[Pharmwaste] RD Papework

Jeff Hollar jhollar at pwaste.com
Wed Sep 29 11:18:33 EDT 2010


William,

Regarding Reverse Distributor (RD) paperwork:  I spoke to a state board
agency that indicated to me that they expect the generator (hospital
pharmacy) to review the non-creditable inventory list they receive from the
reverse distributor and note the hazardous waste sent back.  If there is a
history of a particular item that is being sent back that shows a pattern of
its disposition being non-creditable hazardous waste, then they are not to
send this pharmaceutical back to the reverse distributor for processing.
For this very reason at least one company has a website feature that allows
the user to scan in the NDC/UPC and review the manufacturer's return policy
information.  Can one realistically expect the generator to go through past
RD reports, evaluate and make inferences???

 Jeff Hollar

President

PharmWaste Technologies, Inc.

4164 NW Urbandale Dr., Ste A

Urbandale, IA 50322

515-276-5302 (general)

515-331-7310 (direct)

515-360-9785 (cell)

 <http://www.pwaste.com/> www.pwaste.com

 

From: William More [mailto:wamore at gw.dec.state.ny.us] 
Sent: Thursday, September 23, 2010 3:03 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Re: Pharmwaste Digest, Vol 59, Issue 13

 


So what are your states saying to the retail pharmaceutical sellers, i.e.
drug stores, as to the proper way to dispose of the non hazardous, non DEA,
non RMW, waste pharmaceuticals?

 

Have any of the your states done any outreach to them, the drug stores?

 

Is anyone doing Hazardous Waste Inspections of the Pharmacies at Drug
stores?  What kind of compliance issues are coming up(other than the film
developer) with the handling of the Pharmacy wastes?

 

And in a different direction, has anybody complied, from "non credited
returns" paperwork, a list of companies that don't ever give credit for
attempted return of pharmaceuticals?  From that massive pile of paper that
the hospital or pharmacy or nursing care facility gets after the Reverse
Distributor takes it all away for them, does anyone ever look at them and
make a determination that there are Hazardous Waste that would not ever be
expected to be "credited"?

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