[Pharmwaste] Re: LTC to DEA Pharm drop off

Thu Mar 17 11:53:09 EDT 2011

Hey Allen,
I know they sewer a lot, so from that standpoint are a huge source. Are you also saying it is documented that they are a huge source for diversion? I did not know this. I figured it is much like any place that is well stocked with pharms, there is always the potential for pilfering, but not that they are a large source of pharms that are being sold on the street.  I assumed most of the source for abuse is people having access to almost unlimited prescriptions, including online and from anyone's unguarded medicine cabinet. I guess I haven't thought about sources further than that.  Does anyone know of a study?

My thoughts on Mr. More's message, other than I agree with it all, is that if DEA is going to collect from LTC's as if they are households for this nationwide event, someone from high up in EPA should be involved in advising them on participation and disposal. It appears to be causing some chaos at the state level.

________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Gilliam, Allen [GILLIAM at adeq.state.ar.us]
Sent: Thursday, March 17, 2011 10:32 AM
To: 'William More'; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Re: LTC to DEA Pharm drop off

LTCs are a HUGE source.  This info from some co-workers who have worked in, have family or friends working in them.  They both flush AND toss UEMs into their outside dumpsters.  I’m sure (kinda) they’re a little more cognitive regarding disposal of controlled substances what with the DEA’s mandatory paper trail, but am of the opinion most of the “nurses” on duty might not know a P or U haz waste from an aspirin.
Charlotte Smith probably has a much better perspective of LTC facililties’ pharma disposal practices overall.
Allen Gilliam/ADEQ State Pretreatment Coordinator/501.682.0625
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of William More
Sent: Thursday, March 17, 2011 9:01 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Re: LTC to DEA Pharm drop off

How is it that commercial generators can get an allowance for use of a freebie, when there are regulations in place, that have been in place, and should be considered a business expense and should be budgeted for.

Is DEA sponsoring an, " anybody can bring it event" or are they sponsoring a home owner cleanup event to limit the available "pharms to the street market".  LTC's should not be a source to the "pharms in the street market".  Are LTC such a source?  If so, then we should be expending some effort there.  An if they are, they should be held to meet the existing requirements for proper management through commercial disposal under the regs. and not be given a pass.

If we are piggybacking diversion from flushing to our Waste Water Treatment Plants and Landfills on the DEA event, then we need to look at our regulations and see if they are adequate and if not allow a general amnesty on LTC storage until the regs are fixed.

There are LTC generated pharms that are Hazardous Waste and even Acute Hazardous Waste. These regulations on the federal level were not enacted yesterday, but are approx 30 yrs. old.  What happens to these materials that are under a "cradle to grave" tracking when they are dumped wholesale at a DEA sponsored HHW pharm cleanup day? Is the LTC going to have a possibly required manifest for their Hazardous Waste? Are the pharms going to be adequately identified and quantified for the required records? Are we just going to give them a pass on the federal regulations?  Proper management has been mandated by the regulation for approx. 30 years and now we have a problem? What have they been doing for the 30 years? And in regards to the Acute Hazardous Waste, are the LTC's meeting the paperwork regs. that go with being a Large Quantity Generator if the they have 1Kg(2.2lbs) in total Acute Hazardous Waste (and contaminated packaging)?

EPA has had outreach programs to Hospitals that included proper management of pharms,  have they included LTC's?  The Hospital outreach program is ongoing and maybe LTC if they are not included could be added and there could be a organized/codified allowance for on site storage under consent until the LTC's could show that they can meet the regs.

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