[Pharmwaste] RE: Request to NCPA to modify their web page about drug mail backs.

[Gressitt, Stevan]

Many of us have run across a number of difficulties in attempting to
provide a consumer-friendly unused medicine disposal process. There have
been instances of individuals using this context to engage in frankly
illegal acts and have been prosecuted. That makes it difficult for those
attempting to follow the rules and regulations that are in existence
today as increased scrutiny, fear, or hesitation makes engaging others
perhaps more difficult. It is good news on the one hand that the White
House Office of National Drug Control Policy points to the explicit need
for more drug return programs, yet there will be those who take
advantage of those who do not know better and create programs or
situations that will interfere with the progress we all are trying to
make.

 

Maine has a mailback pilot test program which does indeed take
controlled drugs, but is NOT a permanent sustainably funded program. 

 

It is solely a proof of concept test. 

 

We believe it has been successful and replicable when the proper
legislation can be enacted to enable such an extension. It is our
understanding that indeed that legislation is before congress which will
enable DEA to move forward toward perhaps multiple different processes
across the country which will at the same time not enable industrial
scale diversion of controlled drugs. I doubt anyone on this list does
not want the enabling legislation. 

 

However recently it has come to our attention that a mailback is being
promoted across the country. Those of us in Maine believe it can be
misconstrued to legally accept controlled drugs which it cannot. We
believe it has misconstrued those pharmacies in Maine who have been part
of our pilot as to not being able to accept controlled drugs which is
incorrect 

 

We fear that if indeed this program insists that they have the answer
there will be less interest in attempting to support the congressional
action needed to facilitate the DEA. In short setting us all back. If
the organization wishes to help out, it seems to us they should engage
their community pharmacists in approaching congress and or their
patients to assist with resolving the problems. The simple undersized
statement that "Some limitations may apply" in the smallest typeface on
the web page are not enough notice to indicate an awareness of the steep
hill we have yet to still climb. 

 

 

Stevan Gressitt, M.D., 

 

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