[Pharmwaste] Take backs, Law enforcement, Med transport

[Jaramillo, Jeanie]

I've been reading the string of posts on the list serve with great interest.  As the developer of a program in Texas and having lived through the challenges with mixing law enforcement, environmental, pharmaceutical, and transportation issues; thought I'd share my two cents.

First, in response to the comment that Maine "found a way" to allow controls to be turned in through the mail, I wanted to point out that Maine is unique in that they have their own DEA that is independent of the standard DEA that we all talk about.  Because their mail back program incorporates mailing these envelopes directly to their DEA, the problem of allowing controls to be mailed was overcome.  Unfortunately, most of us do not have that option because we do not have our own independent DEAs.  Your thoughts, Dr. Gressitt?

We experienced much difficulty in gaining the participation of local law enforcement agencies because they did not want to have to accept the burden of storing and/or disposing of the meds (many actually store these in their evidence "lockers" which are often not that large) and on occasion, even if they had the space available, they did not have the dollars to support such efforts.  As a compromise, we offered to sort controls from non-controls and have LE take only the controls; thus reducing the burden.  In our city (population ~190,000), we routinely have about 300 cars come through during our drive through events and law enforcement routinely only has to take ~85 pounds (2-3 boxes) of controlled meds with them for disposal.  We considered not sorting, but this would mean that an officer would have to transport (or at least ride with the driver) the meds to the incinerator facility.  Our closest incinerator approved for pharmaceuticals is a 10 hour drive, which means an overnight stay (drugs in a truck overnight...not a good plan).  Our law enforcement can use commercial transporters, but they would still have to ride with them or the commercial transporter would have to employee a licensed officer as a driver.  This is why most commercial transporters do not accept controlled substances.  That was much more costly than having trained volunteers sort controls/non-controls.  That being said, we are affiliated with a school of pharmacy, so we have resources available that many programs do not.  (I would suspect one could recruit a volunteer pharmacist or pharmacy tech in almost any community to sort meds.  Sorting is very simple and can be done very quickly if you are familiar with the meds.)

I advocate for law enforcement at all events as these are prime targets for drug seekers.  (Aside from it being against the law to accept controls unless law enforcement is there to do so.)  I've heard many discussions in which persons were advocating that law enforcement not be required and I believe that is just asking for trouble.  Event staff and participants alike should have some assurance of safety (within reason).  A question the DEA needs to consider is "what qualifies as law enforcement?"  or maybe even better "what SHOULD qualify as law enforcement?"  A security guard?  Licensed peace officer?  My personal preference is an armed officer!  Our local law enforcement agencies who were previously skeptical now gladly participate as they've seen the benefits.  Getting drugs out of homes removes the potential for those drugs to reach the streets and lead to criminal activity and unfortunately, it's not just controlled meds that can be a problem.

Events can be run fairly smoothly with minimal staff and an officer.  They don't have to be cost prohibitive.  Unfortunately, there are those out there who decide a take back is a great idea, do little to no research on the relevant requirements, and put together haphazard programs that are often illegal.  With no one looking over these and putting a stop to them, eventually we will have an incident in which drugs are diverted or someone is shot/robbed.  Then, all of our programs will be put in jeopardy.

Jeanie Jaramillo, PharmD
Managing Director, Texas Panhandle Poison Center
Director, Medication Cleanout(tm)
Assistant Professor, Texas Tech UHSC School of Pharmacy
1501 S. Coulter St.
Amarillo, TX 79106
P: (806) 354-1611
C: (806) 672-0833
F: (806) 354-1667
Cisco IP: 30412

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