[Pharmwaste] Does activated carbon treatment meet "non-retrievable" standard?

Tue Apr 14 13:31:14 EDT 2015

Hi Jan,

You are absolutely correct, the DEA rule does not apply to ultimate users.  In the referenced case of "Medsaway" they claim it meets the DEA standard.  I am seeking information to verify their, and others, assertion that activated carbon renders medications unrecoverable.

DEA compliance is a big part of the spreadsheet because most of the disposal products listed are sold to institutions and not just end users.  "The Pill Catcher", is marketed on-line to end users with the claim it meets EPA, "the only agency you should listen to", disposal standards (TCLP.)  When I called this mom and pop business (they answer the phone, "Hello") I was told their product was fine to use in hospitals.

Element MDS is marketed to hospice and other agencies.  They claim that their gel based product meets the DEA standard "for everything except patches."  When I asked for test results they said their claim is based on their interpritation of the rule.  When I asked if it might be possible to chemically extract a drug from the gel they replied that their product is a nondescript white bottle so that wouldn't happen.  They have not checked to see if retrieval is possible.

And, to be clear, I have no doubt that Sharps Compliance drop boxes and mailers are in full compliance with the DEA rule.  I have been seeking evidence regarding the ability of activated carbon and gels to render medications non-recoverable.

Does anyone know if the DEA will be the agency responsible for checking product claims?  Will claims ever get checked?  What will be the consequences for false claims?

I'm extremely pessimistic after reading the shocking story of EPA's collusion with pesticide manufactures fraud:  http://www.truth-out.org/news/item/30097-failure-to-regulate-pesticide-data-fraud-comes-home-to-roost.
Hundreds of pesticides are still sold even after the revelation that safety testing was falsified and, in some cases, new evidence of harm has been shown!

Thanks Jen for adding Sharps Compliance prepaid mailers to the spreadsheet.

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: Jan Harris [jharris at sharpsinc.com]
Sent: Tuesday, April 14, 2015 11:18 AM
To: Ed Gottlieb; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Does activated carbon treatment meet "non-retrievable" standard?

I’m not speaking to the effectiveness of any product to degrade drugs, however, I think it’s important to remember that products sold to an ultimate user to destroy her OWN medications at home are not regulated under the DEA rule; just like vinegar or soft drinks which can also be bought by the consumer and used to destroy their drugs before putting into the trash. So I’m not sure why DEA is being referenced in the attachment. These products really have nothing to do with the rule unless they are being used by a registrant to destroy drugs. As the rule summary states, “These regulations will implement the Secure and Responsible Drug Disposal Act of 2010 by expanding the options available to collect controlled substances from ultimate users for the purpose of disposal, including: Take-back events, mail-back programs, and collection receptacle locations.” The purpose was to give ultimate users (and LTC) options to “hand off” the drugs for destruction other than putting them the trash or sewer.

Thanks,

Jan Harris, MPH
Director, EHS
Sharps Compliance
jharris at sharpsinc.com<mailto:jharris at sharpsinc.com>
713-927-9956

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 Ed Gottlieb
Sent: Monday, April 13, 2015 10:31 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Does activated carbon treatment meet "non-retrievable" standard?

Hi All,

In response to inquires regarding destruction products, today I received the attached letter.  It has URLs to a number of studies that show activated carbon in general or the medsaway product in particular work as advertized, given enough hours.

I noted they were written by one of the companies principles or the study was funded by the manufacturer.  Two were presented at conferences.  I wrote back to ask if any have been published in a peer reviewed journal.

Phoned a large activated carbon supplier (buyactivatedcharcoal.com) and they were quite convincing, that once pharmaceuticals bind to the activated carbon, they can't be extracted.  The knowledgeable person I spoke with will follow-up with their expert and send me any published studies they can find that would support this conclusion.
Will pass on what I receive.
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

[COLLECT/PROTECT/RESPECT]
Sharps Compliance repurposed an estimated 758 million syringes into a material powering over 250 homes per year and collected 320,000 pounds of unused medications, reducing potential harm to citizens and the earth.

PRIVACY NOTICE: This information is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential or exempt from disclosure under applicable federal or state law. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of communication is strictly prohibited. If you have received this communication in error, contact the sender and delete the material from any computer.

-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150414/5c93c7a8/attachment-0001.htm