[Pharmwaste] What to restrict from drop-boxes?

Mon Jun 9 10:06:36 EDT 2014

Hi all,

You're right Fred, AK uses a lot of air transport, however for haz mats/HW,
shipment by freighter is an option.  

Deborah, if a disposal company is a reverse distributor, they can take back
controlled substances.  Where the problems arise is when the controlled
substance may also be considered a hazardous waste, e.g. a testosterone gel
with alcohol-then shipments by mail/UPS/FedEx are not permitted.  Because
consumer pharmaceuticals are not regulated by EPA, there is a haz waste
exemption, but not necessarily a hazardous material exemption under DOT
rules.  

Its all very complicated and locality rules can make it even more so.  

That is why I continue to beat the distant, albeit best option, source
reduction drum.  J

Very truly yours,

Catherine Zimmer, MS, BSMT

Zimmer Environmental Improvement, LLC

St. Paul, MN 

Ph:  651.645.7509

 <mailto:zenllc at usfamily.net> zenllc at usfamily.net

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of DeBiasi,
Deborah (DEQ)
Sent: Monday, June 09, 2014 8:40 AM
To: Catherine; 'Volkman, Jennifer (MPCA)'; 'Howard Anderson'; 'Ed Gottlieb';
pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] What to restrict from drop-boxes?

As far as I know, mail-back companies cannot take back controlled
substances, which is the category for most of the hazardous waste items. 

Deborah L. DeBiasi, Virginia DEQ 
Office of Water Permits 
Email:   Deborah.DeBiasi at deq.virginia.gov
PH:         804-698-4028

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Catherine
Sent: Monday, June 09, 2014 9:28 AM
To: 'Volkman, Jennifer (MPCA)'; 'Howard Anderson'; 'Ed Gottlieb';
pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] What to restrict from drop-boxes?

Hi all,

Actually, as you all know, a great deal of consumer pharmaceutical waste is
disposed of via mail or send back programs, which may be sent via air.  So
it is something to consider when putting together collection programs.  

Very truly yours,

Catherine Zimmer, MS, BSMT

Zimmer Environmental Improvement, LLC

St. Paul, MN 

Ph:  651.645.7509

 <mailto:zenllc at usfamily.net> zenllc at usfamily.net

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Volkman,
Jennifer (MPCA)
Sent: Friday, June 06, 2014 10:55 AM
To: Howard Anderson; 'Ed Gottlieb'; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] What to restrict from drop-boxes?

We don't restrict liquids or aerosols in MN and have no plans to do so. I
don't know why there is mention of restrictions related to shipment by
air--for disposal? No one does that. This is not an issue. 

  _____  

From: pharmwaste-bounces at lists.dep.state.fl.us
[pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Howard Anderson
[NDBoPh at btinet.net]
Sent: Thursday, June 05, 2014 9:24 AM
To: 'Ed Gottlieb'; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] What to restrict from drop-boxes?

Sometimes we come up with so many scare tactics, we do not accomplish
anything!

Howard

Howard C. Anderson, Jr.,R.Ph.

Retired and Now

Treasurer/Chief Compliance Officer

North Dakota Board of Pharmacy

1906 E. Broadway Ave.

P.O. Box 1354

Bismarck, ND  58502-1354

Phone (701) 328-9535

Fax (701) 328-9536

Web site www.nodakpharmacy.com

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, June 04, 2014 9:31 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] What to restrict from drop-boxes?

Hi pharmwaste listserv,

All drop-box programs list items that are accepted and items that aren't.  

Sharps, bio-hazardous waste, chemotherapy medications, and thermometers are
almost always listed as not accepted.  Some programs specifically restrict
less (or more!) obvious items such as:  trash, mail, and guns.

I think we can all agree there are good reasons for not accepting any of
these items.  

What about liquids, ointments, inhalers, and aerosol cans?  I regularly see
these on "not accepted" lists.  

Most boxes have internal, removable totes that should be lined with a
plastic bag.  Liquid spills should not be a problem from the clean-up
perspective.  I've not seen any evidence that spilled liquids can cause
dangerous chemical reactions to occur, an explanation I was given for one
programs ban.  Are there documented problems caused by a spill of hydrogen
peroxide, alcohol, or any other liquid medication?  Can explosive conditions
develop?  Will active ingredients volatilize and contaminate the air if
spilled alcohol dissolves medication it comes in contact with?  

Do inhalers and other aerosol cans actually cause problems in a drop-box or
at the incinerator?  

I believe that most programs copy their "not accepted" list from an existing
program.  Maybe some of these restricted items could be safely accepted?
Or, is it wiser to keep restricting them to avoid a possible hazard, however
unlikely?

With luck, pharmacies will soon be launching their own programs, greatly
expanding the accessability of take-back programs.  Can we offer them
guidance on this issue?  Your thoughts are appreciated.

Ed

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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