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

Wed Oct 8 15:52:04 EDT 2014

I invited comments and now I’m just going to provide more quotes to reinforce my initial point. Sorry.
The note in the message string says:

“Drug Dispose All is NOT for disposing of hazardous materials or chemicals.” We can interpret that sentence plus this from the website “The Disposal of Medication and Controlled Substances is Now Affordable” to mean it isn’t to be used for something other than medications, which is a good point to make. If we look more at the website, we see, well first we see the name Drug Dispose All, then:

“Drug Dispose All renders tablets, capsules, patches, synthetics, liquids and all controlled substances inert in just minutes.” Note the “and” which is in all of the sentences.
”Drug Dispose All offers a more affordable way for institutional disposal of medication. Methods such as incineration, reverse distribution or disposal in landfills can be costly and may delay the prompt disposal of pills, patches and other controlled substances. For example, incineration can be as much as 20% more costly than the Drug Dispose All system.”
“Making sure expired and unused drugs are properly disposed of is one of today’s biggest liabilities for hospitals,…”

Nowhere does it say it is only to be used for non-haz controlled substances. It implies use for all.

Please know I’m not arguing for the sake of arguing. We’ve had situations here in MN where a company presented and sold a similar product to pharmacies, leading them to believe they could use this system for management of any pharms and that trash disposal would be in compliance with RCRA. Another came to sell boxes to ship all pharms (excluding CS, but not HW pharms), and again, led pharmacies to believe that they could put any HH pharm that wasn’t a CS in the box and mail it somewhere. Neither of these systems comply with MN rules and/or Board Statutes and caused a whole lot of trouble for the dozen pharmacies that bought into the systems without first checking Board of Pharmacy and MPCA regulations. There could be more out there using any of these systems now, believing they are doing the right thing. I don’t want to see pharmacies and institutions set up for non-compliance when they are making a good faith effort to help with the problem.

As I noted before, there is value to nearly immediately changing pills into inedible goo. Emphasize that vs disposal. Put a large note on your website that pharmacists should contact their Pharmacy Board and Fed, State or County disposal authority to find out if the system is compliant for disposal of all pharms or just some. Simple, then we’re good to go! We had another company actually check with us and decide to wait on selling their system to pharmacies until our rules were revised.

“Meets the standard for non-retrievable established by the DEA, EPA, CDC, and FDA” is repeated several times on the website. We all know that the DEA has the non-retrievable standard, not the EPA, CDC or FDA. What is implied by including all of these agencies in that sentence?

Other statements on the website are just interesting:
“The general public and government regulators trend toward anti-incineration views due to public perception and the clean air regulations based on state and federal limits.”
“Drug Dispose All is safer, faster & 20% more affordable than Red Waste incineration.”

An 8 oz bottle of DrugDisposeAll is $11.95 + $5.95 shipping on Amazon. A 128 oz jug is $85.

I think others are checking on the report they will provide if you call. This is another of the numerous proprietary chemical jug/bottle/sink processes out there. For MPCA, we’d need to know that a different protocol was in place for managing HW pharms; that only non-haz pharms are put in the jugs; and we’d need TCLP results (probably from a pharmacy/generator, I don’t think we do blanket approvals), to determine whether it could be used as a disposal system. MPCA does not have an opinion on whether it meets DEA non-retrievable standards.

JV

P.S. I can’t get your Zenith Environmental website to open!

From: Barry E. Stewart [mailto:bstewart at zenithenvironmental.com]
Sent: Wednesday, October 08, 2014 11:11 AM
To: Volkman, Jennifer (MPCA)
Cc: pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] RE: New Product for Drug Disposal--not

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!

Sent from my iPhone

Barry E. Stewart

Zenith Environmental Services, LLC
Operations & Compliance Manager
2257 Vista Parkway #3<x-apple-data-detectors://3>
West Palm Beach, FL 33411<x-apple-data-detectors://3>

www.zenithenvironmental.com<http://www.zenithenvironmental.com/>

772-607-1113<tel:772-607-1113>

UPCOMING TRAINING EVENTS CLICK BELOW- PLEASE CONTACT US FOR PRICING

https://zenithenvironmentalevents.webex.com/mw0306ld/mywebex/default.do?siteurl=zenithenvironmentalevents

On Oct 7, 2014, at 12:19 PM, Volkman, Jennifer (MPCA) <jennifer.volkman at state.mn.us<mailto: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<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>] on behalf of Reibstein, Rick (ENV) [rick.reibstein at state.ma.us<mailto: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<mailto: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> [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<mailto: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<http://www.seminolecountyfl.gov/>
twaters at seminolecountyfl.gov<mailto:twaters at seminolecountyfl.gov>

<image001.png>

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: Tuesday, October 07, 2014 7:38 AM
To: 'pharmwaste at lists.dep.state.fl.us<mailto: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> [mailto:rketring at aol.com]
Sent: Friday, October 03, 2014 5:26 PM
To: pharmwaste at lists.dep.state.fl.us<mailto: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<http://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<mailto:rketring at disposaltechnologies.com>

________________________________
****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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