[Pharmwaste] DEA results and future plans

Ed Gottlieb egottlieb at cityofithaca.org
Mon May 7 14:13:35 EDT 2012


Based on a comment I received, I want to clarify my last email.
 
My thought was to ask the DEA to request any information collected by
locations on their own initiative.  I would not dream of asking the DEA
to request that anyone collect more information than they want to.
Providing the form with questions would give participants who want to
collect data ideas about what they might choose to focus on.  Just
creating this list reminded me that I had forgotten to weigh the
recycling we pulled out of the material brought in.  Luckily, it was
still around!
 
The only additional work generated would be a few minutes for sites
with additional data (probably a very small percent of participating
sites) to send it to the DEA.  The DEA could choose to have someone
analyze the information that comes in or they could simply hold it for
others (maybe some of us) to download and analyze.
 
By the way, we recycled less than half of the packaging that came in
(had to give it up when we fell behind.)  It came to 114.1 pounds (53.5
of which was pill bottles.)  Adding this total to the 1227.5 taken by
the DEA yields a packaging diversion rate of 8.5% by weight.  My
guesstimate would be towards the lower half of the 25%-35% packaging
range offered below.
 
Ed
 
>>> "DeBiasi, Deborah (DEQ)" <Deborah.DeBiasi at deq.virginia.gov>
5/7/2012 10:43 AM >>>
Ed,

           Every agent does things a little differently so it may be
that the agent that covers New York isn’t as forthcoming with
information about the individual sites as the agent we have in Virginia.
 Jay shares a lot of what he sends to Law Enforcement with me, mostly
because I established a good relationship with him/DEA when he was first
tasked with doing the collections.  He is pretty meticulous with
recording the information collected in his jurisdiction, and distributes
items provided to him by Poison Control and us, the environmental agency
along with the DEA materials for collection day..
           The overall goal of the DEA Take Back program is to collect
as much as they can, and to make it as simple and safe for law
enforcement as possible.  (Remember that not all law enforcment folks
are created or trained equally, and may only have one bullet for a
reason.)  Law enforcement appreciates their intent since they too are
mostly interested in the end result of getting the drugs out of homes.
The DEA directions include encouraging people to drop their drugs into
the collection box in whatever the participants have them in so that law
enforcement doesn’t have to handle them – just no sharps or aerosols.
The only way to collect more information would be to have additional
volunteers that are pharmacists, or pharmacology students to sort and do
record keeping.  The DEA agents probably aren’t going to want to deal
with encouraging that additional level of staffing at the sites given
the monumental task of organizing this endeavor nationwide.  The
secondary issue is whether the law enforcement that run each site will
want to deal with collecting that level of detailed information, versus
“just throw it in the box” instructions.  Another complication may be
something as simple as “turf”, given the DEA is federal suggesting extra
work to state, municipal or county law enforcement.
           It is interesting to see the breakdown of controlled
substances, non-controlled substances, recyclable vials and trash that
are turned in and ultimately destroyed, but I don’t know how relevant it
really is to the people sponsoring the events.  My “guesstimate” is that
about 25-35% of what is collected is packaging based on what I’ve seen
during my county collections.
           The law enforcement perspective is that there are less
controlled substances that can be abused in their jurisdiction.  The
health and poison control professions would be glad to see all of the
medications destroyed to keep them from being abused, and if some paper
and vials go with them, so be it.  The environmental perspective would
be focused on the amount of drugs (all of them) that were removed from
potentially being in the environment, and possibly the amount of vials
that could be recycled.  The medical and pharmacology professions may
want to know the details of exactly what was collected and why, but I
don’t see a lot of interest from them to provide the staff volunteers
and record keeping abilities at these collections to get this
information.  I suspect that if the Medicare/Medicaid folks thought
about it, they would be excited (and not in a good way) about the amount
of medications that are being destroyed that their funds may have paid
for.
Required Information
Host department:          Noted on the DEA locater site
Collection date:             Set by DEA
Collection site:              Noted on the DEA locater site
 
Weight collected:      (specify: if this includes all packaging or if a
significant amount of packaging was first removed)
 
Voluntary Information (note "n/a" if information not available)
Approximate weight of trash and recycling removed from flow before
final weight taken:    Law enforcement encouraged to not handle the
drugs dropped off
Number of participants: Law enforcement are encouraged to note how many
cars/participants there were
Estimated doses of controlled substances collected:    (specify how
counting was done)      DEA is willing to pay for incineration of
whatever is collected, so the breakdown of
controlled/non-controlled/recyclable drug vials/packing is moot to them
Percent of controlled dispensed to controlled received:     See above
By weight % of controlled received to total collected:       See above
Number of officers, staff, & volunteers helping at site:      We note
this in Virginia – don’t know about other states
Inventory data  None collected
Any other data collected            In Virginia, each full bag of drugs
is sealed, numbered, weighed and labeled with the site information prior
to being moved to the next consolidation point.
Was the DEA outreach material utilized?              Like what
specifically?
    They delivered 11x17" posters in Spanish and 1/3 page fliers in
English & Spanish (just a few days ahead of the event.)
DEA HQ contracts to put ads in papers and on TV nationally.  The agents
in each state vary with their outreach.  Our agent in Virginia works
with the AG’s office, school board, governors office and law enforcement
professional groups to spread the word.  Our environmental agency
reaches out to citizen environmental groups and river keeper
organizations, environmental staff, POTW staff, and other groups as I
come across contacts for them.  I also put a link on our agency website
for the DEA collection event.
 
How much money was spent on additional outreach?  Spent by whom?  The
law enforcement who ran the site(s)?
    Anyone involved in a collection.  Where the money came from is
another interesting question.
 
Comments:
 Deborah L. DeBiasi, Virginia DEQ
Office of Water Permit and Compliance Assistance Programs
Email:   Deborah.DeBiasi at deq.virginia.gov
PH:         804-698-4028
 

From: Ed Gottlieb [mailto:egottlieb at cityofithaca.org]
Sent: Monday, May 07, 2012 7:10 AM
To: DeBiasi, Deborah (DEQ)
Cc: Burke.Lucy at CalRecycle.ca.gov; Margaret Shield; Jennifer (MPCA)
Volkman
Subject: RE: [Pharmwaste] DEA results and future plans

 

Deborah,

 

>From what you say it seems I should ask our state agent again if more
detailed information is now available.  Though the State & Federal
office indicated to me that the information was not available, it does
seem silly that information collected by local agents wouldn't be sent
to the State and the National office.

 

What I was suggesting is that we encourage the DEA to invite all
participating law enforcement agencies to submit any data collected at
their site in addition to the required weight collected number.  The
invitation could be accompanied by a form with questions like:

Required Information

Host department:

Collection date:

Collection site:

Weight collected:      (specify: if this includes all packaging or if a
significant amount of packaging was first removed)

Voluntary Information (note "n/a" if information not available)

Approximate weight of trash and recycling removed from flow before
final weight taken:

Number of participants:

Estimated doses of controlled substances collected:    (specify how
counting was done)

Percent of controlled dispensed to controlled received:

By weight % of controlled received to total collected:

Number of officers, staff, & volunteers helping at site:

Inventory data

Any other data collected

Was the DEA outreach material utilized?

How much money was spent on additional outreach?

Comments:

 

Ed

 

>>> "DeBiasi, Deborah (DEQ)" <Deborah.DeBiasi at deq.virginia.gov>
5/4/2012 2:20 PM >>>

Ed,
           The DEA agent for your state should be able to provide the
sites and pounds collected at each site.  Our agent in Virginia is very
forthcoming with that information, and sends it to me.  Virginia had 180
sites run by 130 law enforcement agencies, and collected 16,899.2 pounds
of drugs this time.  That was a big increase over previous collection
events.  For Virginia, drugs are collected at the sites in bags which
are tagged with the site name/address and rough weight, then taken to
the State Police Regional Office for holding, consolidated by the DEA
agents, weighed exactly and then taken to the incinerator for
destruction.  Our agent puts the info on a spreadsheet with the totals.
Not all states have that degree of thoroughness and sharing.
           I don’t know what you are asking here:  Do you think that if
some of us asked the DEA to offer to accept any data a site wishes to
provide at the fall collection, they would do so?  We could suggest that
their offer could be structured in a way that would generate comparable
results.  Am I wasting my time?
 
 
 

Deborah L. DeBiasi, Virginia DEQ
Office of Water Permit and Compliance Assistance Programs
Email:   Deborah.DeBiasi at deq.virginia.gov
PH:         804-698-4028

 

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Ed
Gottlieb
Sent: Friday, May 04, 2012 1:42 PM
To: Stevan Gressitt; pharmwaste
Subject: [Pharmwaste] DEA results and future plans

 

I called the DEA Public Affairs phone number, listed on the press
release Stevan sent us (below), to see if I could get more data.  They
only have total weights for States and DEA Regions.  They can't get and
didn't seem interested in any information other than this...old news, I
know.  The women I spoke with actually was under the impression that
privacy rules would not allow them to get participation numbers.  I
pointed out that was not an issue since no names were being collected
(let alone names linked with medications.)  She provided contact
information for the NY DEA Public Affairs office.
 
The NY office called me back since the data was just coming in.  NYS
had more than 300 sites and collected 37,000 pounds of medications.
When I asked for a more accurate site count she referred me to the DEA
site locator.  That was already taken down I told her.  The NY office
probably had just gotten more detail than this (maybe the totals were
not done?) since she was able to tell me that the Syracuse regional
office collected 5285 pounds.  Not having an exact number of sites or
weight count only allows a rough state average to be
calculated…123#/site.  I called the Syracuse office to learn that
they had 34 sites (yielding a more accurate local average of 155#/site.)
 I presume that all sorts of data were collected at a minority of sites
nationwide, especially the number of participants.  Since the DEA
doesn't ask for any information other than weight, they aren't given it.
 At this point, it would be very difficult to find the data that was
collected.
 
Do you think that if some of us asked the DEA to offer to accept any
data a site wishes to provide at the fall collection, they would do so?

We could suggest that their offer could be structured in a way that
would generate comparable results.  Am I wasting my time?
 
I think the following information was already posted on the Listserv.
For my own clarity, I asked the main DEA office what their plans were
for future collection events.  She confirmed that they are planning a
fall collection since the rules for the Safe Drug Disposal Act will not
be in place before then.  They have no intent to hold any collections
after that.  Once the new rules are published in the Federal Register
there will be a final comment period.  The DEA may choose to make
changes, based on the comments received, before they publish the final
rules.
 
Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY 14850
(607) 273-8381
fax: (607) 273-8433

>>> Stevan Gressitt <gressitt at gmail.com> 5/3/2012 6:28 PM >>>
http://www.justice.gov/dea/pubs/pressrel/pr050312p.html

--
Stevan Gressitt, M.D., D.F.A.P.A.
Faculty Associate, University of Maine Center on Aging
Academic Member, Athens Institute for Education and Research
Athens, Greece
Founding Director, International Institute for Pharmaceutical Safety
University of New England, College of Pharmacy
Department of Pharmaceutical Sciences
Associate Professor of Clinical Psychiatry
University of New England, College of Osteopathic Medicine
314 Clark Road
Unity, Maine, 04988
gressitt at gmail.com
Cell: 207-441-0291
www.benzos.une.edu
www.safemeddisposal.com
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