[Pharmwaste] Re: Pharmwaste Digest, Vol 88, Issue 1

Mon Feb 4 20:02:53 EST 2013

I believe Charlotte is correct but they (Clean Harbors) were having difficulties working out how to live with the DEA requirements from a logistical standpoint.  WTE plants are a good option as well, and likely offer an easier path due to the absence of RCRA permit restrictions.

Fred

From: Catherine Zimmer [mailto:zenllc at usfamily.net] 
Sent: Monday, February 04, 2013 4:27 PM
To: Smith, Charlotte; Fred Miller; 'Tanya Roberts'; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Re: Pharmwaste Digest, Vol 88, Issue 1

Hi Everyone,

Tanya, what would help the most to minimize the waste and risk of diversion is to reduce the amount of pharmaceuticals in circulation.  Our elected officials need to encourage physicians and other practitioners to follow the recommendations of CMS’ new rules calling on new prescriptions to be a trial dose, and to minimize prescribing in general.  Everyone can point to an instance of where they were prescribed 30 days worth of Vicodin, when they needed less than a week’s worth.  Practitioners should also rely more on non-pharmaceutical interventions such as physical therapy, Neti pots, exercise, etc., rather than being so quick to “take a pill”.  

PSC LLC is another hazardous waste hauler that can dispose of controlled substances using its DEA reverse distribution registration.  

Very truly yours,

Catherine Zimmer, MS, BSMT

ZEn LLC

From: Smith, Charlotte <mailto:csmith at pharmecology.com>  

Sent: Monday, February 04, 2013 11:02 AM

To: Fred Miller <mailto:millerfl at tricity.wsu.edu>  ; 'Tanya Roberts' <mailto:tanyaproberts at gmail.com>  ; pharmwaste at lists.dep.state.fl.us 

Subject: RE: [Pharmwaste] Re: Pharmwaste Digest, Vol 88, Issue 1

It’s my understanding that Clean Harbors, Veolia, and Heritage all have DEA reverse distribution registrations and are therefore already set for at least one of each of their locations to handle controlled substances.  We are recommending that mailback options be extended to reverse distributors who do not have incineration facilities so there are more options. The returns can be consolidated at the reverse distributors and hauled to the incinerators in a more economical fashion. This would also open up the waste-to-energy incinerators, not just RCRA, for those not living in states that require RCRA incineration. 

Best regards,

Charlotte A. Smith, R. Ph., M.S.

Senior Regulatory Advisor

WM Healthcare Solutions 

Tel 713-725-6363 

877-247-7430

Waste Management 

1001 Fannin

Houston, TX 77002

 <http://www.linkedin.com/company/wm-healthcare-solutions/products> Follow Waste Management on LinkedIn

 <http://www.linkedin.com/groups/Sustainable-Healthcare-Solutions-4024202?goback=%2Eanp_4024202_1312471264838_1%2Egna_4024202> Join our Healthcare Sustainability group on LinkedIn

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Fred Miller
Sent: Monday, February 04, 2013 10:46 AM
To: 'Tanya Roberts'; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Re: Pharmwaste Digest, Vol 88, Issue 1

In my perfect world someone would direct the DEA to work with any/all RCRA permitted incineration facilities to establish them as allowable outlets for disposal of controlled substances.  Such a program would entail sensible, workable, economically viable means for the incinerators to accomplish this so they have the economic incentive to get into the business.  Further, transportation to such facilities would be addressed in a similar manner.

Fred Miller

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Tanya Roberts
Sent: Friday, February 01, 2013 1:15 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Re: Pharmwaste Digest, Vol 88, Issue 1

Next week I am heading to D.C. and will be on Capital Hill to advocate for substance abuse prevention issues. One of my primary issues will be the prescription drug epidemic and concerns about the proposed DEA regulations for the take back events. What recommendations do you have for requests of our federal elected officials? What can they as our legislators actually assist us in doing? I want to be prepared to ask for things they CAN do. Thank you for your insights!

Tanya

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