[Pharmwaste] DEA Collection Correction

[Ed Gottlieb]

Jennifer,
 
Thanks for your thoughts.  From what you say it seems we have some hope
for an early start time on April 28th.
 
I offered our local DEA agent the option of a pick-up late Saturday,
Sunday, or Monday.  Secure storage is not a problem since we recently
bought a 20' trailer specifically to stockpile pharm waste generated by
our upcoming drop-box program.  
The agent I spoke with seemed set on a same day pick-up.  It seems DEA
headquarters expects regional offices to report results for all
collections, and complete destruction, that same day.  
 
Of the many DEA agents I have spoken with, not one expressed interest
in seeing inventory results.  It seems to me they view inventorying it
as a possible diversion (in both senses) from the collection/destruction
task at hand.
 
Could the MN DEA have gotten a variance to use an incinerator that
isn’t approved by the MPCA for disposal?  Here in NY, we need to get
a variance to use an EPA approved energy recovery incinerator for
pharmaceutical destruction.
 
I don't think law enforcement agencies in my area have received a
letter from the DEC inviting participation.
 
Ed
 
>>> "Volkman, Jennifer (MPCA)" jennifer.volkman at state.mn.us> 2/23/2012
7:48 PM >> ( mailto:jennifer.volkman at state.mn.us )

When DEA does events here, they seem to be compelled to collect and
destroy everything the same day as the collection event. Maybe that is a
parameter they’ve decided to stick firmly to? As such, extending the
hours any later doesn’t work here, although I think an earlier start
would be fine. They don’t do much advertising and last time they did a
press conference for the event, it wasn’t covered by any of the news
media as far as we could find, so adjusting the hours locally to be
earlier would probably work out. Advertising may be different/better in
your state, but they pretty much leave it to the locals here. 
DEA sets the pickup/drop off locations and time for participating law
enforcement. If you miss the handoff place and time, you don’t get your
pharm waste transport and disposal cost covered by them. If people here
were interested in inventorying, they could, they just wouldn’t get
their costs covered, which may or may not be a big deal. It seems they
could find a secure location to hold the stuff for a day to allow for
inventorying and a larger window of time for law enforcement to bring in
their waste. We have a brand new giant BCA building here in St. Paul… 
Our DEA sent out a letter on Feb 6 to the MN’s Sheriff’s Association
inviting participants. I received it from one of the county participants
on Feb 7, so they forwarded it out right away. In this letter they
listed an incinerator that they’ve used but isn’t approved by the MPCA
for disposal, further confusing the disposal issue that I’ve been
chasing down and presenting workshops on for over a year. 
Perhaps if you help them locate a secure storage facility (local
evidence rooms aren’t generally large enough) and whatever else you can
do to make it easier, they’ll agree to it. The data would be useful to
DEA unless they are hoping that the percentage of controlled substances
collected is more than the usual 5-10%. It is still significant at that
level given they collected 377,096 total pounds at the Sept 2011 event
last year.

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Ed
Gottlieb
Sent: Thursday, February 23, 2012 12:48 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] DEA Collection Correction

 

Hi All,

 

On 1/21 (Vol 75, Issue 13) I reported that a DEA officer told me law
enforcement agencies wouldn't be able to sign-up for the April 28th
collection event until 6 or 7 weeks before the event.  That was not
correct.  They can sign-up now.

 

My DEA regional office has not yet gotten back to me to about three
questions I asked them.

1. Can we extending the hours of collection beyond the standard 10-2?

2. Can DEA arrange a pick-up a bit later in the afternoon so that we
can complete an inventory of all controlled substances, and possibly a
random selection of other medications?

3. Can other collection sites in our county deliver what was turned in
to a central site for inventorying?

 

I'll let you know what they say when I hear.

 

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

 
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