[Pharmwaste] Items Accepted at Permanent Collection

[Fredrick L. Miller]

That's the easy and cheap part.....for those with the trained staff.
That's why I suggest the HHW programs are the right place to locate the
pharm take back programs.

 

What Alice has described is only a small part of the equation.  When one
gets down into the weeds of 49 CFR there are all sorts of nasty little
requirements such as initial and refresher training for all HAZMAT
employees, having staff with adequate knowledge of the chemical and
physical properties of all materials shipped to act as 24/7 emergency
response POC while shipments are in transit, transportation security
plans (when required),  as well as the knowledge and experience to deal
with the oddball situations which are sure to crop up.  

 

Remember, DOT doesn't care that we're doing good things for the
community and the environment.  All the inspector who catches an
improperly manifested load knows is a violation occurred.  Once they get
done writing your waste hauler a ticket for that, they're going to come
inspect your program.  They're going to want to see at least two years'
worth of shipping records, training records, and your TSP.  They're
likely going to interview your employees.  Then they're going to
determine whether your violation was just a one-time occurrence, a
matter of ignorance, or a matter of willful disregard.  First fines are
pretty light.  Somewhere in the $15-30k range.  Get caught again in the
subsequent two year period and the entry fee jumps to around $100k.  Get
a third in that period and they start looking at potential criminal
prosecution if the same management/executive level names keep cropping
up.   Personally, I find the EPA and OSHA to be real pussycats compared
to DOT when it comes to enforcement actions.  But there are those who
insist on trying it their way.  You can view their fate on DOT's web
site if you care to look.

 

Fred Miller

 

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Chapman,
Alice
Sent: Wednesday, March 28, 2012 5:50 PM
To: 'pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] Items Accepted at Permanent Collection

 

Hello,

 

Part of this discussion thread raised concerns about the potential
application of DOT regulations to law enforcement medicine take-back
programs.

 

When we worked with local pharmacies and other partners to develop
take-back programs, we carefully walked thru the DOT regulations with
the assistance of DOT staff and were able to find proper shipping names,
labels, and convenient non-bulk packaging that suited the operation. 

 

If law enforcement were to change from self-transportation to using
commercial transportation, they could use the same options that have
successfully been used at pharmacy take-back programs since 2006. Other
areas of the US, such as Maine, have learned how to transport materials
in the mail.

 

We recommend that take-back programs stick with standardized protocols
that have been demonstrated successful at preventing many of the
problems and concerns that were raised in this discussion thread.
Appropriate agencies need to be involved in developing protocols that
work, and to have a role in ongoing oversight and assistance of
take-back operations. Learn about take-back programs in Washington here:
http://www.takebackyourmeds.org/why/how-medicine-take-back-works. 

 

Thanks, ac

 

Alice Chapman, PE | Local Hazardous Waste Management Program in King
County
130 Nickerson St, #100  Seattle, WA  98109 | 206-263-3058 ph |
206-263-3070 fax 
alice.chapman at kingcounty.gov | www.lhwmp.org 

 

Research Services: 
Providing the scientific foundation for 
LHWMP's technical assistance and programs.

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