[Pharmwaste] Items Accepted at Permanent Collection

[Jeff Travis]

Hello,



This is a very interesting and informative discussion.  It illuminates the issue of how to dispose of unused or expired medications, but also highlights valid concerns of two primary stakeholders, pharmacies and HHW facilities.  As the manager of our Environmental Center where we collect HHW and recyclables from citizens, I share the safety and security concerns mentioned in regard to receiving medications at our HHW facility.



I can also understand the concerns of the pharmacist as outlined by Mr. Larson, and I might add that a HHW facility would also need to ensure that medications are not pilfered by staff at the facility.  It seems that collection of medications at either a pharmacy or an HHW facility would require robust safety, security and tracking procedures to ensure staff safety and guard against diversion.



Here in Washington County, MN, my Department and the Sheriff have jointly developed a permanent drop-off program to collect unused or expired medicines from citizens.  It starts next week and is located in the lobby of the Sheriff's Office.  We will be looking to site additional locations. Other Minneapolis-St. Paul area environmental health departments are also offering this type of program in conjunction with their Sheriff. A couple of Sheriff's have joined with local police departments to site convenient collection locations.



A couple of years ago collecting medicines was just an idea; I look forward to seeing these programs evolve and how we can make a continued impact on drug diversion and environmental protection.

Jeff Travis | Program Manager
Washington County Department of Public Health & Environment
14949 62nd St N, PO Box 6 | Stillwater MN 55082
* 651.430.4033  |  6  651.430.4030
* jeff.travis at co.washington.mn.us<mailto:jeff.travis at co.washington.mn.us>




-----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 2:07 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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