[Pharmwaste] Do drug collection programs address possession of controlled substances that are not in their original containers?

Wed Mar 28 18:52:52 EDT 2012

As Amy and I have discussed, the point of the ordinances is to deal with illegal sale of prescription drugs. You bust someone with a baggie full of oxycontin or other CS and they better have a prescription bottle somewhere with their name on it. Preferably on them with the pills in it, or you'll get busted for dealing. I think that if people haven't seen much of these ordinances, you could start seeing more in the near future.

All of our collection points are at law enforcement centers and the medications are incinerated at approved Waste to Energy facilities. There is no requirement to sort controlled from non-controlled, it is all packed together and sealed in fiber drums, then delivered by law enforcement and fed into the incinerator with law enforcement witnessing the burn. The cost to pay someone to sort and law enforcement to oversee the sorting generally outweighs the disposal cost of just shipping them all.

Since there is no sorting going on for data purposes and there is no need to sort out CS from non-CS, the thought was to reduce the volume and therefore the cost of the program to law enforcement. As was noted in a previous string of messages, law enforcement is sometimes balking at paying for burning non-CS as well as all of the packaging. Also, it could be that recycling pill bottles will become more prevalent and we'd be advocating recycling.

I hadn't really thought about it before we talked, but MN's Board of Pharmacy regulations allow for people to possess prescription pharms from other people for the purpose of disposal at a legitimate collection site. Most Boards only allow the person who is prescribed the medication to possess it. 

So, due to the ordinances and because of the way the Board of Pharmacy regulations are written, prescribed medications should stay in their original containers, but we could try to encourage consumers to baggie up the non-prescription meds and recycle containers if that is available in their area. At least it is simpler to explain the difference between OTC and prescription medication than it is to explain CS/non-CS.  

And then, regardless of what we advise, we'll still get them in baggies or other containers and that is just going to happen a certain percentage of the time. 

Also, related to the previous string on law enforcement balking at accepting anything other than CS, you could recite the high percentage of poisonings related to OTC's like acetaminophen, iron vitamins and that there is a cost to  respond to those situations via 911. The education that goes along with collecting everything helps raise awareness of the drug abuse, poisoning and environmental issues. It's all good! There is no reason that the County Public Health Department, County Solid Waste Department and County sheriff can't all work together to share resources along with the manufacturers.

JV
_______________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Perry, William [William.Perry at kingcounty.gov]
Sent: Tuesday, March 27, 2012 4:45 PM
To: 'Amy.Roering at co.hennepin.mn.us'; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Do drug collection programs address possession of     controlled substances that are not in their original containers?

Greetings, Amy -  I've never heard of any ordinances in our area regarding pill containers, but containers are a big factor in the program operated by our retail pharmacy partner here in Washington State.  In that program , a pharmacist must examine the medicines  brought in by customers before they can be dumped in the secure collection bins.  The big thing that the pharmacists are looking for are controlled substances, since they can't legally accept those drugs due  to the current DEA regs.  The info on the containers is key to identifying the controlled substances - for that reason, all the customer education directs folks to bring in their unwanted meds in original containers.  When customers do bring in medicines in plastic bags or other non-original containers, the pharmacists often reject those medicines, and direct the customer to a law enforcement location that can accept all medicines, including controlled substances.  Sometimes, if the pharmacist is confident that they can identify all the mis-packaged meds, they'll accept them.

I'm also aware of the medicine safety aspects - medicines in unlabeled containers might be involved in a poisoning or some other form of mistake.  If a poisoning were to occur, then proper labeling would be crucial for any  medical responders treating the victim.  I'd see this as another reason we advise folks to keep their medicines in the original containers.  On the other side, I've hear arguments that advocate the removal controlled substances from their original containers, so the labeling won't clue in those interested in recreational use.  You hear this argument from those that point to the garbage can as an appropriate disposal method for waste medicines.  I'd say that this is more of a point in favor of providing secure and convenient return programs for those drugs.  Tata -

Will Perry
Health & Environmental Investigator II
Public Health / Seattle & King County
401 Fifth Ave, Suite 1100
Seattle, WA 98104
206-263-8477   william.perry at kingcounty.gov

-----Original Message-----
From: Amy.Roering at co.hennepin.mn.us [mailto:Amy.Roering at co.hennepin.mn.us]
Sent: Tuesday, March 27, 2012 7:01 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Do drug collection programs address possession of controlled substances that are not in their original containers?

Hello,

We've run across a couple of city ordinances that forbid people from possessing controlled substances in anything but their original containers.  This presents a problem because, in reality, some people carry these drugs around in other containers or keep them in pill reminders.  Or, people
(caregivers) may dispose of these drugs of behalf of someone else.

Have any other drug collection programs addressed this issue?  If so, what do you advise residents to do in these situations?

Amy Roering
Hennepin County | Department of Environmental Services | MC L-609
701 Fourth Avenue South, Suite 700 | Minneapolis, MN 55415 Office phone (612) 348-8992 | Cell phone (612) 382-5790 Faxes (612) 348-6510 & (612) 348-8532 amy.roering at co.hennepin.mn.us

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