[Pharmwaste] RE: New Product for Drug Disposal--not

Wed Oct 8 12:10:38 EDT 2014

If I'm not mistaken one of the first emails/posts regarding the device said a possible option for  non hazardous controlled substances... No where has anyone, that I can see, discussed putting RCRA hazardous drugs into the device ... Just my two cents!

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Barry E. Stewart

Zenith Environmental Services, LLC
Operations & Compliance Manager
2257 Vista Parkway #3
West Palm Beach, FL 33411

www.zenithenvironmental.com

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> On Oct 7, 2014, at 12:19 PM, Volkman, Jennifer (MPCA) <jennifer.volkman at state.mn.us> wrote:
> 
> The whole works would have to be disposed of as a HW in MN. That is, unless no one using it puts a HW pharm in it. Then I don't know what the recommendation is for disposal. I would think the best practice of high temperature incineration still applies. 
> 
> Treatment in a container or other RCRA treatment regulations might apply if the business is using it in an attempt to render the mixture non-hazardous, but I don't think that is the point of these systems. I think the value is in making the pharms more difficult for employees to divert. These are handy "non-retrievable" systems for those concerned about that issue, but they have nothing to do with "disposal" really. I would also question any company that claims these systems meet DEA's non-retrievable standard because I don't think they give out clear cut approvals for these. Maybe that has changed. 
> 
> For the medical industry or pharm collection sites that are confident they have a good system in place to manage waste pharms (bins and containers), this is an unnecessary step/cost. They don't replace the need to handle the mixture as a HW. In MN we allow HH pharms to be managed at WTE facilities and hospitals/pharmacies manage what they generate as a HW unless they sort haz/non-haz. I don't see the point of doing that type of sort unless you want to be able to throw some pharms in with regular solid waste. 
> 
> If I look at this from the perspective of collection of household pharms, I don't see how it fits in with DEA's regulations or bin collection because I don't think the pharmacists are supposed to handle the drugs and I'm not sure if they would want to police the box to see that customers are using it right (empyting pill bottles and foil/plastic packs). 
> 
> Again, not a "drug disposal" product as far as I can see, but I'd like to hear what others think.
>  
> From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Reibstein, Rick (ENV) [rick.reibstein at state.ma.us]
> Sent: Tuesday, October 07, 2014 10:22 AM
> To: Waters, Tom; 'Tenace, Laurie'; 'pharmwaste at lists.dep.state.fl.us'
> Subject: [Pharmwaste] RE: New Product for Drug Disposal
> 
> Wouldn’t it be “treatment without a license” if this were performed on any acutely hazardous waste?
>  
> From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Waters, Tom
> Sent: Tuesday, October 07, 2014 9:06 AM
> To: 'Tenace, Laurie'; 'pharmwaste at lists.dep.state.fl.us'
> Subject: [Pharmwaste] RE: New Product for Drug Disposal
>  
> Great –
> How do you “neutralize” drugs?
> I doubt if most landfills would knowingly accept such “treated drugs” without a complete waste determination, including TCLP.
> Tom Waters 
> Environmental Programs Manager 
> Solid Waste Management Division 
> Seminole County Government 
> 1950 State Road 419 
> Longwood, FL 32750
> Office 407-665-2261 
> Fax 407-324-5731 
> www.seminolecountyfl.gov
> twaters at seminolecountyfl.gov
>  
> <image001.png>
>  
>  
>  
> From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Tenace, Laurie
> Sent: Tuesday, October 07, 2014 7:38 AM
> To: 'pharmwaste at lists.dep.state.fl.us'
> Subject: [Pharmwaste] FW: New Product for Drug Disposal
>  
> All,
> I am not promoting this product. I think we all need to be aware of these products as they come on the market. 
> Laurie
>  
> From: rketring at aol.com [mailto:rketring at aol.com] 
> Sent: Friday, October 03, 2014 5:26 PM
> To: pharmwaste at lists.dep.state.fl.us
> Subject: New Product for Drug Disposal
>  
> I would like to introduce you to a new product that was developed at the University of Texas in Arlington for drug disposal.  The name of this product is Drug Dispose All.
> 
> This may sound like an infomercial—and it is—but—You won't find one product in the market that will be the answer to every situation.  The more options you have, and the more knowledge you have about those options, the better decisions you can make about your situation.
> 
> Drug Dispose All is a chemical solution that comes in a plastic container.  To use this product you simply open the container and place pills, capsules, patches and or liquids into the container and shake it up.  Within 30 minutes all of the drugs will have been neutralized. They will be rendered both inert as well as non-retrievable meeting the DEA definition of destruction.  Drug Dispose All is a multi-use item so you can keep using it until the container is full.  Once full you can dispose of the full container in your everyday trash.
> 
> You can dispose of controlled substances using Drug Dispose All. Of course you must follow DEA regulations on documentation.
> 
> Drug Dispose All is NOT for disposing of hazardous materials or chemicals.
> 
> Drug Dispose All comes in three sizes:  8 oz.,  1 Gallon and 5 Gallon.  As a point of reference you can process approximately 3,000 pills using a 1 Gallon container.
> 
> We will be happy to supply test data that substantiates the claims of drugs being destroyed using this product.
> 
> Disposal Technologies is the company with this product.  We are a new startup company based out of the DFW area in Texas.  You can get more information about this product from our website www.disposaltechnologies.com.  Or you can reach us via our toll free number 855 562-2711.
> 
> If you have any questions or concerns we would love to hear from you.
> 
> Thank You
> 
> Rick Ketring
> 
> Disposal Technologies
> 
> rketring at disposaltechnologies.com
> 
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> ****Florida has a very broad Public Records Law. Virtually all written communications to or from State and Local Officials and employees are public records available to the public and media upon request. Seminole County policy does not differentiate between personal and business emails. E-mail sent on the County system will be considered public and will only be withheld from disclosure if deemed confidential pursuant to State Law.****
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