[Pharmwaste] Cytotoxic drug management

Barry Fernandez barry at clean-fuels.net
Thu Oct 2 12:16:48 EDT 2014


Hello Jim.  I've followed your work with great interest for several years.  We began managing hazardous waste and chemo drugs in the late 90's for our healthcare customers and have evolved over the years.  I've always considered this an issue to which little or no attention was given and watched from a distance as you've struggled to move the issue to the forefront.  I admire your perseverance.

This issue has been on my mind as of late, not for business, but from a very personal perspective.  Within the last two months I've had three family members diagnosed with cancer and are in varying stages of treatment.   All of them will undergo outpatient chemo and radiation.  They each come from different households (one aunt and two cousins) but the same side of the family.  We are a large family and very tightly knit as most Latino families are.  We will all be tending to their needs and I'm concerned for the very reasons you've made this your life's work.  We have everyone from infants to elderly and pets.  Family members are offering their homes and transportation and some will be tending to the "dirty work" as it were.  Like Jennifer, I too was looking for resources that families can implement to minimize exposure to these dangerous drugs.

I haven't inquired at the hospital (all three family members are at the same hospital) to see if they have a program in place, but I'm not optimistic.  I do plan to get the family together and make them aware of the risks and would like to be able to offer solutions and resources, not just more bad news.  There's lots of material on your website, mostly geared toward regulatory change and I applaud and support that effort.  But what specifically can you recommend to patients and their families?  As you know, getting hospitals or governments to implement change is a long-term proposition.  Unfortunately time is not on our side when the problem is at your doorstep.

Best Regards,
Barry

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

From: Jim Mullowney [mailto:jmullowney at pharma-cycle.com]
Sent: Thursday, October 02, 2014 10:57 AM
To: 'Volkman, Jennifer (MPCA)'; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Cytotoxic drug management

Jennifer, the program must be administered by the hospital and according to the World Health Organization it is the responsibility of the Pharmacist to control the Genotoxic waste including the urine and feces for 48 hours. 85% of Chemotherapy drugs are given on an outpatient basis so most of the collection is done in the home. The box is 16 inches by 16 inches and is delivered to the patients home the day before the infusion. The box contains enough containers to collect the patient waste for two days. The waste containers are put back in the box and shipped back to Pharma-Cycle for consolidation and final disposal.

Simple solution for a complex problem.

Jim M

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: Wednesday, October 01, 2014 5:08 PM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] Cytotoxic drug management

I didn't find where to "set up a program" on your link. Your information appears well sourced. I agree that better education and equipment is needed for patients receiving chemo at home and their families. I hope the proposed legislation is successful. Given the toxicity of chemo related drugs and the random access nature of collection in bins, I don't think any chemo related waste or unused liquids should be put in pharm collection bins.

I was looking for more information on the shipping box-type/size/construction. Without knowing exactly what they are, I can assume they are larger than the "mail slot" size of the collection containers around the country and that one kit would likely fill a collection bin. I think mail back makes sense and/or a partnership with local clinics and hospitals that prescribe home chemo treatment to take back the packaged materials. Is that what you envision?
________________________________
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 Jim Mullowney [jmullowney at pharma-cycle.com]
Sent: Wednesday, October 01, 2014 2:38 PM
To: 'Seery, Scott, Env. Health'; 'Tenace, Laurie'; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: RE: [Pharmwaste] RE: Alameda County ordinance upheld by federal appeal court
I think it is time to add the collection of human waste containing Cytotoxic Chemotherapy drugs to the program..
Check out www.cytotoxicsafety.org<http://www.cytotoxicsafety.org> to set up a program.

Jim M.

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 Seery, Scott, Env. Health
Sent: Wednesday, October 01, 2014 3:25 PM
To: 'Tenace, Laurie'; 'pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] RE: Alameda County ordinance upheld by federal appeal court

Yes, we think it's pretty awesome over here.  :)

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 Tenace, Laurie
Sent: Wednesday, October 01, 2014 12:05 PM
To: 'pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] Alameda County ordinance upheld by federal appeal court
Importance: High

Please note that this email originated with Catherine Zimmer, not me. I am forwarding it for her. Always let me know if you have problems posting to the list serve.
Laurie


From: Catherine Zimmer [mailto:zenllc at usfamily.net]
Sent: Wednesday, October 01, 2014 8:53 AM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: FW: Alameda County Drug ordinance upheld by federal appeal court!!! WooHoo!!!
Importance: High

This opens the door for EPR in all the states.  Along with the new rules for CS management not only will the burden be shifted from the public-although management of the waste should have oversight, maybe we will also see some source reduction.

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: cpsc-pharmaceuticals-listserv at googlegroups.com<mailto:cpsc-pharmaceuticals-listserv at googlegroups.com> [mailto:cpsc-pharmaceuticals-listserv at googlegroups.com] On Behalf Of Heidi Sanborn
Sent: Tuesday, September 30, 2014 4:41 PM
To: CPSC Pharmaceutical Listserv (cpsc-pharmaceuticals-listserv at googlegroups.com<mailto:cpsc-pharmaceuticals-listserv at googlegroups.com>)
Subject: FW: Alameda County Drug ordinance upheld by federal appeal court!!! WooHoo!!!
Importance: High


A federal appeals court rejected a challenge Tuesday by the pharmaceutical industry to an Alameda County ordinance, the first in the nation to require drug manufacturers to pay disposal costs for consumers' unused medications.



Drug companies, backed by trade associations and the U.S. Chamber of Commerce, argued that the 2012 ordinance illegally shifts local costs to out-of-state producers and interferes with interstate commerce. But the Ninth U.S. Circuit Court of Appeals in San Francisco said the county's measure treats all manufacturers equally and imposes no substantial burden on interstate businesses.



The ordinance "applies to all manufacturers that make their drugs available in Alameda County - without respect to the geographic location of the manufacturer," Judge N. Randy Smith said in the 3-0 ruling, which upheld a federal judge's decision in the county's favor. "Given that the ordinance applies across the board, it does not discriminate at all," nor does it regulate conduct outside the county, he said.



Smith also noted that pharmaceutical companies collect $950 million a year in sales revenue in Alameda County and could comply with the ordinance at an annual cost of $1.2 million, by the comnpanies' estimate, or $330,000 by the county's estimate. The companies could recoup their costs by raising prices in Alameda County by one cent for each $10 in sales, said Arthur Shartsis, a lawyer for the county.





The court's affirmance of local regulation was crucial, Shartsis said, because "the pharmaceutical industry has the lobbying power to stop these kinds of programs at the state level. It does not have the power to stop them at the county level."



Pharmaceutical Research and Manufacturers of America, which sued to overturn the ordinance, was not immediately available for comment. The organization could ask the U.S. Supreme Court to review the ruling.



The ordinance was approved by county supervisors in July 2012 and is still in the process of being implemented. It requires makers of prescription drugs sold in the county to fund a program that picks up and disposes of leftover drugs.



Alameda County now operates and pays for about 30 drop-off sites where consumers can discard their pills. County officials who backed the ordinance said drug companies should bear the cost of cleaning up their products for the sake of the environment and their customers' health. The Natural Resources Defense Council, city and county governments and Attorney General Kamala Harris filed arguments asking the court to uphold the ordinance.



Bob Egelko is a San Francisco Chronicle staff writer. E-mail: begelko at sfchronicle.com<mailto:begelko at sfchronicle.com>. Twitter: @egelko



For the ruling:



UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT - PHARMACEUTICAL RESEARCH & MANU V. COUNTY OF ALAMEDA Opinion



http://cdn.ca9.uscourts.gov/datastore/opinions/2014/09/30/13-16833.pdf




Bill Pollock
Program Manager
Alameda County Household Hazardous Waste program
1131 Harbor Bay Parkway M/S51701  (mailing address only)
Alameda, CA 94502
510-670-6460  Fax 510-293-9374

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