[Pharmwaste] Take-back?Mail-back? 100% solutions

Fri Jul 8 11:22:37 EDT 2011

It will be hard to "bullet proof" any diversion program to recycling program.  RCRA and other Federal and state statutes are not configured to accelerate or enhance diversion or recycling (with the exception of a few rules or exemptions), they are designed to prevent further contamination, public heath threats and criminal activity.  These principals often conflict with other  International, Federal or State statutes causing further complications.  It is not just Pharms, but dozens of emerging problematic waste streams and existing standard waste categories that have similar conflicts.

The public does not want the recycling infrastructure near them out of fear of contamination or blight.  Each industry has "vested interests" that don't want change since they control the current process. Manufacturers do not want to incurr the cost of recycling, since the end of life collection problems have so many instutional and local contractual issues in the waste industry to overcome, that that task is currently impossible to overcome and hard to put a price on to incorporate into the cost of goods sold.  Government itself does not like change, eventhough that is there basic mandate.  All the lobbyists for these groups are in a protective mode and their influence modifies change to protect the interests of their groups.

By and large RCRA has served its original purpose to stop runaway mishandling of wastestream in the last 35 years.  To go to a full Resource Conservation ideal it will need to be realigned with other statutes as well.  This will take courage, leadership and lots of coordination at the federal level.  Any thing short of this, and we will continue to nickle and dime our way along, while running into self made obsticles.  I'm not saying to give up, but to continue our current efforts and engage all stakeholders in a long range master effort that is currently lacking.

Matt McCarron
Dept. of Toxic Substances Control
Pollution Prevention - Green Business
700 Heinz Ave. Suite 300
Berkeley, CA 94710

510-540-3828

Your current purchasing decisions affect the success or failure of our future on this planet!!   Buy Green, Invest Green, Act Green, and Teach Green
>>> "Price, John L. "Jack"" <John.L.Price at dep.state.fl.us> 07/08/11 5:43 AM >>>
Jan: Thank you for putting diversion concerns in perspective. While even a single incidence of diversion can have tragic results, we need to acknowledge that the real world precludes us getting to zero diversion. In my opinion, we should not allow the quest for perfection to stop or slow down programs that improve the situation.

Jack

John L. (Jack) Price
Environmental Manager
Waste Reduction MS 4555
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL  32399-2400
Phone:850.245.8751
Fax: 850.245.8811
john.l.price at dep.state.fl.us<mailto:john.l.price at dep.state.fl.us>
www.dep.state.fl.us/waste<http://www.dep.state.fl.us/waste>
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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 Jan Harris
Sent: Thursday, July 07, 2011 5:34 PM
To: Jeff Hollar; 'Stevan Gressitt'; 'pharmwaste'; 'rxnews'
Subject: RE: [Pharmwaste] Fwd: Google Alert - unused medicine disposal

Jeff and all,

I can understand anyone's concern regarding diversion. I have been in the medical waste industry for over 20 years in both the hauling business, mailback, and as an independent consultant. I used to hear the same concerns about medical waste being handed over to a truck driver - "wouldn't it be safer to destroy/encapsulate/burn it yourself and put it in the trash?" As long as humans are involved in the handling of anything of value there is the potential for diversion. How is it any safer to hand a truckload of pharmaceuticals to a hauling company driver  with no enforcement component to his company after a takeback program than a citizen handing a non-descript mailer to a postal worker who does?

In addition, look at how those drugs get to pharmacies in the first place. Would we suggest that the millions of prescription drugs transported by USPS, UPS and FedEx every year to pharmacies throughout the world be stopped - and instead hauled by independent hauling companies?

The USPS handles millions of hazardous and non-hazardous, valuable and non-valuable pieces of mail every day. I would have to ask what controls are in place to 100% eliminate diversion by haulers, doctors prescribing and handing out samples, grandma's grandson stealing drugs from her medicine cabinet, police officers in evidence rooms, and yes, common carriers. If someone can come up with a 100% foolproof method I think we would all gladly implement it.

Non-controlled household drugs are solid waste and can be incinerated at a variety of types of permitted incinerators.  Our mailers have gone through extensive evaluation by the USPS and approved based on an extensive history of compliance and safety. They go directly to a mail distribution center, then directly to our facility. They don't end up at a post office somewhere for sorting. They are received, off-loaded, caged, scanned, and incinerated all by law enforcement. Our program is as much about safe handling and treatment as it is about source reduction and improved outcomes.

Here is my take. We all have our own opinions based on a variety of data as to what is best, safest, most convenient, most confidential, etc. However, often times our opinions are based on our own personal or business biases. I can find something wrong with any method you choose. There is no one right way to solve the issue of unused medication disposal. My wish is that we all could understand that we want the same thing - the safety of our water, land, air, and citizens.  Some people love the takeback idea, some people love the mailback; some people will pay to have their drugs disposed properly, some people will not pay. Then there are those who don't care, or have not bought into the fact that this is an problem worth solving. Instead of fighting over mailback or takeback, why don't we work toward moving those folks who don't want to take advantage of either to one or the other.

Thanks Jeff for bringing up the concerns, and to this list serve for allowing us to have these discussions.

Jan Harris | Director, Environmental Health & Safety

Sharps Compliance, Inc.
| m-713-927-9956

jharris at sharpsinc.com<mailto:jharris at sharpsinc.com> | http://www.sharpsinc.com

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jeff Hollar
Sent: Thursday, July 07, 2011 8:54 AM
To: 'Stevan Gressitt'; 'pharmwaste'; 'rxnews'
Subject: RE: [Pharmwaste] Fwd: Google Alert - unused medicine disposal

Regarding mailback programs:  What about the potential of theft in transit?  Mailmen, sorters, etc.  What controls in place to 100% eliminate this?  If someone diverts one mail back pouch, will this be caught?  What if someone opens one up and takes 5 pills from a bottle?  What if someone puts the mail back pouch in their mailbox and it gets swiped before the mailman picks it up?  How do the various mailback programs address these diversion issues?

On a related note, I am aware of at least one mailback program that is not permitted to take back DEA controlled substances.  Obviously DEA controls will make it through.  What happens when this mailback program facility receives DEA controls?  How can this even be monitored if the container contents being shipped are not 100% examined?

Regarding disposal:  If these pharmaceuticals came from a non-household entity, the RCRA waste would likely have to be segregated and destroyed in a RCRA incinerator.  What is the typical disposal method used in mailback programs?  WTE Incinerator, RCRA Incinerator, autoclave, landfilled?

I would like to learn more about the issues I raised above.  Can those of you involved with the various mailback programs shed some light on these questions?

Warmest Regards,

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

From: Stevan Gressitt [mailto:gressitt at gmail.com]<mailto:[mailto:gressitt at gmail.com]>
Sent: Tuesday, July 05, 2011 5:55 PM
To: pharmwaste; rxnews
Subject: [Pharmwaste] Fwd: Google Alert - unused medicine disposal

Mailback would have precluded this problem
---------- Forwarded message ----------
From: Google Alerts <googlealerts-noreply at google.com<mailto:googlealerts-noreply at google.com>>
Date: Tue, Jul 5, 2011 at 5:43 PM
Subject: Google Alert - unused medicine disposal
To: gressitt at gmail.com<mailto:gressitt at gmail.com>
News

1 new result for unused medicine disposal

Accused Yorkville officer takes unpaid leave<http://www.google.com/url?sa=X&q=http://beaconnews.suntimes.com/news/6358045-418/accused-yorkville-officer-takes-unpaid-leave.html&ct=ga&cad=CAcQARgAIAAoATAAOABA5YrO8ARIAVAAWABiBWVuLVVT&cd=506Kb9rPxRU&usg=AFQjCNHLWhpF3cML2daOKmUAOJ3ZsIiQng>
Chicago Sun-Times
Prosecutors claim that Delaney took prescription medicine for his personal use from the supplies turned in by residents as part of an unused medication disposal program. He is scheduled to make his first appearance in court today. ...
See all stories on this topic ><http://www.google.com/url?sa=X&q=http://news.google.com/news/story%3Fncl%3Dhttp://beaconnews.suntimes.com/news/6358045-418/accused-yorkville-officer-takes-unpaid-leave.html%26hl%3Den%26geo%3Dus&ct=ga&cad=CAcQARgAIAAoBjAAOABA5YrO8ARIAVAAWABiBWVuLVVT&cd=506Kb9rPxRU&usg=AFQjCNFzJphdvxpixG92roh6mgxa275I4A>

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--
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/>

[COLLECT/PROTECT/RESPECT]
Sharps Compliance prevented the improper disposal of 624 million syringes from the solid waste stream and 123,000 pounds of unused patient medications from potentially harming our citizens and the environment.

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