[Pharmwaste] Items Accepted at Permanent Collection

[Grasso, Cheri]

Medicine take-back program that are operated under strict protocols with individual pharmacy take-backs obtaining approval from the state's Board of Pharmacy can be very secure and are! Washington State has several pharmacy take-back locations that have been operating since 2006 (www.takebackyourmeds.org/what-you-can-do/locations ) and we have had no incidents of diversion. The reason is due to strict protocols that require secure steel collection containers that are bolted to the floor and are double-locked. Two separate keys are needed to access the medicines.  The consumers deposit the medicines into the containers themselves, and the medicines fall into a box inside the container. When the box is full, it requires two pharmacy staff with separate keys that have been assigned to them to open the container. Instead of individual pills being tracked, the entire is box is tracked and pharmacists notify their central pharmacy warehouse that a box (sealed with security tape) is ready to be picked up. We have more information on this on our website http://www.takebackyourmeds.org/why/how-medicine-take-back-works 

Cheri Grasso 
Pharmaceuticals Project 
Local Hazardous Waste Management Program in King County
130 Nickerson Street, Suite 100 | Seattle, WA  98109 | 206-263-3089
Local Governments for Health and the Environment www.lhwmp.org 
Protect our Kids, Families, the Environment  www.takebackyourmeds.org


-----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: Tuesday, March 27, 2012 12:07 PM
To: Howard Anderson; 'Fredrick L. Miller'; pharmwaste at lists.dep.state.fl.us
Cc: Fran G Gronberg; 'Mark Hardy'; Katie Miller; 'Bonnie Thom'; Halvorson, Diane; Bonnie Thom; Angela.Scharnowske; Amanda Volochenko; 'Rick Detwiller'; Michelle.Mckay at ndsu.edu; 'Laurel Haroldson (E-mail)'; Harvey Hanel; Daniel.Duletski at ndsu.edu; Gary Dewhirst; 'Dewey'; Joyce, Brendan; Gayle Ziegler; Dave Olig; Diane Halvorson; 'Eileen'; 'Judy Swisher'; Justin Stubstad; Marissa Clarin; 'David Lindell'
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection

Dear Mr. Anderson,

I understand your stance on this issue.  However, I still feel that
accepting unused medications in pharmacies would be a mistake.

One of the primary ways those diverting medications are caught is due to
the tracking systems in place (e.g., controlled substance logs).  In this
environment, inspections and proper procedures designed to detect
diversionary activities usually work.

For example, one can simply look at the pharmacy's purchase orders for a
medication such as OxyContin, subtract the number of tablets dispensed, and
compare that to the current count in the safe or on the shelf.  If there are
discrepancies, you start an investigation to identify who is diverting.
These systems not only catch diverters, but hopefully deter people from
diverting in the first place for fear of being caught.

Now, add in a take-back program.  Mr. Smith just passed away from bone
cancer, but he had a bottle of 500 mail-order OxyContin 80mg tablets that he
never took.  His widow brings the bottle into the pharmacy with all of his
other medications (chemo, blood pressure, etc.), and hands them over to an
employee.   At this point, there are no controlled substance logs to compare
any count to.  There are no legitimate records of the medications anywhere.

An employee could simply stash the OxyContin bottle in their lunch bag and
walk out with it at then end of their shift, and no one else would be the
wiser.  With a street value of about $50,000 for just this one bottle, I
would think that this might be more than a remote possibility.

Mr. Smith's expensive high blood pressure and chemo medications might not
command that high of a price on the street, but they could just as easily
find their way back on the pharmacy shelf in order to increase the store's
profitability. Again, since there is no tracking system in place, it would
be difficult to detect.

I hope you are right though, and my imagination is getting the best of me.
I would hope that everyone employed in pharmacies are responsible,
upstanding citizens.  And adding a steady stream of untraceable,
highly-addictive and/or expensive medications into this environment won't
increase the incidence of diversion.

Rod

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


On 3/26/12 5:21 PM, "Howard Anderson" <ndboph at btinet.net> wrote:

> 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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