[Pharmwaste] Unwanted Medicine - Police Station Drop Boxes -RESULTS

Wed May 19 11:41:41 EDT 2010

For MN:
Illicit drugs/controlled substances confiscated by law enforcement during drug busts is considered by EPA to be business generated waste. In MN controlled substances/illicit drugs are considered to be haz waste. If the amount confiscated does not exceed the CESQG limits, some states may allow for incineration at SW facilities.  MN does not, it must go to a HW incinerator for witnessed burn.

Household pharms collected by law enforcement are considered to be household waste. As noted above controlled substances are considered to be HW, so in MN, controlled substances generated by households are household hazardous waste (HHW). HHW iis not regulated by EPA. Each state's HHW program and/or HW program has rules/management standards that need to be followed for legal disposal of HHW.  In MN, the only disposal currently allowed is HW incineration. However, we're working on opening up a pathway for SW/WTE incineration within MN for all household pharms, including controlled substances.  The pathway we're working through is based on our specific rules and statutes, so it would not likely work in another state.

40 CFR, EPA's regulations should not apply to HHW pharms, it applies to pharms generated by the medical industry and confiscated by law enforcement.  I also believe states vary on whether they designate controlled substances to be haz waste. in MN they are HW unless proven otherwise due to our lethality characteristic.  No one has tried to prove otherwise.

I don't know if that all helped, but that is one of the problems. Every state has a DEA with more or less support for these programs. There is inconsistency in the types of collection options that DEA will approve across the US.  Every state also has a Board of Pharmacy with varying statutes related to possession of pharms.  And every state manages CESQG HW and HHW slightly differently based on their rules and statutes.

JV

________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jessica Willard [JWillard at kdheks.gov]
Sent: Wednesday, May 19, 2010 9:19 AM
To: 'Grasso, Cheri'; VeoraLittle at aol.com; Brandon.Kernen at des.nh.gov; Stevan.Gressitt at maine.gov; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Unwanted Medicine - Police Station Drop Boxes -RESULTS

I have been following the pharmaceutical take back discussion for the last month. We are interested in implementing a model here in Kansas. But I would really like to know what happens to the controlled substances collected by law enforcement.  Specifically how, what size, and where they are incinerating the controlled substances.  Title 40 Chapter I Subchapter C Part 60 appears to block incineration of pharmaceuticals by other solid waste incineration units, however I have heard of other states using them.  Can anyone please help me to answer this question? Thanks

Jessica Willard
Environmental Scientist
Household Hazardous Waste Program Manager
Kansas Dept of Health & Environment
jwillard at kdheks.gov
________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Grasso, Cheri
Sent: Tuesday, May 18, 2010 6:41 PM
To: VeoraLittle at aol.com; Brandon.Kernen at des.nh.gov; Stevan.Gressitt at maine.gov; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Unwanted Medicine - Police Station Drop Boxes -RESULTS

Washington State DEA allows controlled substances (and other medicines) to be returned to police stations.  There are over 40 ongoing medicine return programs at law enforcement offices.  See www.medicinereturn.com<http://www.medicinereturn.com/>

The law enforcement office contacts the local DEA with their request, and DEA has a standard letter they send out allowing the medicine return.

There have been no problems with the medicine return programs either at law enforcement offices or pharmacies in Washington State.

Cheri Grasso

Cheri Grasso
Pharmaceuticals Project
Local Hazardous Waste Management Program in King County
130 Nickerson Street, Suite 100 | Seattle, WA  98109 | 206-263-3089
www.lhwmp.org
________________________________
From: VeoraLittle at aol.com [mailto:VeoraLittle at aol.com]
Sent: Monday, May 17, 2010 2:01 PM
To: Brandon.Kernen at des.nh.gov; Stevan.Gressitt at maine.gov; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Unwanted Medicine - Police Station Drop Boxes -RESULTS

Don't forget Florida, for some reason this may not have reached you so I am resending. thanks.
Veora Little, CRNA, Naples, Florida, veoralittle at aol.com
1)       What state do you work in or represent?
Collier County, Florida (DrugFreeCollier, a substance abuse coalition.)
        2)       Are police station drop boxes allowed or prohibited in your state?
Yes they are allowed, we have them at 2 police and sheriff's office(total 3)  Our medical examiner also will collect all drugs including controlled substances at her office.
   3)       Is there specific guidance or legal requirements associated with the drop boxes beyond obtaining DEA waivers and complying with haz waste rules/exemptions?
Law Enforcement presence at all times is a requirement.  We have a letter from DEA stating we run program within their guidelines.  No waiver necessary.  All medications are collected as abandoned property and incinerated as evidence. Medical Examiner has statutes that allow them to house these substances, they incinerate as well..
        4)       Have there been any problems with police station drop boxes in your state?
              No, just lots of very happy citizens sharing they want a place to bring their old medications.  We also do a collection event, "OPERATION MEDICINE CABINET" two times a year at 10 locations throughout the county to collect in convenient locations, Law Enforcement is present at these events. Next event November 13, 2010, join us.  Happy to share any information.  veoralittle at aol.com<mailto:veoralittle at aol.com> Thanks.

In a message dated 5/17/2010 4:57:22 P.M. Eastern Daylight Time, Brandon.Kernen at des.nh.gov writes:
Respondents explained that eight states (CA, FL, ID, MN, ND, NM, UT, WI) have one or more police station drop boxes.  Additionally, I am aware of five other states (AR, MA, ME, NH and TN) where drop boxes are present. Two states described some issues associated with small businesses disposing their unwanted pharmaceuticals in the drop boxes as well as other materials such as sharps.  These problems were addressed through education and/or placing the drop boxes in an area that could be scrutinized more closely.

Two replies to my inquiry indicated that police station drop boxes are not present in IN or VA.

While some states have general requirements/guidelines associated with the collection of controlled substances, I did not receive any responses that indicate states have developed detailed guidance for constructing and operating a police station drop box. Instead, local police stations are sometimes developing and implementing their own procedures.

No attempt was made to determine the status of police drop boxes in states that no one responded about.

This information people provided was very helpful in broadly addressing some questions and concern from policymakers in NH.  Thank you!

I did get a lot of detail from some respondents and can forward the package of responses I received if anyone wants them.

Regards

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
-----Original Message-----
From: Gressitt, Stevan [mailto:Stevan.Gressitt at maine.gov]
Sent: Monday, May 10, 2010 10:24 AM
To: Kernen, Brandon; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Unwanted Medicine - Police Station Drop Boxes

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/

Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s).  It may contain confidential and privileged information.  Any unauthorized review, copy, use, disclosure, or distribution is prohibited.  If you are not the intended recipient, please note that any dissemination, distribution or copying of this is strictly prohibited.  Please contact me by reply e-mail or telephone and destroy all copies of this message.
The Department of Health and Human Services (DHHS) does not discriminate on the basis of disability, race, color, creed, gender, sexual orientation, age, or national origin, in admission to, access to, or operations of its programs, services, or activities, or its hiring or employment practices.  This notice is provided as required by Title II of the Americans with Disabilities Act of 1990 and in accordance with the Civil Rights Act of 1964 as amended, Section 504 of the Rehabilitation Act of 1973, as amended, the Age Discrimination Act of 1975, Title IX of the Education Amendments of 1972 and the Maine Human Rights Act and Executive Order Regarding State of Maine Contracts for Services.  Questions, concerns, complaints or requests for additional information regarding the ADA may be forwarded to DHHS’ ADA Compliance/EEO Coordinators, 11 SHS-221 State Street, Augusta, Maine 04333, 207-287-4289 (V), 207-287-3488 (V), 1-800-606-0215 (TTY).

________________________________
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

---
Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients.
---
TO SUBSCRIBE, go to:   http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe at lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank.
If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste
FOR PROBLEMS:  Contact List Administrator Laurie.Tenace at dep.state.fl.us
SEND MAIL to the list server at:  pharmwaste at lists.dep.state.fl.us
-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20100519/c65bca0e/attachment-0001.htm