[Pharmwaste] DEA Rules to be published on Friday

[Jaramillo, Jeanie]

I've just begun reviewing.  As a researcher, I've noted a couple of problems.  1) They want only an officer to handle a control (language even specifies "not a take-back volunteer") -- this means an officer would have to handle everything (because it would not allow for a sorting process) and 2) they prohibit counting or inventorying of controls (detrimental to our research program - how are we going to show physicians that they are over-prescribing opiates if we can't document?)

Goodness, their proposed changes are long.  Get your highlighter ready!

Jeanie Jaramillo, PharmD
Managing Director, Texas Panhandle Poison Center
Director, Medication Cleanout
Assistant Professor, Texas Tech UHSC School of Pharmacy
1501 S. Coulter St.
Amarillo, TX 79106
P: (806) 354-1611
C: (806) 672-0833
F: (806) 354-1667
________________________________
From: Ed Gottlieb [egottlieb at cityofithaca.org]
Sent: Thursday, December 20, 2012 8:41 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] DEA Rules to be published on Friday

Hi All,

A congressional staffer let me know yesterday:

"the DEA has drafted a comprehensive Notice of Proposed Rulemaking (NPRM) to implement the Secure and Responsible Drug Disposal Act of 2010.  The White House Office of Management and Budget concluded its review on December 14, 2012, and publication is anticipated on Friday this week.  The draft NPRM proposes a variety of disposal options for how ultimate users may return controlled substances for the purpose of disposal. I do not know for sure, but I assume that these will be published as proposed rules with an opportunity for comment."

Assuming there is an opportunity to comment, I would like to suggest that we use this Listserv to share our thoughts on the proposed rules.  Having others perspectives would help me craft better comments.  It could turn out that the DEA did a great job and all I will need to say is, "well done".  I will certainly say that about as many parts as I can, to balance the suggested changes I will likely submit.

Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY 14850
(607) 273-8381
fax: (607) 273-8433

p.s. Don't know why this failed to post yesterday.
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