[Pharmwaste] Destruction Products

Fri Apr 10 12:05:22 EDT 2015

Brian,

Not sure if my reply yesterday was posted.  So, I expanded on it and am sending it again.

Also, I will try to share a spreadsheet with information on all the disposal products I located.
You and others are welcome to edit or add to it.

Charlotte and Stephen are correct, the DEA has bailed on their highly successful take back initiative.

The product you mention, and similar products, claim to meet the DEA's non-retrievable standard.  Most use some form of activated carbon and water as their primary method.  Bentonite clay is also used.  Some use a gelling agent to solidify the dissolved/adsorbed/absorbed medications.

I have spoken with Disposaltechnologies and other manufactures (DrugBusters, CACTUS Smart Sink.)  The evidence two provided (DrugBusters didn't send info), to show they meet the non-retrievable standard, has not (yet) been peer reviewed.  They told me that the DEA sent agents to their factory and arranged to test their product, concluding that they were effective.  They expressed frustration that the DEA has not provided them with a written statement to this effect.

My guess is that the DEA is concerned that if they certify a product, it will appear to be an endorsement, something they are probably forbidden to do.  I left a message with Disposaltechnologies DEA contact, who I have spoken to before.  Maybe I'll have better luck in getting a response.  Not holding my breath...

Liquids have been a side discussion here.  My program (nine boxes) accepts them and we have had no problems.

As another aside, pills in blister packs would be a problem for these types of products.  Pills would need to be removed before adding them.

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

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: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of veora little [veoralittle at gmail.com]
Sent: Thursday, April 09, 2015 4:09 PM
To: Volkman, Jennifer (MPCA)
Cc: pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] RE: Destruction Product

  1.  We collect medications in Collier County Florida with Operation Medicine Cabinet and the Collier County Sheriff's Office.  We tighten the lids and tube containers and accept liquids.  Our boxes are lined and easy to handle. They are taken to Covanta for incineration.  We have not had any issue with liquids (i.e. Codeine, milk of magnesia, some eye drop medications) etc.   Veora Little

If I am not home accepting the things I can not change,
I am out changing the things I can not accept.
veoralittle at gmail.com<mailto:veoralittle at gmail.com>
home 239-649-6042, cell 239-450-2883

On Wed, Apr 8, 2015 at 7:10 PM, Volkman, Jennifer (MPCA) <jennifer.volkman at state.mn.us<mailto:jennifer.volkman at state.mn.us>> wrote:
These disposal systems are acceptable for households to use, probably in any jurisdiction.

Tangent…
Brian noted that law enforcement doesn’t accept liquids in FL. In MN, the MPCA doesn’t prohibit putting liquids in collection bins, because the inner liners are supposed to be puncture proof and contain liquids. I’m not sure why anyone prohibits liquids unless law enforcement is not concerned about codeine cough syrup and other liquid CS, like the liquid muscle relaxer prescribed to my mother. I have heard this stated a few places and I don’t understand the origin of a liquids prohibition. Many of the free bins from NADDI are printed with a no liquids symbol or statement and I believe they specify that recipients may not collect liquids in order to receive the free bin. I suppose I could call them to find out why. Other than the few NADDI boxes around here, some prohibit infectious waste including IV bags, but not ampules, aerosols, syringes, etc. I know I don’t want any of them to accept liquid chemo in any type of container/IV bag/ampule. OH! Maybe I answered my own question…still working with our Board to make the prescribing clinic or hospital take that back.

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<mailto:pharmwaste-bounces at lists.dep.state.fl.us>] On Behalf Of Smith, Charlotte
Sent: Wednesday, April 08, 2015 12:48 PM
To: Brian Usher; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] RE: Destruction Product

Hi Brian,

It is my understanding the Disposal system is based on activated charcoal to which the drug molecules can adhere, making it difficult to divert. The contents would then be disposed by the homeowner into the trash, so it would still be landfilled but leaching would be greatly reduced. I do not know if long term leaching could occur. So it may make sense for the homebound to use such a system.   It does concern me that the unit is also being marketed to institutions with no consideration for RCRA hazardous waste regulations or landfill waste acceptance procedures from businesses.  I do not know of any approvals issued by DEA for this type of technology.

DEA will not be funding any additional take-back days. The State of Wisconsin, where I am located, will be funding biannual take-back days to assist law enforcement in the disposal of their collected materials. Perhaps other states will step into the gap.

Best regards,

Charlotte A. Smith, R. Ph., M.S.
Senior Regulatory Advisor
WMSS PharmEcology Services
csmith at pharmecology.com<mailto:msmith at wm.com>
713-725-6363<tel:713-725-6363>

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 Brian Usher
Sent: Wednesday, April 08, 2015 9:30 AM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] Destruction Product

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<tel:%28941%29%20650-8078>
Fax:  (941) 316-1300<tel:%28941%29%20316-1300>

________________________________

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