[Pharmwaste] RE: question about hospitals in DEA rules

[Volkman, Jennifer (MPCA)]

I read the DEA's summary of why they preferred to allow collection bins in retail and hospital pharmacies. I think it is reasonable. DEA is allowing more collection opportunities with the proposed rule, as they intended when they started the process. Pharmacies are the most logical collection point for convenience for household participation. We know that the general public doesn't participate if collection isn't convenient. There are thousands more pharmacies than hospitals. Every hospital I've been in has a pharmacy. If you consider implementation and oversight, DEA will have much to do to evaluate the safety and security of the additional opportunities they are allowing with the draft rule. I would argue that to ensure household participation, they've offered enough.
________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Ed Gottlieb [egottlieb at cityofithaca.org]
Sent: Thursday, February 14, 2013 5:58 AM
To: Deb Hoffman; Pharmwaste at lists.dep.state.fl.us; Charlotte Smith
Subject: [Pharmwaste] RE: question about hospitals in DEA rules

Deb,

You pose an interesting question.  If Charlotte's understanding is correct, then why not directly address DEA's concerns?

Couldn't we suggest that DEA allow hospitals to install duel-lock, secure drop-boxes in nurses stations?  That would put collected medications in a highly tamper resistant container in a monitored location, away from visitors and patients.  For that matter, don't many hospitals have locked storage closets for medical supplies that would also be secure enough to house a drop-box?


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


>>> "Smith, Charlotte" <csmith at pharmecology.com> 2/13/2013 3:38 PM >>>
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] On Behalf Of Hoffman, Deb
Sent: Wednesday, February 13, 2013 2:17 PM
To: 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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