[Pharmwaste] Items Accepted at Permanent Collection

[Howard Anderson]

Dear Pharm Waste:

Maybe we need to get our laws cleaned up to allow what is in the best
interest of the public, or else pass out signs to the public that say,
"House open from 3 to4 on Fridays, the medicine cabinet is in the bathroom
on the second floor".

Howard

Howard C. Anderson, Jr.,R.Ph.
Executive Director
North Dakota Board of Pharmacy
1906 E. Broadway Ave.
P.O. Box 1354
Bismarck, ND  58502-1354
Phone (701) 328-9535
Fax (701) 328-9536
Web site www.nodakpharmacy.com

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Fredrick L.
Miller
Sent: Monday, March 26, 2012 4:40 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Items Accepted at Permanent Collection

Burke brings up another good point.  Transportation will be an issue.
Unless LE is going to transport their collections all the way to the end
disposal facility they're going to end up using commercial transporters at
some point and at that moment the stuff becomes fully regulated with no
exceptions or exemptions.  All it takes is for a transporter to get caught
with something in the load that isn't manifested correctly for
the whole shebang to come to a screeching halt.   It is unlikely the
agencies involved have the people on staff at every location with the
education, experience, and training necessary to fully comply with 49
CFR.   It's even more unlikely they're aware of the magnitude of the
penalties involved for typical 49 CFR violations.  If they knew the
financial liability they're contemplating taking on they'd be running away
at full speed.

Fred


-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Lucy, Burke
Sent: Monday, March 26, 2012 2:17 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Items Accepted at Permanent Collection

Regardless of whether a state exempts household waste through the end of
life, haulers still have to follow U.S. DOT standards.  So that's one of the
benefits of using a law enforcement collection program since they have their
own transport process.  The U.S. DOT does not exempt household waste from
regulation if it's "consolidated shipments of household hazardous materials
transported from collection centers" (CFR, Title 49, Section 171.8).  If the
new DEA regulations provide more flexibility for collecting controlled
substances at pharmacies, the hauling process could still be a sticking
point.  

Burke 


Mr. Burke Lucy
Integrated Waste Management Specialist
Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street, PO Box 4025
Sacramento, CA 95812
Burke.Lucy at CalRecycle.ca.gov
916.341.6592

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