[Pharmwaste] Unwanted Medicine - Police Station Drop Boxes

Tue May 11 13:29:48 EDT 2010

I'm currently surveying all pharma collection sites in California to comply with our SB 966<http://www.leginfo.ca.gov/pub/07-08/bill/sen/sb_0951-1000/sb_966_bill_20071012_chaptered.html> so I have a pretty good handle on all the roughly 45 law enforcement sites in the state - although I'll know more after all the results come in.
1)       What state do you work in or represent? California
2)       Are police station drop boxes allowed or prohibited in your state? SB 966 mandated that my agency create model program guidelines<http://www.calrecycle.ca.gov/HomeHazWaste/Medications/ModelProgram/Criteria.pdf>, which are now the leading officially-sanctioned guidelines in California.  Those non-mandatory guidelines include language specific to law enforcement programs, and SB 966 includes this statement:
(d) Model programs deemed in compliance with this article shall be deemed in compliance with state law and regulation concerning the handling, management, and disposal of drug waste for the purposes of implementing the model program.
3)       Is there specific guidance or legal requirements associated with the drop boxes beyond obtaining DEA waivers and complying with haz waste rules/exemptions?
You're welcome to look through our 15-page guidelines<http://www.calrecycle.ca.gov/HomeHazWaste/Medications/ModelProgram/Criteria.pdf> since much of it touches on law enforcement and controlled substances issues.  However, these two provisions stand out:
For controlled substances, the signed inventory must accompany the pharmaceutical waste and must stay with law enforcement in the evidence storage locker and through the point of destruction. Before the home-generated pharmaceutical waste is destroyed, the contents must be checked against the inventory to ensure that there has been no diversion. This is a U.S. Drug Enforcement Agency law.
Events:
c. Law Enforcement - Law enforcement may participate in a collection event to provide security for event personnel. This is optional and at the discretion of collection organizers. A law enforcement officer is only required to attend and participate in a collection event only if controlled substances are to be accepted at the event. Per U.S. Drug Enforcement Agency (DEA) law, only a law enforcement officer may accept controlled substances from the consumer. If controlled substances will be accepted, the operator of the event shall ask the law enforcement agency that is providing the officer if the agency has any specific requirements that the event must adhere to. For example, the law enforcement agency may specify the type of packaging that the drugs must be contained in to be accepted into their evidence locker, or if the containers the collection event will provide, are adequate for the law enforcement agency purposes. For controlled substances only, law enforcement must be on site at all times and be able to see the collection and movement of the home-generated pharmaceutical wastes from the public to the collection location. Law enforcement must be able to see the transfer of home-generated pharmaceutical wastes from vehicles to the collection containers. The operator should coordinate with law enforcement to determine the appropriate position for law enforcement to be stationed.
4)       Have there been any problems with police station drop boxes in your state?
One program has their drop-box under surveillance in the parking lot about 50 feet from the entrance to their law enforcement facility.  They said they had some trouble with what they were assuming were small businesses dropping off a lot of pharmaceutical waste and/or sharps but that may have worked itself out by now.  They also told me if they had to do it over again, they wouldn't recommend putting the bin in the parking lot if for no other reason because of the inconvenience of emptying the box that's 50 feet away.

There's another program that has secure collection bins in pharmacies (and at law enforcement locations) but only allows law enforcement to collect the waste including controlled substances.  The DEA told them they didn't like that and would follow up with an official letter saying that, but it's been about 9 months now and they still haven't received that letter.

You're welcome to contact me directly if you'd like contacts or more details.

Burke

Mr. Burke Lucy
Integrated Waste Management Specialist
Department of Resources Recycling and Recovery (CalRecycle)
(formerly California Integrated Waste Management Board)
1001 I Street, PO Box 4025
Sacramento, CA 95812
Burke.Lucy at CalRecycle.ca.gov
916.324.6848

IMPORTANT!  Effective May 1, 2010, the only active work-related E-mail address for me will be Burke.Lucy at CalRecycle.ca.gov<mailto:FirstName.LastName at CalRecycle.ca.gov>. any E-mail messages sent to my prior BLucy at CIWMB.ca.gov address will not be forwarded. Please update any contact or address book entries by that date to ensure that your E-mail messages will be correctly routed to me. Thank you!

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of MARIA DIMEGLIO
Sent: Tuesday, May 11, 2010 10:09 AM
To: Brandon Kernen; pharmwaste at lists.dep.state.fl.us; Stevan Gressitt
Subject: RE: [Pharmwaste] Unwanted Medicine - Police Station Drop Boxes

1)       What state do you work in or represent?

           California

2)       Are police station drop boxes allowed or prohibited in your state?

          Not sure

3)       Is there specific guidance or legal requirements associated with the drop boxes beyond obtaining DEA waivers and complying with haz waste rules/exemptions?

         Not sure

4)       Have there been any problems with police station drop boxes in your state?

              Not sure

I would be interested to see the survey results.

Maria Francesca Di Meglio, M.S.
Public Works Department
City of Alameda
Phone:  (510) 749-5840
FAX:     (510) 749-5867
email: mdimegli at ci.alameda.ca.us<mailto:mdimegli at ci.alameda.ca.us>

"If it can't be reduced, reused, repaired, rebuilt, refurbished, refinished, resold or recycled then it should be restricted, redesigned or removed from production."    Pete Seeger

>>> On 5/10/2010 at 7:23 AM, <Stevan.Gressitt at maine.gov> wrote:
I'd be very interested in seeing the result of this survey.Please?

Stevan Gressitt, M.D., Medical Director
Office of Adult Mental Health Services
Department of Health and Human Services
Marquardt Building, 2nd Floor
11 State House Station
32 Blossom Lane
Augusta, ME  04333-0011
Ph: (207)287-4273
Fax: (207)287-1022
Cell Phone: (207) 441-0291
E-Mail : stevan.gressitt at maine.gov<mailto:stevan.gressitt at maine.gov>
http://www.maine.gov/dhhs/mh/

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________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Kernen, Brandon
Sent: Monday, May 10, 2010 8:59 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Unwanted Medicine - Police Station Drop Boxes

NH is considering clarifying state law to allow for police stations to have drop boxes for unwanted/expired medicine.  Although some of these exist in NH already, NH state law inadvertently does not permit these at this time.

I would appreciate if you could answer the following questions:

1)       What state do you work in or represent?
2)       Are police station drop boxes allowed or prohibited in your state?
3)       Is there specific guidance or legal requirements associated with the drop boxes beyond obtaining DEA waivers and complying with haz waste rules/exemptions?
4)       Have there been any problems with police station drop boxes in your state?

Thank you

Brandon Kernen, PG - Supervisor, Hydrology and Conservation Program
Drinking Water and Groundwater Bureau  Phone: 603 271 0660/Fax: 603 271 0656
http://des.nh.gov/organization/divisions/water/dwgb/dwspp/index.htm

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