[Pharmwaste] RE: question about hospitals in DEA rules

[Michael Wahl]

I would add that hospitals serve a specific purpose, to care for the acutely and critically ill.  They should not be thought of as open environments for the general public to walk through like a library, post office, police station or community pharmacy.

Hospitals are also critical community resources for disasters, pandemics/epidemics and malicious/terrorist events.  For the latter, the federal and state governments consider hospitals to be high risk targets.

Given the above, hospitals really are not appropriate places to have the general public drop off expired medications into an unsupervised bin.

Mike Wahl



From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Smith, Charlotte
Sent: Wednesday, February 13, 2013 2:39 PM
To: Hoffman, Deb; Pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: question about hospitals in DEA rules

Hi Deb,

It is my understanding from the discussion in the proposed regs that DEA feels that the hospital environment is too open and unsecured. Visitors may be in the area for hours, whereas people are usually in and out of a retail pharmacy, making it easier to keep an eye on those who might pose a risk.

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


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From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Hoffman, Deb
Sent: Wednesday, February 13, 2013 2:17 PM
To: Pharmwaste at lists.dep.state.fl.us<mailto:Pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] question about hospitals in DEA rules

Hello everyone,

I have been contacted a few times over the years about whether or not hospitals could collect pharms and I've always had to say "No."

Can someone tell me why DEA specifically excluded hospitals from being allowed to collect in the proposed rules?  I know retail pharmacies in hospitals can collect, but I'd like to know why nowhere else.

I'm working on some comments, so if you could get back to me soon, that would be much appreciated.

Thank you,
Deb Hoffman
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