[Pharmwaste] Rite Aid now partnered with Sharp'sComplianceCorporation to sell drug mail back envelopes

Gilliam, Allen GILLIAM at adeq.state.ar.us
Thu Mar 17 10:09:26 EDT 2011


Yep, Dr. Mireles is right.  Different states with different interpretations or current state regs that would have to be revised to allow take-backs to receive long term care facilities UEMs.  See below a response I received from our state’s OLTC:
****************************************
Some points to consider:

1.            The Act does not yet authorize long-term care facilities to participate in take-back programs.  While the Act does "authorize long term care facilities, as defined by the Attorney General by regulation, to dispose of controlled substances on behalf of ultimate users who reside, or have resided, at such long-term care facilities", those facilities must do so "in a manner that the Attorney General determines will provide effective controls against diversion and be consistent with the public health and safety."  This means that the Attorney General must first promulgate regulations that define what constitutes a long term care facility for purposes of the Act and to establish the procedures that constitute "effective controls against diversion and be consistent with the public health and safety."

2.            An issue in Arkansas is that Section VII, entitled "Surrender of Unwanted Controlled Substances", of the Dept. of Health's (DOH) "Rules and Regulations Pertaining to Controlled Substances" will need to be amended, as that section sets out the manner in which narcotics may be destroyed by long-term care facilities.  The upshot is that under those regulations, as I read them, all controlled substances must be delivered by a long-term care facility to the DOH for destruction.

3.            It appears that Arkansas law may need amending, as well.  The DOH regulations are based, in part, on Ark. Code Ann. § 20-64-201 et seq. and Ark. Code Ann. § 20-64-301 et seq.  If any provisions in those laws prevent facilities from using take-back programs, they will need amending.

I have taken the liberty of including Ms. Elizabeth Andreoli in this email for her thoughts and input.  Ms. Andreoli is legal counsel for the Arkansas Health Care Association (AHCA), which represents the vast majority of nursing facilities in Arkansas.

Frank GoBell
**************************
Allen Gilliam
ADEQ State Pretreatment type-guy
501.682.0625

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: Wednesday, March 16, 2011 4:06 PM
To: Volkman,Jennifer (MPCA); 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 [pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Smith, Charlotte [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
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 (cell)
414-292-3959
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.

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Volkman, Jennifer (MPCA)
Sent: Wednesday, March 16, 2011 11:59 AM
To: Jan Harris; DeBiasi, Deborah (DEQ); pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Rite Aid now partnered with Sharp'sComplianceCorporation to sell drug mail back envelopes

Thank you for the clarification. I checked in with the DEA in Texas and found that the Sharps facility has a solid record of compliance with DEA regulations as a reverse distributor. In communication with DEA and others on the technology and operations it appears that Sharps is already set up to accept controlled substances from a regulatory perspective. Since CS abuse is so prevalent and it is the main argument for collection, at least here in MN, I wanted to add empahsis to Deb's note.

Also, did you see the picture of the drugs collected last year during DEA's event where it shows them being open burned in TX? Maybe you can help them out with their April 30 event.



________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jan Harris [jharris at sharpsinc.com]
Sent: Wednesday, March 16, 2011 10:06 AM
To: DeBiasi, Deborah (DEQ); pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Rite Aid now partnered with Sharp'sComplianceCorporation to sell drug mail back envelopes
You can count on it, Deborah.

From: DeBiasi, Deborah (DEQ) [mailto:Deborah.DeBiasi at deq.virginia.gov]
Sent: Wednesday, March 16, 2011 9:55 AM
To: Jan Harris; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Rite Aid now partnered with Sharp'sComplianceCorporation to sell drug mail back envelopes

Jan,

            I appreciate you taking the time to provide this clarification.   Please keep us informed if the Sharps Compliance TakeAway program should expand to include controlled substances.

Deborah L. DeBiasi, Virginia DEQ
Office of Water Permit and Compliance Assistance Programs
Email:   Deborah.DeBiasi at deq.virginia.gov<mailto:Deborah.DeBiasi at deq.virginia.gov>
PH:         804-698-4028

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jan Harris
Sent: Wednesday, March 16, 2011 10:09 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Rite Aid now partnered with Sharp'sComplianceCorporation to sell drug mail back envelopes

After reading a number of continued posts regarding the Sharps Compliance TakeAway™ envelopes being provided by a variety of healthcare professionals and transported by USPS, I thought it might be helpful to respond. Sharps Compliance has worked with USPS since 1994 regarding mailing of sharps and other regulated medical waste. USPS and Sharps Compliance developed the initial envelope system and released it with great success. USPS and Sharps Compliance elected to improve envelop securities, not as a result of any failure, but as a part of constant product improvement. That is why revised packaging measures where applied. Neither Sharps Compliance nor any of the pharmacies providing systems were ever asked to recall any envelopes. The envelopes were already approved as safe – USPS simply wanted to make the envelop even better. The new USPS-approved envelopes where re-launched in January 2011 to continue to provide an inexpensive, convenient source reduction method to keep unused meds and OTCs out of our water and landfills.  It has been painful to see so much misinformation and speculation surrounding this program. If you have any additional questions regarding this option for patient med disposal, please feel free to contact Sharps Compliance directly.



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 Lucy, Burke
Sent: Tuesday, March 15, 2011 12:41 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Rite Aid now partnered with Sharp's ComplianceCorporation to sell drug mail back envelopes

I’m wary of speaking for any particular company especially when I see no public notice but our regional Sharps Compliance sales person e-mailed me on Oct. 29, 2010 saying sales were temporarily halted pending USPS evaluation and again on January 7th to say the USPS gave them the okay to sell the TakeAway mailers again.  This is interesting - now we have Walgreens selling the mailers for $2.99, Rite Aid for $3.99, and in California at least 200 Kaiser hospitals selling them for $4.95.

Burke Lucy
916.341.6592

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of DeBiasi, Deborah (DEQ)
Sent: Tuesday, March 15, 2011 10:22 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Rite Aid now partnered with Sharp's Compliance Corporation to sell drug mail back envelopes


Last October-November, we had some discussion about Walgreens selling the drug mail back envelopes from Sharps Compliance, and someone mentioned that there was a “cease and desist” order on them.  I never did see a source for that comment.  Does anyone know if there was a “cease and desist” order on either Walgreens for selling the envelopes, or Sharps for offering the service?  If there was, what did it affect, and is it still in effect?

*********

Rite Aid News

Rite Aid Encourages Customers To Dispose of Medication Safely With New Medication Disposal Program

Special Envelopes Offer a Safe and Easy Way to Dispose of Prescription and OTC Medications

Camp Hill, PA (March 14, 2011) – To help its customers safely dispose of unused, outdated or unwanted medications, Rite Aid pharmacies now have specially-designed disposal envelopes available for purchase. Customers can place unwanted prescription and over-the-counter medications in the envelope. Once sealed and placed in any U.S. Postal Service mailbox, the envelope is sent to an approved medication incinerator, where a licensed law enforcement official oversees the safe and environmentally-friendly disposal process. Postage is included in the cost of the envelope, which is $3.99.

Rite Aid is working with Sharps Compliance Corporation, a leading full-service provider of cost-effective solutions for disposing of medical waste and unused medications, to provide the envelopes.

The envelopes are available at all Rite Aid pharmacies except in Maine, where another type of disposal program is available.

“For years, Rite Aid has participated in community medication take-back events organized by local health officials and law enforcement agencies,” said Dan Miller, Rite Aid Senior Vice President of Pharmacy. “Our customers often ask how to dispose of medication. By making these envelopes available in our stores, we’re offering an easy and safe disposal solution for customers looking to safely dispose of expired, unused or unwanted medications.”

Controlled medications are excluded from this program due to current federal regulations.

Rite Aid (NYSE: RAD) is one of the nation’s leading drugstore chains with more than 4,700 stores in 31 states and the District of Columbia and fiscal 2010 annual revenues of $25.7 billion. Information about Rite Aid, including corporate background and press releases, is available through the company’s website at www.riteaid.com<http://www.riteaid.com>.

# # #

Contact:

Media:Ashley Flower 717-975-5718

Deborah L. DeBiasi
Email:   Deborah.DeBiasi at deq.virginia.gov<mailto:Deborah.DeBiasi at deq.virginia.gov> (NEW!)
WEB site address:  www.deq.virginia.gov<http://www.deq.virginia.gov>
Virginia Department of Environmental Quality
Office of Water Permit and Compliance Assistance Programs
Industrial Pretreatment/Whole Effluent Toxicity (WET) Program
PPCPs, EDCs, and Microconstituents
www.deq.virginia.gov/vpdes/microconstituents.html<http://www.deq.virginia.gov/vpdes/microconstituents.html>
Mail:          P.O. Box 1105, Richmond, VA  23218
Location:  629 E. Main Street, Richmond, VA  23219
PH:         804-698-4028
FAX:      804-698-4032



[COLLECT/PROTECT/RESPECT]
Sharps Compliance prevented the improper disposal of 600 million syringes from the solid waste stream and 90,000 pounds of unused patient medications from potentially harming our citizens and the environment.

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