[Pharmwaste] Re: Pharmwaste Digest, Vol 104, Issue 19

Mon Jun 23 13:42:51 EDT 2014

Jeff:

We checked a couple years ago as well with our Savannah/Atlanta DEA offices when approached by Smart Sink and they said the same to us. 

Brian Stenz, President
Return Logistics International Corporation
22 Artley Road
Savannah, GA 31408
561-573-5538 cell

On Jun 23, 2014, at 12:00 PM, pharmwaste-request at lists.dep.state.fl.us wrote:

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>   1. RE: Anyone using Cactus Sink? (Jeff Hollar)
> 
> From: "Jeff Hollar" <jhollar at pwaste.com>
> Subject: [Pharmwaste] RE: Anyone using Cactus Sink?
> Date: June 22, 2014 at 1:58:31 PM EDT
> To: <pharmwaste at lists.dep.state.fl.us>
> 
> 
> 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)
> 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: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Massoomi, Fred [Fred.Massoomi at nmhs.org]
> Sent: Thursday, June 19, 2014 8:26 AM
> To: 'Lotzer Donna M'; '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
> 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 OfLotzer Donna M
> Sent: Thursday, June 19, 2014 8:11 AM
> To: '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
> 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 message may contain privileged, confidential and/or proprietary information intended only for the person(s) named. Unauthorized forwarding, printing, copying, distribution, or use of such information is strictly prohibited and may be unlawful. If you are not the addressee, please promptly delete this message and notify the sender of the delivery error by e-mail or you may call Nebraska Methodist Health System and its affiliates in Omaha, Nebraska, U.S.A at (402)354-2280.
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