[Pharmwaste] RE: Anyone using Cactus Sink?
Jeff Hollar
jhollar at pwaste.com
Sun Jun 22 13:58:31 EDT 2014
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
System and its affiliates and are intended only for the addressee. The
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