[Pharmwaste] DEA Event in April and SRDDA

Wed Mar 16 21:56:07 EDT 2011

Whoops, I'll try not to clog up the list serve with replies to every state. :)

________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Volkman, Jennifer (MPCA) [Jennifer.Volkman at state.mn.us]
Sent: Wednesday, March 16, 2011 8:48 PM
To: Stevan Gressitt
Cc: pharmwaste at lists.dep.state.fl.us; Matthew C. Mireles
Subject: RE: [Pharmwaste] DEA Event in April and SRDDA

So it is working out to do that wiith your regulations in Maine?  Are they taking HW pharms from LTC's to a HW facility for disposal?

________________________________
From: Stevan Gressitt [gressitt at gmail.com]
Sent: Wednesday, March 16, 2011 6:49 PM
To: Volkman, Jennifer (MPCA)
Cc: Matthew C. Mireles; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] DEA Event in April and SRDDA

In Maine all LTCF have been informed of the event with how to participate.

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/>

On Wed, Mar 16, 2011 at 7:24 PM, Volkman, Jennifer (MPCA) <Jennifer.Volkman at state.mn.us<mailto:Jennifer.Volkman at state.mn.us>> wrote:
As per Laurie Tenace's previous requests, I changed the subject heading since we sort of moved on to the DEA event and questions about the Secure and Responsible Drug Disposal Act.

Hi Matt,
I know all about that. We have a fact sheet. :) I put an exerpt at the bottom of the message. There is always a percentage of people who will try to take advantage of "free" disposal. What I also know is that DEA here wants to include LTC waste as part of their April 30 event. I have asked that they keep that waste stream separate from the HH pharms, but I really don't know how this will turn out at this point in time.

For MN, we have worked out a review and approval process for WTE's to accept HH only pharms for destruction. The CS have to be delivered by law enforcement for witnessed burn. However, EPA's and our state rules don't allow the LTC pharms to also go to a SW WTE facility, so it greatly complicates disposal for DEA. It would be simpler if LTC's were left out, but the inclusion of LTC facilities is what has been proposed for MN at this point in time.

I am curious if other states have had their DEA talk with them about including LTC facilities in the April event. There may be some reason or pressure to include them because they are called out in the Secure and Responsible Drug Disposal Act. This would also be another reason to segregate that waste stream for this event--in order to generate some data.

Pharmaceutical hazardous waste generated from commercial activities is regulated hazardous waste in Minnesota regardless of where it is generated. Pharmaceutical waste generated from non-commercial household activities is unregulated household hazardous waste in Minnesota, unless and until collected by a household hazardous waste collection program. Health care providers that generate pharmaceutical hazardous wastes from commercial activities are regulated hazardous waste generators. The MPCA considers that the degree of centralized control and storage of pharmaceuticals in a facility is the most significant indicator of generation from commercial activities. Applying this indicator:

 1.  Pharmaceuticals stored in a centralized, employee-controlled location separate from resident living areas, such as is required at hospitals, nursing homes, and boarding-care homes, will be considered generated from commercial activities and therefore regulated when discarded.
 2.

Pharmaceuticals stored in resident rooms or other non-central and unrestricted-access location, such as at home-care client houses, may be considered generated from non-commercial household activities and therefore unregulated when discarded.

________________________________
From: Matthew C. Mireles [mirelesmc at earthlink.net<mailto:mirelesmc at earthlink.net>]
Sent: Wednesday, March 16, 2011 4:06 PM
To: Volkman, Jennifer (MPCA); pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: RE: [Pharmwaste] Rite Aid now partnered with Sharp'sComplianceCorporation to sell drug mail back envelopes

Jennifer,

You may have to check with your state's regulations regarding definition, oversight and requirements for LTC facilities.  In TX, they are considered healthcare institutions and must comply with the reverse distribution system for drug disposal.  Most of the programs that are discussed on this listserv including the DEA's national campaign (Sept 25 and April 30 collection dates) are specifically designed for consumer drug return.  We were exploring a research project involving mortality review of patient cases from LTC, often renamed as "state schools", as part of a patient safety initiative for the TX  DHHS.  Nursing homes and some assisted home facilities fall under LTC facilities but rules vary from state to state.  We discourage hospitals and organized clinics and medical offices from using community-based drug take-back system.  I believe in Houston one DEA officer turned away a doctor who was emptying his stockroom.  My guess is that compliance to any program would be difficult and impossible to enforce.

-----Original Message-----
From: "Volkman, Jennifer (MPCA)"
Sent: Mar 16, 2011 2:02 PM
To: "pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>"
Subject: RE: [Pharmwaste] Rite Aid now partnered with Sharp'sComplianceCorporation to sell drug mail back envelopes

Charlotte, I hope you are in on that rule drafting business. I suppose there isn't much of an update from the first hearing, but anything you can share would be appreciated.  I am hoping that EPA is involved and considering what can be done to help out the LTC facilities. DEA in MN wants to include them in the April 30 collection event, which is more problematic from a disposal perspective than just managing household waste.

It is also difficult to explain EPA's distinction that pharms confiscated during a drug bust are considered to be business waste while the same pharms turned in by a household at a collection event or drop box are household waste and are not regulated by EPA.

With all due respect to DEA for their efforts, I would rather see them focused on the criminal element and to leave collection and disposal to those experts.

________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us>] On Behalf Of Smith, Charlotte [csmith at pharmecology.com<mailto:csmith at pharmecology.com>]
Sent: Wednesday, March 16, 2011 1:15 PM
To: Volkman, Jennifer (MPCA); Jan Harris; DeBiasi, Deborah (DEQ); pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: RE: [Pharmwaste] Rite Aid now partnered with Sharp'sComplianceCorporation to sell drug mail back envelopes

Please note that no DEA-registered reverse distributors are currently authorized to accept controlled substances from consumers, only from other DEA registrants. The DEA is currently drafting regulations that will enable some type of consumer take-back process, but these have not been published or finalized as of yet.

Best regards,

Charlotte A. Smith, R. Ph., M.S., HEM
Director, PharmEcology Services
WM Healthcare Solutions, Inc.
W124N8925 Boundary Road
Menomonee Falls, WI 53051-2402
713-725-6363<tel:713-725-6363> (cell)
414-292-3959<tel:414-292-3959>
414-479-9941<tel:414-479-9941>(fax)
csmith at pharmecology.com<mailto:csmith at pharmecology.com>

Waste Management's renewable energy projects create enough energy to power over 1 million homes.

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