[Pharmwaste] Publication Date for new DEA Rule?

Ed Gottlieb egottlieb at cityofithaca.org
Thu Feb 27 15:40:38 EST 2014


Hi All,
 
Someone on the Listserv asked me if the rumor of a delay in the
publication of the rule is true.  Not having heard back from the DEA's
office of Public Affairs, I called Special Agent Moses again.  He
apologized for not getting back to me, they have been very caught-up in
the recent arrest of the head of the world's largest drug cartel.
 
After looking into my questions, he repeated his story:
The first reason it is taking a long time is that a very large number
of comments were received and each had to be individually addressed.
The other reason is that many regulations in this rule (small "r" by the
way) need to mesh with rules from many other agencies.  At least some of
these agencies (he use the OMB as an example) are required to respond
within a set period of time from when they receive the draft.  Then,
every change that each agency asks for has to make the rounds of all the
other agencies until a final version is approved by them all.  Agent
Moses is not allowed to say (and probably doesn't know) where the rule
has made it to in this process.  Until it is final, the DEA can't
comment on any aspect of the rule.  Once the rule is published, his
office will have time to coordinate a press release/outreach plan with
the Office of Diversion Control.
 
The bottom line is the DEA may, or may not, publish the final rule on
schedule this coming month.
 
Going to the "front door" of the DEA has not gotten the answers we
seek.  Writing now, in retrospect, when the rumor was mentioned, I
should have enquired where they heard it and offered to help trace it
back to it's source.  It could be based on real information or could
easily have arisen from a misunderstood conversation.
 
If someone tells you they heard publication is delayed (or on-time),
please see if you can track it down.  Maybe it will led to someone who
says that they spoke to an official, in a position to know, who couldn't
comment on the record.  That is the sort of rumor I'd like to hear
about!
 
Ed
 
 
 
The new DEA rules are due to be published sometime next month.
 
Considering the amount of free media coverage CVS is getting for
announcing they will no longer sell cigarettes, I am hopeful that at
least some pharmacy chains will jump on this opportunity to stand out by
doing something that is good for public health and the environment.
 
I called the DEA office of Public Affairs to find out what they are
planning on doing when the new rules are published.  Special Agent
Joseph Moses told me that:
 
·       Every registrant approved to sell controlled substances will be
notified of the new rules.
·       Either the DEA Office of Diversion Control or the Public
Affairs office will issue a press release.
·       Some pharmacies have expressed interest in collecting
medications under the new, anticipated, rules.
·       Until they are published he can’t comment on the content of the
rules.
·       He doesn't know when they will be published.
·       The April collection event may (or may not) be the last one
they organize.
·       He will look into my question of how the DEA is planning get
the word out and get back to me next week.  He seemed to agree that a
change in the legality of trashing and flushing unwanted medications is
significant and a public ad campaign would be appropriate.  Decisions
about things like this are not his to make.
·       I should pursue my ideas for a local public education effort.

 
Are any of you considering a public education campaign to announce the
change in the law (once it is official) and promote your safe disposal
options?
 
Should we consider pooling resources to produce quality outreach
materials (print ad, flier/poster, radio and T.V. spots, and …?) to
which local disposal information can be added?  And/or should we be
encouraging the DEA to do this?
 
The group I work with, the Coalition for Safe Medication Disposal, met
today and discussed outreach ideas.
 
·        Issue a press release about the new rules.
·        Ask the Sheriff or a police chief to record a 30 second radio
PSA (free.)  We can help with the script.
·        Have this law enforcement leader pose with handcuffs raised
behind someone pouring pills in a toilet for a poster/print ad;
important that this is done with humor!
·        Enlist the help of a local high-school or college media lab to
produce a PSA for public access cable TV.  Again, the Sheriff or Chief
could be featured.
·       When it is time for the DEA spring take-back event, use the
news radio air-time we always get to talk about the new rules and local
disposal options.
·        Send a letter to all the local pharmacies, with copies to
their corporate headquarters, asking if they plan on participating in a
drop-box program and offering to help publicize it if they do.
·        Ask local municipalities to mention the new rules and promote
our drop-boxes on their websites, bulletin boards, news-letters, etc.
·        We decided to not organize a large, drive-thru collection
event in April.  Instead, we will focus our energy on promoting local
drop-boxes, both our own and any that open in pharmacies.
 
We would be happy to consider any additional outreach ideas you would
like to contribute.  Thanks!
 
Regards,
 
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
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