[Pharmwaste] RE DEA rule-making & DEA Spring Collection April 28th

Sun Jan 22 14:10:15 EST 2012

Hi all - I've been reading this interesting email string, and wondering if we're getting confused between DEA rule-making and legislation.  I'd appreciate clarification from Vickie per her original comments.

DEA is in the midst of rule-making - and we hope they hurry up! - to implement the "Secure and Responsible Drug Disposal Act of 2010" (S. 3397). This law authorized DEA to issue new regulations (a.k.a. rules) for additional options for collection of controlled substances by take-back programs, ie without involvement of law enforcement.
See basic info on that law on our website: http://www.takebackyourmeds.org/make-it-happen/proposed-state-law/new-federal-bill
See DEA's website with all rule-making info at:  http://www.deadiversion.usdoj.gov/drug_disposal/non_registrant/index.html
Link to law language: http://www.deadiversion.usdoj.gov/drug_disposal/non_registrant/s_3397.pdf

Here are some important parts of this law, as I and others understand it:  
*  This law removes barriers to providing even more effective medicine take-back programs in our communities.  
*  The law does NOT create or fund any drug take-back programs. 
*  It does NOT require any entity to collect drugs, saying "Such regulations may not require any entity to establish or operate a delivery or disposal program."  
We certainly hope/expect the DEA to authorize take-back of controlled substances by pharmacies and other appropriate entities under secure protocols, but the DEA cannot require any pharmacy to provide take-back.  We hope/expect many pharmacies will voluntarily participate in drug take-back systems, as many across the country currently are for non-controlled medicines.  Many more pharmacies should be willing to serve as take-back collection sites when the drug manufacturers become part of the solution and contribute financing as part of cost of selling their product.

DEA has consistently said that they will cease coordinating any national prescription drug take-back events once those regulations are finalized.  It will then be up to others, most appropriately the pharmaceutical industry, to provide the take-back programs in our states and communities. 

Let's make that happen!
Margaret

Margaret Shield PhD, Policy Liaison
Local Hazardous Waste Management Program in King County
130 Nickerson Street, Suite 100, Seattle, WA 98109-1658
(w) 206-263-3059  (c) 206-265-9732

Protect Our Kids, Families, and Environment - www.TakeBackYourMeds.org

________________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Zimmer, Catherine (PSC) [Catherine.Zimmer at pscnow.com]
Sent: Sunday, January 22, 2012 9:53 AM
To: Vickie Davis; Ed Gottlieb; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] DEA Spring Collection April 28th

Hi Victoria,
I'm curious about where we might get more info on DEA's pending legislation.  Thanks!

Very truly yours,

Catherine Zimmer, MS, BSMT
Industry Leader, Caring for the Environment
PSC Healthcare Services
Office:  651.645.7509
Mobile: 713.829.6365
www.pscnow.com
Catherine.zimmer at pscnow.com

Live green now!
Reduce, reuse, repair, recycle.

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Vickie Davis
Sent: Saturday, January 21, 2012 9:15 PM
To: Ed Gottlieb; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] DEA Spring Collection April 28th

Hi Ed,

We started our unwanted medicine collections the year DEA started theirs and coincidentally they selected a Saturday we had already chosen and advertised.  Unfortunately, our hours were 9 - noon and theirs were 10 to something.  I asked if there was any flexibility and they said "no."

I also heard from a seemingly reliable source that this April's collection will be the last DEA collection due to pending federal legislation to take care of pharmaceuticals in another way (such as requiring pharmacies to develop programs for counties of 10,000 or more), but we'll see.

Victoria Davis
Upper Valley Lake Sunapee Regional Planning Commission
10 Water Street, Suite 225
Lebanon, NH 03766
________________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Ed Gottlieb [egottlieb at cityofithaca.org]
Sent: Thursday, January 19, 2012 10:56 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] DEA Spring Collection April 28th

Some time ago, the DEA announced their Spring collection event, part of their National Take Back Initiative.
http://www.deadiversion.usdoj.gov/drug_disposal/takeback/

This web page says, "Please check back in March to locate collection sites near you."  I've been checking back every day hoping to find information on how to sign up.  If the DEA expects to know who is participating by March, it seemed to me that sign-up should begin soon.  Made some phone calls to DEA as well (which I don't recommend doing unless you have a reliable contact there or it's absolutely necessary.)

The DEA just added some information to that web page:
"Law Enforcement Agencies Only:  For law enforcement agencies that wish to host a collection site please cal the POC in your area."
A link is provided to a table of Point of Contact persons for each state.

I was able to learn, through phone inquiries, that the sign-up form will go live only 6 or 7 weeks ahead of the event.  The agent I spoke with will be sending a suggestion to DEC HQ that they change "March" to "April" in, "Please check back in March to locate collection sites near you."

That agent also took my request that one of our counties planned collection sites be allowed to extend the hours of operation from 10-2 to 9-3 (the hours of our previous  events.)  I also requested that the DEA pick-up collected material later in the afternoon to allow us time to do some inventory data collection.  Finally, I asked that some collection locations be allowed to deliver their material (with proper chain of custody transfer) to our central collection.  I was told there is precedent for this gathering material from multiple sites to one location for DEA pick-up.  Our hope is we would have time to inventoried the controlled substances from those sites as well.  I'll send out an update with their reply, once it's received.

If the DEA is totally inflexible, our group will face a tough choice.
1.  Join the DEA program and inventory only at our central location.  We might have to stop the inventory process once the DEA arrives to collect the material.
2. Hold our collections on the same day (which we picked before the DEA announced their date) and get permits, as we have in the past, through the NYS DOH Bureau of Narcotic Enforcement and the NYS DEC.  Unlike the easy DEA registration process, state permitting requires significant effort.  We could then inventory as planned.

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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