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

Vickie Davis vdavis at uvlsrpc.org
Mon Jan 23 12:40:17 EST 2012


Hi,

My information came from a phone conversation from someone at the regional office of DEA in NH who stated the April collection would be the last, and the collections were only offered until there was federal legislation put in place for alternative collection methods.  The best information I get is from this list serve which I am very grateful for.

On another note, if anyone out there is interested, the State of NH is devising rules on unwanted medicine collections that will require two police officers.  Attached are some proposed rules from the NH Pharmacy Board for medicine collection boxes and one-day collections.  You can make written comments on these rules until January 30th and submit them to Marta Modigliani at marta.modigliani at dos.nh.gov.

These are the first rules the state will have on how to collect unwanted medicines at one-day collections like ours.  Unfortunately, these rules do not coincide with the NERC published method which was developed with much research ("Best Management Practices for Holding Unwanted Medication Collections: A Legal & Safe Approach for Community Pharmacies" and  "Holding an Unwanted Medication Collection as Part of a Household Hazardous Waste Event-A Legal & Safe Approach").  These documents can be found at www.nerc.org --click on "documents" at  the top and then select the topic of "unwanted medicines."

The only NH collections that I am aware of are ours here in the Upper Valley and Sullivan County and Sarah Silk's over in Wolfeboro/Alton.  We both feel our collections have been very effective and cost efficient using the method published by NERC.  We both use one police officer.  Sarah pays her pharmacist $50 an hour which is negligible for a 3-hour collection.  Dartmouth-Hitchcock Pharmacy provides our pharmacy services for free.  The big cost for the collections is the police oversight.  We only have one police officer and it can be pretty pricey up to $400 for the 3-hour collection.  We also pay about $150 for the disposal of the drugs by our HHW hauler.

The new rules eliminate the pharmacist and require that there be two police officers who take ALL the medications instead of just the controlled substances.  The two police officers would then be required to transport or follow a truck with all the drugs to an incinerator to witness their destruction right after the collection-usually on a Saturday.  Two police officers will more than double the cost because not only will we be paying for a second officer, but we'll have to pay them for their time to transport the materials to an incinerator and possibly pay for the vehicle used in transportation-and potentially a driver if a truck must be hired.

Typically we get about 2 30-gallon barrels of noncontrolled drugs and over-the-counter stuff like aspirin.  The proposed rules will require that they be taken by the police.  This just doesn't seem to make sense for our programs which have been held very successfully.  Until now, the controlled drugs taken by the police along with evidence have been incinerated for free.  However, now that we're talking about substantially more waste (controlled and noncontrolled), it's not clear if there will be a charge and how much it will be.

Unfortunately,  a Wolfeboro police officer recently was stealing oxycoton from the police evidence room.  He was caught and the publicity has hurt our programs--thus probably the requirement for two police officers at our collections.  He had actually stolen from the drop box stash and not the one-day collection stash, but this doesn't seem to matter to our Pharmacy Board.  There is an inventory of the one-day collection drugs and none for a drop-box collection or a DEA collection.

Again, you can submit written comments to Marta at the NH Department of Safety by January 30th.  I attended the hearing last week.  Sarah and I spoke against the rules for one-day collections and police officers from New Hampton and Keene spoke against the rules for the collection boxes.  I hope you will take a few minutes to send in your comments to provide NH with some guidance from experienced collectors.

Thanks.

Victoria Davis
Upper Valley Lake Sunapee Regional Planning Commission
10 Water Street, Suite 225
Lebanon, NH 03766
603-448-1680
603-448-0170 fax


-----Original Message-----
From: Shield, Margaret [mailto:Margaret.Shield at kingcounty.gov] 
Sent: Sunday, January 22, 2012 2:10 PM
To: Zimmer, Catherine (PSC); Vickie Davis; Ed Gottlieb; pharmwaste at lists.dep.state.fl.us
Subject: RE DEA rule-making & DEA Spring Collection April 28th

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


---
Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients.
---
TO SUBSCRIBE, go to:   http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe at lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank.
If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste
FOR PROBLEMS:  Contact List Administrator Laurie.Tenace at dep.state.fl.us SEND MAIL to the list server at:  pharmwaste at lists.dep.state.fl.us
---
Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients.
---
TO SUBSCRIBE, go to:   http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe at lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank.
If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste
FOR PROBLEMS:  Contact List Administrator Laurie.Tenace at dep.state.fl.us SEND MAIL to the list server at:  pharmwaste at lists.dep.state.fl.us
---
Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients.
---
TO SUBSCRIBE, go to:   http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe at lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank.
If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste
FOR PROBLEMS:  Contact List Administrator Laurie.Tenace at dep.state.fl.us SEND MAIL to the list server at:  pharmwaste at lists.dep.state.fl.us
-------------- next part --------------
A non-text attachment was scrubbed...
Name: ProposedRules2012.pdf
Type: application/pdf
Size: 26570 bytes
Desc: ProposedRules2012.pdf
Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20120123/fb3dad57/ProposedRules2012-0001.pdf


More information about the Pharmwaste mailing list