it could cost us a thousand dollars
if
>he has a successful event. (that's a lot of car washes).  Covanta
will
>do it for free if we rent a truck and deliver it to their plant in
>Niagara Falls. (not very eco-friendly and will a rent-a-truck company
>let us transport meds across state in their trucks?).
>
>We're looking for suggestions and/or help for this scout for what I
>think could be a very worthwhile project.   His plans include
>public-education on this topic with handouts so the opportunity for a
>sponsorship is there.
>
>Thanks for your help,
>Steve Meier, Asst Scoutmaster Troop 383, Mentor OH
>
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