[Pharmwaste] RE: Group discussion on take back programs - OhioEPA comment

Tue Oct 14 11:13:55 EDT 2014

In response to Jim’s question and breaking it down with regard to LE:
1317.75:

-       law enforcement can voluntarily continue to conduct take-back events, administer mail-back programs, and maintain collection receptacles.

-       Collection receptacles shall be securely placed and maintained: (1) Inside a collector’s registered location, inside law enforcement’s physical location

-       Law enforcement that conducts a take-back event or a mail-back program or maintains a collection receptacle should maintain any records of removal, storage, or destruction of the controlled substances collected in a manner that is consistent with that agency’s recordkeeping requirements for illicit controlled substances evidence.

-       Any controlled substances collected by law enforcement through a take-back event, mail-back program, or collection receptacle should be stored in a manner that prevents the diversion of controlled substances and is consistent with that agency’s standard procedures for storing illicit controlled substances.

-       Law enforcement that transfers controlled substances collected from ultimate users pursuant to this part to a reverse distributor for destruction should maintain a record that contains the following information:

o    unique identification number of the sealed inner liner transferred and size of the sealed inner liner transferred (e.g., 5-gallon, 10-gallon, etc.)

o    if a mail-back package, the unique identification number of each package; the date of the transfer; and the name, address, and registration number of the reverse distributor to whom the controlled substances were transferred.

Jan Harris | Director, Environmental Health & Safety

Sharps Compliance, Inc.
d- 713-927-9956

jharris at sharpsinc.com | <mailto:jharris at sharpsinc.com> http://www.sharpsinc.com
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 14, 2014 9:42 AM
To: 'pharmwaste at lists.dep.state.fl.us'
Subject: FW: [Pharmwaste] RE: Group discussion on take back programs - OhioEPA comment

I’m not sure why this didn’t post for Deb. Please always let me know if you have problems with emails not posting to the list serve.

Laurie

From: Hauser, Deborah [mailto:Deborah.Hauser at epa.ohio.gov]
Sent: Tuesday, October 14, 2014 9:52 AM
To: Jim Humter; Gilliam, Allen
Cc: Jaramillo, Jeanie; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: RE: [Pharmwaste] RE: Group discussion on take back programs

Here in Ohio, it seems a number of law enforcement collections were saving up what they collected and then bringing it to the DEA Take Back Day every  6 months.  What I’m hearing from a few law enforcement offices is that they are wondering what their options will be now that the DEA collection has ended.  Fortunately for us, we have 2 hazardous waste incinerators in Ohio and I believe they are charging about $1 per pound.  So it wouldn’t be excessively expensive for LE offices in Ohio to dispose of their collected pharms.  It will be a matter of the LE offices committing financially and with time to transporting collected pharms to one of these incinerators a few times a year.

We have 276 locations in Ohio.

Deb

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 Jim Humter
Sent: Monday, October 13, 2014 12:02 PM
To: Gilliam, Allen
Cc: Jaramillo, Jeanie; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: Re: [Pharmwaste] RE: Group discussion on take back programs

The DEA website has easy to understand materials for you.

Sent from Jim Hunter's iPhone

On Oct 13, 2014, at 8:43 AM, Gilliam, Allen <GILLIAM at adeq.state.ar.us<mailto:GILLIAM at adeq.state.ar.us>> wrote:
Ok, I have to admit I haven’t read the new DEA reg very carefully.  How would it affect current take-back programs with LE?  Is it the controlled substance requirements?  Please break this down in the simplest terms possible ‘cause this really isn’t in my job description.

Allen Gilliam
ADEQ State Pretreatment Coordinator
501.682.0625

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 Jaramillo, Jeanie
Sent: Friday, October 10, 2014 3:39 PM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] Group discussion on take back programs

To those who have been conducting take back programs with law enforcement,

Now that the new DEA rule has been out for a bit and we've had some time to absorb the information, I am interested in coordinating a group discussion for those who have been conducting take back programs with law enforcement and are now concerned that they may have to discontinue their programs.

If you're interested in having a discussion, perhaps sometime next week, please email me directly at jeanie.jaramillo at ttuhsc.edu<mailto:jeanie.jaramillo at ttuhsc.edu> .

Jeanie Jaramillo, PharmD
Managing Director, Texas Panhandle Poison Center
Asst. Professor, Texas Tech UHSC School of Pharmacy
1300 S. Coulter St., Suite 105
Amarillo, TX 79106
(office): (806)414-9299
(mobile): (806)376-0039

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[COLLECT/PROTECT/RESPECT]
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