[Pharmwaste] Items Accepted at Permanent Collection

[Howard Anderson]

Dear Dr. Larson:

I happen to be one of the commenters who suggested that the best way to get
these drugs out of the home and properly destroyed is to let the consumer
take them back to the place where they got them in the first place, their
own community pharmacy.

Yes, there will be some diversion, just like there is now, but we will have
them in a place where we are used to handling those issues through
inspections and proper procedures. If we find interns, technicians or
pharmacists taking them for their own use, we will get them into treatment
and a contract with our impaired pharmacist committees. If we find they
divert them for sale or to Pharm parties, we will find them a ticket to jail
or a least, a different line of work.

Pretending we do not have any responsibility or that we might get our hands
dirty, is not a good excuse.

Sincerely,

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 Rod Larson
Sent: Monday, March 26, 2012 3:53 PM
To: Fredrick L. Miller; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection

I agree that pharmacists have the training and familiarity to get the job
done.  However, having the public return their unused medications to
pharmacies is a very bad idea in my opinion.

Pharmacy has a very good tracking system in place for the ordering, storing,
dispensing, and returning of medications.  Even with this, however, there is
a problem with employee diversion at each step.

Adding a steady stream of unknown medications into this system would likely
result in some of these medications getting back into the legitimate
pipeline to be dispensed again (which is illegal).  Or they will be diverted
into the illicit pipeline, ending up at high school and college parties.
This latter diversion would be much easier than it is now, since the
diverter wouldn't have to circumvent a relatively tight tracking system for
controlled substances. The high costs of medications are just to tempting
for this not to occur.

I was at a recent presentation by the DEA agent who stated that the new
regulations will have a heavy pharmacy component to them, since many of the
public comments gathered recommended this.  This scares me a great deal.

Rod Larson

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Rodney A. Larson, Ph.D., R.Ph.
Founding Dean
Husson University School of Pharmacy




On 3/26/12 4:09 PM, "Fredrick L. Miller" <millerfl at tricity.wsu.edu> wrote:

> It's a slippery slope they're on.  They can maintain their HHW exemption
> so long as they are fastidious about their recordkeeping and never mix
> one drop/gram of non-traceable waste.  That means they can't
> legitimately claim the household exemption if they allow anonymous or
> unattended drop-offs.  They lose control of the process and open the
> door to commercial source wastes (e.g. pharmacy/clinical) dumping.
> Also, they have to be careful never to mix their own wastes with the
> household wastes or they turn the whole lot into RCRA regulated
> materials.
> 
> Then there's the issue of legacy and nuclear meds.  How do they keep
> things like "seeds" out of their waste?  How about old stuff laden with
> mercury and barium?  While the HHW exemption may apply to them as a
> generator, those issues can still bite disposal facilities where the
> waste is accepted and all it takes is one "oops" to kill the entire
> process for one and all.  Nothing spreads in the disposal business like
> the news of getting burnt and once burnt, industry reacts far more
> quickly and in far more draconian fashion than regulators ever could.
> They simply start saying "no" to any and all comers who look like the
> party that started the problem.
> 
> In my opinion, pharmacists are the only folks out there with the
> education and familiarity sufficient to get the job done.  Unfortunately
> their time is usually far too precious to spend on such programs.  Until
> industry, USEPA, and DEA get their act together and sing a little
> harmony this problem will remain with us.
> 
> Fred Miller
> USTUR
> Board Member, College and University Hazardous Waste Conference
> 
> 
> -----Original Message-----
> From: pharmwaste-bounces at lists.dep.state.fl.us
> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Maureen
> Bascom
> Sent: Monday, March 26, 2012 12:39 PM
> To: ANGELA Deckers; pharmwaste at lists.dep.state.fl.us
> Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection
> 
> I would be interested in knowing if any unused pharma from households,
> that falls under RCRA, such as P or U listed wastes are being deposited
> in the police collection containers.  If so, does that now make the
> police generators of hazardous wastes?
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