[Pharmwaste] Destruction Product Rx Destroyer

[Ed Gottlieb]

Hi Brian,

The manufacturer says the DEA ran tests and orally agreed the product achieved the non-retrievable standard.  Though they have made many requests, over many months, the DEA has not provided a letter they can use to back-up this claim.

I left a message with the DEA administrator who was their contact person for product testing.  I don't have much hope that I will have better luck than they did in getting a response.

Pills would need to be removed from blister packs for this type of products to be effective.

Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY  14850
(607) 273-8381
fax: (607) 273-8433
________________________________
From: Lotzer Donna M [DLotzer at uwhealth.org]
Sent: Thursday, April 09, 2015 2:17 PM
To: 'Brian Usher'; Lotzer Donna M
Subject: RE: [Pharmwaste] Destruction Product Rx Destroyer

Hi again Brian – have been trying to look more at the Rx Destroyer product and the “samples” I received this week. It reminds me in many ways of the DrugDisposeAll one you originally asked about. However their “secret” formula (meaning they refuse to tell me what is in it and the MSDS does not give anything away) appears much more benign than the DDA one (no methanol in the formula that I can determine).

The information sent to me on Rx Destroyer says it is “a drug disposal device formulated to quickly inactivate and adsorb medications to a harmless form. The free-floating molecules   (??) are adsorbed and neutralized by the activated charcoal which is the main ingredient in the Rx Destroyer”. That being said there is nothing I could see that tells me the adsorptive capacity of a bottle of this stuff (e.g. it will inactivate X tablets of drug Z /8 oz bottle). I got 3 bottles, including one which is 2.5 gallon!!! The darn thing weighs a ton.

The cover letter with the product states “Rx Destroyer is used for wasting of non-hazardous substances.” There is also an email exchange with a person from the WI DNR where it is stated that if no hazardous drugs are included then ”the WI DNR rules for hazardous waste do not apply and the disposal units may be disposed in a licensed solid waste landfill.” It also states “the ingredients are pharmacist developed, trade secret, biodegradable, non-toxic and include: a dissolving agent, activated charcoal, anti-mold agent, anti-freezing agent, anti-foaming agent, and FASCINATINGLY an anti-abuse agent to induce vomiting if ingested” (makes me wonder if they put Bitrex in it, but when I tasted it cautiously I did not notice any taste, good or bad). The letter also states that “Rx Destroyer meats EPA, FDA and the new DEA controlled substance destruction regulations by deeming non-hazardous substances as non-retrievable.” Another qualifier: Rx Destroyer is not used for the hazardous u-listed or p-listed drugs”.

The MSDS on the Rx Destroyer says it contains no hazardous ingredients which makes me wonder if it is just charcoal in water. States it is non-combustible, irritant only because of the charcoal, has no apparent odor that I could detect, and the stated pH = 6.5 so essentially neutral. Specific gravity is 1.004, again making me lean to just water.

The paperwork included a sheet prepared by the company and intended to address the non-retrievable DEA requirement. Pretty much it paraphrases the DEA rule and then says Rx Destroyer meets those requirements.

Looking at the actual bottle the label includes this information: “Pharmacist approved and recommended”; “Do not ingest – will induce vomiting”; “Active ingredient – Carbon”; “Rx Destroyer can be used for all non-hazardous medications. Effervescent medications are not recommended. Please go to www.rxdestroyer.com<http://www.rxdestroyer.com> for federal and state guidelines on how to determine if medications are hazardous waste and how to dispose of them”. No further details on any of these statements.

Don’t know if any of this helps you but it is what I have dug out…Donna
Donna Lotzer, Senior Clinical Pharmacist
Poison Education Coordinator
University of WI Hospital & Clinics Poison Prevention Center
600 Highland Ave, MC# 9475, Madison, WI 53792
dlotzer at uwhealth.org<mailto:dlotzer at uwhealth.org> Phone: 608-265-8160
Please encourage others to save 800-222-1222 in both cell and home phones.
This number will connect callers anywhere in the U.S. to a poison center.
Calls are free, confidential and answered 24/7/365.
Please help me educate your community about poison prevention.
Call or email me for materials or program opportunities.

From: Brian Usher [mailto:busher at scgov.net]
I was hoping someone else might have more extensive knowledge and could provide insight of this product:  http://disposaltechnologies.com/for-institutions/
This is being considered as a product to provide to homebound residents through a local drug coalition.  The only “proper” collection options currently available in the area are drop boxes at law enforcement offices which only accept solids or waiting for a DEA take-back day.


Brian Usher, CHMM
Operations Manager
Sarasota County Solid Waste
8750 Bee Ridge Road, Sarasota, FL  34241
Cell:  (941) 650-8078
Fax:  (941) 316-1300

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