[Pharmwaste] What to restrict from drop-boxes?

Volkman, Jennifer (MPCA) jennifer.volkman at state.mn.us
Mon Jun 9 10:51:08 EDT 2014


Well then, I guess we're lucky in MN to be able to transport whatever is put in the bins to local WTE's. I wasn't referring to mail back or reverse distribution, which I don't think anyone does with the contents of the bins. I didn't think about Alaska or Hawaii. Sorry peoples from God's country's! :)

To curl the discussion back toward contents in general... I did like how WA stated said no peroxide. The DEA rules will curtail our ability to visually check contents as they are dumped from the collection container inside the bin into the container that goes to the WTE. It is where programs do a check for thermometers--mainly mercury; I think they let everything else go. I believe most sites use plastic lined fiber containers for shipping waste, so they'll have to collect in those and just put the lid on. We'll lose that checking ability, which is unfortunate. I did a quick poll and I think the number of thermometers caught was 3, statewide in several years time. I think I'll check again. The one item I was trying to get some support from the Board of Pharmacy on is chemotherapy waste management. Those drugs should go back to the clinic they came from for proper handling. The poll I did on that showed very little coming in, mainly a pill form that is probably ok to put in the bins, but some of that is very toxic and should not go in bins.

Has any state had luck with ensuring chemotherapy waste goes back to the hospital or clinic that provides it?
________________________________
From: Catherine [zenllc at usfamily.net]
Sent: Monday, June 09, 2014 9:06 AM
To: 'DeBiasi, Deborah (DEQ)'; 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,
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.  :)

Very truly yours,

Catherine Zimmer, MS, BSMT
Zimmer Environmental Improvement, LLC
St. Paul, MN
Ph:  651.645.7509
zenllc at usfamily.net<mailto: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<mailto: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> [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<mailto: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
zenllc at usfamily.net<mailto:zenllc at usfamily.net>

From: 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 Volkman, Jennifer (MPCA)
Sent: Friday, June 06, 2014 10:55 AM
To: Howard Anderson; 'Ed Gottlieb'; pharmwaste at lists.dep.state.fl.us<mailto: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<mailto: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<mailto: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<http://www.nodakpharmacy.com>

From: 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 Ed Gottlieb
Sent: Wednesday, June 04, 2014 9:31 AM
To: pharmwaste at lists.dep.state.fl.us<mailto: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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