[Pharmwaste] Collection Receptacles/Inner Liners New DEA Regs

[Ed Gottlieb]

Angela,

I think you are absolutely correct.  With the labeling fix you noted, the dVault system of using disposable cardboard boxes lined with plastic bags should be compliant with the new regs.

My situation is different.  The dVault box we use has a heavy duty, reusable plastic tote that we line with a plastic bag.   

Ed   

>>> Angela Deckers <ADECKERS at cityofboise.org> 1/30/2013 10:54 AM >>>

All – Please correct me if I am wrong, but when I read the proposed requirements for the inner liner I assumed that our 14 inch cube boxes with plastic liners would be the “liner” of our dVault collection containers. When our units are serviced by police officers or evidence room techs, the plastic liner is folded into the cube box which is custody sealed and entered into the police evidence room with a unique tracking number.  The boxes are opaque, no one goes through the contents prior to sealing, and the box is given a tracking number. As far as I can see, the only requirement we may not be meeting is: “size of inner liner must be clearly marked on the outside of the liner.” I would think a sharpie could remedy this requirement.
Feedback would be appreciated, especially if I am missing something.
Thanks.
___________________________________________________________
Angela Deckers
Hazardous Materials Coordinator
Environmental Division, Public Works
CITY OF BOISE
Phone 208/384.3983; Fax 208/433.5650
adeckers at cityofboise.org

 
 
 
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Ed Gottlieb
Sent: Wednesday, January 30, 2013 6:51 AM
To: info at greatlakescleanwater.org; Pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Collection Receptacles/Inner Liners New DEA Regs
 
I'm wondering if anyone else would join me in requesting a tweak to the proposed new regulations for inner liners?
 
We line our drop-boxes reusable, removable tote with a black plastic bag.  When full, the bag is lifted out, taped shut, and placed inside a hinged lid plastic storage container.  This container is sealed with a numbered zip-tie.  
 
Though our system meets the spirit of the proposed new regulations, the current wording would require us to change procedures so the bag rather that the bin is labeled.  I will be requesting a wording change to broaden the securely sealed and uniquely ID'ed requirements.
 
If current wording remains, do you think our numbered zip-tie could be used to seal the bag closed?  Then we would leave the storage bin unsealed.  Or, would it be better to shop for a non-removable bar code or numbered sticker large enough to seal the plastic bag or we could seal the bag with evidence tape and attach a separate ID sticker for each bag. 
 
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


>>> "Chris Angel" <info at greatlakescleanwater.org> 1/29/2013 5:29 PM >>>
Regarding Collection Receptacles. In addition to the New Proposed DEA Regulations for receptacles mentioned previously, DEA is proposing New Regulations for the inner liner of containers. Details can be found on pages 125-127 of the proposed Rules. Entities looking at purchasing collection receptacles should inquire with collection receptacle manufacturers how their products address those new requirements for inner liners as well as the new requirements for  the Collection Receptacles.

Our system will be using barcode identification and tracking of all Jugs/inner liners with an outer container meeting all  requirements of the proposed rules.


Chris Angel,President
Great Lakes Clean Water Organization
Yellow Jug Old Drugs program
www.greatlakescleanwater.org
989.736.8179

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