[Pharmwaste] Police Dept Accreditation vs. Drop-box

[Volkman, Jennifer (MPCA)]

There is variability in how local law enforcement decides to handle collected pharms and I find that they sometimes ask me about security, which throws me off guard since I figure that is their area of expertise. Regardless of certification or whatever DEA might allow with their rules, law enforcement entities will also have different protocol based on their experience or preference.

I believe some here in MN have also called it abandoned waste. This isn't "evidence". Regardless, once pharms are in law enforcement's possession, they may want to secure it like other evidence. In order to know whether anyone is stealing from the evidence room, they need counts. And for those that are a slot that dumps into a bin in the evidence room, they need to continuously count what drops so no one dips in for a snack. Then you'd also have to count everything on the way out. If you don't do all of those things, you've done nothing significantly different from those that simply take in sealed boxes and ship out sealed boxes. I've used that ol' red evidence tape and there must be something even better these days.

Due to evidence security concerns, one of our counties chose to only do collection events. Many law enforcement staff oversee the event to ensure all the pills get containerized, the containers get sealed and packed in the Contractor's truck. Then it is the Contractor's problem to establish their own protocol to see that nothing gets diverted. To my knowledge, HW contractors have secure areas for storing pharms. I am certain they don't do pill counts.

We had one county that took in a couple of boxes of controlled substance pharms and he wouldn't wait for the much cheaper in-state disposal because it just made him too nervous to have boxes of "who knows what" in his evidence room. But, the majority of our collectors haven't spent much time agonizing over it and are good with sealed boxes. I am going to do a workshop later this week and we'll discuss it again. I like them to talk to each other to get tips. They will talk about whether they have cameras (not all do), secure entry to the collection box from the street (rare), protocol for emptying the collection box (daily, weekly, who, how...), how it is stored... Some also transport between satellite sites to a main site for pick up by disposal contractors.

I can't imagine doing pill counts for this program. If you gave me a bag of beans to count, I would never get the same number twice. And I would definitely get less the second time if I were counting M&M's.

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of veora
Sent: Monday, January 30, 2012 3:15 PM
To: egottlieb at cityofithaca.org; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Police Dept Accreditation vs. Drop-box



Here in Collier County, Florida, we have a protocol written by our law enforcement partner specifically to address our "Operation Medicine Cabinet" Pharmaceutical take back program.  This protocol establishes that all materials collected by our events are collected by law enforcement and taken into custody as abandoned property. These boxes are sealed at site and taken to the evidence locker the day of the event.  They are never opened again but taken directly to incineration under law enforcement supervision..

 Our drop boxes are all double locked and camera secured (we have 4)  They are in lobbies of law enfocement.  The same protocol applies (written by law enforcement).  Materials collected are in double locked containers, and when emptied by law enforcement are taped secure as abandoned property.  Hope this assists.

Veora Little CRNA,   www.drugfreecollier.org

veoralittle at gmail.com

-----Original Message-----
From: Ed Gottlieb <egottlieb at cityofithaca.org>
To: pharmwaste <pharmwaste at lists.dep.state.fl.us>
Sent: Mon, Jan 30, 2012 1:51 pm
Subject: [Pharmwaste] Police Dept Accreditation vs. Drop-box
A police chief, who wants to host a drop-box in the program we are establishing, just informed me of a major obstacle to her participation.  Chief Ryan's department is accredited by the New York State Association of Chiefs of Police (NYSACP), currently the only department in our county to have this honor.  NYSACP guidelines require a police department receiving medications from citizens, including from a drop-box, to create an incident report with an itemized list of medications received.  Each item would also need to be individually bagged and sealed.  That burden would keep her department from participating.  Some other police departments in our county, who have agreed to host a drop-box, are working towards becoming accredited.  In the future, when they are ready to submit applications for accreditation, they would have to close their boxes.

There is hope.  Specific NYSACP guidelines do not have to be adhered to if they are in conflict with local law.  I am now looking into what would be involved for our county to create a M.O.U. establishing the drop-box program and specifying how it is to be operated, including that collected materials do not need to be itemized before witnessed destruction.  If this is possible, our group will work with Chief Ryan and NYSACP to be sure the draft county M.O.U. properly address this issue before finalizing it.

I don't know if this problem exists in other states.  I don't even know if all states have police associations that grant certification or what standards they might have regarding the handling of "evidence" created by an "incident" such as someone dropping off unwanted medications.  I also don't know about standards for national accreditation from programs such as the one administered by the International Association of Campus Law Enforcement Administrators.

Assuming this problem has not yet been pointed out, it may be because certification is difficult and no law enforcement agency currently participating in one day collections or drop-box programs is certified.  Or, maybe some states certification standards make allowance for these high volume programs by not requiring such detailed tracking and secure handling procedures?

If you are starting a drop-box program, I'd certainly suggest that ask local law enforcement if such a conflict could exist.  If so, maybe the solution we are trying will work for you.

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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