[Pharmwaste] Pharmaceutical drop off event at College Campuses during move out?

Fri Jun 7 15:15:56 EDT 2013

In NYS, permits are needed from the DEC and DOH Bureau of Narcotic
Enforcement and notification needs to be given to a very specific office
of the DEA.  The permits include: site plan, traffic flow, spill
containment and clean-up provisions, evacuation procedures, SOP, officer
badge number & contact info, disposal location, etc.  Depending on the
type of incinerator, a variance is likely to be needed to burn this
waste.  I've done the whole process a few times and it got easier,
though it is still quite a bit of effort.
Hope the DEA keeps up their collections!

Ed

Ed Gottlieb
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY  14850
(607) 273-8381
fax: (607) 273-8433
>>> "Volkman, Jennifer (MPCA)" <jennifer.volkman at state.mn.us> 6/7/2013
2:56 PM >>>

Given the issues with controlled substance abuse, I think it should be
easier to convince law enforcement to participate so you can collect
controlled substances. Without that, it doesn’t seem like there’d be all
that much to capture or a strong reason to do it? I would think they’d
take them with them vs. the couches and desks…

I am curious about the “required state permits”. Are these through DEA
or a state agency? The DEA here is not so stringent. They were at first,
but as long as law enforcement is involved, they don’t require an
additional permit or specific submittal. The Board of Pharmacy wants a
simple notification if the event takes place at a pharmacy and the MN
Pollution Control Agency requires collection sites to obtain an EPA ID
number and to submit a one page notification form. Then we ask them to
report the pounds collected annually.

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, June 07, 2013 11:22 AM
To: pharmwaste at lists.dep.state.fl.us; Paul Prange
Subject: Re: [Pharmwaste] Pharmaceutical drop off event at College
Campuses during move out?

Hi Paul,

This year, an Ithaca College (IC) student took on the task, rather last
minute, of organizing a campus take back for non-controlled in the week
leading up to the April 27th DEA collection.  It was done in the IC
health center where staff had the expertise to not accept controlled.  I
think they collected about 6 pounds.  I know some fliers were posted on
campus.  Don't know what other outreach was done.

A few years ago, before we installed a drop-box at the Cornell
University (CU) Police station, we discussed the possibility of holding
a collection event there at the end of the school year.  Staff that
clean the dorms routinely find abandoned medications.

It didn't end up happening primarily because getting required state
permits to collect controlled substances would have taken a substantial
amount of time and effort.  I have been told that will remain the case
in NY even after the new DEA regulations take effect.

During the discussions with CU, we did conclude that choosing the right
date was key to a successful event.  Too soon before the end of the
semester and students might not be ready to part with medications that
might still be needed.  Too close to the end and students would be so
focused on finals that they probably wouldn't take the time to
participate.

Like you, I'm curious to hear if anyone has done an end of term
collection at a campus and if they think they found the "sweet spot"
timing for the event.

My own opinion is that a well advertized campus drop-box would be a
more convenient disposal option than a one day event.  Of the eight new
boxes that opened for use in Tompkins Count on April 27, the only one to
deliver a load to the Sheriff for storage was CU (29.65 pounds.)  Be
prepared for delays if you decide to do drop-boxes.  We purchased one
for IC after their police chief told us she wanted it.  She did warn us
that it still required approval by Administration.  Her request was
submitted to the schools General Council 18 months ago.  A decision has
not yet been made.

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

>>> "Prange, Paul" <Paul.Prange at sanjoseca.gov> 6/7/2013 11:23 AM >>>

Has anyone done or do you know about anyone who has done a
Pharmaceutical drop off event at the end of term at a College Campus?
It seems like the students would be disposing of all their collected
meds as they move out of student housing so I would be interested to
hear if this actually worked as a collection event.  Please send me a
link if you have it.

Thank you

Paul Prange
Pollution Prevention
Watershed Protection
City of San Jose
Phone 408-793-5325
paul.prange at sanjoseca.gov

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