FW: [Pharmwaste] DEA and Post consumer medications

Fri Oct 22 13:22:39 EDT 2010

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From: Howard Anderson [mailto:ndboph at btinet.net]
Sent: Friday, October 22, 2010 11:39 AM
To: 'Matthew C. Mireles'; 'Stevan Gressitt'; 'pharmwaste'
Cc: 'Caverly, Mark W'; Joe Cappello; Jackie L Henderson; Bonnie Thom; 'Bonnie Thom'; 'David Lindell'; 'Dewey'; Gary Dewhirst; 'Gayle Ziegler'; Gayle Ziegler; 'Gerald R. Johnson'; 'Judy Swisher'; Justin Stubstad; 'Laurel Haroldson (E-mail)'; 'Rick Detwiller'; william.grosz at netzero.net
Subject: RE: [Pharmwaste] DEA and Post consumer medications

Dear Dr. Gressitt Mr. Mireles and others:

Please do not get the DEA into the collection business. They should be writing simple regulations to allow Pharmacies, Boards of Pharmacy, Pharmacy Organizations, Return Companies, Police Departments and others to do the collection and disposal.

If the DEA wants data there should be a simple online data collection tool that can be used by everyone. It should have a big section for unidentified medication.

Keep in mind that these are consumer medications, they are a very small part of what is manufactured in the first place, and we want them off the street when they are no longer being used as prescribed.

Please minimize the (hazardous, nonhazardous, household waste) concerns and make it as easy as possible to get these to disposal sites, or you will only succeed in impeding the process. Forget about the waste generator idea, these were generated by the manufacturer when he made the stuff in the first place. These are all going someplace now, so do your research once the new methods are in place and then come up with constructive tweaks, once you have identified significant issues.

We have a pretty good ongoing program in North Dakota between our pharmacies and the Attorney General's office, with participation by many local sheriffs and police departments. Please do not sabotage it by adding several more layers of complexity to the process.

Sincerely,

Howard

Howard C. Anderson, Jr.,R.Ph.
Executive Director
North Dakota Board of Pharmacy
1906 E. Broadway Ave.
P.O. Box 1354
Bismarck, ND  58502-1354
Phone (701) 328-9535
Fax (701) 328-9536
Web site www.nodakpharmacy.com
________________________________
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: Friday, October 22, 2010 10:11 AM
To: Stevan Gressitt; pharmwaste
Subject: Re: [Pharmwaste] DEA not collaborating with american medicine chest

Dr. Gressitt, we attended a special debrief in Houston with local DEA agents and we learned about the same thing---nobody knows what's going on.   I understand that DEA field officers are convening in DC with Cathy Gallagher and others to get a handle of the new Secure and Responsible Drug Dispoal Act, 2010.  Our impression is that the DEA may want to unilaterally lead this campaign but they are strictly concerned with drug diversion.  The purposes of the debrief was to recap on the "success" of drug collection in Harris Co. and to solicit ideas from the audience of mostly law enforcement about concerns and questions that should be asked in DC next week.

here is our list:

1.  how does the DEA define unused and expired medicines?  (hazardous, nonhazardous household waste, etc.)

2.  what collection mechanism would be preferred by the DEA?

3.  what level of accountabilty must be set up to handle and transfer consumers' unwanted narcotics

4.  would the DEA only collect controlled substances?  what about other prescription drugs and legacy drugs?

5.  how would the DEA measure its program and any oversight of other "agencies" approved to collect controlled substances?

6.  what data would be collected, who will collect data, etc.?

7.  would the DEA have manpower and resources to enact the new law?

8.  where is the funds coming from?

9.  would the DEA office be considered a "waste generator", depending on chosen classification or definition of UEMs.

We collected about 3 tons in the county.  The DEA local field office will destroy them via contracted reverse distributor.   In Houston, there is interest for only 2 annual events.  The Sheriff department is already understaff and may not be able to provide personnel.  For a city of 4 million, only one police station participated.  The chief complain was that there wasn't sufficient time and DEA planners want to invest more into promotion and publicity.  The prevailing attitude seems to be setting up secure collection bins for drop offs at designated locations.  The speaker thought direct mailback would invite more tampering and diversion.   There seems to be some misunderstanding about the sources of unwanted meds and whether consumers' controlled substances at home, workplace or on person should be addressed relative to the DEA's concept of a strict, closed-loop system with registrants, etc.

Matthew Mireles

-----Original Message-----
From: Stevan Gressitt
Sent: Oct 22, 2010 7:49 AM
To: pharmwaste
Subject: [Pharmwaste] DEA not collaborating with american medicine chest
I learned at a conference this week for what it is worth that DEA is not collaborating with the american medicinechest drug return in november despite any sponsor claims. There is also a newspaper article I found that sclaims incorrectly that the new law allows a pharmacy to collect controlled drugs. Strange things coming out of the woodwork.

Stevan Gressitt, M.D.
Faculty Associate, University of Maine Center on Aging
Academic Member, Athens Institute for Education and Research
Athens, Greece
Founding Director, International Institute for Pharmaceutical Safety
University of New England, College of Pharmacy
Department of Pharmaceutical Sciences
Associate Professor of Clinical Psychiatry
University of New England, College of Osteopathic Medicine
716 Stevens Avenue
Portland, Maine 04103
gressitt at gmail.com<mailto:gressitt at gmail.com>
Cell: 207-441-0291
www.benzos.une.edu<http://www.benzos.une.edu/>
www.safemeddisposal.com/<http://www.safemeddisposal.com/>

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