[Pharmwaste] RE: Anyone using Cactus Sink?

Dave Maness dmaness at cactusllc.net
Tue Jul 1 09:42:35 EDT 2014


Thank you for interest on this topic.  I wanted to take a moment and respond
to Jeff's feedback with our comments below.  

 

1.      Smart Sink does not meet DEA regulations for the disposal of DEA
controlled substances.

The DEA does not categorically approve or endorse any particular product or
method other than flushing or incineration.  When a medical facility or
system requests guidance they may receive various and often conflicting
responses.  In regions or states that have already or are moving toward "no
flushing" policy there are typically no options.  If they choose
"incineration", under the current rule, the customer will need a DEA
registrant (a reverse distributor) to send cartridges for final documented
incineration. The Smart Sink renders the byproduct "un-usable" and
"non-retrievable"   Many consider this option a safer and more effective
system, and the perfect transport vessel for final "documented destruction"
of the byproduct.   

 

2.      The facilities that are using the Smart Sink have approached their
local DEA/State Regulatory entity and have received written exception
approval to dispose of DEA controls under an agreed upon process - meaning,
they are now within compliance.

We agree, it will be the responsibility of the medical facility to reach out
to their local, State or regional DEA/Regulatory agency for proper waste
classifications and documentation for final disposal/destruction.   For the
first time in many years, we see State DEPs and DEA working together to help
provide workable solutions for this complex and environmentally sensitive
issue.  

Of course this is the primary goal of the Pending Proposed Rule from the
DEA.  

 

3.      Regulatory approval is not an automatic or guaranteed process.  

Reaching out to the appropriate local or state agency may be more effective
from an IDN or system approach.  In some cases it is also advisable to reach
out to your State Board of Pharmacy. 

 

4.      Dan (Dave) would be happy to work with facilities and regulatory
agencies to receive written approval.

 

This makes sense.  I would recommend that all facilities utilizing the Smart
Sink for DEA control disposal (non-RCRA hazardous) to have readily available
this written approval in the event of a DEA audit.  I am surprised that none
of the Smart Sink users have brought this to our attention as this is very
important.     

In many cases we find nursing staff wasting narcotics in inappropriate
containers such as red sharps buckets or trash bins.  Our goal is to improve
this process, force witness and wasting in the open and provide an
effective, compliant, green solution for narcotics disposal.  

 

 

Jeff, Fred, Barry,  thank you for your comments and recommendations.  If
needed, my direct contact information is also attached.   

 

 

Sincerely, 

 

Dave 

 

 

Dave Maness 

Cactus LLC

 <mailto:mitchell at cactusllc.net> dmaness at cactusllc.net

Office: 843.856.7400 |Fax: 843.856.7408

www.CactusLLC.net

 <http://www.cactusllc.net/> cactus logo for email

Makers of the Smart SinkR - An Innovative, 'Go Green' alternative to drain
disposal for pharmaceutical waste.

 

This email may contain confidential information intended for the use of the
recipient(s) only.  Do not forward, copy or distribute this email or
attachments without written permission from Cactus, LLC.

 

 

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jeff Hollar
Sent: Thursday, June 26, 2014 12:42 PM
To: 'Massoomi, Fred'; 'Barry Fernandez'; pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: Anyone using Cactus Sink?

 

I had a nice conversation with Dan Maness at Cactus LLC.  Here's the
synopsis of what I got out of our conversation as it pertains to DEA
Regulations.

 

5.      Smart Sink does not meet DEA regulations for the disposal of DEA
controlled substances.

6.      The facilities that are using the Smart Sink have approached their
local DEA/State Regulatory entity and have received written exception
approval to dispose of DEA controls under an agreed upon process - meaning,
they are now within compliance.

7.      Regulatory approval is not an automatic or guaranteed process.

8.      Dan would be happy to work with facilities and regulatory agencies
to receive written approval.

 

This makes sense.  I would recommend that all facilities utilizing the Smart
Sink for DEA control disposal (non-RCRA hazardous) to have readily available
this written approval in the event of a DEA audit.  I am surprised that none
of the Smart Sink users have brought this to our attention as this is very
important.     

 

We really did not get into DOT or EPA compliance.

 

Jeff Hollar

President

PharmWaste Technologies, Inc.

4164 NW Urbandale Dr., Ste A

Urbandale, IA 50322

515-276-5302 (general)

515-331-7310 (direct)

515-360-9785 (cell)

www.pwaste.com <http://www.pwaste.com/> 

 

 

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Massoomi,
Fred
Sent: Monday, June 23, 2014 1:43 PM
To: 'Barry Fernandez'; Jeff Hollar; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] RE: Anyone using Cactus Sink?

 

It is interesting that the comments noted sound more like what we see in a
retail setting, just my assumption (we all what that means!).

 

In the hospital (and that is the only area we have the sinks) the products
are in ready to use formulation for the nurses at the bedside.  In the case
where a partial dose (not vial of 100 tablets, or a liter of a product) is
given to a patient, we direct the nurses to use the Cactus Sink for only the
unwanted portion of the drug.  And, only for controlled substances.  We have
a commercial vendor to manage the hazardous, RCRA and non-hazardous RX
waste, but they offered no solution to managing controlled substances waste.
When I queried our nurses on how they were disposing of controlled
substances waste I got a variety of answers: red sharps, trash can, carpet,
sink , toilet, into the patients linen.  You would be surprised at the
answers you get when you ask.

 

So we opted for the Cactus Sink, which is located at each Pyxis station and
we changed our practice to obtaining the drug from the Pyxis and the nurse
putting in what dose she will be administering to the patient.  If there is
waste, then the nurse must have another nurse witness and document the waste
at the Pxyis station and directly observe the nurse wasting the portion of
drug into the Smart Sink, prior to nurse administering the drug.

 

As I have asked in the past, if someone can give me a better process for
managing controlled substances wastes, I am open.  

 

But the red sharps, trash can, carpet, sink , toilet, into the patients
linen are not good options.

 

Firouzan 'Fred' Massoomi, Pharm.D., FASHP

Nebraska Pharmacists Association

President 2014            

 

Nebraska Methodist Hospital

Pharmacy Operations Coordinator

Department of Pharmacy Services

8303 Dodge St.

Omaha, NE  68114

 <mailto:fred.massoomi at nmhs.org> fred.massoomi at nmhs.org

 (402) 354-4340 office            

P How do YOU dispose of unwanted drugs?

 

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Barry
Fernandez
Sent: Monday, June 23, 2014 1:26 PM
To: Jeff Hollar; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] RE: Anyone using Cactus Sink?

 

Very good questions and keen observations from Jeff Hollar.  

 

In addition I presume that the nurses or clinicians would need to "unpack"
the drugs from their receptacles or containers in order to use the Smart
Sink.  Wouldn't one still have to deal with packaging, especially if it
contains protected patient information?  Even if there is no patient
information, a bottle or several, even if empty, of say Percocet or Dilaudid
in the garbage could attract some unwanted scavengers.  My apologies to the
Cacti people, and I don't question their good intentions, but it seems the
rebuttable presumption to claim that they are better for the environment and
compliance seems untested from many points of view.  Would really like to
hear from the regulatory community on this.

 


Clean Fuels of Florida, Inc. email signature
 <http://www.clean-fuels.net> www.clean-fuels.net

	Barry Fernandez, President
Mobile (305) 216-4941 barry at clean-fuels.net  
Office (954) 791-9588 Fax (954) 791-9366
2635 NE 4th Avenue | Pompano Beach, Florida 33064


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and delete this message and any attached file(s). Thank you.

 

From: Jeff Hollar [mailto:jhollar at pwaste.com] 
Sent: Sunday, June 22, 2014 1:59 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: Anyone using Cactus Sink?

 

Let me start of by stating I believe the Smart Sink is a better
environmental option than drain disposal for DEA Controls.  I have two
questions that primarily deal with the compliance of DEA's current
regulations.

 

Earlier this year I checked with our local (Des Moines) DEA office and they
were very clear that for DEA Registrants, the Cactus Smart Sink, by itself,
was not an acceptable technology for the disposal of DEA controls.  It's my
understanding that they received their direction from the St. Louis
division.  Any controlled substances in the cartridge were to be handled as
if they were in their original final dosage form.  Meaning, any transference
to another DEA Registrant would be subject to DEA regs (e.g., control
inventory, DEA Form 222, etc) and in turn, any disposal would be subject to
DEA regulations (e.g., control inventory, DEA Form 41).  This makes sense to
me because if the DEA felt the Smart Sink rendered the controlled substances
unrecoverable, then the facility would have the option of simply discarding
their cartridge in their regular trash (with some exceptions).  Question #1
- Are other DEA regional divisions consistent with this position?  

 

Question #2 - If your facility takes the stance that the DEA controls being
disposed of are owned by the patient (ultimate user) and not the DEA
registrant (hospital), then under today's current DEA regulations, how can
you transfer DEA controlled substances owned by non-DEA registrant (ultimate
user) to a DEA registrant (reverse distributor) for disposal?  In other
words how can a DEA Registrant accept controlled substances from a non-DEA
Registrant?

 

As far as the hazardous waste side...  Introducing hazardous drugs into the
cartridge may increase your hazardous waste generation which in turn could
affect your generator status.  Not to mention the EPA and DOT regulatory
handling of the resulting waste.  Something to consider if you choose to
discard hazardous drugs in the Smart Sink.  In all the Cactus literature I
reviewed, I could find no specific reference to RCRA hazardous drugs and
usage in the Smart Sink.

 

Are there any representatives on this listserv from: Cactus LLC, EXP, DEA or
EPA that could give us some insight?  

 

Jeff Hollar

President

PharmWaste Technologies, Inc.

4164 NW Urbandale Dr., Ste A

Urbandale, IA 50322

515-276-5302 (general)

515-331-7310 (direct)

515-360-9785 (cell)

 <http://www.pwaste.com/> www.pwaste.com

 

 

 

 

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Shield,
Margaret
Sent: Friday, June 20, 2014 10:06 AM
To: Volkman, Jennifer (MPCA)
Cc: pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] RE: Anyone using Cactus Sink?

 

I have seen several presentations from Cactus Sink representatives and
spoken to them at meetings. Fred's description of use of the product is
great confirmation of what their rep's describe.

One of the things I appreciate about Cactus Sink's business model and
outreach is their understanding that proper disposal of their unit depends
on local laws and regulations for the drugs being disposed.  We have
discussed how their unit with captured drugs is often disposed as hazardous
waste as Jennifer suggests. A refreshing change from some other companies
promoting pill sequestration products as "safe" for other disposal methods
that are not appropriate. Cactus Sink does seem to be a better approach for
clinical disposal of controlleds, and I hope it will reduce flushing of
those drugs, including unused partial doses in syringes.

Margaret Shield

Local Hazardous Waste Management Program in King County

cell 206-265-9732

 

iTyped with my iThumbs :-)


On Jun 20, 2014, at 6:30 AM, "Volkman, Jennifer (MPCA)"
<jennifer.volkman at state.mn.us> wrote:

I think it would work in MN if the contents were managed as a hazardous
waste, it wouldn't fit our interpretation of reverse distribution. It seems
like the main value is making controlled substances immediately unlikely to
be diverted or sewered.  


  _____  


From:  <mailto:pharmwaste-bounces at lists.dep.state.fl.us>
pharmwaste-bounces at lists.dep.state.fl.us [
<mailto:pharmwaste-bounces at lists.dep.state.fl.us>
pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Massoomi, Fred [
<mailto:Fred.Massoomi at nmhs.org> Fred.Massoomi at nmhs.org]
Sent: Thursday, June 19, 2014 8:26 AM
To: 'Lotzer Donna M'; ' <mailto:pharmwaste at lists.dep.state.fl.us>
pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] RE: Anyone using Cactus Sink?

Donna-

We have used the Cactus Sink for about a year now on our patient care units.
Almost two years in our IV room.

We have limited its use for controlled substances waste only.  Until we get
updated regulations, this system offers a better solution than the
alternative (sink or inappropriate use of sharps containers).

 

Rational: 

Provides a good process to render unwanted  controlled substances
irretrievable (versus the sewer and sharps containers).  

The full cartridges can be picked up by a reverse distributor.

Our waste hauler for our hospital had no other solution to provide us

Addresses solids, liquids and patches

 

Issues:

Other items end up in the sink, ie trash, attempts at syringes

Cleaning, they get messy.

Only one reverse distributor is assigned to take the full cartridges back,
however the company is great to work with.

Volume capacity for PCA and Epidurals

 

Overall:

Great point of waste system that is small and secure.

Nursing adaptation was quick and well received.

The Cactus company has great videos and information to make the system
successful.

 

Please let me know if you need any additional information.

 

Firouzan 'Fred' Massoomi, Pharm.D., FASHP

Nebraska Pharmacists Association

President 2014            

 

Nebraska Methodist Hospital

Pharmacy Operations Coordinator

Department of Pharmacy Services

8303 Dodge St.

Omaha, NE  68114

 <mailto:fred.massoomi at nmhs.org> fred.massoomi at nmhs.org

 (402) 354-4340 office            

P How do YOU dispose of unwanted drugs?

 

From:  <mailto:pharmwaste-bounces at lists.dep.state.fl.us>
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 Lotzer Donna M
Sent: Thursday, June 19, 2014 8:11 AM
To: ' <mailto:pharmwaste at lists.dep.state.fl.us>
pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] Anyone using Cactus Sink?

 

Just found out this morning our hospital is trialing Cactus Sink for
controlled substance med disposal on two inpatient units and the emergency
department - anyone else using it? Any concerns/comments? Thanks.Donna
Lotzer

 

Donna Lotzer, Clinical Pharmacist, Poison Education Coordinator

University of WI Hospital & Clinics Poison Prevention Center

600 Highland Avenue, MC # 9475, Madison, WI 53792

 <mailto:dlotzer at uwhealth.org> dlotzer at uwhealth.org     Phone: 608-265-8160

Please encourage others to save 800-222-1222 in both cell and home phones. 

This number will connect callers anywhere in the U.S. to a poison center. 

Calls are free, confidential and answered 24/7/365. 

Please help me educate your community about poison prevention. 

Call or email me for materials or program opportunities.

 

 


This message and any included attachments are from Nebraska Methodist Health
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