[Pharmwaste] RE: Group discussion on take back programs

[Price, John L. "Jack"]

In researching DEA regs for an upcoming collection event in FL, I found this 9/9//2014 letter<http://www.deadiversion.usdoj.gov/drug_disposal/dear_registrant_disposal.pdf> from J.T. Rannazzisi , Deputy Assistant Administrator, DEA Office of Diversion Control. It summarizes the final rule from the point of view of registrants.  Parts of this letter relate to events.  Of particular interest to the planning of our event was this statement on page 2, paragraph 2:


"Law enforcement continues to have autonomy with respect to how they collect pharmaceutical controlled substances from ultimate users, including maintaining collection receptacles, and conducting mail-back programs and take-back events." [Emphasis added]



Of course, the meaning of "autonomy" may open up some more questions. It did for us.



Also, note the caution on page 1, paragraph 3, to consult your local DEA field office:

"This letter is not a complete list of all changes, nor does it detail the nuances of the various requirements. Please consult the final rule, the Code of Federal Regulations, or your local DEA field office for detailed information."



Not sure how much information relevant to those planning collection events is presented here. But, Al, the information presented is "in the simplest terms possible."

Jack

John L. (Jack) Price
Environmental Consultant
Waste Reduction MS 4555
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL  32399-2400
Phone:850.245.8751
Fax: 850.245.8803
john.l.price at dep.state.fl.us<mailto:john.l.price at dep.state.fl.us>
www.dep.state.fl.us/waste<http://www.dep.state.fl.us/waste>
Please Note:  Florida has a very broad public records law.  Most written communications to or from state officials regarding state business are public records available to the public and media upon request.  Your e-mail is communications and may therefore be subject to public disclosure.

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Gilliam, Allen
Sent: Monday, October 13, 2014 8:43 AM
To: Jaramillo, Jeanie; pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: Group discussion on take back programs

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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