From scott.seery at acgov.org Mon Feb 2 12:12:33 2015 From: scott.seery at acgov.org (Seery, Scott, Env. Health) Date: Mon Feb 2 12:12:45 2015 Subject: [Pharmwaste] RE: Still waiting for SC announcement In-Reply-To: <65AC0C9A3A6A474EAD8D56070FED66983E4AA2F6@MAIL.cityofithaca.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E4AA2F6@MAIL.cityofithaca.org> Message-ID: <4B6970A4E28E994681D9EB5C39585D5250F98CCCD4@US001EX14V.user.root.acgov.org> There are new statements on this SCOTUS page regarding the writ: Jan 28 2015 Motion for leave to file amici brief filed by Washington Legal Foundation, et al. . Jan 28 2015 Motion for leave to file amicus brief filed by Chamber of Commerce of the United States of America. I am not sure what to make from this, or whether it means the case was taken up. --Scott From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Wednesday, January 28, 2015 11:02 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Still waiting for SC announcement I phoned the U.S. Supreme Court and learned that today was the estimated decision day. That still may turn out to be accurate. The staff have no way of knowing exactly when the Justices will make the announcement that they will hear the Alameda case or let the District court decision stand. By the way, I have heard the argument that the best outcome would be for the court to hear the case and uphold the law. That precedent would do more to prevent future legal challenges to similar laws than if they simply let the lower court ruling stand. If you want to be one of the first to know what they decide, check this link regularly: http://www.supremecourt.gov/search.aspx?filename=/docketfiles/14-751.htm 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150202/909cd0cd/attachment.htm From EGottlieb at cityofithaca.org Mon Feb 2 13:11:19 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Mon Feb 2 13:11:46 2015 Subject: [Pharmwaste] RE: Still waiting for SC announcement In-Reply-To: <4B6970A4E28E994681D9EB5C39585D5250F98CCCD4@US001EX14V.user.root.acgov.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E4AA2F6@MAIL.cityofithaca.org>, <4B6970A4E28E994681D9EB5C39585D5250F98CCCD4@US001EX14V.user.root.acgov.org> Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E63DF31@MAIL.cityofithaca.org> What a a lawyer friend explained to me today is that the Jan 28th deadline was for filings related to the case. Two "friend of the court" documents were submitted on that day in support of the legal challenge. The court has not yet decided if they will hear the case or if they will accept the amici briefs that were filed. If four or more justices want to hear the case, it will be heard. My friend said I should hope they let the lower court ruling stand, without hearing the case. He thinks this is the most activist court since the 1950's. They pay little heed to precedent when it stands in the way of a making a pro business decision. I can't help but add that this also seems to apply to their political decisions; consider the case of Bush vs. Gore. 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: Seery, Scott, Env. Health [scott.seery@acgov.org] Sent: Monday, February 02, 2015 12:12 PM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: Still waiting for SC announcement There are new statements on this SCOTUS page regarding the writ: Jan 28 2015 Motion for leave to file amici brief filed by Washington Legal Foundation, et al. . Jan 28 2015 Motion for leave to file amicus brief filed by Chamber of Commerce of the United States of America. I am not sure what to make from this, or whether it means the case was taken up. --Scott From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Wednesday, January 28, 2015 11:02 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Still waiting for SC announcement I phoned the U.S. Supreme Court and learned that today was the estimated decision day. That still may turn out to be accurate. The staff have no way of knowing exactly when the Justices will make the announcement that they will hear the Alameda case or let the District court decision stand. By the way, I have heard the argument that the best outcome would be for the court to hear the case and uphold the law. That precedent would do more to prevent future legal challenges to similar laws than if they simply let the lower court ruling stand. If you want to be one of the first to know what they decide, check this link regularly: http://www.supremecourt.gov/search.aspx?filename=/docketfiles/14-751.htm 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150202/0c4c997e/attachment.htm From info at greatlakescleanwater.org Mon Feb 2 13:45:05 2015 From: info at greatlakescleanwater.org (Chris Angel, President) Date: Mon Feb 2 13:45:21 2015 Subject: [Pharmwaste] Est cost of take back per site? In-Reply-To: <65AC0C9A3A6A474EAD8D56070FED66983E63AE76@MAIL.cityofithaca.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E63AE76@MAIL.cityofithaca.org> Message-ID: <7782c9d2d929c720c62785a80f4fe63c.squirrel@webmail04.register.com> Ed and ListServe Info below as of October 2014   We have demonstrated that the maximum cost per location is $300 per year. This includes all materials to collect unused/unwanted drugs, posters, hand-outs and the transport of collected Rx waste for ultimate disposal/destruction at a high temperature incinerator. Currently the program has 352 pharmacies participating in MI,IL, WI and IN. OH to be added in October 2015. PA NY to be added in 2015 and we will soon be offering the program to other states. Because of the economy of scale, as the number of pharmacies increase it is feasible that the cost per location could be less than $300. FR: Chris Angel President Great Lakes Clean Water Conclusions based on six years of operating Yellow Jug Old Drugs Rx-Waste Collection/Disposal Program at pharmacies in the Great Lakes region.  Rationale for considering funding options other than Full Producer Responsibility Funding Benchmark Cost Per Pharmacy   Large Scale-state wide and regional drug collection programs provide the most cost effective method of collection and disposal of unused/unwanted drugs. Having many locations under one umbrella program with a low administrative overhead is preferable to local programs providing service to a smaller number of locations yet incurring similar administrative costs.   Pharmacies are the most logical, convenient, safe and most effective locations for  proper collection and disposal of unused/unwanted drugs   The Secure and Responsible Drug Disposal Act will now allow pharmacies to collect controlled substances in much the same manner they have been doing with Yellow Jug Old Drugs. This will provide even better access for citizens wanting to dispose of unused/unwanted drugs. Law enforcement will soon be deferring collection of controlled substances to pharmacies and more pharmacies will be providing collection/disposal of Rx-Waste for their customers    Independent pharmacies are willing to provide financial support to provide program to their communities. Chain pharmacies which make up a majority of pharmacies in the country should be strongly encouraged to participate to provide even greater access to citizens wanting to properly dispose of unused/unwanted drugs.   There are several reasons that citizens should be educated and encouraged to properly dispose of unused/unwanted drugs. These include; Environmental, Water Quality, Public Health and Safety and Substance Abuse Prevention. Individuals deciding to take action are motivated by sometimes more than one concern. We feel that a primary focus on Great Lakes Water Quality is one of the major factors in the success of the Yellow Jug Old Drugs Program. The issue of water quality, whether it’s drinking water or lakes, rivers or streams for recreation, has been a unifying message while also addressing the other concerns cited.     Sustainable Funding     Long –term sustainable funding is critical to long term success of Rx waste collection and disposal programs. The Yellow Jug Old Drugs program is currently funded primarily by support from participating pharmacies with a small percentage funded by grants. It is the goal of GLCW to have funding sustained by 1/3 pharmacies, 1/3 individuals and grant funding and 1/3 pharmaceutical companies.   Some groups have supported the idea that the Pharmaceutical Industry should fund the entire cost of Pharmaceutical Collection/Disposal Programs. We have been encouraging them to consider funding that would include the Pharmaceutical Industry in the overall solution but not as the only source of funding. It is our opinion that all of us; pharmacies, consumers and pharmaceutical companies contribute to creating drug waste and we all benefit by proper disposal so we should all be part of the solution to fund collection and disposal.   Asking the Pharmaceutical Industry to be responsible for all the costs is a bit like asking the Automobile Industry to fund the operation of all junk yards recycling all unused automobiles.   Some support the idea that the Pharmaceutical Industry should support all the cost of Rx-Waste collection/disposal much the same as the producers of electronics, paints, metals, plastics etc. help fund programs to recycle those items. The major difference being that these recyclable items have some value in the marketplace so it is advantageous for producers to help fund collection of these materials. Rx-Waste is never recycled and has no value. It is collected and taken to a High temp incinerator for complete destruction.   We have seen some estimates for funding collection programs at pharmacies in the range of $2000-$2500 per location. It has been our goal to operate the Yellow Jug Old Drugs Program at the lowest possible cost to reach the maximum number of people. We feel that this is critical to educate the greatest number of people about the importance of proper disposal for Rx-Waste.   Benchmark Cost Per Pharmacy $300 per year   We have demonstrated that the maximum cost per location is $300 per year. This includes all materials to collect unused/unwanted drugs, posters, hand-outs and the transport of collected Rx waste for ultimate disposal/destruction at a high temperature incinerator. Currently the program has 352 pharmacies participating in MI,IL, WI and IN. OH to be added in October 2015. PA NY to be added in 2015 and we will soon be offering the program to other states. Because of the economy of scale, as the number of pharmacies increase it is feasible that the cost per location could be less than $300.   Having effectively demonstrated that a collection/disposal program can operate very successfully within a budget of $300 per location will be beneficial especially for local and state governments to compare costs that they incur to operate Rx-Waste collection/disposal programs. It will also provide a benchmark for actual costs of a collection/disposal program to aid in planning any legislative efforts.     I hope the thoughts that I have shared will be the start of a deeper conversation amongst all interested parties about long-term, sustainable funding for Rx Waste collection/disposal programs.  Chris Angel, GLCW President         ---------------------------- Original Message ---------------------------- Subject: [Pharmwaste] Est cost of take back per site? From: "Ed Gottlieb" Date: Sat, January 31, 2015 10:29 am To: "pharmwaste@lists.dep.state.fl.us" -------------------------------------------------------------------------- > The pharmaceutical lobby claims that the cost of take back programs is too high. > > I'd like to estimate what it would cost and see how that compares, percentage wise, to other industries with product stewardship programs. > > I don't know what percent of gross sales are used to pay for outreach, waste collection and disposal by industries with lifecycle programs. Maybe the folks at PSI have some numbers? Does the percent vary widely or are they in the same ballpark? Could a pharmaceutical program be done for a similar or lower percentage? > > A quick check shows there are approximately 67,000 pharmacies (Wiki) and 16,000 nursing homes (CDC) in the U.S. Couldn't find a number for narcotic treatment centers. It is not likely that every pharmacy, long term care facility, and narcotic treatment center will become a collection site, even if the cost of the program is covered. I'm going to optimistically assume high participation rate of 85,000 collection sites. > > In 2009, gross sales of pharmaceuticals in the US totalled 300 billion dollars [http://www.bls.gov/ppi/pharmpricescomparison.pdf]. With the growth of health care costs, it is safe to assume that this is now a low number. > > Not yet knowing what percent of gross sales other industries put into collection and disposal, I'm going to make a big assumption. I'd guess that most people would agree that 1/10 of 1% of gross sales is not a lot to cover the costs of a take back program. Using my assumptions, 300 million dollars is roughly $3500 per collection site per year. > > Obviously, the start-up cost for a pharmaceutical program is significantly higher than the ongoing costs since drop boxes need to be purchased, staff needs to be trained, and outreach materials developed. We should also assume there will be ongoing government oversight costs that need to be covered. > > There is an economy of scale that applies here. For example, if the manufactures chose to work together, one outreach program could be used nationwide, tweaking it for maximum effectiveness in different regions. Also, the cost of a collection box (roughly 7-9 hundred) will come down some with large volume purchases. > > Are my assumptions and quoted numbers reasonable? How does the $3500/site figure compare to the start up and maintenance costs of your take back program? > > Your thoughts are appreciated! > > 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 > --- > Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients. > --- > TO SUBSCRIBE, go to: http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste > TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe@lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank. > If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste > FOR PROBLEMS: Contact List Administrator Laurie.Tenace@dep.state.fl.us > SEND MAIL to the list server at: pharmwaste@lists.dep.state.fl.us >       Chris Angel, President       www.GreatLakesCleanWater.org                     989.736.8179 Facebook https://www.facebook.com/pages/Great-Lakes-Clean-Water-Organization/250252498393081 Twitter https://twitter.com/CleanWater9 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150202/31f80c9b/attachment.htm From Paul.Prange at sanjoseca.gov Tue Feb 3 11:28:43 2015 From: Paul.Prange at sanjoseca.gov (Prange, Paul) Date: Tue Feb 3 11:29:12 2015 Subject: [Pharmwaste] Re: Still waiting for SC announcement In-Reply-To: <4B6970A4E28E994681D9EB5C39585D5250F98CCCD4@US001EX14V.user.root.acgov.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E4AA2F6@MAIL.cityofithaca.org>, <4B6970A4E28E994681D9EB5C39585D5250F98CCCD4@US001EX14V.user.root.acgov.org> Message-ID: <1422980922757.57316@sanjoseca.gov> http://www.law.cornell.edu/rules/supct/rule_37? Rule 37. Brief for an Amicus Curiae | LII / Legal Information Institute 1. An amicus curiae brief that brings to the attention of the Court relevant matter not already brought to its attention by the parties may be of considerable help to the Court. An amicus curiae brief that does not serve this purpose burdens the Court, and its filing is not favored. An amicus curiae brief may be filed only by an attorney admitted to practice before this Court as provided in Rule 5. Read more... My brief read of this indicates these are supporting motions filed to cover areas not in the original filing, link is included. Paul Prange Environmental Services Specialist City of San Jose Watershed Protection Pollution Prevention (408) 793-5325 ________________________________ From: pharmwaste-bounces@lists.dep.state.fl.us on behalf of Seery, Scott, Env. Health Sent: Monday, February 2, 2015 9:12 AM To: 'Ed Gottlieb'; pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] RE: Still waiting for SC announcement There are new statements on this SCOTUS page regarding the writ: Jan 28 2015 Motion for leave to file amici brief filed by Washington Legal Foundation, et al. . Jan 28 2015 Motion for leave to file amicus brief filed by Chamber of Commerce of the United States of America. I am not sure what to make from this, or whether it means the case was taken up. --Scott From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Wednesday, January 28, 2015 11:02 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Still waiting for SC announcement I phoned the U.S. Supreme Court and learned that today was the estimated decision day. That still may turn out to be accurate. The staff have no way of knowing exactly when the Justices will make the announcement that they will hear the Alameda case or let the District court decision stand. By the way, I have heard the argument that the best outcome would be for the court to hear the case and uphold the law. That precedent would do more to prevent future legal challenges to similar laws than if they simply let the lower court ruling stand. If you want to be one of the first to know what they decide, check this link regularly: http://www.supremecourt.gov/search.aspx?filename=/docketfiles/14-751.htm 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150203/82521d07/attachment.html From Burke.Lucy at CalRecycle.ca.gov Tue Feb 3 20:52:39 2015 From: Burke.Lucy at CalRecycle.ca.gov (Lucy, Burke@CalRecycle) Date: Tue Feb 3 20:53:50 2015 Subject: [Pharmwaste] Est cost of take back per site? In-Reply-To: <7782c9d2d929c720c62785a80f4fe63c.squirrel@webmail04.register.com> References: <65AC0C9A3A6A474EAD8D56070FED66983E63AE76@MAIL.cityofithaca.org> <7782c9d2d929c720c62785a80f4fe63c.squirrel@webmail04.register.com> Message-ID: Ed/all, This info is old and in some cases shows early findings based on some newer programs at the time like mailback, but may still be worth a look, keeping in mind our notes/disclaimer(s) below. From our 2010, Report to the Legislature: Recommendations for Home-Generated Pharmaceutical Collection Programs in California: Costs Program type Average Range (low) Range (high) # Reporting Pharmacy $5.60/lb $1.00/lb $16.67/lb 75 Law Enforcement $4.56/lb $0.38/lb $13.89/lb 63 Household Hazardous Waste Facility $2.86/lb* $0.13/lb $6.38/lb 15 Collection Events $6.06/lb $0.87/lb $16.67/lb 36 Mailback $6.54/lb* $4.59/lb $8.10/lb 3 * This average is considerably lower than the average costs of other programs; however, the weights of pharmaceuticals at HHW programs are more likely to be estimated rather than measured, which could impact the cost-effectiveness results (e.g., if the estimated amounts are twice the actual weight, the cost per pound will be half what it should be). ** Because all mail-back programs started in 2009 and are relatively new in California, CalRecycle only includes the costs and pounds collected for returned mailers. Program managers pay for mailers up-front regardless of whether they are subsequently used or not. If generators (residents) do not return some mailers, then overall cost per pound will increase (e.g., if residents returned only half of the mailers, the cost per pound would double). A mailer?s $3.65 flat rate cost per envelope may encompass more upfront costs than the reported costs from pharmacy programs (e.g., staff time, kiosk cost and maintenance, and lost retail space, etc.). Finally, if residents put more pharmaceuticals in each envelope, the cost effectiveness increases (i.e., a lower cost per pound) because the current mail-back programs use flat rate shipping arrangements. However, encouraging residents to hold onto materials longer and send fewer, fuller envelopes may increase illegal diversion opportunities. In addition, Walgreens has made postage paid mailers available in its stores nationwide for $2.99 each,56 and at least 200 Kaiser Permanente Hospitals in California are offering the same mailers for $4.95 each. Anecdotally, Kaiser has had considerable customer demand. Notes: CalRecycle also cautions readers about trying to compare the different program types. First, the data varied significantly within each program type as well as between program types; when this type of variability exists, one must use caution when comparing averages. Second, the program types vary tremendously in whom they serve and how they provide their services. By way of example, grocery stores, fast food chains and high-end restaurants all provide food but do so very differently and each type excels in different situations. Similarly, the fundamental differences in service delivery models in different pharmaceutical collection program types make comparisons fruitless. ? Responses that did not include both costs and pounds of pharmaceutical waste collected were not included in the cost-effectiveness analysis. Errors or misreporting in overall cost or amount collected will impact the reliability of the cost-per-pound calculation. Program costs may include: 1) advertising costs; 2) a medical or hazardous waste hauler?s collection, transportation, disposal, and processing fees (hauler fees); and 3) administrative/staff time. Survey respondents could choose to provide costs for any or all of these categories. This analysis uses the cost data that program managers provided. For instance, many programs did not provide advertising costs because their program was mature enough that advertising was not needed, or funds were so limited that it was not an option. In addition, in many cases, staff time was not tracked and was not provided. Out of all survey responses, 51 percent of the programs and sites representing a cross section of all program types did not have associated staff costs. Because all costs were not included, the results presented here may be a low estimate. The cost data varied significantly within program type as well as between program types; when this type of variability exists, readers need to use caution when comparing averages. CalRecycle did not adjust the reported amount of pharmaceutical waste collected to compensate for packaging discarded with the pharmaceuticals. While some programs encourage participants to remove packaging more than other programs, CalRecycle could not quantify the effect of this encouragement due to lack of accurate data. As a result, the cost effectiveness and efficacy relate to the combined weight of pharmaceuticals and associated packaging. Most HHW programs do not track pharmaceutical weights separately from other household wastes they collect; most reported estimated weights. CalRecycle excluded one HHW program from the analysis because it reported a combined weight of household wastes and pharmaceuticals. ?also note that roughly one-third of all programs met our voluntary model guidelines (see breakdown in graph below), which include some standards that may be more onerous than the new DEA regulations. For instance, from the guidelines: ?Bins located at pharmacies shall have a two key security system--one in the possession of the collection site?s designated responsible person and the other in the possession of the licensed hauler who will pick up the contents for appropriate destruction.? [cid:image009.jpg@01D03FDA.33CC1EA0] Mr. Burke Lucy Environmental Scientist Department of Resources Recycling and Recovery (CalRecycle) 1001 I Street, PO Box 4025 Sacramento, CA 95812 Burke.Lucy@CalRecycle.ca.gov 916.341.6592 [California Department of Resources Recycling and Recovery (CalRecycle)] Connect with us! [Visit CalRecycle on FaceBook] [Follow CalRecycle on Twitter] [Subscribe to CalRecycle Feeds] [Find CalRecycle videos on YouTube] [CalRecycle Mobile App] From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Chris Angel, President Sent: Monday, February 02, 2015 10:45 AM To: Ed Gottlieb Cc: pharmwaste@lists.dep.state.fl.us Subject: Re: [Pharmwaste] Est cost of take back per site? Ed and ListServe Info below as of October 2014 * We have demonstrated that the maximum cost per location is $300 per year. This includes all materials to collect unused/unwanted drugs, posters, hand-outs and the transport of collected Rx waste for ultimate disposal/destruction at a high temperature incinerator. Currently the program has 352 pharmacies participating in MI,IL, WI and IN. OH to be added in October 2015. PA NY to be added in 2015 and we will soon be offering the program to other states. Because of the economy of scale, as the number of pharmacies increase it is feasible that the cost per location could be less than $300. FR: Chris Angel President Great Lakes Clean Water Conclusions based on six years of operating Yellow Jug Old Drugs Rx-Waste Collection/Disposal Program at pharmacies in the Great Lakes region. Rationale for considering funding options other than Full Producer Responsibility Funding Benchmark Cost Per Pharmacy * Large Scale-state wide and regional drug collection programs provide the most cost effective method of collection and disposal of unused/unwanted drugs. Having many locations under one umbrella program with a low administrative overhead is preferable to local programs providing service to a smaller number of locations yet incurring similar administrative costs. * Pharmacies are the most logical, convenient, safe and most effective locations for proper collection and disposal of unused/unwanted drugs * The Secure and Responsible Drug Disposal Act will now allow pharmacies to collect controlled substances in much the same manner they have been doing with Yellow Jug Old Drugs. This will provide even better access for citizens wanting to dispose of unused/unwanted drugs. Law enforcement will soon be deferring collection of controlled substances to pharmacies and more pharmacies will be providing collection/disposal of Rx-Waste for their customers * Independent pharmacies are willing to provide financial support to provide program to their communities. Chain pharmacies which make up a majority of pharmacies in the country should be strongly encouraged to participate to provide even greater access to citizens wanting to properly dispose of unused/unwanted drugs. * There are several reasons that citizens should be educated and encouraged to properly dispose of unused/unwanted drugs. These include; Environmental, Water Quality, Public Health and Safety and Substance Abuse Prevention. Individuals deciding to take action are motivated by sometimes more than one concern. We feel that a primary focus on Great Lakes Water Quality is one of the major factors in the success of the Yellow Jug Old Drugs Program. The issue of water quality, whether it?s drinking water or lakes, rivers or streams for recreation, has been a unifying message while also addressing the other concerns cited. Sustainable Funding * Long ?term sustainable funding is critical to long term success of Rx waste collection and disposal programs. The Yellow Jug Old Drugs program is currently funded primarily by support from participating pharmacies with a small percentage funded by grants. It is the goal of GLCW to have funding sustained by 1/3 pharmacies, 1/3 individuals and grant funding and 1/3 pharmaceutical companies. * Some groups have supported the idea that the Pharmaceutical Industry should fund the entire cost of Pharmaceutical Collection/Disposal Programs. We have been encouraging them to consider funding that would include the Pharmaceutical Industry in the overall solution but not as the only source of funding. It is our opinion that all of us; pharmacies, consumers and pharmaceutical companies contribute to creating drug waste and we all benefit by proper disposal so we should all be part of the solution to fund collection and disposal. * Asking the Pharmaceutical Industry to be responsible for all the costs is a bit like asking the Automobile Industry to fund the operation of all junk yards recycling all unused automobiles. * Some support the idea that the Pharmaceutical Industry should support all the cost of Rx-Waste collection/disposal much the same as the producers of electronics, paints, metals, plastics etc. help fund programs to recycle those items. The major difference being that these recyclable items have some value in the marketplace so it is advantageous for producers to help fund collection of these materials. Rx-Waste is never recycled and has no value. It is collected and taken to a High temp incinerator for complete destruction. * We have seen some estimates for funding collection programs at pharmacies in the range of $2000-$2500 per location. It has been our goal to operate the Yellow Jug Old Drugs Program at the lowest possible cost to reach the maximum number of people. We feel that this is critical to educate the greatest number of people about the importance of proper disposal for Rx-Waste. Benchmark Cost Per Pharmacy $300 per year * We have demonstrated that the maximum cost per location is $300 per year. This includes all materials to collect unused/unwanted drugs, posters, hand-outs and the transport of collected Rx waste for ultimate disposal/destruction at a high temperature incinerator. Currently the program has 352 pharmacies participating in MI,IL, WI and IN. OH to be added in October 2015. PA NY to be added in 2015 and we will soon be offering the program to other states. Because of the economy of scale, as the number of pharmacies increase it is feasible that the cost per location could be less than $300. * Having effectively demonstrated that a collection/disposal program can operate very successfully within a budget of $300 per location will be beneficial especially for local and state governments to compare costs that they incur to operate Rx-Waste collection/disposal programs. It will also provide a benchmark for actual costs of a collection/disposal program to aid in planning any legislative efforts. I hope the thoughts that I have shared will be the start of a deeper conversation amongst all interested parties about long-term, sustainable funding for Rx Waste collection/disposal programs. Chris Angel, GLCW President ---------------------------- Original Message ---------------------------- Subject: [Pharmwaste] Est cost of take back per site? From: "Ed Gottlieb" > Date: Sat, January 31, 2015 10:29 am To: "pharmwaste@lists.dep.state.fl.us" > -------------------------------------------------------------------------- > The pharmaceutical lobby claims that the cost of take back programs is too high. > > I'd like to estimate what it would cost and see how that compares, percentage wise, to other industries with product stewardship programs. > > I don't know what percent of gross sales are used to pay for outreach, waste collection and disposal by industries with lifecycle programs. Maybe the folks at PSI have some numbers? Does the percent vary widely or are they in the same ballpark? Could a pharmaceutical program be done for a similar or lower percentage? > > A quick check shows there are approximately 67,000 pharmacies (Wiki) and 16,000 nursing homes (CDC) in the U.S. Couldn't find a number for narcotic treatment centers. It is not likely that every pharmacy, long term care facility, and narcotic treatment center will become a collection site, even if the cost of the program is covered. I'm going to optimistically assume high participation rate of 85,000 collection sites. > > In 2009, gross sales of pharmaceuticals in the US totalled 300 billion dollars [http://www.bls.gov/ppi/pharmpricescomparison.pdf]. With the growth of health care costs, it is safe to assume that this is now a low number. > > Not yet knowing what percent of gross sales other industries put into collection and disposal, I'm going to make a big assumption. I'd guess that most people would agree that 1/10 of 1% of gross sales is not a lot to cover the costs of a take back program. Using my assumptions, 300 million dollars is roughly $3500 per collection site per year. > > Obviously, the start-up cost for a pharmaceutical program is significantly higher than the ongoing costs since drop boxes need to be purchased, staff needs to be trained, and outreach materials developed. We should also assume there will be ongoing government oversight costs that need to be covered. > > There is an economy of scale that applies here. For example, if the manufactures chose to work together, one outreach program could be used nationwide, tweaking it for maximum effectiveness in different regions. Also, the cost of a collection box (roughly 7-9 hundred) will come down some with large volume purchases. > > Are my assumptions and quoted numbers reasonable? How does the $3500/site figure compare to the start up and maintenance costs of your take back program? > > Your thoughts are appreciated! > > 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 > --- > Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients. > --- > TO SUBSCRIBE, go to: http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste > TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe@lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank. > If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste > FOR PROBLEMS: Contact List Administrator Laurie.Tenace@dep.state.fl.us > SEND MAIL to the list server at: pharmwaste@lists.dep.state.fl.us > Chris Angel, President www.GreatLakesCleanWater.org 989.736.8179 Facebook https://www.facebook.com/pages/Great-Lakes-Clean-Water-Organization/250252498393081 Twitter https://twitter.com/CleanWater9 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150204/14cdc72e/attachment-0001.htm -------------- next part -------------- A non-text attachment was scrubbed... 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Name: image009.jpg Type: image/jpeg Size: 31718 bytes Desc: image009.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150204/14cdc72e/image009-0001.jpg From EGottlieb at cityofithaca.org Wed Feb 4 08:58:52 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Wed Feb 4 09:00:50 2015 Subject: [Pharmwaste] Sheriff ends take back program Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E63E04B@MAIL.cityofithaca.org> I wonder how many more programs have ended do to the discontinuation of DEA support? http://www.thenewscenter.tv/home/headlines/Prescription-Drug-Take-Back-Program-Ends-at-Wood-County-Sheriffs-Office-290706161.html 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150204/a0434b7e/attachment.html From EGottlieb at cityofithaca.org Wed Feb 4 13:54:44 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Wed Feb 4 13:55:11 2015 Subject: [Pharmwaste] Est cost of take back per site? In-Reply-To: <7782c9d2d929c720c62785a80f4fe63c.squirrel@webmail04.register.com> References: <65AC0C9A3A6A474EAD8D56070FED66983E63AE76@MAIL.cityofithaca.org>, <7782c9d2d929c720c62785a80f4fe63c.squirrel@webmail04.register.com> Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E63E303@MAIL.cityofithaca.org> Thanks Chris! The Yellow Jug, Old Drugs program that you created is extremely impressive. You have found a way to make the program so attractive to pharmacies that it has, and continues, to grow at a tremendous rate. A big part of that is do to it being so affordable. I'm sure that a total cost of only $300 per box per year translates to a very low cost per pound of disposed medication. Can you please let us know how the transition to collecting controlled will happen in your program? Have any of the participating pharmacies already applied to be a controlled take back location? If so, do you know if it was as simple as the DEA claims it to be? Finally, I would respectfully disagree with the analogy, "Asking the Pharmaceutical Industry to be responsible for all the costs is a bit like asking the Automobile Industry to fund the operation of all junk yards recycling all unused automobiles." Junk yards exist because most old vehicles contain value that can be extracted at a profit. They don't require the support of auto makers. Not so for tires or pharmaceuticals. Only a small percent of tires can processed for other uses at a profit. To keep them out of landfills, recycling needs to be subsidized. With no profit possible from waste pharmaceuticals a greater level of industry support is required. Similarly, the fact that some call for industry to support the collection/reuse/re-purposing/recycling/disposal of waste electronics, paints, metals, plastics etc., materials that have some value, is not an argument against calling for industry to fully support the collection of pharmaceuticals that have no value. Reiterating, when waste has some value the amount of industry support needed for a collection/reuse/re-purposing/recycling/disposal program to be viable is less than the amount (in percent) needed for a material with no value. Thanks again for your effective leadership that has created the largest regional collection program in the country! Best regards, 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: Chris Angel, President [info@greatlakescleanwater.org] Sent: Monday, February 02, 2015 1:45 PM To: Ed Gottlieb Cc: pharmwaste@lists.dep.state.fl.us Subject: Re: [Pharmwaste] Est cost of take back per site? Ed and ListServe Info below as of October 2014 * We have demonstrated that the maximum cost per location is $300 per year. This includes all materials to collect unused/unwanted drugs, posters, hand-outs and the transport of collected Rx waste for ultimate disposal/destruction at a high temperature incinerator. Currently the program has 352 pharmacies participating in MI,IL, WI and IN. OH to be added in October 2015. PA NY to be added in 2015 and we will soon be offering the program to other states. Because of the economy of scale, as the number of pharmacies increase it is feasible that the cost per location could be less than $300. FR: Chris Angel President Great Lakes Clean Water Conclusions based on six years of operating Yellow Jug Old Drugs Rx-Waste Collection/Disposal Program at pharmacies in the Great Lakes region. Rationale for considering funding options other than Full Producer Responsibility Funding Benchmark Cost Per Pharmacy * Large Scale-state wide and regional drug collection programs provide the most cost effective method of collection and disposal of unused/unwanted drugs. Having many locations under one umbrella program with a low administrative overhead is preferable to local programs providing service to a smaller number of locations yet incurring similar administrative costs. * Pharmacies are the most logical, convenient, safe and most effective locations for proper collection and disposal of unused/unwanted drugs * The Secure and Responsible Drug Disposal Act will now allow pharmacies to collect controlled substances in much the same manner they have been doing with Yellow Jug Old Drugs. This will provide even better access for citizens wanting to dispose of unused/unwanted drugs. Law enforcement will soon be deferring collection of controlled substances to pharmacies and more pharmacies will be providing collection/disposal of Rx-Waste for their customers * Independent pharmacies are willing to provide financial support to provide program to their communities. Chain pharmacies which make up a majority of pharmacies in the country should be strongly encouraged to participate to provide even greater access to citizens wanting to properly dispose of unused/unwanted drugs. * There are several reasons that citizens should be educated and encouraged to properly dispose of unused/unwanted drugs. These include; Environmental, Water Quality, Public Health and Safety and Substance Abuse Prevention. Individuals deciding to take action are motivated by sometimes more than one concern. We feel that a primary focus on Great Lakes Water Quality is one of the major factors in the success of the Yellow Jug Old Drugs Program. The issue of water quality, whether it?s drinking water or lakes, rivers or streams for recreation, has been a unifying message while also addressing the other concerns cited. Sustainable Funding * Long ?term sustainable funding is critical to long term success of Rx waste collection and disposal programs. The Yellow Jug Old Drugs program is currently funded primarily by support from participating pharmacies with a small percentage funded by grants. It is the goal of GLCW to have funding sustained by 1/3 pharmacies, 1/3 individuals and grant funding and 1/3 pharmaceutical companies. * Some groups have supported the idea that the Pharmaceutical Industry should fund the entire cost of Pharmaceutical Collection/Disposal Programs. We have been encouraging them to consider funding that would include the Pharmaceutical Industry in the overall solution but not as the only source of funding. It is our opinion that all of us; pharmacies, consumers and pharmaceutical companies contribute to creating drug waste and we all benefit by proper disposal so we should all be part of the solution to fund collection and disposal. * Asking the Pharmaceutical Industry to be responsible for all the costs is a bit like asking the Automobile Industry to fund the operation of all junk yards recycling all unused automobiles. * Some support the idea that the Pharmaceutical Industry should support all the cost of Rx-Waste collection/disposal much the same as the producers of electronics, paints, metals, plastics etc. help fund programs to recycle those items. The major difference being that these recyclable items have some value in the marketplace so it is advantageous for producers to help fund collection of these materials. Rx-Waste is never recycled and has no value. It is collected and taken to a High temp incinerator for complete destruction. * We have seen some estimates for funding collection programs at pharmacies in the range of $2000-$2500 per location. It has been our goal to operate the Yellow Jug Old Drugs Program at the lowest possible cost to reach the maximum number of people. We feel that this is critical to educate the greatest number of people about the importance of proper disposal for Rx-Waste. Benchmark Cost Per Pharmacy $300 per year * We have demonstrated that the maximum cost per location is $300 per year. This includes all materials to collect unused/unwanted drugs, posters, hand-outs and the transport of collected Rx waste for ultimate disposal/destruction at a high temperature incinerator. Currently the program has 352 pharmacies participating in MI,IL, WI and IN. OH to be added in October 2015. PA NY to be added in 2015 and we will soon be offering the program to other states. Because of the economy of scale, as the number of pharmacies increase it is feasible that the cost per location could be less than $300. * Having effectively demonstrated that a collection/disposal program can operate very successfully within a budget of $300 per location will be beneficial especially for local and state governments to compare costs that they incur to operate Rx-Waste collection/disposal programs. It will also provide a benchmark for actual costs of a collection/disposal program to aid in planning any legislative efforts. I hope the thoughts that I have shared will be the start of a deeper conversation amongst all interested parties about long-term, sustainable funding for Rx Waste collection/disposal programs. Chris Angel, GLCW President ---------------------------- Original Message ---------------------------- Subject: [Pharmwaste] Est cost of take back per site? From: "Ed Gottlieb" Date: Sat, January 31, 2015 10:29 am To: "pharmwaste@lists.dep.state.fl.us" -------------------------------------------------------------------------- > The pharmaceutical lobby claims that the cost of take back programs is too high. > > I'd like to estimate what it would cost and see how that compares, percentage wise, to other industries with product stewardship programs. > > I don't know what percent of gross sales are used to pay for outreach, waste collection and disposal by industries with lifecycle programs. Maybe the folks at PSI have some numbers? Does the percent vary widely or are they in the same ballpark? Could a pharmaceutical program be done for a similar or lower percentage? > > A quick check shows there are approximately 67,000 pharmacies (Wiki) and 16,000 nursing homes (CDC) in the U.S. Couldn't find a number for narcotic treatment centers. It is not likely that every pharmacy, long term care facility, and narcotic treatment center will become a collection site, even if the cost of the program is covered. I'm going to optimistically assume high participation rate of 85,000 collection sites. > > In 2009, gross sales of pharmaceuticals in the US totalled 300 billion dollars [http://www.bls.gov/ppi/pharmpricescomparison.pdf]. With the growth of health care costs, it is safe to assume that this is now a low number. > > Not yet knowing what percent of gross sales other industries put into collection and disposal, I'm going to make a big assumption. I'd guess that most people would agree that 1/10 of 1% of gross sales is not a lot to cover the costs of a take back program. Using my assumptions, 300 million dollars is roughly $3500 per collection site per year. > > Obviously, the start-up cost for a pharmaceutical program is significantly higher than the ongoing costs since drop boxes need to be purchased, staff needs to be trained, and outreach materials developed. We should also assume there will be ongoing government oversight costs that need to be covered. > > There is an economy of scale that applies here. For example, if the manufactures chose to work together, one outreach program could be used nationwide, tweaking it for maximum effectiveness in different regions. Also, the cost of a collection box (roughly 7-9 hundred) will come down some with large volume purchases. > > Are my assumptions and quoted numbers reasonable? How does the $3500/site figure compare to the start up and maintenance costs of your take back program? > > Your thoughts are appreciated! > > 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 > --- > Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients. > --- > TO SUBSCRIBE, go to: http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste > TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe@lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank. > If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste > FOR PROBLEMS: Contact List Administrator Laurie.Tenace@dep.state.fl.us > SEND MAIL to the list server at: pharmwaste@lists.dep.state.fl.us > Chris Angel, President www.GreatLakesCleanWater.org 989.736.8179 Facebook https://www.facebook.com/pages/Great-Lakes-Clean-Water-Organization/250252498393081 Twitter https://twitter.com/CleanWater9 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150204/2a0ed32f/attachment.htm From Deborah.DeBiasi at deq.virginia.gov Wed Feb 4 15:05:25 2015 From: Deborah.DeBiasi at deq.virginia.gov (DeBiasi, Deborah (DEQ)) Date: Wed Feb 4 15:11:55 2015 Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions Message-ID: <2FB366A29AAF0D47BD422C53F698353F2B0D29FA@COVMSGCES-MBX02> http://www.theguardian.com/environment/2015/feb/02/suppressed-eu-report-could-have-banned-pesticides-worth-billions 'Suppressed' EU report could have banned pesticides worth billions Science paper recommended ways of identifying hormone-mimicking chemicals in pesticides linked to foetal abnormalities, genital mutations, infertility and other diseases including cancer As many as 31 pesticides with a value running into billions of pounds could have been banned because of potential health risks, if a blocked EU paper on hormone-mimicking chemicals had been acted upon, the Guardian has learned. The science paper, seen by the Guardian, recommends ways of identifying and categorising the endocrine-disrupting chemicals (EDCs) that scientists link to a rise in foetal abnormalities, genital mutations, infertility, and adverse health effects ranging from cancer to IQ loss. Commission sources say that the paper was buried by top EU officials under pressure from big chemical firms which use EDCs in toiletries, plastics and cosmetics, despite an annual health cost that studies peg at hundreds of millions of euros. (Long article - read the rest at the site above) Deborah L. DeBiasi Email: Deborah.DeBiasi@deq.virginia.gov WEB site address: www.deq.virginia.gov Virginia Department of Environmental Quality Office of Water Permits Industrial Pretreatment/Whole Effluent Toxicity (WET) Program PPCPs, EDCs, and Microconstituents http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDischargeElimination/Microconstituents.aspx Mail: P.O. Box 1105, Richmond, VA 23218 Location: 629 E. Main Street, Richmond, VA 23219 PH: 804-698-4028 FAX: 804-698-4032 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150204/c9d67155/attachment.htm From GILLIAM at adeq.state.ar.us Wed Feb 4 16:03:52 2015 From: GILLIAM at adeq.state.ar.us (Gilliam, Allen) Date: Wed Feb 4 16:03:36 2015 Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions In-Reply-To: <2FB366A29AAF0D47BD422C53F698353F2B0D29FA@COVMSGCES-MBX02> References: <2FB366A29AAF0D47BD422C53F698353F2B0D29FA@COVMSGCES-MBX02> Message-ID: Sounds like something that typically happens with our policy makers on the hill... Does anyone practice the Precautionary Principal anymore? And didn't I read the EU was decades ahead of the U.S. in its use? Allen g From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of DeBiasi, Deborah (DEQ) Sent: Wednesday, February 04, 2015 2:05 PM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions http://www.theguardian.com/environment/2015/feb/02/suppressed-eu-report-could-have-banned-pesticides-worth-billions 'Suppressed' EU report could have banned pesticides worth billions Science paper recommended ways of identifying hormone-mimicking chemicals in pesticides linked to foetal abnormalities, genital mutations, infertility and other diseases including cancer As many as 31 pesticides with a value running into billions of pounds could have been banned because of potential health risks, if a blocked EU paper on hormone-mimicking chemicals had been acted upon, the Guardian has learned. The science paper, seen by the Guardian, recommends ways of identifying and categorising the endocrine-disrupting chemicals (EDCs) that scientists link to a rise in foetal abnormalities, genital mutations, infertility, and adverse health effects ranging from cancer to IQ loss. Commission sources say that the paper was buried by top EU officials under pressure from big chemical firms which use EDCs in toiletries, plastics and cosmetics, despite an annual health cost that studies peg at hundreds of millions of euros. (Long article - read the rest at the site above) Deborah L. DeBiasi Email: Deborah.DeBiasi@deq.virginia.gov WEB site address: www.deq.virginia.gov Virginia Department of Environmental Quality Office of Water Permits Industrial Pretreatment/Whole Effluent Toxicity (WET) Program PPCPs, EDCs, and Microconstituents http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDischargeElimination/Microconstituents.aspx Mail: P.O. Box 1105, Richmond, VA 23218 Location: 629 E. Main Street, Richmond, VA 23219 PH: 804-698-4028 FAX: 804-698-4032 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150204/5df77ae2/attachment.htm From Margaret.Shield at kingcounty.gov Wed Feb 4 18:51:25 2015 From: Margaret.Shield at kingcounty.gov (Shield, Margaret) Date: Wed Feb 4 18:51:47 2015 Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions In-Reply-To: References: <2FB366A29AAF0D47BD422C53F698353F2B0D29FA@COVMSGCES-MBX02> Message-ID: <4B5D22CD2328F442862E4FC8982A612044F18F5B@MAILQDC3.kc.kingcounty.lcl> The Precautionary Principle is a strategy that must then be carried out in policies, laws, regulations. It's use by the EU has been under attack with renewed vigor. Here's one perspective on why: 25 August 2014 Chemical Industry using TTIP 'to attack the precautionary principle' Trade deal presents long-awaited opportunities for fresh assaults on regulation writes Axel Singhofen health and environment advisor Greens/EFA group Republished with the kind permission of Chemical Watch. CW. Global Business Briefing, July/August 2014 / Europe The last 12 months have seen a surge of attacks against the EU's precautionary principle. Some law firms consider it as a potential obstacle to the Transatlantic Trade and Investment Partnership (TTIP), and UK Conservative MEP Julie Girling considers that "the EU's expanding embrace of `precautionary' regulation... may well be the biggest threat" to an agreement being signed off. Last October, 12 CEOs of mainly chemical companies wrote to the presidents of the European Commission, Council and Parliament, calling for the formal adoption of an "innovation principle" as a counterbalance to "precautionary legislation", because they were concerned that "the necessary balance of precaution and proportion is increasingly being replaced by a simple reliance on the precautionary principle and the avoidance of technological risk. Some academics even conjure up a "precautionary impasse in Europe", claim an "apparent gap between evidence-based analysis and expert-informed recommendations, and policy decisions that can seem disconnected from both", and conclude there is "a necessity for change in light of the impracticability of a status quo that leads to scattered ill-thought out bans". Read more at.... http://www.ttip2014.eu/blog-detail/blog/precautionary%20principle%20TTIP.html Margaret Shield PhD, Policy Liaison Local Hazardous Waste Management Program in King County desk 206-477-6238 cell 206-265-9732 Local Governments for Health and the Environment - www.lhwmp.org From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Gilliam, Allen Sent: Wednesday, February 4, 2015 1:05 PM To: DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions Sounds like something that typically happens with our policy makers on the hill... Does anyone practice the Precautionary Principal anymore? And didn't I read the EU was decades ahead of the U.S. in its use? Allen g From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of DeBiasi, Deborah (DEQ) Sent: Wednesday, February 04, 2015 2:05 PM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions http://www.theguardian.com/environment/2015/feb/02/suppressed-eu-report-could-have-banned-pesticides-worth-billions 'Suppressed' EU report could have banned pesticides worth billions Science paper recommended ways of identifying hormone-mimicking chemicals in pesticides linked to foetal abnormalities, genital mutations, infertility and other diseases including cancer As many as 31 pesticides with a value running into billions of pounds could have been banned because of potential health risks, if a blocked EU paper on hormone-mimicking chemicals had been acted upon, the Guardian has learned. The science paper, seen by the Guardian, recommends ways of identifying and categorising the endocrine-disrupting chemicals (EDCs) that scientists link to a rise in foetal abnormalities, genital mutations, infertility, and adverse health effects ranging from cancer to IQ loss. Commission sources say that the paper was buried by top EU officials under pressure from big chemical firms which use EDCs in toiletries, plastics and cosmetics, despite an annual health cost that studies peg at hundreds of millions of euros. (Long article - read the rest at the site above) Deborah L. DeBiasi Email: Deborah.DeBiasi@deq.virginia.gov WEB site address: www.deq.virginia.gov Virginia Department of Environmental Quality Office of Water Permits Industrial Pretreatment/Whole Effluent Toxicity (WET) Program PPCPs, EDCs, and Microconstituents http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDischargeElimination/Microconstituents.aspx Mail: P.O. Box 1105, Richmond, VA 23218 Location: 629 E. Main Street, Richmond, VA 23219 PH: 804-698-4028 FAX: 804-698-4032 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150204/1a89ef84/attachment-0001.htm From EGottlieb at cityofithaca.org Thu Feb 5 11:08:11 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Thu Feb 5 11:08:34 2015 Subject: [Pharmwaste] Pharmacies in 3 States Can't Take Back Controlled Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E6419EC@MAIL.cityofithaca.org> I didn't remember that during the Office of National Drug Control Policy (ONDCP) webinar we were told that state board of pharmacy rules did not allow controlled substances to be taken back in Georgia, Oklahoma and Hawaii. I wrote to the National Association of Boards of Pharmacy to get this and related information. My email and their reply are below. Ed Dear Mr. Gottlieb, Thank you for contacting the National Association of Boards of Pharmacy? (NABP?). NABP is the independent, international, and impartial association that assists its member boards and jurisdictions for the purpose of protecting the public health. NABP does not have any regulatory or interpretive authority over its member boards. Since the DEA Final Rule on Disposal of Controlled Substances is a new federal regulation, unfortunately; the majority of the states that have not previously prohibited community pharmacies from taking back controlled substances are still silent on the issue and are in the process of reviewing their existing statutes and regulations. Until new laws/regulations are enacted or it is addressed through policy interpretation, we do not have new information to share. NABP is following this issue and we are staying vigilant on the matter. We will inform our member boards and the public through our website as more information becomes available. In the meantime, according to the Office of National Drug Control Policy (ONDCP) webinar, the following states may not permit pharmacies to take back controlled substances: Georgia, Oklahoma and Hawaii. Respectfully, Professional Affairs Hello, It is my understanding that the existing rules (and recommendations?) of many state boards of pharmacy are in conflict with the new DEA rule allowing pharmacies to take back controlled substances. If my understanding is correct, do you know which states need to make changes to be in-line with this DEA rule? Can you please provide me with details? Has, or will, your organization be encouraging members to make the changes necessary to allow pharmacies to participate in controlled take back? If you have, may I please see a copy of what you did? If you haven't, please consider doing so. Though it is possible that not many pharmacies will participate in this voluntary, unfunded opportunity, it would be unfortunate if those that wanted to provide this important public service were unable to do so because some state boards of pharmacy's failed to act. Thanks for your assistance and consideration. Sincerely, 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150205/443d64bd/attachment.html From GILLIAM at adeq.state.ar.us Thu Feb 5 13:04:56 2015 From: GILLIAM at adeq.state.ar.us (Gilliam, Allen) Date: Thu Feb 5 13:04:43 2015 Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions In-Reply-To: <4B5D22CD2328F442862E4FC8982A612044F18F5B@MAILQDC3.kc.kingcounty.lcl> References: <2FB366A29AAF0D47BD422C53F698353F2B0D29FA@COVMSGCES-MBX02> <4B5D22CD2328F442862E4FC8982A612044F18F5B@MAILQDC3.kc.kingcounty.lcl> Message-ID: Thanks for the sad story Margaret, Not wishing to offend others' religious beliefs (and I'm no Bible totin or even Sunday Christian), but 1 Timothy 6:10 (New Living Translation [had to look it up]) says, "For the love of money is the root of all kinds of evil. And some people, craving money, have wandered from the true faith and pierced themselves with many sorrows." seems to be applying itself in mother earth's demise in so many facets of our environment. Absolutely NO offense intended to anyone, Allen g From: Shield, Margaret [mailto:Margaret.Shield@kingcounty.gov] Sent: Wednesday, February 04, 2015 5:51 PM To: Gilliam, Allen; DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions The Precautionary Principle is a strategy that must then be carried out in policies, laws, regulations. It's use by the EU has been under attack with renewed vigor. Here's one perspective on why: 25 August 2014 Chemical Industry using TTIP 'to attack the precautionary principle' Trade deal presents long-awaited opportunities for fresh assaults on regulation writes Axel Singhofen health and environment advisor Greens/EFA group Republished with the kind permission of Chemical Watch. CW. Global Business Briefing, July/August 2014 / Europe The last 12 months have seen a surge of attacks against the EU's precautionary principle. Some law firms consider it as a potential obstacle to the Transatlantic Trade and Investment Partnership (TTIP), and UK Conservative MEP Julie Girling considers that "the EU's expanding embrace of `precautionary' regulation... may well be the biggest threat" to an agreement being signed off. Last October, 12 CEOs of mainly chemical companies wrote to the presidents of the European Commission, Council and Parliament, calling for the formal adoption of an "innovation principle" as a counterbalance to "precautionary legislation", because they were concerned that "the necessary balance of precaution and proportion is increasingly being replaced by a simple reliance on the precautionary principle and the avoidance of technological risk. Some academics even conjure up a "precautionary impasse in Europe", claim an "apparent gap between evidence-based analysis and expert-informed recommendations, and policy decisions that can seem disconnected from both", and conclude there is "a necessity for change in light of the impracticability of a status quo that leads to scattered ill-thought out bans". Read more at.... http://www.ttip2014.eu/blog-detail/blog/precautionary%20principle%20TTIP.html Margaret Shield PhD, Policy Liaison Local Hazardous Waste Management Program in King County desk 206-477-6238 cell 206-265-9732 Local Governments for Health and the Environment - www.lhwmp.org From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Gilliam, Allen Sent: Wednesday, February 4, 2015 1:05 PM To: DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions Sounds like something that typically happens with our policy makers on the hill... Does anyone practice the Precautionary Principal anymore? And didn't I read the EU was decades ahead of the U.S. in its use? Allen g From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of DeBiasi, Deborah (DEQ) Sent: Wednesday, February 04, 2015 2:05 PM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions http://www.theguardian.com/environment/2015/feb/02/suppressed-eu-report-could-have-banned-pesticides-worth-billions 'Suppressed' EU report could have banned pesticides worth billions Science paper recommended ways of identifying hormone-mimicking chemicals in pesticides linked to foetal abnormalities, genital mutations, infertility and other diseases including cancer As many as 31 pesticides with a value running into billions of pounds could have been banned because of potential health risks, if a blocked EU paper on hormone-mimicking chemicals had been acted upon, the Guardian has learned. The science paper, seen by the Guardian, recommends ways of identifying and categorising the endocrine-disrupting chemicals (EDCs) that scientists link to a rise in foetal abnormalities, genital mutations, infertility, and adverse health effects ranging from cancer to IQ loss. Commission sources say that the paper was buried by top EU officials under pressure from big chemical firms which use EDCs in toiletries, plastics and cosmetics, despite an annual health cost that studies peg at hundreds of millions of euros. (Long article - read the rest at the site above) Deborah L. DeBiasi Email: Deborah.DeBiasi@deq.virginia.gov WEB site address: www.deq.virginia.gov Virginia Department of Environmental Quality Office of Water Permits Industrial Pretreatment/Whole Effluent Toxicity (WET) Program PPCPs, EDCs, and Microconstituents http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDischargeElimination/Microconstituents.aspx Mail: P.O. Box 1105, Richmond, VA 23218 Location: 629 E. Main Street, Richmond, VA 23219 PH: 804-698-4028 FAX: 804-698-4032 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150205/02c44c75/attachment.htm From LDean at STERICYCLE.com Thu Feb 5 13:12:12 2015 From: LDean at STERICYCLE.com (Dean, Lorna) Date: Thu Feb 5 13:12:29 2015 Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions In-Reply-To: References: <2FB366A29AAF0D47BD422C53F698353F2B0D29FA@COVMSGCES-MBX02> <4B5D22CD2328F442862E4FC8982A612044F18F5B@MAILQDC3.kc.kingcounty.lcl> Message-ID: Beautiful, no offense taken. From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Gilliam, Allen Sent: Thursday, February 05, 2015 12:05 PM To: Shield, Margaret; DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions Thanks for the sad story Margaret, Not wishing to offend others' religious beliefs (and I'm no Bible totin or even Sunday Christian), but 1 Timothy 6:10 (New Living Translation [had to look it up]) says, "For the love of money is the root of all kinds of evil. And some people, craving money, have wandered from the true faith and pierced themselves with many sorrows." seems to be applying itself in mother earth's demise in so many facets of our environment. Absolutely NO offense intended to anyone, Allen g From: Shield, Margaret [mailto:Margaret.Shield@kingcounty.gov] Sent: Wednesday, February 04, 2015 5:51 PM To: Gilliam, Allen; DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions The Precautionary Principle is a strategy that must then be carried out in policies, laws, regulations. It's use by the EU has been under attack with renewed vigor. Here's one perspective on why: 25 August 2014 Chemical Industry using TTIP 'to attack the precautionary principle' Trade deal presents long-awaited opportunities for fresh assaults on regulation writes Axel Singhofen health and environment advisor Greens/EFA group Republished with the kind permission of Chemical Watch. CW. Global Business Briefing, July/August 2014 / Europe The last 12 months have seen a surge of attacks against the EU's precautionary principle. Some law firms consider it as a potential obstacle to the Transatlantic Trade and Investment Partnership (TTIP), and UK Conservative MEP Julie Girling considers that "the EU's expanding embrace of `precautionary' regulation... may well be the biggest threat" to an agreement being signed off. Last October, 12 CEOs of mainly chemical companies wrote to the presidents of the European Commission, Council and Parliament, calling for the formal adoption of an "innovation principle" as a counterbalance to "precautionary legislation", because they were concerned that "the necessary balance of precaution and proportion is increasingly being replaced by a simple reliance on the precautionary principle and the avoidance of technological risk. Some academics even conjure up a "precautionary impasse in Europe", claim an "apparent gap between evidence-based analysis and expert-informed recommendations, and policy decisions that can seem disconnected from both", and conclude there is "a necessity for change in light of the impracticability of a status quo that leads to scattered ill-thought out bans". Read more at.... http://www.ttip2014.eu/blog-detail/blog/precautionary%20principle%20TTIP.html Margaret Shield PhD, Policy Liaison Local Hazardous Waste Management Program in King County desk 206-477-6238 cell 206-265-9732 Local Governments for Health and the Environment - www.lhwmp.org From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Gilliam, Allen Sent: Wednesday, February 4, 2015 1:05 PM To: DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions Sounds like something that typically happens with our policy makers on the hill... Does anyone practice the Precautionary Principal anymore? And didn't I read the EU was decades ahead of the U.S. in its use? Allen g From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of DeBiasi, Deborah (DEQ) Sent: Wednesday, February 04, 2015 2:05 PM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions http://www.theguardian.com/environment/2015/feb/02/suppressed-eu-report-could-have-banned-pesticides-worth-billions 'Suppressed' EU report could have banned pesticides worth billions Science paper recommended ways of identifying hormone-mimicking chemicals in pesticides linked to foetal abnormalities, genital mutations, infertility and other diseases including cancer As many as 31 pesticides with a value running into billions of pounds could have been banned because of potential health risks, if a blocked EU paper on hormone-mimicking chemicals had been acted upon, the Guardian has learned. The science paper, seen by the Guardian, recommends ways of identifying and categorising the endocrine-disrupting chemicals (EDCs) that scientists link to a rise in foetal abnormalities, genital mutations, infertility, and adverse health effects ranging from cancer to IQ loss. Commission sources say that the paper was buried by top EU officials under pressure from big chemical firms which use EDCs in toiletries, plastics and cosmetics, despite an annual health cost that studies peg at hundreds of millions of euros. (Long article - read the rest at the site above) Deborah L. DeBiasi Email: Deborah.DeBiasi@deq.virginia.gov WEB site address: www.deq.virginia.gov Virginia Department of Environmental Quality Office of Water Permits Industrial Pretreatment/Whole Effluent Toxicity (WET) Program PPCPs, EDCs, and Microconstituents http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDischargeElimination/Microconstituents.aspx Mail: P.O. Box 1105, Richmond, VA 23218 Location: 629 E. Main Street, Richmond, VA 23219 PH: 804-698-4028 FAX: 804-698-4032 ----------------------------------------- CONFIDENTIALITY NOTICE: The information in this Email is confidential and may be privileged. This Email is intended solely for the named recipient or recipients. If you are not the intended recipient, any use, disclosure, copying or distribution of this Email is prohibited. If you are not the intended recipient, please inform us by replying with the subject line marked "Wrong Address" and then deleting this Email and any attachments. Stericycle, Inc. uses regularly updated anti-virus software in an attempt to reduce the possibility of transmitting computer viruses. We do not guarantee, however, that any attachments to this Email are virus-free. Nota de confidencialidad: La informaci?n que presenta este correo es confidencial, y puede ser de uso privilegiado. Este correo intenta ser enviado solo al destinatario, o a los destinatarios. Si usted no es el destinatario, no podr? usar, desglosar, copiar, o distribuir la informaci?n de este correo ya que est? prohibido. Si usted no es el correcto destinatario, por favor inf?rmenos reenvi?ndonos el mismo con el asunto ?Direcci?n Incorrecta?, y luego borre el correo y los adjuntos. Stericycle, Inc. usa regularmente actualizaciones de software anti-virus para as? reducir posibles virus. De todas maneras, no garantizamos que los adjuntos est?n libres de virus. -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150205/29080d7e/attachment-0001.htm From hodgetf at auburn.edu Thu Feb 5 13:48:40 2015 From: hodgetf at auburn.edu (Thomas Hodges) Date: Thu Feb 5 13:49:21 2015 Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions In-Reply-To: References: <2FB366A29AAF0D47BD422C53F698353F2B0D29FA@COVMSGCES-MBX02> <4B5D22CD2328F442862E4FC8982A612044F18F5B@MAILQDC3.kc.kingcounty.lcl> Message-ID: <99689B6A37CE194BB8FB2A34901404819F20CB6D@exmb1> I am in wholehearted agreement. Thank you for the reminder to everyone. Tom H From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Gilliam, Allen Sent: Thursday, February 05, 2015 12:05 PM To: Shield, Margaret; DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions Thanks for the sad story Margaret, Not wishing to offend others' religious beliefs (and I'm no Bible totin or even Sunday Christian), but 1 Timothy 6:10 (New Living Translation [had to look it up]) says, "For the love of money is the root of all kinds of evil. And some people, craving money, have wandered from the true faith and pierced themselves with many sorrows." seems to be applying itself in mother earth's demise in so many facets of our environment. Absolutely NO offense intended to anyone, Allen g From: Shield, Margaret [mailto:Margaret.Shield@kingcounty.gov] Sent: Wednesday, February 04, 2015 5:51 PM To: Gilliam, Allen; DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions The Precautionary Principle is a strategy that must then be carried out in policies, laws, regulations. It's use by the EU has been under attack with renewed vigor. Here's one perspective on why: 25 August 2014 Chemical Industry using TTIP 'to attack the precautionary principle' Trade deal presents long-awaited opportunities for fresh assaults on regulation writes Axel Singhofen health and environment advisor Greens/EFA group Republished with the kind permission of Chemical Watch. CW. Global Business Briefing, July/August 2014 / Europe The last 12 months have seen a surge of attacks against the EU's precautionary principle. Some law firms consider it as a potential obstacle to the Transatlantic Trade and Investment Partnership (TTIP), and UK Conservative MEP Julie Girling considers that "the EU's expanding embrace of `precautionary' regulation... may well be the biggest threat" to an agreement being signed off. Last October, 12 CEOs of mainly chemical companies wrote to the presidents of the European Commission, Council and Parliament, calling for the formal adoption of an "innovation principle" as a counterbalance to "precautionary legislation", because they were concerned that "the necessary balance of precaution and proportion is increasingly being replaced by a simple reliance on the precautionary principle and the avoidance of technological risk. Some academics even conjure up a "precautionary impasse in Europe", claim an "apparent gap between evidence-based analysis and expert-informed recommendations, and policy decisions that can seem disconnected from both", and conclude there is "a necessity for change in light of the impracticability of a status quo that leads to scattered ill-thought out bans". Read more at.... http://www.ttip2014.eu/blog-detail/blog/precautionary%20principle%20TTIP.html Margaret Shield PhD, Policy Liaison Local Hazardous Waste Management Program in King County desk 206-477-6238 cell 206-265-9732 Local Governments for Health and the Environment - www.lhwmp.org From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Gilliam, Allen Sent: Wednesday, February 4, 2015 1:05 PM To: DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions Sounds like something that typically happens with our policy makers on the hill... Does anyone practice the Precautionary Principal anymore? And didn't I read the EU was decades ahead of the U.S. in its use? Allen g From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of DeBiasi, Deborah (DEQ) Sent: Wednesday, February 04, 2015 2:05 PM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions http://www.theguardian.com/environment/2015/feb/02/suppressed-eu-report-could-have-banned-pesticides-worth-billions 'Suppressed' EU report could have banned pesticides worth billions Science paper recommended ways of identifying hormone-mimicking chemicals in pesticides linked to foetal abnormalities, genital mutations, infertility and other diseases including cancer As many as 31 pesticides with a value running into billions of pounds could have been banned because of potential health risks, if a blocked EU paper on hormone-mimicking chemicals had been acted upon, the Guardian has learned. The science paper, seen by the Guardian, recommends ways of identifying and categorising the endocrine-disrupting chemicals (EDCs) that scientists link to a rise in foetal abnormalities, genital mutations, infertility, and adverse health effects ranging from cancer to IQ loss. Commission sources say that the paper was buried by top EU officials under pressure from big chemical firms which use EDCs in toiletries, plastics and cosmetics, despite an annual health cost that studies peg at hundreds of millions of euros. (Long article - read the rest at the site above) Deborah L. DeBiasi Email: Deborah.DeBiasi@deq.virginia.gov WEB site address: www.deq.virginia.gov Virginia Department of Environmental Quality Office of Water Permits Industrial Pretreatment/Whole Effluent Toxicity (WET) Program PPCPs, EDCs, and Microconstituents http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDischargeElimination/Microconstituents.aspx Mail: P.O. Box 1105, Richmond, VA 23218 Location: 629 E. Main Street, Richmond, VA 23219 PH: 804-698-4028 FAX: 804-698-4032 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150205/348134f9/attachment.htm From jmullowney at pharma-cycle.com Thu Feb 5 15:02:46 2015 From: jmullowney at pharma-cycle.com (Jim Mullowney) Date: Thu Feb 5 14:58:41 2015 Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions In-Reply-To: <99689B6A37CE194BB8FB2A34901404819F20CB6D@exmb1> References: <2FB366A29AAF0D47BD422C53F698353F2B0D29FA@COVMSGCES-MBX02> <4B5D22CD2328F442862E4FC8982A612044F18F5B@MAILQDC3.kc.kingcounty.lcl> <99689B6A37CE194BB8FB2A34901404819F20CB6D@exmb1> Message-ID: <00fa01d0417e$b60aa4e0$221feea0$@pharma-cycle.com> This post reminded me of a publication from 2010 from our friend Christian Daughton. Drugs are Chemicals Too. A perspective regarding drug lethality can be gained by comparison with pesticide toxicities. Lethal doses in humans for pesticides are often rated on a scale where the two most lethal groups have LD50's of less than 1 mg/kg (extremely toxic) and 1-50 mg/kg (highly toxic). But keep in mind that these are two classes are no longer sold for home use; because of their extreme toxicity, they are available only for use by professionals. If we examine fentanyl (or a number of other drugs not uncommonly available in homes) (Daughton and Ruhoy 2009a), we see that they can be lethal to children in doses of mg/body - one or more orders more toxic than the most toxic pesticides. Given that the less-toxic pesticides used by consumers are rarely stored inside homes, the gross disparity in the way which these hazardous medicinal substances are treated is evident From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Thomas Hodges Sent: Thursday, February 05, 2015 1:49 PM To: Gilliam, Allen; Shield, Margaret; DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions I am in wholehearted agreement. Thank you for the reminder to everyone. Tom H From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Gilliam, Allen Sent: Thursday, February 05, 2015 12:05 PM To: Shield, Margaret; DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions Thanks for the sad story Margaret, Not wishing to offend others' religious beliefs (and I'm no Bible totin or even Sunday Christian), but 1 Timothy 6:10 (New Living Translation [had to look it up]) says, "For the love of money is the root of all kinds of evil. And some people, craving money, have wandered from the true faith and pierced themselves with many sorrows." seems to be applying itself in mother earth's demise in so many facets of our environment. Absolutely NO offense intended to anyone, Allen g From: Shield, Margaret [mailto:Margaret.Shield@kingcounty.gov] Sent: Wednesday, February 04, 2015 5:51 PM To: Gilliam, Allen; DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions The Precautionary Principle is a strategy that must then be carried out in policies, laws, regulations. It's use by the EU has been under attack with renewed vigor. Here's one perspective on why: 25 August 2014 Chemical Industry using TTIP 'to attack the precautionary principle' Trade deal presents long-awaited opportunities for fresh assaults on regulation writes Axel Singhofen health and environment advisor Greens/EFA group Republished with the kind permission of Chemical Watch. CW. Global Business Briefing, July/August 2014 / Europe The last 12 months have seen a surge of attacks against the EU's precautionary principle. Some law firms consider it as a potential obstacle to the Transatlantic Trade and Investment Partnership (TTIP), and UK Conservative MEP Julie Girling considers that "the EU's expanding embrace of `precautionary' regulation... may well be the biggest threat" to an agreement being signed off. Last October, 12 CEOs of mainly chemical companies wrote to the presidents of the European Commission, Council and Parliament, calling for the formal adoption of an "innovation principle" as a counterbalance to "precautionary legislation", because they were concerned that "the necessary balance of precaution and proportion is increasingly being replaced by a simple reliance on the precautionary principle and the avoidance of technological risk. Some academics even conjure up a "precautionary impasse in Europe", claim an "apparent gap between evidence-based analysis and expert-informed recommendations, and policy decisions that can seem disconnected from both", and conclude there is "a necessity for change in light of the impracticability of a status quo that leads to scattered ill-thought out bans". Read more at.. http://www.ttip2014.eu/blog-detail/blog/precautionary%20principle%20TTIP.htm l Margaret Shield PhD, Policy Liaison Local Hazardous Waste Management Program in King County desk 206-477-6238 cell 206-265-9732 Local Governments for Health and the Environment - www.lhwmp.org From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Gilliam, Allen Sent: Wednesday, February 4, 2015 1:05 PM To: DeBiasi, Deborah (DEQ); pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions Sounds like something that typically happens with our policy makers on the hill. Does anyone practice the Precautionary Principal anymore? And didn't I read the EU was decades ahead of the U.S. in its use? Allen g From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of DeBiasi, Deborah (DEQ) Sent: Wednesday, February 04, 2015 2:05 PM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] 'Suppressed' EU report could have banned pesticides worth billions http://www.theguardian.com/environment/2015/feb/02/suppressed-eu-report-coul d-have-banned-pesticides-worth-billions 'Suppressed' EU report could have banned pesticides worth billions Science paper recommended ways of identifying hormone-mimicking chemicals in pesticides linked to foetal abnormalities, genital mutations, infertility and other diseases including cancer As many as 31 pesticides with a value running into billions of pounds could have been banned because of potential health risks, if a blocked EU paper on hormone-mimicking chemicals had been acted upon, the Guardian has learned. The science paper, seen by the Guardian, recommends ways of identifying and categorising the endocrine-disrupting chemicals (EDCs) that scientists link to a rise in foetal abnormalities, genital mutations, infertility, and adverse health effects ranging from cancer to IQ loss. Commission sources say that the paper was buried by top EU officials under pressure from big chemical firms which use EDCs in toiletries, plastics and cosmetics, despite an annual health cost that studies peg at hundreds of millions of euros. (Long article - read the rest at the site above) Deborah L. DeBiasi Email: Deborah.DeBiasi@deq.virginia.gov WEB site address: www.deq.virginia.gov Virginia Department of Environmental Quality Office of Water Permits Industrial Pretreatment/Whole Effluent Toxicity (WET) Program PPCPs, EDCs, and Microconstituents http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDis chargeElimination/Microconstituents.aspx Mail: P.O. Box 1105, Richmond, VA 23218 Location: 629 E. Main Street, Richmond, VA 23219 PH: 804-698-4028 FAX: 804-698-4032 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150205/68562f28/attachment-0001.htm From Margaret.Shield at kingcounty.gov Thu Feb 5 20:03:19 2015 From: Margaret.Shield at kingcounty.gov (Shield, Margaret) Date: Thu Feb 5 20:03:51 2015 Subject: [Pharmwaste] Lewis County Sheriff's Successful Drug Drop Box Program, WA State Message-ID: <4B5D22CD2328F442862E4FC8982A612044F1BEB4@MAILQDC3.kc.kingcounty.lcl> Hi all, I'm pleased to share one success story of many from WA State's local medicine take-back collection sites. Please see the attached media release for details about the Lewis County Sheriff's medicine take-back program, celebrating four years of safe drug disposal. The media release includes collection totals for each year from five drop box locations. Lewis County, WA has a population of roughly 75,000. See more info about Lewis County here: http://lewiscountywa.gov/ [cid:image003.jpg@01D04162.E3656D60] Photo: Sheriff Rob Snaza (left) and Undersheriff Wes Rethwill (right) near the Drug Drop Box in the Law and Justice Center. Congratulations to Sheriff Rob Snaza, Undersheriff Wes Rethwill, Chief Deputy Stacy Brown and everyone at the Lewis County Sheriff's Office for this great community service. Thanks also to Mark Bronson, HHW Coordinator with Lewis County Solid Waste Utility. A great team in Lewis County! Margaret Shield PhD, Policy Liaison Local Hazardous Waste Management Program in King County desk 206-477-6238 cell 206-265-9732 Local Governments for Health and the Environment - www.lhwmp.org -------------- next part -------------- An HTML attachment was scrubbed... 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Name: 01-27-14 LCSO Drug Drop Box Success.pdf Type: application/pdf Size: 535624 bytes Desc: 01-27-14 LCSO Drug Drop Box Success.pdf Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150206/9c4f22f7/01-27-14LCSODrugDropBoxSuccess-0001.pdf From James.Laurenson at fda.hhs.gov Fri Feb 6 11:17:02 2015 From: James.Laurenson at fda.hhs.gov (Laurenson, James) Date: Fri Feb 6 11:17:58 2015 Subject: [Pharmwaste] Lewis County Sheriff's Successful Drug Drop Box Program, WA State In-Reply-To: <4B5D22CD2328F442862E4FC8982A612044F1BEB4@MAILQDC3.kc.kingcounty.lcl> References: <4B5D22CD2328F442862E4FC8982A612044F1BEB4@MAILQDC3.kc.kingcounty.lcl> Message-ID: <8C393F82878AD64AAA267CD0CCE4F49D459770F6@FDSWP3318.fda.gov> That is good news. Here's another that just came out, "Safe way to dispose of medications spreading in N.J.," http://www.pressofatlanticcity.com/news/breaking/safe-way-to-dispose-of-medications-spreading-in-n-j/article_4113b3d4-abf0-11e4-8e61-03595d48ac0e.html Jim Jim Laurenson Environmental Officer Center for Drug Evaluation & Research U.S. Food & Drug Administration 10903 New Hampshire Ave., Bldg. 21, Rm. 1626 Silver Spring, MD 20993 301-796-4872 (office) 703-342-9496 (cell) james.laurenson@fda.hhs.gov From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Shield, Margaret Sent: Thursday, February 05, 2015 8:03 PM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Lewis County Sheriff's Successful Drug Drop Box Program, WA State Hi all, I'm pleased to share one success story of many from WA State's local medicine take-back collection sites. Please see the attached media release for details about the Lewis County Sheriff's medicine take-back program, celebrating four years of safe drug disposal. The media release includes collection totals for each year from five drop box locations. Lewis County, WA has a population of roughly 75,000. See more info about Lewis County here: http://lewiscountywa.gov/ [cid:image001.jpg@01D041FE.6C809890] Photo: Sheriff Rob Snaza (left) and Undersheriff Wes Rethwill (right) near the Drug Drop Box in the Law and Justice Center. Congratulations to Sheriff Rob Snaza, Undersheriff Wes Rethwill, Chief Deputy Stacy Brown and everyone at the Lewis County Sheriff's Office for this great community service. Thanks also to Mark Bronson, HHW Coordinator with Lewis County Solid Waste Utility. A great team in Lewis County! Margaret Shield PhD, Policy Liaison Local Hazardous Waste Management Program in King County desk 206-477-6238 cell 206-265-9732 Local Governments for Health and the Environment - www.lhwmp.org -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150206/84b09e44/attachment.htm -------------- next part -------------- A non-text attachment was scrubbed... Name: image001.jpg Type: image/jpeg Size: 19812 bytes Desc: image001.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150206/84b09e44/image001.jpg From jennifer.volkman at state.mn.us Fri Feb 6 17:48:11 2015 From: jennifer.volkman at state.mn.us (Volkman, Jennifer (MPCA)) Date: Fri Feb 6 17:46:37 2015 Subject: [Pharmwaste] RE: Pharmacies in 3 States Can't Take Back Controlled In-Reply-To: <65AC0C9A3A6A474EAD8D56070FED66983E6419EC@MAIL.cityofithaca.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E6419EC@MAIL.cityofithaca.org> Message-ID: Everyone who works with take backs should talk with their Board of Pharmacy to see what is allowed. Most BoP statutes prohibit possession of ALL legend pharms (not just the controlled substance portion), to the person to whom they are prescribed. Like DEA, their regulations didn't address take backs because there was no such thing. Pharmacists can possess the stock and distribute, I suppose nurses can possess for the purpose of dispensing, but pharmacists can't possess what has been sold. HW transporters can't possess, WTE's can't possess. You can't possess on behalf of anyone other than your pet or child under 18. Although most state's statutes restrict both the possession of pharms and sharps to the person to whom they are prescribed, they have exercised enforcement discretion for waste haulers who dispose of them. We worked with our BoP to revise their statutes several years ago to allow law enforcement, permitted waste management facilities and licensed transporters to possess legend drugs for the purpose of participating in a waste pharm collection program operated in compliance with rules, regs, ordinances...It also allowed for "people" to possess legend pharms for the purpose of disposal at a registered collection site. Now the Board is revising the statutes again to add in pharmacists and to take out "people", since DEA and many local ordinances don't allow possession of CS by anyone other than the person they are prescribed to. We asked the Board if they would do a similar fix for sharps at the same time, but they are concerned it could bollix things up at the legislature. They plan to do it next year. Meantime, they will continue not to enforce possession limitations for sharps. I think our BoP has about 10 staff, if that. They cover a lot of territory. They've been awesome to work with, I hope that yours are great partners too! JV From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 05, 2015 10:08 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Pharmacies in 3 States Can't Take Back Controlled I didn't remember that during the Office of National Drug Control Policy (ONDCP) webinar we were told that state board of pharmacy rules did not allow controlled substances to be taken back in Georgia, Oklahoma and Hawaii. I wrote to the National Association of Boards of Pharmacy to get this and related information. My email and their reply are below. Ed Dear Mr. Gottlieb, Thank you for contacting the National Association of Boards of Pharmacy(r) (NABP(r)). NABP is the independent, international, and impartial association that assists its member boards and jurisdictions for the purpose of protecting the public health. NABP does not have any regulatory or interpretive authority over its member boards. Since the DEA Final Rule on Disposal of Controlled Substances is a new federal regulation, unfortunately; the majority of the states that have not previously prohibited community pharmacies from taking back controlled substances are still silent on the issue and are in the process of reviewing their existing statutes and regulations. Until new laws/regulations are enacted or it is addressed through policy interpretation, we do not have new information to share. NABP is following this issue and we are staying vigilant on the matter. We will inform our member boards and the public through our website as more information becomes available. In the meantime, according to the Office of National Drug Control Policy (ONDCP) webinar, the following states may not permit pharmacies to take back controlled substances: Georgia, Oklahoma and Hawaii. Respectfully, Professional Affairs Hello, It is my understanding that the existing rules (and recommendations?) of many state boards of pharmacy are in conflict with the new DEA rule allowing pharmacies to take back controlled substances. If my understanding is correct, do you know which states need to make changes to be in-line with this DEA rule? Can you please provide me with details? Has, or will, your organization be encouraging members to make the changes necessary to allow pharmacies to participate in controlled take back? If you have, may I please see a copy of what you did? If you haven't, please consider doing so. Though it is possible that not many pharmacies will participate in this voluntary, unfunded opportunity, it would be unfortunate if those that wanted to provide this important public service were unable to do so because some state boards of pharmacy's failed to act. Thanks for your assistance and consideration. Sincerely, 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150206/729ea690/attachment.htm From EGottlieb at cityofithaca.org Mon Feb 9 08:49:43 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Mon Feb 9 08:50:08 2015 Subject: [Pharmwaste] Hospital Discharge Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E641EE6@MAIL.cityofithaca.org> A fellow wastewater pretreatment coordinator from Ohio just posted this to the pretreatment Listserv. Anyone have advice that I can pass along? Thanks! We have been requested to accept the periodic discharge of controlled substances by a local hospital. The specific request is for morphine, lorazepam and Phenobarbital. I have a few questions. Has anyone else received a similar request? What was your response? What should be my concerns? 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150209/11654b9c/attachment.html From Jeanie.Jaramillo at ttuhsc.edu Mon Feb 9 13:17:23 2015 From: Jeanie.Jaramillo at ttuhsc.edu (Jaramillo, Jeanie) Date: Mon Feb 9 15:50:42 2015 Subject: [Pharmwaste] FW: American Pharmacists Association promoting a government funded program with voluntary pharmacy participation In-Reply-To: <24D2A3DBD4377240A1B613A8B5293DBD1F479E6A@MBX029-E1-VA-8.EXCH029.DOMAIN.LOCAL> References: <24D2A3DBD4377240A1B613A8B5293DBD1F479E6A@MBX029-E1-VA-8.EXCH029.DOMAIN.LOCAL> Message-ID: <89794C5282FE3149A068A7A5111C0DB088ED6D67@LUBMB02.ttuhsc.edu> From: cpsc-pharmaceuticals-listserv@googlegroups.com [mailto:cpsc-pharmaceuticals-listserv@googlegroups.com] On Behalf Of Heidi Sanborn Sent: Monday, February 09, 2015 10:54 AM To: CPSC Pharmaceutical Listserv (cpsc-pharmaceuticals-listserv@googlegroups.com) Subject: American Pharmacists Association promoting a government funded program with voluntary pharmacy participation American Pharmacists Association: https://www.pharmacist.com/who-should-pay-take-back-programs-pharmacies Who should pay for take-back programs in pharmacies? Share This Page Share on facebook Share on twitter Share on linkedin Share on email Share on print February 06, 2015 State associations weigh in Advertisement Now that pharmacies have the authority to collect unwanted or unused medications from patients through drug take-back programs, some states are grappling with who should be paying for the maintenance and disposal of collection receptacles that would reside in pharmacies. One California county issued an ordinance putting the cost on drug manufacturers. But when the pharmaceutical industry challenged the ordinance last year, it was rejected by a federal appeals court. Costs a concern Costs are especially a concern for some states that are considering legislation mandating take-back programs in pharmacies, and state pharmacy organizations don?t want pharmacies to be held responsible. In January, a New Mexico state senator filed a bill that would require the state board of pharmacy to establish a take-back program in community pharmacies to collect unused or unwanted medications from consumers. Dale Tinker, Executive Director of the New Mexico Pharmacists Association, said they are concerned about what is expected to be an unfunded mandate. ?No one disagrees that there needs to be ways to safely dispose of medications. But how are pharmacists going to manage a take-back program and pay for it?? he told Pharmacy Today. Take-back programs are currently voluntary in New Mexico, and no pharmacies so far have receptacles onsite, according to Tinker. But some pharmacies provide consumers with envelopes for the option of mailing in unused or unwanted prescription medications, which Tinker thinks is a more reasonable approach since the medication goes directly to a certified incineration location. The state of New Jersey also has legislation pending; as presently written, it would be an unfunded mandate requiring community and hospital pharmacies to install take-back receptacles. Elise Barry, CEO of the New Jersey Pharmacists Association, said they are pleased to be working with legislative staff on the issue, but have concerns about the legislation. First, there are both installation and removal costs for take-back programs. For a monthly fee, a certified service must take away the contents for safe disposal. There?s also paperwork involved. Many pharmacists are concerned about security as well. ?An individual could place inappropriate or hazardous materials in the receptacle and you [the pharmacist] are not able to open the dropbox,? Barry told Today. The Tennessee Pharmacists Association (TPA) is taking a proactive approach by working with members of Congress to draft legislation that complements recent regulatory changes from the Tennessee Board of Pharmacy allowing pharmacists to participate in take-back programs. ?The proposed legislation establishes that a pharmacy?s participation in drug disposal programs would be voluntary, authorizes the pharmacist-in-charge to make the final determination regarding the pharmacy?s participation, and adds certain protections from liability for pharmacists participating in drug disposal programs,? Micah Cost, PharmD, Executive Director of TPA, told Today. Alternative approaches Legislation shaping up in California would not require pharmacies to participate in take-back programs?but if they do, it would put the cost of the program as a small fee or tax on all consumer and business sanitation district bills. Jon Roth, CAE, CEO of the California Pharmacists Association (CPhA), said CPhA is not sponsoring the legislation but has been informed about it from the bill sponsor?s office. Other states have dealt with the issue of cost in other ways. According to Joni Cover, JD, Executive Director of the Nebraska Pharmacists Association, Nebraska has been part of a statewide drug disposal project that pays for Sharps boxes?which house only noncontrolled substances?for any pharmacy in Nebraska that wants to participate, and at no cost to the pharmacy. ?We are asking the Nebraska legislature for a 2-year funding appropriation beginning in 2016 for a continuation of the grant, which would provide free containers for the pharmacies for both controlled and noncontrolled substances,? said Cover. Since 2009, Iowa has had a drug disposal program funded by the state, first through an Iowa Department of Natural Resources grant and then more recently from the Iowa Board of Pharmacy. ?The legislature, the board, and IPA [Iowa Pharmacists Association] all see this model as a good one for the public and the profession,? said Kate Gainer, PharmD, Executive Vice President and CEO of IPA. Loren Bonner, MA, Reporter -- --- You received this message because you are subscribed to the Google Groups "CPSC Pharmaceuticals Stewardship Bill Listserv" group. To unsubscribe from this group and stop receiving emails from it, send an email to cpsc-pharmaceuticals-listserv+unsubscribe@googlegroups.com. For more options, visit https://groups.google.com/d/optout. -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150209/73af02e7/attachment.htm From Copeland.Stephen at epa.gov Tue Feb 10 10:19:06 2015 From: Copeland.Stephen at epa.gov (Copeland, Stephen) Date: Tue Feb 10 10:19:36 2015 Subject: [Pharmwaste] RE: Pharmwaste Digest, Vol 112, Issue 11 In-Reply-To: <20150210085814.8CD821111E6@lists.dep.state.fl.us> References: <20150210085814.8CD821111E6@lists.dep.state.fl.us> Message-ID: I Stephen G. Copeland NPDES Permits Branch (3WP41) Water Protection Division 1650 Arch Street Philadelphia, PA 19103-2029 (215) 814-5792 e-mail:- copeland.stephen@epa.gov -----Original Message----- From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of pharmwaste-request@lists.dep.state.fl.us Sent: Tuesday, February 10, 2015 3:58 AM To: pharmwaste@lists.dep.state.fl.us Subject: Pharmwaste Digest, Vol 112, Issue 11 Send Pharmwaste mailing list submissions to pharmwaste@lists.dep.state.fl.us To subscribe or unsubscribe via the World Wide Web, visit http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste or, via email, send a message with subject or body 'help' to pharmwaste-request@lists.dep.state.fl.us You can reach the person managing the list at pharmwaste-owner@lists.dep.state.fl.us When replying, please edit your Subject line so it is more specific than "Re: Contents of Pharmwaste digest..." Today's Topics: 1. Hospital Discharge (Ed Gottlieb) ---------------------------------------------------------------------- Message: 1 Date: Mon, 9 Feb 2015 13:49:43 +0000 From: Ed Gottlieb Subject: [Pharmwaste] Hospital Discharge To: "pharmwaste@lists.dep.state.fl.us" Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E641EE6@MAIL.cityofithaca.org> Content-Type: text/plain; charset="iso-8859-1" A fellow wastewater pretreatment coordinator from Ohio just posted this to the pretreatment Listserv. Anyone have advice that I can pass along? Thanks! We have been requested to accept the periodic discharge of controlled substances by a local hospital. The specific request is for morphine, lorazepam and Phenobarbital. I have a few questions. Has anyone else received a similar request? What was your response? What should be my concerns? 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150209/11654b9c/attachment-0001.html ------------------------------ --- Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients. --- TO SUBSCRIBE, go to: http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe@lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank. If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste FOR PROBLEMS: Contact List Administrator Laurie.Tenace@dep.state.fl.us SEND MAIL to the list server at: pharmwaste@lists.dep.state.fl.us End of Pharmwaste Digest, Vol 112, Issue 11 ******************************************* From Copeland.Stephen at epa.gov Tue Feb 10 10:33:06 2015 From: Copeland.Stephen at epa.gov (Copeland, Stephen) Date: Tue Feb 10 10:33:22 2015 Subject: [Pharmwaste] RE: Pharmwaste Digest, Vol 112, Issue 11 In-Reply-To: <20150210085814.8CD821111E6@lists.dep.state.fl.us> References: <20150210085814.8CD821111E6@lists.dep.state.fl.us> Message-ID: The first thing you should do is check with the DEA. Controlled substances are usually not allowed to be discharged. Stephen G. Copeland NPDES Permits Branch (3WP41) Water Protection Division 1650 Arch Street Philadelphia, PA 19103-2029 , or (215) 814-5792 e-mail:- copeland.stephen@epa.gov -----Original Message----- From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of pharmwaste-request@lists.dep.state.fl.us Sent: Tuesday, February 10, 2015 3:58 AMwould To: pharmwaste@lists.dep.state.fl.us Subject: Pharmwaste Digest, Vol 112, Issue 11 Send Pharmwaste mailing list submissions to pharmwaste@lists.dep.state.fl.us To subscribe or unsubscribe via the World Wide Web, visit http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste or, via email, send a message with subject or body 'help' to pharmwaste-request@lists.dep.state.fl.us You can reach the person managing the list at pharmwaste-owner@lists.dep.state.fl.us When replying, please edit your Subject line so it is more specific than "Re: Contents of Pharmwaste digest..." Today's Topics: 1. Hospital Discharge (Ed Gottlieb) ---------------------------------------------------------------------- Message: 1 Date: Mon, 9 Feb 2015 13:49:43 +0000 From: Ed Gottlieb Subject: [Pharmwaste] Hospital Discharge To: "pharmwaste@lists.dep.state.fl.us" Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E641EE6@MAIL.cityofithaca.org> Content-Type: text/plain; charset="iso-8859-1" A fellow wastewater pretreatment coordinator from Ohio just posted this to the pretreatment Listserv. Anyone have advice that I can pass along? Thanks! We have been requested to accept the periodic discharge of controlled substances by a local hospital. The specific request is for morphine, lorazepam and Phenobarbital. I have a few questions. Has anyone else received a similar request? What was your response? What should be my concerns? 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150209/11654b9c/attachment-0001.html ------------------------------ --- Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients. --- TO SUBSCRIBE, go to: http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe@lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank. If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste FOR PROBLEMS: Contact List Administrator Laurie.Tenace@dep.state.fl.us SEND MAIL to the list server at: pharmwaste@lists.dep.state.fl.us End of Pharmwaste Digest, Vol 112, Issue 11 ******************************************* From Deborah.DeBiasi at deq.virginia.gov Tue Feb 10 17:33:40 2015 From: Deborah.DeBiasi at deq.virginia.gov (DeBiasi, Deborah (DEQ)) Date: Tue Feb 10 17:37:59 2015 Subject: [Pharmwaste] USGS Man-made Pollutants Finding Their Way Into Groundwater Through Septic Systems Message-ID: <2FB366A29AAF0D47BD422C53F698353F2B0D435A@COVMSGCES-MBX02> ________________________________ Man-made Pollutants Finding Their Way Into Groundwater Through Septic Systems Posted: 10 Feb 2015 06:43 AM PST Summary: Pharmaceuticals, hormones and personal care products associated with everyday household activities are finding their way into groundwater through septic systems in New York and New England, according to the U.S. Geological Survey ________________________________ Contact Information: Patrick J. Phillips ( Phone: 518-285-5667 ); Irene J. Fisher ( Phone: 631-736-0783x117 ); Hannah Hamilton ( Phone: 703-648-4356 ); ________________________________ TROY, NY. -- Pharmaceuticals, hormones and personal care products associated with everyday household activities are finding their way into groundwater through septic systems in New York and New England, according to the U.S. Geological Survey. "Septic systems nationwide are receiving increased attention as environmental sources of chemical contamination," said USGS scientist Patrick Phillips, lead author of the study published in the journal Science of the Total Environment. Two different well networks were studied, one in New England and the other in New York, looking for micropollutants in groundwater samples collected downgradient of septic systems. "Downgradient" is the term used for how groundwater flows under the ground, and is a similar term to "downstream" when describing surface water. The scientists tested for items such as pharmaceuticals, personal care products, and plasticizer compounds (which make things more flexible). "High nitrate concentrations in groundwater samples downgradient of septic systems in both these regions led us to investigate what other chemicals might also be present," said Phillips. Septic systems are common in areas lacking connection to larger scale sewage treatment, such as a sewer. Septic systems consist of holding tank (usually below ground) where raw sewage collects and separates into a sludge (solid) and liquid effluent. The liquid effluent either leaches directly into the surrounding soil or goes into a leach field for final treatment by the soil. The liquid effluent from septic systems ultimately moves into the groundwater. Septic systems have been identified as the source of a variety of micropollutants in groundwater. In New York, groundwater samples were collected from a barrier island with a dense (5 dwellings/acre) summer population. These New York septic systems have minimal treatment of wastewater before mixing with shallow groundwater that moves towards a large, sensitive estuary where a decline in fisheries and shellfish along with a higher ratio of female-to-male fish have been reported. Shallow groundwater samples collected along the beach of this estuary downgradient of the septic systems were found to have hormones; detergent degradation products; galaxolide, a fragrance found in various products; insect repellent; sunscreen additives; floor cleaner; and two pharmaceuticals (lidocaine, a local anesthetic; and carbamazepine, an anti-convulsant and mood stabilizing drug). In New England, groundwater samples were collected from below a septic system leachbed serving an elderly-care 65-bed nursing home and from wells downgradient of this leachbed. Numerous prescription pharmaceuticals were found in the groundwater samples, such as anesthetics; a muscle relaxant; an antifungal; an antiepileptic; an antibiotic; a sleep aid; and also a floor cleaner. Natural groundwater flow in this area could transport these contaminants toward areas used for a drinking water supply. Results from both groundwater networks indicate that septic systems are sources for a variety of micropollutants to groundwater and surface water that potentially affect environmental ecosystems and even drinking water. Land-use, in particular, is one of the deciding factors that control the type of contaminants entering the groundwater system. This study found that monitoring for micropollutants, such as pharmaceuticals, hormones, and personal care products in areas experiencing high nitrogen levels was important to understanding the breadth of contaminants present in groundwater and surface-water resources. This study also presents some of the first results from a new pharmaceutical method developed by the USGS National Water Quality Laboratory that determines more than 100 pharmaceuticals, pharmaceutical degradates and related contaminants. This method is highly sensitive, with method detection limits for many compounds in the low nanogram-per-liter range, and significantly advances the abilities of the USGS to assess the presence and concentrations of pharmaceuticals in the environment. The paper, "Concentrations of hormones, pharmaceuticals and other micropollutants in groundwater affected by septic systems in New England and New York" has been published in Science of the Total Environment To learn more about USGS environmental health science, please visit the USGS Environmental Health website and sign up for our GeoHealth Newsletter. Deborah L. DeBiasi Email: Deborah.DeBiasi@deq.virginia.gov WEB site address: www.deq.virginia.gov Virginia Department of Environmental Quality Office of Water Permits Industrial Pretreatment/Whole Effluent Toxicity (WET) Program PPCPs, EDCs, and Microconstituents http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDischargeElimination/Microconstituents.aspx Mail: P.O. Box 1105, Richmond, VA 23218 Location: 629 E. Main Street, Richmond, VA 23219 PH: 804-698-4028 FAX: 804-698-4032 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150210/379ab9e5/attachment.htm From EGottlieb at cityofithaca.org Thu Feb 12 09:01:07 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Thu Feb 12 09:02:32 2015 Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E6452D2@MAIL.cityofithaca.org> Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to-funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/0aa7aa00/attachment.html From EGottlieb at cityofithaca.org Thu Feb 12 10:14:53 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Thu Feb 12 10:16:17 2015 Subject: [Pharmwaste] Feb 27 Supreme Court Conference Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E6453A3@MAIL.cityofithaca.org> Posted on the Supreme Court Website yesterday: Feb 11 2015 DISTRIBUTED for Conference of February 27, 2015. I take this to mean that during their February 27 Conference, the Justices will discuss, and possibly vote on, if they will hear the appeal (both the Petition for a writ of certiorari and the two motions for leave to file amici brief) later in this years session (or possibly in next years session?) or, if they will let the lower court ruling stand. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/ed126c3e/attachment.htm From Amy.Tiemeier at stlcop.edu Thu Feb 12 10:43:27 2015 From: Amy.Tiemeier at stlcop.edu (Tiemeier, Amy) Date: Thu Feb 12 10:44:43 2015 Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? In-Reply-To: <65AC0C9A3A6A474EAD8D56070FED66983E6452D2@MAIL.cityofithaca.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E6452D2@MAIL.cityofithaca.org> Message-ID: <63D1A0176CC2FE48AB7A99254EAB9A2FB1CC018670@STLXOPMX08.stlcop.local> Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit (www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice [cid:image001.jpg@01D046A8.5A6C9560] 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to-funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/aa8c5f1a/attachment.htm -------------- next part -------------- A non-text attachment was scrubbed... Name: image001.jpg Type: image/jpeg Size: 2662 bytes Desc: image001.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/aa8c5f1a/image001.jpg From EGottlieb at cityofithaca.org Thu Feb 12 11:33:24 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Thu Feb 12 11:33:38 2015 Subject: [Pharmwaste] Which States Can't Do Pharmacy Take Back? + US SC Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E6453FE@MAIL.cityofithaca.org> Thanks Amy! It sounds like multiple state agencies, including the Board of Pharmacy, need to change their rules to allow for pharmacy take back of controlled substances in MO. I wonder if the National Association of Boards of Pharmacy missed listing any other states? I also learned that here in New York, there is a Health Department rule that prohibits pharmacy take back. They are working to change it so that pharmacies can take advantage of the new DEA rule. I will try to get a time line from them ASAP. This leaves me with the question of how many other states have departments with rules that currently prevent pharmacy take back? Finally, a list serve member who is a lawyer was kind enough to send me this explanation of the process happening at the Supreme Court. A very brief explanation is that this means that the case has been distributed and the court is reviewing whether to consider taking the case. At this stage, the Court staff will prepare a memo which the justices will review with the filed papers to make a determination if they anyone wishes to discuss whether to hear the case or not. If no justice indicates they want to discuss the case, the Court will issue an order that the case will not be considered, and the writ denied. This could occur as early as the following week. If any justice decides they do want to consider hearing the case, the Court will ask for more information before they discuss it. If that is the case, the Court will issue an order, likely in March, that they want a full brief from the County before making a decision on whether hear the case. There are some other things that can occur, however, these two scenarios are the most likely. It is my understanding that if, after getting the full brief, three or more justices vote to hear the case it will be scheduled on their docket. 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: Tiemeier, Amy [Amy.Tiemeier@stlcop.edu] Sent: Thursday, February 12, 2015 10:43 AM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit (www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice [Description: EmailSignatureLogo] 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to-funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/b8429d6f/attachment.htm -------------- next part -------------- A non-text attachment was scrubbed... Name: image001.jpg Type: image/jpeg Size: 2662 bytes Desc: image001.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/b8429d6f/image001.jpg From GROSSMANC at michigan.gov Thu Feb 12 12:15:46 2015 From: GROSSMANC at michigan.gov (Grossman, Christine (DEQ)) Date: Thu Feb 12 12:18:12 2015 Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? In-Reply-To: <63D1A0176CC2FE48AB7A99254EAB9A2FB1CC018670@STLXOPMX08.stlcop.local> References: <65AC0C9A3A6A474EAD8D56070FED66983E6452D2@MAIL.cityofithaca.org> <63D1A0176CC2FE48AB7A99254EAB9A2FB1CC018670@STLXOPMX08.stlcop.local> Message-ID: The Michigan's Board of Pharmacy rules for utilization/disposal are found on-line at http://www7.dleg.state.mi.us/orr/Files/AdminCode/1263_2013-071LR_AdminCode.pdf. The Michigan solid waste regulations that would apply to household generated unwanted drugs collected at a pharmacy. Those are found under Part 115 of the Michigan Natural Resource and Environmental Protection Act. The solid waste provisions of this act were amended on 3/4/14 to formally authorize waste diversion centers to collect pharmaceuticals and divert them from landfills, along with other household hazardous wastes, so long as they were destined for and environmentally preferred management method. The waste diversion center operating requirements are found under Section 11524b of Part 115. We advocate the pharmaceuticals be incinerated to destroy the chemicals within the drugs, preventing them from entering our water. For non-household generated drugs, we have a tutorial, a pharmaceutical waste management guide, and a guide example posting to help health care navigate through the various regulations and select a management option that considers the waste handling requirements for the various wastes they generate. All of these resources and more on Michigan regulations can be found at www.michigan.gov/deqhealthcare under the Waste Health Care Resources Web link. Regards, Christine Grossman, Compliance Assistance Specialist Training and Outreach Unit, Office of Environmental Assistance, Michigan Department of Environmental Quality Direct Phone: 517-284-6860 Environmental Assistance Center: 1-800-662-9278 or deq-assist@michigan.gov [Follow us on Twitter] [cid:image004.gif@01CE6C2B.594AC930] From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Tiemeier, Amy Sent: Thursday, February 12, 2015 10:43 AM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit (www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice [Description: EmailSignatureLogo] 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to-funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/5c47b729/attachment.htm -------------- next part -------------- A non-text attachment was scrubbed... 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Name: image004.jpg Type: image/jpeg Size: 2662 bytes Desc: image004.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/5c47b729/image004.jpg From jennifer.volkman at state.mn.us Thu Feb 12 13:50:26 2015 From: jennifer.volkman at state.mn.us (Volkman, Jennifer (MPCA)) Date: Thu Feb 12 13:50:50 2015 Subject: [Pharmwaste] Board regs and pharmacy take back Message-ID: This is very similar to a message I wrote on this last week-just a note so you can skip it :) I think most Boards were waiting on DEA before they made changes to allow pharmacists to possess dispensed drugs for the purpose of operating take back programs. Ed, I don't know where you got your list of 3, but our Board and probably the vast majority of state Boards haven't updated their regulations. DEA's revisions came out in July, so now that our legislature is in session, our Board is bringing forward the statutory revisions needed to allow pharmacies to collect. It was simpler to wait because Boards can now make a very simple change related to possession and then cite DEA's regulations on how to operate the take back. Boards aren't actively trying to keep pharmacies from collecting (far as I know), their regulations simply didn't encompass the take back concept, same as DEA's did not. As long as regulatory revisions don't require pharmacies to collect, this modification should go relatively smoothly in any state. Most Boards do probably need advocates like Amy and Christine to work with them on drafting the changes. We regulate disposal and the law enforcement entities that collect now, so it made sense for us to help out our Board with the changes. I'd share our proposed language changes, but we have this weird statute: While most data created and held by executive branch agencies is presumed public, Minn. Stat. 13.605, Subd. 1, classifies legislative proposals that are created or maintained by "...any state agency that is under the direct control of the governor..." as being non-public. And someone decided the Board is under the direct control of the Governor when we asked about it sharing them. I can say that we kept it very simple. There are about 5 lines worth of changes allowing pharmacists, law enforcement, waste transporters and waste management facilities to possess pharms for the purpose of destruction and another line or two directing pharmacies to comply with DEA rules regarding operations. This is our second modification. We modified the statutes several years ago to allow for law enforcement possession of legend pharms, which is another thing most Board regulations didn't, and still probably don't, address. We are hopeful that this will go as smoothly as the first. Cheers, JV From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Grossman, Christine (DEQ) Sent: Thursday, February 12, 2015 11:16 AM To: Tiemeier, Amy; Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? The Michigan's Board of Pharmacy rules for utilization/disposal are found on-line at http://www7.dleg.state.mi.us/orr/Files/AdminCode/1263_2013-071LR_AdminCode.pdf. The Michigan solid waste regulations that would apply to household generated unwanted drugs collected at a pharmacy. Those are found under Part 115 of the Michigan Natural Resource and Environmental Protection Act. The solid waste provisions of this act were amended on 3/4/14 to formally authorize waste diversion centers to collect pharmaceuticals and divert them from landfills, along with other household hazardous wastes, so long as they were destined for and environmentally preferred management method. The waste diversion center operating requirements are found under Section 11524b of Part 115. We advocate the pharmaceuticals be incinerated to destroy the chemicals within the drugs, preventing them from entering our water. For non-household generated drugs, we have a tutorial, a pharmaceutical waste management guide, and a guide example posting to help health care navigate through the various regulations and select a management option that considers the waste handling requirements for the various wastes they generate. All of these resources and more on Michigan regulations can be found at www.michigan.gov/deqhealthcare under the Waste Health Care Resources Web link. Regards, Christine Grossman, Compliance Assistance Specialist Training and Outreach Unit, Office of Environmental Assistance, Michigan Department of Environmental Quality Direct Phone: 517-284-6860 Environmental Assistance Center: 1-800-662-9278 or deq-assist@michigan.gov [Follow us on Twitter] [cid:image004.gif@01CE6C2B.594AC930] From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Tiemeier, Amy Sent: Thursday, February 12, 2015 10:43 AM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit (www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice [Description: EmailSignatureLogo] 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to-funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/b796d347/attachment-0001.htm -------------- next part -------------- A non-text attachment was scrubbed... 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Name: image009.jpg Type: image/jpeg Size: 3204 bytes Desc: image009.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/b796d347/image009-0001.jpg From EGottlieb at cityofithaca.org Thu Feb 12 14:07:05 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Thu Feb 12 14:07:29 2015 Subject: [Pharmwaste] RE: Board regs and pharmacy take back In-Reply-To: References: Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E645469@MAIL.cityofithaca.org> JV, It was the National Association of Boards of Pharmacy that gave me the list of three states who had Board of Pharmacy rules that did not permit pharmacies from taking back controlled substances. Seems they missed a state, possibly many. I suspect your impression is correct and many more than three state boards of pharmacy, along with other state agencies, are working on changes to be in compliance with the new DEA rule. 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@lists.dep.state.fl.us [pharmwaste-bounces@lists.dep.state.fl.us] on behalf of Volkman, Jennifer (MPCA) [jennifer.volkman@state.mn.us] Sent: Thursday, February 12, 2015 1:50 PM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Board regs and pharmacy take back This is very similar to a message I wrote on this last week?just a note so you can skip it :) I think most Boards were waiting on DEA before they made changes to allow pharmacists to possess dispensed drugs for the purpose of operating take back programs. Ed, I don?t know where you got your list of 3, but our Board and probably the vast majority of state Boards haven?t updated their regulations. DEA?s revisions came out in July, so now that our legislature is in session, our Board is bringing forward the statutory revisions needed to allow pharmacies to collect. It was simpler to wait because Boards can now make a very simple change related to possession and then cite DEA?s regulations on how to operate the take back. Boards aren?t actively trying to keep pharmacies from collecting (far as I know), their regulations simply didn?t encompass the take back concept, same as DEA?s did not. As long as regulatory revisions don?t require pharmacies to collect, this modification should go relatively smoothly in any state. Most Boards do probably need advocates like Amy and Christine to work with them on drafting the changes. We regulate disposal and the law enforcement entities that collect now, so it made sense for us to help out our Board with the changes. I?d share our proposed language changes, but we have this weird statute: While most data created and held by executive branch agencies is presumed public, Minn. Stat. 13.605, Subd. 1, classifies legislative proposals that are created or maintained by ??any state agency that is under the direct control of the governor?? as being non-public. And someone decided the Board is under the direct control of the Governor when we asked about it sharing them. I can say that we kept it very simple. There are about 5 lines worth of changes allowing pharmacists, law enforcement, waste transporters and waste management facilities to possess pharms for the purpose of destruction and another line or two directing pharmacies to comply with DEA rules regarding operations. This is our second modification. We modified the statutes several years ago to allow for law enforcement possession of legend pharms, which is another thing most Board regulations didn?t, and still probably don?t, address. We are hopeful that this will go as smoothly as the first. Cheers, JV From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Grossman, Christine (DEQ) Sent: Thursday, February 12, 2015 11:16 AM To: Tiemeier, Amy; Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? The Michigan?s Board of Pharmacy rules for utilization/disposal are found on-line at http://www7.dleg.state.mi.us/orr/Files/AdminCode/1263_2013-071LR_AdminCode.pdf. The Michigan solid waste regulations that would apply to household generated unwanted drugs collected at a pharmacy. Those are found under Part 115 of the Michigan Natural Resource and Environmental Protection Act. The solid waste provisions of this act were amended on 3/4/14 to formally authorize waste diversion centers to collect pharmaceuticals and divert them from landfills, along with other household hazardous wastes, so long as they were destined for and environmentally preferred management method. The waste diversion center operating requirements are found under Section 11524b of Part 115. We advocate the pharmaceuticals be incinerated to destroy the chemicals within the drugs, preventing them from entering our water. For non-household generated drugs, we have a tutorial, a pharmaceutical waste management guide, and a guide example posting to help health care navigate through the various regulations and select a management option that considers the waste handling requirements for the various wastes they generate. All of these resources and more on Michigan regulations can be found at www.michigan.gov/deqhealthcare under the Waste Health Care Resources Web link. Regards, Christine Grossman, Compliance Assistance Specialist Training and Outreach Unit, Office of Environmental Assistance, Michigan Department of Environmental Quality Direct Phone: 517-284-6860 Environmental Assistance Center: 1-800-662-9278 or deq-assist@michigan.gov [Follow us on Twitter] [cid:image004.gif@01CE6C2B.594AC930] From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Tiemeier, Amy Sent: Thursday, February 12, 2015 10:43 AM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit (www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice [Description: EmailSignatureLogo] 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to-funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/04b1e4ff/attachment.htm -------------- next part -------------- A non-text attachment was scrubbed... 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Name: image009.jpg Type: image/jpeg Size: 3204 bytes Desc: image009.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/04b1e4ff/image009.jpg From jharris at sharpsinc.com Thu Feb 12 14:07:30 2015 From: jharris at sharpsinc.com (Jan Harris) Date: Thu Feb 12 14:08:23 2015 Subject: [Pharmwaste] Board regs and pharmacy take back In-Reply-To: References: Message-ID: Here at Sharps Compliance, we have contacted the individual state Boards as well as other applicable agencies and have found that approximately 27 states allow collection receptacles at this time. Lots of confusion and unclear interpretation still. Every state expresses eagerness to make the receptacle program available, but often just they need to make the necessary changes as has been discussed. Meanwhile, envelopes/mailbacks can certainly be used for ultimate user controls - typically for a small fee to the consumer though. Jan Jan Harris | Director, Environmental Health & Safety Sharps Compliance, Inc. d- 713-927-9956 jharris@sharpsinc.com | http://www.sharpsinc.com On Feb 12, 2015, at 12:51 PM, "Volkman, Jennifer (MPCA)" > wrote: This is very similar to a message I wrote on this last week?just a note so you can skip it ? I think most Boards were waiting on DEA before they made changes to allow pharmacists to possess dispensed drugs for the purpose of operating take back programs. Ed, I don?t know where you got your list of 3, but our Board and probably the vast majority of state Boards haven?t updated their regulations. DEA?s revisions came out in July, so now that our legislature is in session, our Board is bringing forward the statutory revisions needed to allow pharmacies to collect. It was simpler to wait because Boards can now make a very simple change related to possession and then cite DEA?s regulations on how to operate the take back. Boards aren?t actively trying to keep pharmacies from collecting (far as I know), their regulations simply didn?t encompass the take back concept, same as DEA?s did not. As long as regulatory revisions don?t require pharmacies to collect, this modification should go relatively smoothly in any state. Most Boards do probably need advocates like Amy and Christine to work with them on drafting the changes. We regulate disposal and the law enforcement entities that collect now, so it made sense for us to help out our Board with the changes. I?d share our proposed language changes, but we have this weird statute: While most data created and held by executive branch agencies is presumed public, Minn. Stat. 13.605, Subd. 1, classifies legislative proposals that are created or maintained by ??any state agency that is under the direct control of the governor?? as being non-public. And someone decided the Board is under the direct control of the Governor when we asked about it sharing them. I can say that we kept it very simple. There are about 5 lines worth of changes allowing pharmacists, law enforcement, waste transporters and waste management facilities to possess pharms for the purpose of destruction and another line or two directing pharmacies to comply with DEA rules regarding operations. This is our second modification. We modified the statutes several years ago to allow for law enforcement possession of legend pharms, which is another thing most Board regulations didn?t, and still probably don?t, address. We are hopeful that this will go as smoothly as the first. Cheers, JV From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Grossman, Christine (DEQ) Sent: Thursday, February 12, 2015 11:16 AM To: Tiemeier, Amy; Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? The Michigan?s Board of Pharmacy rules for utilization/disposal are found on-line at http://www7.dleg.state.mi.us/orr/Files/AdminCode/1263_2013-071LR_AdminCode.pdf. The Michigan solid waste regulations that would apply to household generated unwanted drugs collected at a pharmacy. Those are found under Part 115 of the Michigan Natural Resource and Environmental Protection Act. The solid waste provisions of this act were amended on 3/4/14 to formally authorize waste diversion centers to collect pharmaceuticals and divert them from landfills, along with other household hazardous wastes, so long as they were destined for and environmentally preferred management method. The waste diversion center operating requirements are found under Section 11524b of Part 115. We advocate the pharmaceuticals be incinerated to destroy the chemicals within the drugs, preventing them from entering our water. For non-household generated drugs, we have a tutorial, a pharmaceutical waste management guide, and a guide example posting to help health care navigate through the various regulations and select a management option that considers the waste handling requirements for the various wastes they generate. All of these resources and more on Michigan regulations can be found at www.michigan.gov/deqhealthcare under the Waste Health Care Resources Web link. Regards, Christine Grossman, Compliance Assistance Specialist Training and Outreach Unit, Office of Environmental Assistance, Michigan Department of Environmental Quality Direct Phone: 517-284-6860 Environmental Assistance Center: 1-800-662-9278 or deq-assist@michigan.gov From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Tiemeier, Amy Sent: Thursday, February 12, 2015 10:43 AM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit (www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to-funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 --- Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients. --- TO SUBSCRIBE, go to: http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe@lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank. If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste FOR PROBLEMS: Contact List Administrator Laurie.Tenace@dep.state.fl.us SEND MAIL to the list server at: pharmwaste@lists.dep.state.fl.us [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/20150212/34e3f90c/attachment-0001.htm -------------- next part -------------- A non-text attachment was scrubbed... Name: image007.jpg Type: image/jpeg Size: 854 bytes Desc: image007.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/34e3f90c/image007-0001.jpg -------------- next part -------------- A non-text attachment was scrubbed... Name: image008.png Type: image/png Size: 2462 bytes Desc: image008.png Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/34e3f90c/image008-0001.png -------------- next part -------------- A non-text attachment was scrubbed... Name: image009.jpg Type: image/jpeg Size: 3204 bytes Desc: image009.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/34e3f90c/image009-0001.jpg From Jeanie.Jaramillo at ttuhsc.edu Thu Feb 12 14:08:11 2015 From: Jeanie.Jaramillo at ttuhsc.edu (Jaramillo, Jeanie) Date: Thu Feb 12 14:08:52 2015 Subject: [Pharmwaste] Med Take Back and Pharmacies Message-ID: <89794C5282FE3149A068A7A5111C0DB088ED7F5D@LUBMB02.ttuhsc.edu> I see lots of discussion on med take back and pharmacies with some focus on laws needing to be changed for those states that currently prohibit pharmacies from taking back meds, or just controls. There are still some big issues that were not addressed by the DEA regs that most of you are aware of, but perhaps some are not. Drop boxes in pharmacies are a hazard. Pharmacies are being robbed every day across the country for medications; and at an increasing rate. Pharmacists have even lost their lives. This is occurring when people know that controlled substances are stored in locked vaults and that they are closely inventoried, and when there are security cameras rolling. Placing a drop box in a publicly accessible area is an added target, regardless of being bolted to the floor, one way accessible, etc. Not to mention that customers bringing meds for "deposit" make easy targets. Aside from being a target for theft and creating human targets for assault, these boxes are a chemical hazard. Ever wonder what will happen if a gas cloud begins emerging from one of these boxes? Evacuation will be necessary with a disruption to the entire pharmacy. Many meds are reactive and while one would hope people will leave items in their containers, many people do not trust to leave their information on the bottles. As a result, they will mix all their items together and then deposit them. I could tell stories about what we've seen brought to our take back events. Yes, clearly this is not going to be an everyday occurrence, but how often would this have to occur for it to be "significant"? And then there's the funding issue. The DEA was simply providing a stop gap measure from the time the Secure & Responsible Drug Disposal Act of 2010 was enacted until the time the new regs went into place that would "expand" disposal options. Unfortunately, it was not made clear to law enforcement agencies or really to anyone that was continually encouraged to participate and create drop boxes.. that the DEA was going to stop the program entirely. I think this info was there for those who wanted to dig for it, but DEA did not say to participating agencies, "we are only doing this until our regs come out and are enacted." So, now the response regarding why such a hugely successful program is being stopped cold turkey... there was never a budget to provide for the program to begin with. As with most all governmental agencies, funding is limited, sometimes bare bones - presumably, funding for med destruction for the DEA program had to be carved out of their operational budget. So, what's my point? The DEA is not in the drug disposal business. You know what? Neither are pharmacies. They are businesses. They exist to make money. Everything depends on the bottom line. They are "for profit". These are not charitable organizations. They are not a "community service." Why would the DEA or anyone else ever have expected them to voluntarily pay for med disposal boxes that take up floor space that could be used for profitable sales? Attach something that is required to be permanently affixed, or otherwise, non-movable - i.e. destructive to the structure to which its being attached? Then utilize a very specific, highly regulated system for collecting, storing, and disposing of items in the box? This requires money, people (more $), and time (more $). But yet, no funding is being provided. And who thought this would work? The rationale - it will bring customers to the pharmacy....? This is the same pharmacy where I wait in line for 30 minutes to pick up my meds. I don't think they are hurting for customers. But wait, law enforcement can still have boxes, right? Yep. And they all have money to spare! Let me see if their mission/vision includes drug disposal. So, who should fund med disposal? You'll hear at least two answers. 1) the consumer. Next time you go to the pharmacy, ask them if their med disposal mailers are selling like hotcakes. 2) the people who are making the most profit from selling the medications - yes, that would be the drug companies! If we look at other countries across the world, the drug companies DO pay for med disposal; and they don't make a big deal about it. But here in the US, the companies spend their money fighting this. In fact, I'd venture to guess that in the jurisdictions they've been battling with this, they've spent more on the battle than they would have if they'd just agreed to participate in stewardship of their own products. Where do you suppose they get the money to fight against these city ordinances, etc.? From sales of their meds. Take a look at their quarterly profit reports. Unfortunately, while this is all figured out, people will continue to be poisoned. Teens will continue to access med cabinets and abuse meds they find. And some people will get frustrated and flush or trash their unused meds, contributing to the demise of the environment whether it be miniscule or not. In my opinion, the DEA has simply passed the buck on down the line; the buck not really having been theirs in the first place. I say that, not in their defense, because I don't agree with all that they've done; but, being familiar with the government funding process, I think their options were limited. Jeanie Jaramillo, PharmD Managing Director, Texas Panhandle Poison Center Asst. Professor, Texas Tech UHSC School of Pharmacy Director, Medication Cleanout 1300 S. Coulter St., Suite 105 Amarillo, TX 79106 (office): (806)414-9299 (mobile): (806)376-0039 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/4ba7c2cd/attachment.htm From jharris at sharpsinc.com Thu Feb 12 14:28:17 2015 From: jharris at sharpsinc.com (Jan Harris) Date: Thu Feb 12 14:28:54 2015 Subject: [Pharmwaste] Med Take Back and Pharmacies In-Reply-To: <89794C5282FE3149A068A7A5111C0DB088ED7F5D@LUBMB02.ttuhsc.edu> References: <89794C5282FE3149A068A7A5111C0DB088ED7F5D@LUBMB02.ttuhsc.edu> Message-ID: <33FC6C56-8BB8-48B6-888E-BDE8E59574BC@sharpsinc.com> I certain hear your concerns Jeanie. However, several states' pharmacy associations have had take back programs/boxes for non-controls for years in their member pharmacies. We have had tens of thousands of pounds of drugs come back to our facility over the last 5 years with no incidents or chemical reactions. I agree it's a multifaceted issue with not a one-size fits all solution. I applaud all the work that has gone into the efforts of finding solutions by states, federal and private entities. There is no perfect solution, but we are closer to getting there. Thanks to everyone on this list who have helped with those efforts. Jan Jan Harris | Director, Environmental Health & Safety Sharps Compliance, Inc. d- 713-927-9956 jharris@sharpsinc.com | http://www.sharpsinc.com On Feb 12, 2015, at 1:11 PM, "Jaramillo, Jeanie" > wrote: I see lots of discussion on med take back and pharmacies with some focus on laws needing to be changed for those states that currently prohibit pharmacies from taking back meds, or just controls. There are still some big issues that were not addressed by the DEA regs that most of you are aware of, but perhaps some are not. Drop boxes in pharmacies are a hazard. Pharmacies are being robbed every day across the country for medications; and at an increasing rate. Pharmacists have even lost their lives. This is occurring when people know that controlled substances are stored in locked vaults and that they are closely inventoried, and when there are security cameras rolling. Placing a drop box in a publicly accessible area is an added target, regardless of being bolted to the floor, one way accessible, etc. Not to mention that customers bringing meds for ?deposit? make easy targets. Aside from being a target for theft and creating human targets for assault, these boxes are a chemical hazard. Ever wonder what will happen if a gas cloud begins emerging from one of these boxes? Evacuation will be necessary with a disruption to the entire pharmacy. Many meds are reactive and while one would hope people will leave items in their containers, many people do not trust to leave their information on the bottles. As a result, they will mix all their items together and then deposit them. I could tell stories about what we?ve seen brought to our take back events. Yes, clearly this is not going to be an everyday occurrence, but how often would this have to occur for it to be ?significant?? And then there?s the funding issue. The DEA was simply providing a stop gap measure from the time the Secure & Responsible Drug Disposal Act of 2010 was enacted until the time the new regs went into place that would ?expand? disposal options. Unfortunately, it was not made clear to law enforcement agencies or really to anyone that was continually encouraged to participate and create drop boxes.. that the DEA was going to stop the program entirely. I think this info was there for those who wanted to dig for it, but DEA did not say to participating agencies, ?we are only doing this until our regs come out and are enacted.? So, now the response regarding why such a hugely successful program is being stopped cold turkey? there was never a budget to provide for the program to begin with. As with most all governmental agencies, funding is limited, sometimes bare bones ? presumably, funding for med destruction for the DEA program had to be carved out of their operational budget. So, what?s my point? The DEA is not in the drug disposal business. You know what? Neither are pharmacies. They are businesses. They exist to make money. Everything depends on the bottom line. They are ?for profit?. These are not charitable organizations. They are not a ?community service.? Why would the DEA or anyone else ever have expected them to voluntarily pay for med disposal boxes that take up floor space that could be used for profitable sales? Attach something that is required to be permanently affixed, or otherwise, non-movable ? i.e. destructive to the structure to which its being attached? Then utilize a very specific, highly regulated system for collecting, storing, and disposing of items in the box? This requires money, people (more $), and time (more $). But yet, no funding is being provided. And who thought this would work? The rationale ? it will bring customers to the pharmacy?.? This is the same pharmacy where I wait in line for 30 minutes to pick up my meds. I don?t think they are hurting for customers. But wait, law enforcement can still have boxes, right? Yep. And they all have money to spare! Let me see if their mission/vision includes drug disposal. So, who should fund med disposal? You?ll hear at least two answers. 1) the consumer. Next time you go to the pharmacy, ask them if their med disposal mailers are selling like hotcakes. 2) the people who are making the most profit from selling the medications ? yes, that would be the drug companies! If we look at other countries across the world, the drug companies DO pay for med disposal; and they don?t make a big deal about it. But here in the US, the companies spend their money fighting this. In fact, I?d venture to guess that in the jurisdictions they?ve been battling with this, they?ve spent more on the battle than they would have if they?d just agreed to participate in stewardship of their own products. Where do you suppose they get the money to fight against these city ordinances, etc.? From sales of their meds. Take a look at their quarterly profit reports. Unfortunately, while this is all figured out, people will continue to be poisoned. Teens will continue to access med cabinets and abuse meds they find. And some people will get frustrated and flush or trash their unused meds, contributing to the demise of the environment whether it be miniscule or not. In my opinion, the DEA has simply passed the buck on down the line; the buck not really having been theirs in the first place. I say that, not in their defense, because I don?t agree with all that they?ve done; but, being familiar with the government funding process, I think their options were limited. Jeanie Jaramillo, PharmD Managing Director, Texas Panhandle Poison Center Asst. Professor, Texas Tech UHSC School of Pharmacy Director, Medication Cleanout 1300 S. Coulter St., Suite 105 Amarillo, TX 79106 (office): (806)414-9299 (mobile): (806)376-0039 --- Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients. --- TO SUBSCRIBE, go to: http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe@lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank. If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste FOR PROBLEMS: Contact List Administrator Laurie.Tenace@dep.state.fl.us SEND MAIL to the list server at: pharmwaste@lists.dep.state.fl.us [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/20150212/018cbb74/attachment.htm From jennifer.volkman at state.mn.us Thu Feb 12 14:29:38 2015 From: jennifer.volkman at state.mn.us (Volkman, Jennifer (MPCA)) Date: Thu Feb 12 14:30:37 2015 Subject: [Pharmwaste] RE: Med Take Back and Pharmacies In-Reply-To: <89794C5282FE3149A068A7A5111C0DB088ED7F5D@LUBMB02.ttuhsc.edu> References: <89794C5282FE3149A068A7A5111C0DB088ED7F5D@LUBMB02.ttuhsc.edu> Message-ID: I just gave you a standing ovation! I have only a slightly different view point... I don't agree that there is a significant chemical hazard or that it is likely that a cloud will emerge from a collection bin. I understand that many states have hoped pharmacies could collect because surveys say people need this convenience to make collection successful. I am fortunate to live in a state that has a lot of participation by law enforcement and we're still adding collection boxes across the state at their facilities, but that isn't the case everywhere. Now some states are losing those due to discontinuation of funding. We are also fortunate to have low cost WTE incineration available throughout our state. Pharmacies and manufacturers both make profits by selling drugs, I'd like to see them both involved in funding collection. The DEA is chasing the drug abuse issue and it costs them time and money to do so. They could certainly contribute more than updated regulations. We'll all be paying...the goal is the safest, most convenient, most economical collection system that keeps drugs off the streets and out of our water. From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Jaramillo, Jeanie Sent: Thursday, February 12, 2015 1:08 PM To: Pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Med Take Back and Pharmacies I see lots of discussion on med take back and pharmacies with some focus on laws needing to be changed for those states that currently prohibit pharmacies from taking back meds, or just controls. There are still some big issues that were not addressed by the DEA regs that most of you are aware of, but perhaps some are not. Drop boxes in pharmacies are a hazard. Pharmacies are being robbed every day across the country for medications; and at an increasing rate. Pharmacists have even lost their lives. This is occurring when people know that controlled substances are stored in locked vaults and that they are closely inventoried, and when there are security cameras rolling. Placing a drop box in a publicly accessible area is an added target, regardless of being bolted to the floor, one way accessible, etc. Not to mention that customers bringing meds for "deposit" make easy targets. Aside from being a target for theft and creating human targets for assault, these boxes are a chemical hazard. Ever wonder what will happen if a gas cloud begins emerging from one of these boxes? Evacuation will be necessary with a disruption to the entire pharmacy. Many meds are reactive and while one would hope people will leave items in their containers, many people do not trust to leave their information on the bottles. As a result, they will mix all their items together and then deposit them. I could tell stories about what we've seen brought to our take back events. Yes, clearly this is not going to be an everyday occurrence, but how often would this have to occur for it to be "significant"? And then there's the funding issue. The DEA was simply providing a stop gap measure from the time the Secure & Responsible Drug Disposal Act of 2010 was enacted until the time the new regs went into place that would "expand" disposal options. Unfortunately, it was not made clear to law enforcement agencies or really to anyone that was continually encouraged to participate and create drop boxes.. that the DEA was going to stop the program entirely. I think this info was there for those who wanted to dig for it, but DEA did not say to participating agencies, "we are only doing this until our regs come out and are enacted." So, now the response regarding why such a hugely successful program is being stopped cold turkey... there was never a budget to provide for the program to begin with. As with most all governmental agencies, funding is limited, sometimes bare bones - presumably, funding for med destruction for the DEA program had to be carved out of their operational budget. So, what's my point? The DEA is not in the drug disposal business. You know what? Neither are pharmacies. They are businesses. They exist to make money. Everything depends on the bottom line. They are "for profit". These are not charitable organizations. They are not a "community service." Why would the DEA or anyone else ever have expected them to voluntarily pay for med disposal boxes that take up floor space that could be used for profitable sales? Attach something that is required to be permanently affixed, or otherwise, non-movable - i.e. destructive to the structure to which its being attached? Then utilize a very specific, highly regulated system for collecting, storing, and disposing of items in the box? This requires money, people (more $), and time (more $). But yet, no funding is being provided. And who thought this would work? The rationale - it will bring customers to the pharmacy....? This is the same pharmacy where I wait in line for 30 minutes to pick up my meds. I don't think they are hurting for customers. But wait, law enforcement can still have boxes, right? Yep. And they all have money to spare! Let me see if their mission/vision includes drug disposal. So, who should fund med disposal? You'll hear at least two answers. 1) the consumer. Next time you go to the pharmacy, ask them if their med disposal mailers are selling like hotcakes. 2) the people who are making the most profit from selling the medications - yes, that would be the drug companies! If we look at other countries across the world, the drug companies DO pay for med disposal; and they don't make a big deal about it. But here in the US, the companies spend their money fighting this. In fact, I'd venture to guess that in the jurisdictions they've been battling with this, they've spent more on the battle than they would have if they'd just agreed to participate in stewardship of their own products. Where do you suppose they get the money to fight against these city ordinances, etc.? From sales of their meds. Take a look at their quarterly profit reports. Unfortunately, while this is all figured out, people will continue to be poisoned. Teens will continue to access med cabinets and abuse meds they find. And some people will get frustrated and flush or trash their unused meds, contributing to the demise of the environment whether it be miniscule or not. In my opinion, the DEA has simply passed the buck on down the line; the buck not really having been theirs in the first place. I say that, not in their defense, because I don't agree with all that they've done; but, being familiar with the government funding process, I think their options were limited. Jeanie Jaramillo, PharmD Managing Director, Texas Panhandle Poison Center Asst. Professor, Texas Tech UHSC School of Pharmacy Director, Medication Cleanout 1300 S. Coulter St., Suite 105 Amarillo, TX 79106 (office): (806)414-9299 (mobile): (806)376-0039 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/47c53650/attachment-0001.htm From barry at clean-fuels.net Thu Feb 12 18:34:29 2015 From: barry at clean-fuels.net (Barry Fernandez) Date: Thu Feb 12 18:31:46 2015 Subject: [Pharmwaste] RE: Med Take Back and Pharmacies In-Reply-To: References: <89794C5282FE3149A068A7A5111C0DB088ED7F5D@LUBMB02.ttuhsc.edu> Message-ID: <485718AEDB642D45AC78E2E1BCF737BE631E2F82@mbx023-e1-nj-2.exch023.domain.local> I agree with Jennifer. We consolidate between 90 to 100 tons of pharmaceuticals a year. Chemical incompatibility hasn't created any plumes of toxic clouds at our facility. I do agree that security and lack of funding is a deterrent for a pharmacy to put their business and personnel at risk, even for the greater good of the community. Holding pharmaceutical companies financially responsible sounds like a good idea on its face, as proposed by groups like Product Stewardship, however that's tantamount to corporate shakedown. Once you shake the money out of the tree, who do you get to administer the programs and regulate funding? Besides, not all pharmaceutical companies are gargantuan money trees, quite a few (the majority) are struggling small businesses. I believe that the responsibility ultimately falls to local governments. After all, the drugs left behind by my granddad upon his demise are a hazard to the local community, not the whole country. Therefore, I don't see it federally funded by DEA or other Fed agency. The best place for this waste stream to originate is through hospital pharmacies. They are more secure than brick-and-mortar retail pharmacies, they already have a fairly robust program for patient meds, and there's a hospital near you (well, most of you). To integrate the relatively small volume from a community take back would be seamless. To pay for it the city or county could grant a tax credit or some other concession for example. Of course, before any of it could even be contemplated, the DEA would have to come together with EPA and remove the barriers to compliance. Their respective Washington DC offices are literally less than one mile from each other. They could meet at the Starbucks half way and strike a deal before noon. Regards, Barry From: Volkman, Jennifer (MPCA) [mailto:jennifer.volkman@state.mn.us] Sent: Thursday, February 12, 2015 2:30 PM To: Pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] RE: Med Take Back and Pharmacies I just gave you a standing ovation! I have only a slightly different view point... I don't agree that there is a significant chemical hazard or that it is likely that a cloud will emerge from a collection bin. I understand that many states have hoped pharmacies could collect because surveys say people need this convenience to make collection successful. I am fortunate to live in a state that has a lot of participation by law enforcement and we're still adding collection boxes across the state at their facilities, but that isn't the case everywhere. Now some states are losing those due to discontinuation of funding. We are also fortunate to have low cost WTE incineration available throughout our state. Pharmacies and manufacturers both make profits by selling drugs, I'd like to see them both involved in funding collection. The DEA is chasing the drug abuse issue and it costs them time and money to do so. They could certainly contribute more than updated regulations. We'll all be paying...the goal is the safest, most convenient, most economical collection system that keeps drugs off the streets and out of our water. From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Jaramillo, Jeanie Sent: Thursday, February 12, 2015 1:08 PM To: Pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Med Take Back and Pharmacies I see lots of discussion on med take back and pharmacies with some focus on laws needing to be changed for those states that currently prohibit pharmacies from taking back meds, or just controls. There are still some big issues that were not addressed by the DEA regs that most of you are aware of, but perhaps some are not. Drop boxes in pharmacies are a hazard. Pharmacies are being robbed every day across the country for medications; and at an increasing rate. Pharmacists have even lost their lives. This is occurring when people know that controlled substances are stored in locked vaults and that they are closely inventoried, and when there are security cameras rolling. Placing a drop box in a publicly accessible area is an added target, regardless of being bolted to the floor, one way accessible, etc. Not to mention that customers bringing meds for "deposit" make easy targets. Aside from being a target for theft and creating human targets for assault, these boxes are a chemical hazard. Ever wonder what will happen if a gas cloud begins emerging from one of these boxes? Evacuation will be necessary with a disruption to the entire pharmacy. Many meds are reactive and while one would hope people will leave items in their containers, many people do not trust to leave their information on the bottles. As a result, they will mix all their items together and then deposit them. I could tell stories about what we've seen brought to our take back events. Yes, clearly this is not going to be an everyday occurrence, but how often would this have to occur for it to be "significant"? And then there's the funding issue. The DEA was simply providing a stop gap measure from the time the Secure & Responsible Drug Disposal Act of 2010 was enacted until the time the new regs went into place that would "expand" disposal options. Unfortunately, it was not made clear to law enforcement agencies or really to anyone that was continually encouraged to participate and create drop boxes.. that the DEA was going to stop the program entirely. I think this info was there for those who wanted to dig for it, but DEA did not say to participating agencies, "we are only doing this until our regs come out and are enacted." So, now the response regarding why such a hugely successful program is being stopped cold turkey... there was never a budget to provide for the program to begin with. As with most all governmental agencies, funding is limited, sometimes bare bones - presumably, funding for med destruction for the DEA program had to be carved out of their operational budget. So, what's my point? The DEA is not in the drug disposal business. You know what? Neither are pharmacies. They are businesses. They exist to make money. Everything depends on the bottom line. They are "for profit". These are not charitable organizations. They are not a "community service." Why would the DEA or anyone else ever have expected them to voluntarily pay for med disposal boxes that take up floor space that could be used for profitable sales? Attach something that is required to be permanently affixed, or otherwise, non-movable - i.e. destructive to the structure to which its being attached? Then utilize a very specific, highly regulated system for collecting, storing, and disposing of items in the box? This requires money, people (more $), and time (more $). But yet, no funding is being provided. And who thought this would work? The rationale - it will bring customers to the pharmacy....? This is the same pharmacy where I wait in line for 30 minutes to pick up my meds. I don't think they are hurting for customers. But wait, law enforcement can still have boxes, right? Yep. And they all have money to spare! Let me see if their mission/vision includes drug disposal. So, who should fund med disposal? You'll hear at least two answers. 1) the consumer. Next time you go to the pharmacy, ask them if their med disposal mailers are selling like hotcakes. 2) the people who are making the most profit from selling the medications - yes, that would be the drug companies! If we look at other countries across the world, the drug companies DO pay for med disposal; and they don't make a big deal about it. But here in the US, the companies spend their money fighting this. In fact, I'd venture to guess that in the jurisdictions they've been battling with this, they've spent more on the battle than they would have if they'd just agreed to participate in stewardship of their own products. Where do you suppose they get the money to fight against these city ordinances, etc.? From sales of their meds. Take a look at their quarterly profit reports. Unfortunately, while this is all figured out, people will continue to be poisoned. Teens will continue to access med cabinets and abuse meds they find. And some people will get frustrated and flush or trash their unused meds, contributing to the demise of the environment whether it be miniscule or not. In my opinion, the DEA has simply passed the buck on down the line; the buck not really having been theirs in the first place. I say that, not in their defense, because I don't agree with all that they've done; but, being familiar with the government funding process, I think their options were limited. Jeanie Jaramillo, PharmD Managing Director, Texas Panhandle Poison Center Asst. Professor, Texas Tech UHSC School of Pharmacy Director, Medication Cleanout 1300 S. Coulter St., Suite 105 Amarillo, TX 79106 (office): (806)414-9299 (mobile): (806)376-0039 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150212/f46a828d/attachment.htm From jennifer.volkman at state.mn.us Thu Feb 12 19:15:19 2015 From: jennifer.volkman at state.mn.us (Volkman, Jennifer (MPCA)) Date: Thu Feb 12 19:14:35 2015 Subject: [Pharmwaste] RE: Med Take Back and Pharmacies In-Reply-To: <485718AEDB642D45AC78E2E1BCF737BE631E2F82@mbx023-e1-nj-2.exch023.domain.local> References: <89794C5282FE3149A068A7A5111C0DB088ED7F5D@LUBMB02.ttuhsc.edu> <485718AEDB642D45AC78E2E1BCF737BE631E2F82@mbx023-e1-nj-2.exch023.domain.local> Message-ID: What! We only agree on incompatibility. :) Producers generating pills and spending millions to advertise, and government cleans up the waste generated. That is consistent with many economic models. Is this why government is always broke? Good discussion people. Lots of passion. From: Barry Fernandez [mailto:barry@clean-fuels.net] Sent: Thursday, February 12, 2015 5:34 PM To: Volkman, Jennifer (MPCA); Pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] RE: Med Take Back and Pharmacies I agree with Jennifer. We consolidate between 90 to 100 tons of pharmaceuticals a year. Chemical incompatibility hasn't created any plumes of toxic clouds at our facility. I do agree that security and lack of funding is a deterrent for a pharmacy to put their business and personnel at risk, even for the greater good of the community. Holding pharmaceutical companies financially responsible sounds like a good idea on its face, as proposed by groups like Product Stewardship, however that's tantamount to corporate shakedown. Once you shake the money out of the tree, who do you get to administer the programs and regulate funding? Besides, not all pharmaceutical companies are gargantuan money trees, quite a few (the majority) are struggling small businesses. I believe that the responsibility ultimately falls to local governments. After all, the drugs left behind by my granddad upon his demise are a hazard to the local community, not the whole country. Therefore, I don't see it federally funded by DEA or other Fed agency. The best place for this waste stream to originate is through hospital pharmacies. They are more secure than brick-and-mortar retail pharmacies, they already have a fairly robust program for patient meds, and there's a hospital near you (well, most of you). To integrate the relatively small volume from a community take back would be seamless. To pay for it the city or county could grant a tax credit or some other concession for example. Of course, before any of it could even be contemplated, the DEA would have to come together with EPA and remove the barriers to compliance. Their respective Washington DC offices are literally less than one mile from each other. They could meet at the Starbucks half way and strike a deal before noon. Regards, Barry From: Volkman, Jennifer (MPCA) [mailto:jennifer.volkman@state.mn.us] Sent: Thursday, February 12, 2015 2:30 PM To: Pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] RE: Med Take Back and Pharmacies I just gave you a standing ovation! I have only a slightly different view point... I don't agree that there is a significant chemical hazard or that it is likely that a cloud will emerge from a collection bin. I understand that many states have hoped pharmacies could collect because surveys say people need this convenience to make collection successful. I am fortunate to live in a state that has a lot of participation by law enforcement and we're still adding collection boxes across the state at their facilities, but that isn't the case everywhere. Now some states are losing those due to discontinuation of funding. We are also fortunate to have low cost WTE incineration available throughout our state. Pharmacies and manufacturers both make profits by selling drugs, I'd like to see them both involved in funding collection. The DEA is chasing the drug abuse issue and it costs them time and money to do so. They could certainly contribute more than updated regulations. We'll all be paying...the goal is the safest, most convenient, most economical collection system that keeps drugs off the streets and out of our water. From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Jaramillo, Jeanie Sent: Thursday, February 12, 2015 1:08 PM To: Pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Med Take Back and Pharmacies I see lots of discussion on med take back and pharmacies with some focus on laws needing to be changed for those states that currently prohibit pharmacies from taking back meds, or just controls. There are still some big issues that were not addressed by the DEA regs that most of you are aware of, but perhaps some are not. Drop boxes in pharmacies are a hazard. Pharmacies are being robbed every day across the country for medications; and at an increasing rate. Pharmacists have even lost their lives. This is occurring when people know that controlled substances are stored in locked vaults and that they are closely inventoried, and when there are security cameras rolling. Placing a drop box in a publicly accessible area is an added target, regardless of being bolted to the floor, one way accessible, etc. Not to mention that customers bringing meds for "deposit" make easy targets. Aside from being a target for theft and creating human targets for assault, these boxes are a chemical hazard. Ever wonder what will happen if a gas cloud begins emerging from one of these boxes? Evacuation will be necessary with a disruption to the entire pharmacy. Many meds are reactive and while one would hope people will leave items in their containers, many people do not trust to leave their information on the bottles. As a result, they will mix all their items together and then deposit them. I could tell stories about what we've seen brought to our take back events. Yes, clearly this is not going to be an everyday occurrence, but how often would this have to occur for it to be "significant"? And then there's the funding issue. The DEA was simply providing a stop gap measure from the time the Secure & Responsible Drug Disposal Act of 2010 was enacted until the time the new regs went into place that would "expand" disposal options. Unfortunately, it was not made clear to law enforcement agencies or really to anyone that was continually encouraged to participate and create drop boxes.. that the DEA was going to stop the program entirely. I think this info was there for those who wanted to dig for it, but DEA did not say to participating agencies, "we are only doing this until our regs come out and are enacted." So, now the response regarding why such a hugely successful program is being stopped cold turkey... there was never a budget to provide for the program to begin with. As with most all governmental agencies, funding is limited, sometimes bare bones - presumably, funding for med destruction for the DEA program had to be carved out of their operational budget. So, what's my point? The DEA is not in the drug disposal business. You know what? Neither are pharmacies. They are businesses. They exist to make money. Everything depends on the bottom line. They are "for profit". These are not charitable organizations. They are not a "community service." Why would the DEA or anyone else ever have expected them to voluntarily pay for med disposal boxes that take up floor space that could be used for profitable sales? Attach something that is required to be permanently affixed, or otherwise, non-movable - i.e. destructive to the structure to which its being attached? Then utilize a very specific, highly regulated system for collecting, storing, and disposing of items in the box? This requires money, people (more $), and time (more $). But yet, no funding is being provided. And who thought this would work? The rationale - it will bring customers to the pharmacy....? This is the same pharmacy where I wait in line for 30 minutes to pick up my meds. I don't think they are hurting for customers. But wait, law enforcement can still have boxes, right? Yep. And they all have money to spare! Let me see if their mission/vision includes drug disposal. So, who should fund med disposal? You'll hear at least two answers. 1) the consumer. Next time you go to the pharmacy, ask them if their med disposal mailers are selling like hotcakes. 2) the people who are making the most profit from selling the medications - yes, that would be the drug companies! If we look at other countries across the world, the drug companies DO pay for med disposal; and they don't make a big deal about it. But here in the US, the companies spend their money fighting this. In fact, I'd venture to guess that in the jurisdictions they've been battling with this, they've spent more on the battle than they would have if they'd just agreed to participate in stewardship of their own products. Where do you suppose they get the money to fight against these city ordinances, etc.? From sales of their meds. Take a look at their quarterly profit reports. Unfortunately, while this is all figured out, people will continue to be poisoned. Teens will continue to access med cabinets and abuse meds they find. And some people will get frustrated and flush or trash their unused meds, contributing to the demise of the environment whether it be miniscule or not. In my opinion, the DEA has simply passed the buck on down the line; the buck not really having been theirs in the first place. I say that, not in their defense, because I don't agree with all that they've done; but, being familiar with the government funding process, I think their options were limited. Jeanie Jaramillo, PharmD Managing Director, Texas Panhandle Poison Center Asst. Professor, Texas Tech UHSC School of Pharmacy Director, Medication Cleanout 1300 S. Coulter St., Suite 105 Amarillo, TX 79106 (office): (806)414-9299 (mobile): (806)376-0039 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150213/b6aa0632/attachment-0001.htm From barry at clean-fuels.net Thu Feb 12 21:01:29 2015 From: barry at clean-fuels.net (Barry Fernandez) Date: Thu Feb 12 21:01:42 2015 Subject: [Pharmwaste] RE: Med Take Back and Pharmacies In-Reply-To: References: <89794C5282FE3149A068A7A5111C0DB088ED7F5D@LUBMB02.ttuhsc.edu> <485718AEDB642D45AC78E2E1BCF737BE631E2F82@mbx023-e1-nj-2.exch023.domain.local> Message-ID: <0BA1D1B5-85E7-492D-A5FD-485FF338DB82@clean-fuels.net> I'm far outnumbered on this Listserv to debate why government is always broke, lol. Government doesn't pay for anything, taxpayers do. If you tax producers keep in mind that corporations don't pay taxes, consumers do. Taxpayers and consumers are one and the same. That said, the million dollar ad campaigns aren't for fentanyl, methadone or dilaudid which is what we're really talking about here. My concern with producer funding is who gets the money? Who exactly decides how much goes where? There's as much potential for the diversion of money, and for that reason I believe it should be a locally funded program administered by and through hospitals. The mechanisms and processes are already in place. Barry On Feb 12, 2015, at 7:15 PM, Volkman, Jennifer (MPCA) > wrote: What! We only agree on incompatibility. ? Producers generating pills and spending millions to advertise, and government cleans up the waste generated. That is consistent with many economic models. Is this why government is always broke? Good discussion people. Lots of passion. From: Barry Fernandez [mailto:barry@clean-fuels.net] Sent: Thursday, February 12, 2015 5:34 PM To: Volkman, Jennifer (MPCA); Pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] RE: Med Take Back and Pharmacies I agree with Jennifer. We consolidate between 90 to 100 tons of pharmaceuticals a year. Chemical incompatibility hasn?t created any plumes of toxic clouds at our facility. I do agree that security and lack of funding is a deterrent for a pharmacy to put their business and personnel at risk, even for the greater good of the community. Holding pharmaceutical companies financially responsible sounds like a good idea on its face, as proposed by groups like Product Stewardship, however that?s tantamount to corporate shakedown. Once you shake the money out of the tree, who do you get to administer the programs and regulate funding? Besides, not all pharmaceutical companies are gargantuan money trees, quite a few (the majority) are struggling small businesses. I believe that the responsibility ultimately falls to local governments. After all, the drugs left behind by my granddad upon his demise are a hazard to the local community, not the whole country. Therefore, I don?t see it federally funded by DEA or other Fed agency. The best place for this waste stream to originate is through hospital pharmacies. They are more secure than brick-and-mortar retail pharmacies, they already have a fairly robust program for patient meds, and there?s a hospital near you (well, most of you). To integrate the relatively small volume from a community take back would be seamless. To pay for it the city or county could grant a tax credit or some other concession for example. Of course, before any of it could even be contemplated, the DEA would have to come together with EPA and remove the barriers to compliance. Their respective Washington DC offices are literally less than one mile from each other. They could meet at the Starbucks half way and strike a deal before noon. Regards, Barry From: Volkman, Jennifer (MPCA) [mailto:jennifer.volkman@state.mn.us] Sent: Thursday, February 12, 2015 2:30 PM To: Pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] RE: Med Take Back and Pharmacies I just gave you a standing ovation! I have only a slightly different view point? I don?t agree that there is a significant chemical hazard or that it is likely that a cloud will emerge from a collection bin. I understand that many states have hoped pharmacies could collect because surveys say people need this convenience to make collection successful. I am fortunate to live in a state that has a lot of participation by law enforcement and we?re still adding collection boxes across the state at their facilities, but that isn?t the case everywhere. Now some states are losing those due to discontinuation of funding. We are also fortunate to have low cost WTE incineration available throughout our state. Pharmacies and manufacturers both make profits by selling drugs, I?d like to see them both involved in funding collection. The DEA is chasing the drug abuse issue and it costs them time and money to do so. They could certainly contribute more than updated regulations. We?ll all be paying?the goal is the safest, most convenient, most economical collection system that keeps drugs off the streets and out of our water. From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Jaramillo, Jeanie Sent: Thursday, February 12, 2015 1:08 PM To: Pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Med Take Back and Pharmacies I see lots of discussion on med take back and pharmacies with some focus on laws needing to be changed for those states that currently prohibit pharmacies from taking back meds, or just controls. There are still some big issues that were not addressed by the DEA regs that most of you are aware of, but perhaps some are not. Drop boxes in pharmacies are a hazard. Pharmacies are being robbed every day across the country for medications; and at an increasing rate. Pharmacists have even lost their lives. This is occurring when people know that controlled substances are stored in locked vaults and that they are closely inventoried, and when there are security cameras rolling. Placing a drop box in a publicly accessible area is an added target, regardless of being bolted to the floor, one way accessible, etc. Not to mention that customers bringing meds for ?deposit? make easy targets. Aside from being a target for theft and creating human targets for assault, these boxes are a chemical hazard. Ever wonder what will happen if a gas cloud begins emerging from one of these boxes? Evacuation will be necessary with a disruption to the entire pharmacy. Many meds are reactive and while one would hope people will leave items in their containers, many people do not trust to leave their information on the bottles. As a result, they will mix all their items together and then deposit them. I could tell stories about what we?ve seen brought to our take back events. Yes, clearly this is not going to be an everyday occurrence, but how often would this have to occur for it to be ?significant?? And then there?s the funding issue. The DEA was simply providing a stop gap measure from the time the Secure & Responsible Drug Disposal Act of 2010 was enacted until the time the new regs went into place that would ?expand? disposal options. Unfortunately, it was not made clear to law enforcement agencies or really to anyone that was continually encouraged to participate and create drop boxes.. that the DEA was going to stop the program entirely. I think this info was there for those who wanted to dig for it, but DEA did not say to participating agencies, ?we are only doing this until our regs come out and are enacted.? So, now the response regarding why such a hugely successful program is being stopped cold turkey? there was never a budget to provide for the program to begin with. As with most all governmental agencies, funding is limited, sometimes bare bones ? presumably, funding for med destruction for the DEA program had to be carved out of their operational budget. So, what?s my point? The DEA is not in the drug disposal business. You know what? Neither are pharmacies. They are businesses. They exist to make money. Everything depends on the bottom line. They are ?for profit?. These are not charitable organizations. They are not a ?community service.? Why would the DEA or anyone else ever have expected them to voluntarily pay for med disposal boxes that take up floor space that could be used for profitable sales? Attach something that is required to be permanently affixed, or otherwise, non-movable ? i.e. destructive to the structure to which its being attached? Then utilize a very specific, highly regulated system for collecting, storing, and disposing of items in the box? This requires money, people (more $), and time (more $). But yet, no funding is being provided. And who thought this would work? The rationale ? it will bring customers to the pharmacy?.? This is the same pharmacy where I wait in line for 30 minutes to pick up my meds. I don?t think they are hurting for customers. But wait, law enforcement can still have boxes, right? Yep. And they all have money to spare! Let me see if their mission/vision includes drug disposal. So, who should fund med disposal? You?ll hear at least two answers. 1) the consumer. Next time you go to the pharmacy, ask them if their med disposal mailers are selling like hotcakes. 2) the people who are making the most profit from selling the medications ? yes, that would be the drug companies! If we look at other countries across the world, the drug companies DO pay for med disposal; and they don?t make a big deal about it. But here in the US, the companies spend their money fighting this. In fact, I?d venture to guess that in the jurisdictions they?ve been battling with this, they?ve spent more on the battle than they would have if they?d just agreed to participate in stewardship of their own products. Where do you suppose they get the money to fight against these city ordinances, etc.? From sales of their meds. Take a look at their quarterly profit reports. Unfortunately, while this is all figured out, people will continue to be poisoned. Teens will continue to access med cabinets and abuse meds they find. And some people will get frustrated and flush or trash their unused meds, contributing to the demise of the environment whether it be miniscule or not. In my opinion, the DEA has simply passed the buck on down the line; the buck not really having been theirs in the first place. I say that, not in their defense, because I don?t agree with all that they?ve done; but, being familiar with the government funding process, I think their options were limited. Jeanie Jaramillo, PharmD Managing Director, Texas Panhandle Poison Center Asst. Professor, Texas Tech UHSC School of Pharmacy Director, Medication Cleanout 1300 S. Coulter St., Suite 105 Amarillo, TX 79106 (office): (806)414-9299 (mobile): (806)376-0039 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150213/e7c6f558/attachment.htm From NDBoPh at btinet.net Fri Feb 13 08:44:47 2015 From: NDBoPh at btinet.net (Howard Anderson) Date: Fri Feb 13 08:46:14 2015 Subject: [Pharmwaste] Which States Can't Do Pharmacy Take Back? + US SC In-Reply-To: <65AC0C9A3A6A474EAD8D56070FED66983E6453FE@MAIL.cityofithaca.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E6453FE@MAIL.cityofithaca.org> Message-ID: <000d01d04793$3d12ef00$b738cd00$@btinet.net> Hello Everyone: May I suggest that we focus on success stories, instead of the three states that need changes. Focusing on success stories has proven to be the best way to move ideas forward. Even those of us who have allowed takebacks from the beginning still need a lot of help to make them affordable and get them into every pharmacy who wants to participate. Sincerely, Howard Howard C. Anderson, Jr.,R.Ph. Retired and Now Treasurer/Chief Compliance Officer North Dakota Board of Pharmacy 1906 E. Broadway Ave. P.O. Box 1354 Bismarck, ND 58502-1354 Phone (701) 328-9535 Fax (701) 328-9536 Web site www.nodakpharmacy.com From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 10:33 AM To: Tiemeier, Amy; pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Which States Can't Do Pharmacy Take Back? + US SC Thanks Amy! It sounds like multiple state agencies, including the Board of Pharmacy, need to change their rules to allow for pharmacy take back of controlled substances in MO. I wonder if the National Association of Boards of Pharmacy missed listing any other states? I also learned that here in New York, there is a Health Department rule that prohibits pharmacy take back. They are working to change it so that pharmacies can take advantage of the new DEA rule. I will try to get a time line from them ASAP. This leaves me with the question of how many other states have departments with rules that currently prevent pharmacy take back? Finally, a list serve member who is a lawyer was kind enough to send me this explanation of the process happening at the Supreme Court. A very brief explanation is that this means that the case has been distributed and the court is reviewing whether to consider taking the case. At this stage, the Court staff will prepare a memo which the justices will review with the filed papers to make a determination if they anyone wishes to discuss whether to hear the case or not. If no justice indicates they want to discuss the case, the Court will issue an order that the case will not be considered, and the writ denied. This could occur as early as the following week. If any justice decides they do want to consider hearing the case, the Court will ask for more information before they discuss it. If that is the case, the Court will issue an order, likely in March, that they want a full brief from the County before making a decision on whether hear the case. There are some other things that can occur, however, these two scenarios are the most likely. It is my understanding that if, after getting the full brief, three or more justices vote to hear the case it will be scheduled on their docket. 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: Tiemeier, Amy [Amy.Tiemeier@stlcop.edu] Sent: Thursday, February 12, 2015 10:43 AM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit ( www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to- funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150213/7c8c52ae/attachment.html -------------- next part -------------- A non-text attachment was scrubbed... Name: not available Type: image/jpeg Size: 2662 bytes Desc: not available Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150213/7c8c52ae/attachment-0001.jpeg From jharris at sharpsinc.com Fri Feb 13 09:42:38 2015 From: jharris at sharpsinc.com (Jan Harris) Date: Fri Feb 13 09:46:03 2015 Subject: [Pharmwaste] Which States Can't Do Pharmacy Take Back? + US SC In-Reply-To: <000d01d04793$3d12ef00$b738cd00$@btinet.net> References: <65AC0C9A3A6A474EAD8D56070FED66983E6453FE@MAIL.cityofithaca.org>, <000d01d04793$3d12ef00$b738cd00$@btinet.net> Message-ID: <9CE954F4-EB11-4185-BDD6-9B8219011659@sharpsinc.com> A success story: http://m.ksl.com/index/story/sid/33453402?mobile_direct=y Jan Harris | Director, Environmental Health & Safety Sharps Compliance, Inc. d- 713-927-9956 jharris@sharpsinc.com | http://www.sharpsinc.com On Feb 13, 2015, at 7:47 AM, "Howard Anderson" > wrote: Hello Everyone: May I suggest that we focus on success stories, instead of the three states that need changes. Focusing on success stories has proven to be the best way to move ideas forward. Even those of us who have allowed takebacks from the beginning still need a lot of help to make them affordable and get them into every pharmacy who wants to participate. Sincerely, Howard Howard C. Anderson, Jr.,R.Ph. Retired and Now Treasurer/Chief Compliance Officer North Dakota Board of Pharmacy 1906 E. Broadway Ave. P.O. Box 1354 Bismarck, ND 58502-1354 Phone (701) 328-9535 Fax (701) 328-9536 Web site www.nodakpharmacy.com From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 10:33 AM To: Tiemeier, Amy; pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Which States Can't Do Pharmacy Take Back? + US SC Thanks Amy! It sounds like multiple state agencies, including the Board of Pharmacy, need to change their rules to allow for pharmacy take back of controlled substances in MO. I wonder if the National Association of Boards of Pharmacy missed listing any other states? I also learned that here in New York, there is a Health Department rule that prohibits pharmacy take back. They are working to change it so that pharmacies can take advantage of the new DEA rule. I will try to get a time line from them ASAP. This leaves me with the question of how many other states have departments with rules that currently prevent pharmacy take back? Finally, a list serve member who is a lawyer was kind enough to send me this explanation of the process happening at the Supreme Court. A very brief explanation is that this means that the case has been distributed and the court is reviewing whether to consider taking the case. At this stage, the Court staff will prepare a memo which the justices will review with the filed papers to make a determination if they anyone wishes to discuss whether to hear the case or not. If no justice indicates they want to discuss the case, the Court will issue an order that the case will not be considered, and the writ denied. This could occur as early as the following week. If any justice decides they do want to consider hearing the case, the Court will ask for more information before they discuss it. If that is the case, the Court will issue an order, likely in March, that they want a full brief from the County before making a decision on whether hear the case. There are some other things that can occur, however, these two scenarios are the most likely. It is my understanding that if, after getting the full brief, three or more justices vote to hear the case it will be scheduled on their docket. 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: Tiemeier, Amy [Amy.Tiemeier@stlcop.edu] Sent: Thursday, February 12, 2015 10:43 AM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit (www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to-funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 --- Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients. --- TO SUBSCRIBE, go to: http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe@lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank. If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste FOR PROBLEMS: Contact List Administrator Laurie.Tenace@dep.state.fl.us SEND MAIL to the list server at: pharmwaste@lists.dep.state.fl.us [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/20150213/85b75185/attachment.htm -------------- next part -------------- A non-text attachment was scrubbed... Name: image001.jpg Type: image/jpeg Size: 2662 bytes Desc: image001.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150213/85b75185/image001.jpg From James.Laurenson at fda.hhs.gov Fri Feb 13 09:55:56 2015 From: James.Laurenson at fda.hhs.gov (Laurenson, James) Date: Fri Feb 13 09:56:32 2015 Subject: [Pharmwaste] Which States Can't Do Pharmacy Take Back? + US SC In-Reply-To: <9CE954F4-EB11-4185-BDD6-9B8219011659@sharpsinc.com> References: <65AC0C9A3A6A474EAD8D56070FED66983E6453FE@MAIL.cityofithaca.org>, <000d01d04793$3d12ef00$b738cd00$@btinet.net> <9CE954F4-EB11-4185-BDD6-9B8219011659@sharpsinc.com> Message-ID: <8C393F82878AD64AAA267CD0CCE4F49D45978860@FDSWP3318.fda.gov> Here?s another success, also hot off the presses, http://patch.com/new-york/westhampton-hamptonbays/decs-first-long-island-take-back-day-healthcare-facilities-success (pasted in below), though this isn?t at pharmacies, but rather at healthcare facilities, which supports the hosptial idea on the related thread. Jim James Laurenson Toxicologist/Environmental Officer Center for Drug Evaluation & Research U.S. Food & Drug Administration 10903 New Hampshire Ave. Silver Spring, MD 20993 301-796-4872 james.laurenson@fda.hhs.gov DEC's First Long Island Take Back Day For Healthcare Facilities a Success The department collected over 52 boxes of medication. By Priscila Korb (Patch Staff) February 12, 2015 at 1:50pm The New York State Department of Environmental Conservation (DEC) Commissioner Joe Martens announced recently that the DEC collected over 52 boxes of pharmaceutical medications during the first DEC Long Island Pharmaceutical Take Back Day at healthcare facilities. Twenty-five long-term healthcare facilities throughout Nassau and Suffolk counties participated in the program, including at the Westhampton Beach Police Department and the Southampton Town Police Department, which collects and responsibly destroys unused or expired pharmaceuticals. ?Health care facilities can produce large amounts of expired or unused medications and many have few options for disposal,? Martens said. ?The success of this collection by DEC is a positive step that will help to protect the environment by preventing medications from entering waterways. We are grateful to all the facilities that enthusiastically agreed to participate in this event.? DEC received funding through the Environmental Fund for $150,000 to expand the program, which already exists in the New York City Watershed. The program is designed to reduce the amount of pharmaceuticals that are ?flushed? by facilities and can end up in Long Island?s groundwater, bays and estuaries. Pharmaceuticals have been detected at low levels in New York State waterways and Long Island?s shallow groundwater. ?We are thrilled that DEC was able to provide this critical service, which benefits all Long Islanders and goes a long way toward protecting Long Island?s drinking and surface waters from pharmaceutical contaminants,? Adrienne Esposito, Executive Director of Citizens Campaign for the Environment said. ?Giving health care facilities a safe and convenient pharmaceutical disposal option has already reduced the number of institutions flushing unused medications, and now participation in this program needs to be expanded and strengthened in the future.? Participating facilities, made up primarily of nursing, extended care and rehabilitation centers, began storing unused and expired medications in October when they were first contacted by DEC. Environmental Conservation Officers (ECOs) then visited each of the 25 facilities this week to collect the stored medications and brought them to the Covanta Waste-to-Energy Plant in Westbury, which volunteered its services to incinerate the products. Prescription drug take back efforts began in the last few years, but before that, the normal disposal practice was to flush unwanted drugs. With technological advances in analytical techniques, it is now possible to detect very low levels of drugs in surface water and groundwater. Some drugs pass largely unaltered through wastewater treatment plants and enter rivers and other waterways. Drugs from heath care facilities, pharmaceutical manufacturing facilities and farms can also find their way into the water. Flushed medications have been found in New York lakes, rivers and streams which can negatively affect the waterways. A nationwide study done in 1999 and 2000 by the United States Geological Survey (USGS) found low levels of drugs such as antibiotics, hormones, contraceptives and steroids in 80 percent of rivers and streams tested. Medications adversely affect fish and other aquatic wildlife and increase the development of drug-resistant bacteria. For more information on where you can dispose of unused or expired medications, visit DEC?s website at http://www.dec.ny.gov/chemical/63826.html#Long_Island. From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Jan Harris Sent: Friday, February 13, 2015 9:43 AM To: Howard Anderson Cc: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us; Tiemeier, Amy Subject: Re: [Pharmwaste] Which States Can't Do Pharmacy Take Back? + US SC A success story: http://m.ksl.com/index/story/sid/33453402?mobile_direct=y Jan Harris | Director, Environmental Health & Safety Sharps Compliance, Inc. d- 713-927-9956 jharris@sharpsinc.com | http://www.sharpsinc.com On Feb 13, 2015, at 7:47 AM, "Howard Anderson" > wrote: Hello Everyone: May I suggest that we focus on success stories, instead of the three states that need changes. Focusing on success stories has proven to be the best way to move ideas forward. Even those of us who have allowed takebacks from the beginning still need a lot of help to make them affordable and get them into every pharmacy who wants to participate. Sincerely, Howard Howard C. Anderson, Jr.,R.Ph. Retired and Now Treasurer/Chief Compliance Officer North Dakota Board of Pharmacy 1906 E. Broadway Ave. P.O. Box 1354 Bismarck, ND 58502-1354 Phone (701) 328-9535 Fax (701) 328-9536 Web site www.nodakpharmacy.com From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 10:33 AM To: Tiemeier, Amy; pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Which States Can't Do Pharmacy Take Back? + US SC Thanks Amy! It sounds like multiple state agencies, including the Board of Pharmacy, need to change their rules to allow for pharmacy take back of controlled substances in MO. I wonder if the National Association of Boards of Pharmacy missed listing any other states? I also learned that here in New York, there is a Health Department rule that prohibits pharmacy take back. They are working to change it so that pharmacies can take advantage of the new DEA rule. I will try to get a time line from them ASAP. This leaves me with the question of how many other states have departments with rules that currently prevent pharmacy take back? Finally, a list serve member who is a lawyer was kind enough to send me this explanation of the process happening at the Supreme Court. A very brief explanation is that this means that the case has been distributed and the court is reviewing whether to consider taking the case. At this stage, the Court staff will prepare a memo which the justices will review with the filed papers to make a determination if they anyone wishes to discuss whether to hear the case or not. If no justice indicates they want to discuss the case, the Court will issue an order that the case will not be considered, and the writ denied. This could occur as early as the following week. If any justice decides they do want to consider hearing the case, the Court will ask for more information before they discuss it. If that is the case, the Court will issue an order, likely in March, that they want a full brief from the County before making a decision on whether hear the case. There are some other things that can occur, however, these two scenarios are the most likely. It is my understanding that if, after getting the full brief, three or more justices vote to hear the case it will be scheduled on their docket. 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: Tiemeier, Amy [Amy.Tiemeier@stlcop.edu] Sent: Thursday, February 12, 2015 10:43 AM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit (www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to-funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 --- Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients. --- TO SUBSCRIBE, go to: http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to pharmwaste-unsubscribe@lists.dep.state.fl.us -- the subject line and body of the e-mail should be blank. If you believe you may be subscribed with a different email address, please visit the subscriber listing at http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste FOR PROBLEMS: Contact List Administrator Laurie.Tenace@dep.state.fl.us SEND MAIL to the list server at: pharmwaste@lists.dep.state.fl.us [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/20150213/90959901/attachment-0001.htm From Deborah.DeBiasi at deq.virginia.gov Fri Feb 13 14:38:13 2015 From: Deborah.DeBiasi at deq.virginia.gov (DeBiasi, Deborah (DEQ)) Date: Fri Feb 13 14:34:43 2015 Subject: [Pharmwaste] Covanta's Rx4Safety program - Free incineration of collected drugs at 22 plants in 12 states Message-ID: <2FB366A29AAF0D47BD422C53F698353F2B0D5288@COVMSGCES-MBX02> In Virginia, this program works really well. The responsible person for managing the drug collection fills out a form for Covanta to have on file. When a delivery is planned, notify Covanta that you (law enforcement or someone authorized to transport controlled substances) are coming. When you get there, you drive up on the scale for a weight, then take the drugs to the chute for witnessed destruction. You drive up onto the scale for another weight, and that's about it. Covanta will accept drugs from any state that can get them to their incinerator if the regulations for that state allow it. Virginia allows it. The other participating incinerators are listed at the end of this mail. http://www.covanta.com/en/about-covanta/community-engagement/rx4-safety.aspx Community Health & Safety: Prescription for Safety Program (Rx4Safety) Rx4Safety has safely destroyed One Million Pounds of Unwanted Medications! We are celebrating by honoring our partners with the "A Million Thanks" award. Check out the list of awardees here! When flushed down the drain or disposed of in landfills, medications enter waterways and contaminate surface waters, having an adverse effect on our drinking water and the environment. Typical waste water treatment plants are not designed to remove drugs from drinking water, resulting in a negative impact upon aquatic organisms, fish and other wildlife when these pharmaceuticals are disposed of improperly. In addition, unused medication in the household may contribute to growing rates of prescription drug abuse among Americans, particularly teenagers. In support of national efforts to alleviate these issues, Covanta developed the Prescription for Safety Program (Rx4Safety) to provide safe, free disposal of medications collected at community sponsored drug take-back programs. Covanta's Energy-from-Waste (EfW) facilities provide safe, environmentally sound destruction that protects water resources and reduces the risk of drugs reaching unauthorized users. Municipalities interested in participating in Covanta's program must obtain appropriate regulatory approvals in order to ensure that such wastes are not classified as hazardous waste from a federal, state, or local perspective. Each program would be subject to a due diligence review by Covanta. For more information, please email or call John Frotton at JFrotton@covanta.com. John Frotton Area Manager Sustainable Solutions JFrotton@covanta.com Covanta 445 South Street Morristown, NJ 07960 Tel: 862-345-5039 Cell: 973-722-3892 http://covanta.com Here is what Covanta has with reference to plants that participate in the RX4 Safety program INDIANA (Indianapolis) NEW YORK (Niagara Falls, Westbury, Huntington) OREGON (Brooks) MASSACHUSETTS (Haverhill, Pittsfield, West Wareham, Agawam) FLORIDA (Okahumpka) ALABAMA (Huntsville) CONNECTICUT (Preston, Bristol) HAWAII (Honolulu) OKALAHOMA (Tulsa) NEW JERSEY (Rahway, Camden, Newark, Oxford) CALIFORNIA (Crows Landing) VIRGINIA (Alexandria, Lorton) Deborah L. DeBiasi Email: Deborah.DeBiasi@deq.virginia.gov WEB site address: www.deq.virginia.gov Virginia Department of Environmental Quality Office of Water Permits Industrial Pretreatment/Whole Effluent Toxicity (WET) Program PPCPs, EDCs, and Microconstituents http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDischargeElimination/Microconstituents.aspx Mail: P.O. Box 1105, Richmond, VA 23218 Location: 629 E. Main Street, Richmond, VA 23219 PH: 804-698-4028 FAX: 804-698-4032 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150213/abe4d7f7/attachment.htm From jhollar at pwaste.com Tue Feb 17 19:04:10 2015 From: jhollar at pwaste.com (Jeff Hollar) Date: Tue Feb 17 19:04:17 2015 Subject: [Pharmwaste] Police see drug disposal methods after DEA program ends Message-ID: <002201d04b0e$6cfade70$46f09b50$@pwaste.com> Amy and all, Here's a recent article from MO that talks about law enforcement pulling their drug boxes because DEA is no longer involved in the take back events. Police see drug disposal methods after DEA program ends http://www.standard-democrat.com/story/2166771.html Jeff Hollar President PharmWaste Technologies, Inc. 4164 NW Urbandale Dr., Ste A Urbandale, IA 50322 515-276-5302 (general) 515-331-7310 (direct) 515-360-9785 (cell) www.pwaste.com From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Tiemeier, Amy Sent: Thursday, February 12, 2015 9:43 AM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: RE: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Ed, Currently the MO law does not allow for pharmacies to do take back. That being said, when the new rules and regs came out, the MO Board of Pharmacy as well as the BNDD and other state agencies started discussing this. My understanding is that they intend to change the state regulations to allow this and there should be an emergency order coming out soon. In the St. Louis area we still have law enforcement providing med take back through funds and a partnership with a non-profit ( www.missourip2d2.org) that pays for incineration for partner law enforcement. Please let me know if you have any other questions as I am very involved with this issue in St. Louis! Amy Amy Tiemeier, Pharm.D., BCPS Director, Community Partnerships Associate Director, Office of Experiential Education Associate Professor, Department of Pharmacy Practice 4588 Parkview Place, St. Louis, MO 63110-1088 TEL: 314.446.8554 FAX: 314.446.8386 www.stlcop.edu From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 8:01 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Program closes, lack of funds. MO 4th state to not allow pharmacy take back? Another take back program has been forced to close due to the DEA pull out. http://www.kfvs12.com/story/28088776/drug-take-back-program-canceled-due-to- funding-shortfalls This story reports that Missouri state law prohibits pharmacy take back. Missouri is not one of the states (Georgia, Oklahoma and Hawaii) previously identified as not permitting pharmacy take back. Can anyone confirm if Missouri state law prohibits pharmacy take back? If an response is not forthcoming, would anyone from the Show-Me state volunteer to contact your state Board of Pharmacy to ask about restrictions and, if they exist, find out when they will change them to be aligned with the new federal rule? Thanks! Any volunteers from Georgia, Oklahoma and Hawaii willing to do the same? Maybe the gentle pressure of inquires will help motivate those state pharmacy boards to take action sooner. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150217/c92d63dd/attachment.html -------------- next part -------------- A non-text attachment was scrubbed... Name: not available Type: image/jpeg Size: 2662 bytes Desc: not available Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150217/c92d63dd/attachment.jpeg From DLotzer at uwhealth.org Thu Feb 19 08:42:27 2015 From: DLotzer at uwhealth.org (Lotzer Donna M) Date: Thu Feb 19 08:43:23 2015 Subject: [Pharmwaste] WI Attorney General Rx to support drug take back programs Message-ID: <1CCDE0102050044C8DBB849D4C8489B14136585D@UWHC-MBX15.uwhis.hosp.wisc.edu> This press release from our recently elected AG came out Wednesday...no mention of how it will be funded...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@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. -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150219/b5ef568b/attachment-0001.html -------------- next part -------------- A non-text attachment was scrubbed... Name: 20150218 Drug Takeback AG.docx Type: application/vnd.openxmlformats-officedocument.wordprocessingml.document Size: 111711 bytes Desc: 20150218 Drug Takeback AG.docx Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150219/b5ef568b/20150218DrugTakebackAG-0001.bin From Barbara.Bickford at wisconsin.gov Fri Feb 20 17:06:20 2015 From: Barbara.Bickford at wisconsin.gov (Bickford, Barbara J - DNR (Barb)) Date: Fri Feb 20 17:05:35 2015 Subject: [Pharmwaste] Wisconsin DOJ to coordinate take back from law enforcement Message-ID: To follow up on Donna Lotzer's post, here is the link to the press release: https://www.doj.state.wi.us/media-center/2015-news-releases/february-18-2015 And here is the text of the press release: Schimel Launches Prescription Drug Take Back Program -- DOJ spearheads logistics to facilitate cost savings to law enforcement MADISON -Wisconsin law enforcement heard encouraging news today when Attorney General Brad Schimel announced that the Department of Justice will now take the lead and will coordinate a prescription drug disposal program in Wisconsin. "With the opiate epidemic devastating families and communities across our state, we must work together to remove unused prescription opioids from circulation. They need to be collected and destroyed," Schimel said. "This program will also reduce the environmental hazards associated with the improper disposal of unused prescription drugs." In 2010, the Secure and Responsible Drug Disposal Act was signed. As a stop-gap measure until federal regulations were changed, the federal Drug Enforcement Administration (DEA) began conducting take back events to assist local law enforcement agencies and citizens in the disposal of unused prescription drugs. In September of 2014, the federal administrative code regarding drug disposal changed and the DEA announced they would no longer be conducting the drug take back program. The last event conducted by the DEA in Wisconsin was in September 2014. This created a need for local law enforcement agencies and citizens to find a means to safely dispose of excess prescription drugs. Local law enforcement grew to rely on the program and many now have 24/7 drop boxes for the unused prescription drugs. They continue to offer this service to their communities but they require a mechanism to safely, effectively and legally dispose of the drugs they receive, without causing an undue financial burden on their agencies or communities. Personnel and overtime costs have been a challenge for smaller agencies, as some cannot provide an officer at take back events. As a partner with law enforcement and community stakeholders, DOJ will provide the personnel and logistical resources to help make the Attorney General's program a success. The first collection day in 2015 will take place in mid- to late May and DOJ will continue to do a minimum of two collections per year. At the last statewide collection in September 2014, Wisconsin residents safely disposed of more than 17 tons of unused prescription medications, making Wisconsin one of the highest participating states in the nation. A fall collection date will follow, most likely in September/October. If a need for more frequent pickups and disposals is needed, we will work with our local partners to accommodate their requests as we become more efficient in administering the program. Barb Bickford Wisconsin DNR Phone: 608-267-3548 barbara.bickford@wisconsin.gov --Barb -------------------------------------------------------------- We are committed to service excellence. Visit our survey at http://dnr.wi.gov/customersurvey to evaluate how I did. Barb Bickford Medical Waste Coordinator and Hydrogeologist Waste and Materials Mgt/AWaRe Division Wisconsin Department of Natural Resources 101 S. Webster St., PO Box 7921, Madison, WI 53707-7921 Phone: 608-267-3548 Fax: 608-267-2768 barbara.bickford@wisconsin.gov [cid:image001.gif@01D04D26.B8033BA0] dnr.wi.gov [cid:image002.gif@01D04D26.B8033BA0] [cid:image003.gif@01D04D26.B8033BA0] [cid:image004.gif@01D04D26.B8033BA0] [cid:image005.gif@01D04D26.B8033BA0] [cid:image006.gif@01D04D26.B8033BA0] -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150220/564f2ace/attachment.htm -------------- next part -------------- A non-text attachment was scrubbed... Name: image001.gif Type: image/gif Size: 1428 bytes Desc: image001.gif Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150220/564f2ace/image001.gif -------------- next part -------------- A non-text attachment was scrubbed... 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Name: image006.gif Type: image/gif Size: 636 bytes Desc: image006.gif Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150220/564f2ace/image006.gif From Karen at productstewardship.us Tue Feb 24 12:24:10 2015 From: Karen at productstewardship.us (Karen Shapiro) Date: Tue Feb 24 12:29:22 2015 Subject: [Pharmwaste] RE: Feb 27 Supreme Court Conference In-Reply-To: <65AC0C9A3A6A474EAD8D56070FED66983E6453A3@MAIL.cityofithaca.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E6453A3@MAIL.cityofithaca.org> Message-ID: I just checked the SC's website and there's one more addition, dated 2/12. Ed, does this mean that the Court has until March 16th to release their decision about whether or not they will hear the appeal? ~~Date~~~ ~~~~~~~Proceedings and Orders~~~~~~~~~~~~~~~~~~~~~ Dec 29 2014 Petition for a writ of certiorari filed. (Response due January 28, 2015) Jan 28 2015 Motion for leave to file amici brief filed by Washington Legal Foundation, et al. . Jan 28 2015 Motion for leave to file amicus brief filed by Chamber of Commerce of the United States of America. Feb 11 2015 DISTRIBUTED for Conference of February 27, 2015. Feb 12 2015 Response Requested . (Due March 16, 2015) Karen ____________________________________ Karen Shapiro Senior Associate of Policy and Programs Product Stewardship Institute, Inc. 29 Stanhope St., 3rd Floor Boston, MA 02116 Phone: (617) 236-4866 www.productstewardship.us karen@productstewardship.us From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 10:15 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Feb 27 Supreme Court Conference Posted on the Supreme Court Website yesterday: Feb 11 2015 DISTRIBUTED for Conference of February 27, 2015. I take this to mean that during their February 27 Conference, the Justices will discuss, and possibly vote on, if they will hear the appeal (both the Petition for a writ of certiorari and the two motions for leave to file amici brief) later in this years session (or possibly in next years session?) or, if they will let the lower court ruling stand. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150224/2dbb8b57/attachment.htm From jmullowney at pharma-cycle.com Tue Feb 24 12:58:09 2015 From: jmullowney at pharma-cycle.com (Jim Mullowney) Date: Tue Feb 24 12:59:16 2015 Subject: [Pharmwaste] RE: Feb 27 Supreme Court Conference In-Reply-To: References: <65AC0C9A3A6A474EAD8D56070FED66983E6453A3@MAIL.cityofithaca.org> Message-ID: <000c01d0505b$7303a890$590af9b0$@pharma-cycle.com> On the same lines as the court decision for the unused drugs I think the used chemotherapy drugs (contained in urine and feces) would follow the same precedent. . Two recent studies of chemotherapy patients in their homes found exposure and contamination of the home setting and the patient's family's urine. Studies are attached. The patient's chemo drugs were found in the family member's urine samples and significant surface contamination was also documented in the bathroom, with high levels on the floor. Please spread this around. The studies can also be found at www.cytotoxicsafety.org Thank you all Jim Mullowney From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Karen Shapiro Sent: Tuesday, February 24, 2015 12:24 PM To: Ed Gottlieb; pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] RE: Feb 27 Supreme Court Conference I just checked the SC's website and there's one more addition, dated 2/12. Ed, does this mean that the Court has until March 16th to release their decision about whether or not they will hear the appeal? ~~Date~~~ ~~~~~~~Proceedings and Orders~~~~~~~~~~~~~~~~~~~~~ Dec 29 2014 Petition for a writ of certiorari filed. (Response due January 28, 2015) Jan 28 2015 Motion for leave to file amici brief filed by Washington Legal Foundation, et al. . Jan 28 2015 Motion for leave to file amicus brief filed by Chamber of Commerce of the United States of America. Feb 11 2015 DISTRIBUTED for Conference of February 27, 2015. Feb 12 2015 Response Requested . (Due March 16, 2015) Karen ____________________________________ Karen Shapiro Senior Associate of Policy and Programs Product Stewardship Institute, Inc. 29 Stanhope St., 3rd Floor Boston, MA 02116 Phone: (617) 236-4866 www.productstewardship.us karen@productstewardship.us From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 12, 2015 10:15 AM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] Feb 27 Supreme Court Conference Posted on the Supreme Court Website yesterday: Feb 11 2015 DISTRIBUTED for Conference of February 27, 2015. I take this to mean that during their February 27 Conference, the Justices will discuss, and possibly vote on, if they will hear the appeal (both the Petition for a writ of certiorari and the two motions for leave to file amici brief) later in this years session (or possibly in next years session?) or, if they will let the lower court ruling stand. 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150224/36e1db89/attachment-0001.htm -------------- next part -------------- A non-text attachment was scrubbed... Name: Exposure of family members to antineoplastic drugs via excreta of treated cancer patients.pdf Type: application/pdf Size: 212490 bytes Desc: not available Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150224/36e1db89/Exposureoffamilymemberstoantineoplasticdrugsviaexcretaoftreatedcancerpatients-0001.pdf -------------- next part -------------- A non-text attachment was scrubbed... Name: Evaluation of surface contamination with cyclophosphamide in the home setting of outpatients on cancer chemotherapy.pdf Type: application/pdf Size: 115438 bytes Desc: not available Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150224/36e1db89/Evaluationofsurfacecontaminationwithcyclophosphamideinthehomesettingofoutpatientsoncancerchemotherapy-0001.pdf From csmith at pharmecology.com Tue Feb 24 16:22:11 2015 From: csmith at pharmecology.com (Smith, Charlotte) Date: Tue Feb 24 16:22:39 2015 Subject: [Pharmwaste] FW: [p2tech] Green Chemistry Connection, An Online Community for Green Chemistry Practitioners, Launched Nationwide In-Reply-To: References: Message-ID: <74A2611A6ED8F34EA5D2A854C03FF20F207F239B@ADCMBX001.wm.com> This will likely be a technical site but certainly good to see! Best regards, Charlotte A. Smith, R. Ph., M.S. Senior Regulatory Advisor WMSS PharmEcology Services csmith@pharmecology.com 713-725-6363 From: p2tech-bounces@great-lakes.net [mailto:p2tech-bounces@great-lakes.net] On Behalf Of Andy Bray Sent: Tuesday, February 24, 2015 3:02 PM To: Andy Bray Subject: [p2tech] Green Chemistry Connection, An Online Community for Green Chemistry Practitioners, Launched Nationwide [bx_splash_image-cropped] For Immediate Release Contact: Andy Bray, Project Manager NEWMOA (617) 367-8558 x306 abray@newmoa.org Green Chemistry Connection, An Online Community for Green Chemistry Practitioners, Launched Nationwide NATIONAL ? The Northeast Waste Management Officials? Association (NEWMOA) announces the national launch of the ?Green Chemistry Connection,? an online community of green chemistry practitioners and an information clearinghouse now available at www.GreenChemConnect.org. NEWMOA created the Green Chemistry Connection in order to facilitate the exchange of information, ideas, and expertise on one easy-to-access and use web platform. NEWMOA conducted a ?soft-launch? of the website in 2014 in the northeast with more than 115 members. With the re-launch of the website for a national audience, NEWMOA hopes to expand the conversation on green chemistry and further enhance the quantity and quality of information available on the Network. ?Perhaps there is nothing more important when attempting to change the status quo than effective communication. Green chemistry seeks to change the status quo to a more sustainable society and economy through innovation... [GreenChemConnect.org] will allow everyone interested in designing a thriving, prospering, sustainable world in discovering the power and potential of green chemistry to meet environment/health goals at the same time as meeting economic and job creation goals.? Paul Anastas, Yale University GreenChemConnect.org brings together federal, state, and local programs, academic institutions, non-governmental organizations, and private companies that are working on green chemistry initiatives. The goal for the Green Chemistry Connection is to broaden the understanding and adoption of green chemistry practices and principles in business, education, government, health care, and society as a catalyst to growing a sustainable economy. Through www.GreenChemConnect.org, members can network and share information. Some of its features include: ? Discussion forums for sharing ideas or posting questions ? Blogs for sharing views, expertise, and experience ? News complied from multiple sources ? Announcements about upcoming events and activities ? Notices about jobs ? Groups for connecting with members interested in a particular topic ? Library of links to green chemistry websites, publications, videos, case studies, curriculum and training materials, promotional materials, and resource lists ? A Member Directory of organizations, companies, and academic researchers Social media sharing through other social networking sites, such as LinkedIn According to John Warner, President of the Warner Babcock Institute of Green Chemistry, ?This portal has an excellent potential to bring green chemistry community together in an effective way. I look forward to watching this grow.? NEWMOA developed this website using Word Press and administers and maintains the Network. It is funded in part by the U.S. Environmental Protection Agency through the Pollution Prevention Resource Exchange (P2Rx?). NEWMOA thanks the New England Green Chemistry Initiative (NEGCI) Steering Committee and Government Programs and Strategies Workgroup for their involvement and support with developing this Network. Reporter's/Editor's Note: NEWMOA is a non-profit, nonpartisan, interstate governmental association. With membership composed of state environmental agency directors of the hazardous waste, solid waste, waste site cleanup, pollution prevention, and underground storage tank programs in CT, ME, MA, NH, NJ, NY, RI, and VT. For more information, visit: www.newmoa.org. * * * * * * * * * * * * * * * * * * * * * * * * * * * * * p2tech is hosted by the Great Lakes Information Network (GLIN): http://www.great-lakes.net For information about this list, to change your subscription, or search the archives, visit: http://mailman.great-lakes.net/mailman/listinfo/p2tech All views and opinions presented above are solely those of the author or attributed source and do not necessarily reflect those of GLIN or the Great Lakes Commission. * * * * * * * * * * * * * * * * * * * * * * * * * * * * * ---------------------------------------------------------------------- Recycling is a good thing. Please recycle any printed emails. -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150224/a2b7dc2c/attachment-0001.htm -------------- next part -------------- A non-text attachment was scrubbed... Name: image001.jpg Type: image/jpeg Size: 31620 bytes Desc: image001.jpg Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150224/a2b7dc2c/image001-0001.jpg From EGottlieb at cityofithaca.org Thu Feb 26 10:00:36 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Thu Feb 26 10:26:24 2015 Subject: [Pharmwaste] draft Letter to the Editor Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E6524E4@MAIL.cityofithaca.org> Inspired by yet another news story of a law enforcement drop box being installed outside their station, in violation of the new DEA rule, I wrote a letter to the editor (below.) After incorporating your good suggestions, I plan on sending it to two or three of the most widely read law enforcement publications. I'd welcome your editorial suggestions and your advice on which publications to submit it to. Publications I found: Police Chief Magazine; Police; Law & Order; Sheriff; Law Officer; APB Thanks! Ed Pharmaceutical Drop Box Programs Need Review Providing the public with convenient ways to dispose of unwanted medications, especially controlled substances, is an important public service. Removing unwanted pharmaceuticals from homes decreases the likelihood of illegal diversion, accidental overdose, and environmental contamination. After the DEA established the Take Back Initiative, what had been a small number of existing law enforcement collection events quickly multiplied. The ninth and final DEA event, on September 27, 4014, included 4,076 agencies collecting 309 tons of unwanted medications at 5,495 sites in just four hours! To increase disposal convenience, a steadily growing number of law enforcement agencies (and pharmacies, for non-controlled collection) have installed permanent drop boxes at their locations. Thanks to wide community support, and some limited funding from state agencies and others, new drop boxes continue to be installed. Kudos to all of you that have taken the lead on this important issue! Are you aware that your drop box program may need to be modified to be compliant with recent changes to federal take back rules? This letter was inspired by reading multiple stories of new drop boxes being installed that are in violation of a new federal rule. Late in 2014, the DEA issued a rule regulating the take back of controlled substances. The big change is that pharmacies can now apply to take back controlled pharmaceuticals. Since the rule does not require participation, and provides no funding, it may be quite some time before a pharmacy near you participates. Law enforcement programs remain the primary method for safe disposal. As an aside, I want to mention that once the new rule was in place, the DEA announced the end of the hugely successful Take Back Initiative. That decision has left many law enforcement agencies struggling to find the funding needed to keep their one day and/or drop box collection programs going. It is going to be a tough transition time. Back to the point...the rule also specifies how law enforcement collects controlled substances. Please take the time to make sure your program is in compliance with the new rule. Here are a few details, specific to law enforcement, which should be part of your review check list. 1. Boxes must be inside law enforcement buildings. They are looking for active monitoring. ? 1317.35 Collection by law enforcement. (3) Collection receptacles located inside law enforcement's physical address. Also: ? 1317.75 Collection receptacles (d) (1) Inside a collector's registered location, inside law enforcement's physical location, or at an authorized long-term care facility; 2. They must be securely placed so that they cannot be removed, typically bolted to the floor and/or wall from inside the box. [? 1317.75 (e) (1)] 3. Signage must indicate that Schedule II-V controlled and non-controlled substances are acceptable and that Schedule I controlled is not. [? 1317.75 (e) (4)]. (I had to add this wording to my programs signage using stickers.) 4. Collected medications must be, ?stored in a manner that prevents the diversion of controlled substances and is consistent with that agency's standard procedures?? [? 1317.35 (c)] (We wrote an SOP specifying that inventory of the contents was not necessary. It isn't practical to routinely identify and count all the controlled substances received from a take back program. This also clears to way to be in compliance with state accreditation rules.) 5. The box must contain an opaque inner liner that, upon removal, must be labeled as specified in your departments SOP. If custody is to be transferred to a reverse distributor, a specific list of labeling requirements must be followed. [? 1317.35] For those of you holding take back events, you can authorize non-law enforcement personnel to assist with required, and voluntary, activities including: receiving, weighing, separating controlled from non-controlled, removing unacceptable items (sharps, mercury), inventorying, etc. [Executive Summary: J. Prohibition on Handling, Sorting, and Inventorying Inner Liner Contents and Mail-Back Package Contents; Response to Issues 2 & 3,] If you have any questions about the rule, you should contact your DEA field office. I?d also be happy to try and answer your questions. Please let me know if your DEA field office says something in conflict with your reading of rule. Thanks! Keep up the good work! 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150226/d2ea5e28/attachment.html From Burke.Lucy at CalRecycle.ca.gov Thu Feb 26 13:42:25 2015 From: Burke.Lucy at CalRecycle.ca.gov (Lucy, Burke@CalRecycle) Date: Thu Feb 26 13:43:01 2015 Subject: [Pharmwaste] Supreme Court response time extended to April 15 Message-ID: <984272580cc44781b057c9891224c4d1@DR3MAIL01.itservices.network> FYI, in deciding whether to hear the PhRMA et. al. v. Alameda appeal, it appears the Supreme Court just added this yesterday: Feb 25 2015 Order extending time to file response to petition to and including April 15, 2015. -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150226/0ed29186/attachment.htm From EGottlieb at cityofithaca.org Thu Feb 26 13:54:15 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Thu Feb 26 13:54:28 2015 Subject: [Pharmwaste] Supreme Court update Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E65261B@MAIL.cityofithaca.org> Since the folks in Alameda probably aren't allowed to keep us informed about their ongoing case, here is what I just learned: On Feb. 25, the Supreme Court website [http://www.supremecourt.gov/search.aspx?filename=/docketfiles/14-751.htm] added an "Order extending time to file response to petition to and including April 15, 2015." The reference librarian at the Cornell Univ. law library told me that the Feb. 12 "Response Requested (Due March 16)" was the Court asking Alameda County to file a response to the initial PhRMA request to hear the case. On Feb. 25th, they extended the deadline for a response from Alameda to April 15th. Once a response is received, or the deadline for it passes, the case will probably be scheduled for a Conference. It takes only one Justice to initiate a Conference discussion of a case. It takes four Justices, wanting to hear arguments, for a case to put on their docket. Hope this is accurate! 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150226/54fb08f6/attachment.htm From info at greatlakescleanwater.org Thu Feb 26 14:02:21 2015 From: info at greatlakescleanwater.org (Chris Angel, President) Date: Thu Feb 26 14:02:29 2015 Subject: [Pharmwaste] Great Lakes Clean Water Organization/US Clean Water Org. First Non-Profit in the US Licensed as DEA Reverse Distributor to Collect Controlled Substances For Disposal. Message-ID: <0367275bf027de3439b1d603aec409f0.squirrel@webmail04.register.com>       Chris Angel, President       www.GreatLakesCleanWater.org                     989.736.8179 Facebook https://www.facebook.com/pages/Great-Lakes-Clean-Water-Organization/250252498393081 Twitter https://twitter.com/CleanWater9  NEWS RELEASE Issue Date 2.26.15                                                  ;         Contact: Chris Angel    Great Lakes Clean Water Organization First Non-Profit in the US  Licensed as DEA Reverse Distributor to Collect Controlled Substances For Disposal.     A lot of positive changes have taken place since Great Lakes Clean Water Organization started the Yellow Jug Old Drugs program in 2008.The Rx-Waste disposal program works in partnership with local pharmacies to promote proper collection of unused/unwanted drugs to help keep our water clean. Proper disposal of unused/unwanted drugs is also a key weapon in the fight against misuse of prescription drugs. When the program started, there were very few pharmacies providing collection and disposal of unused/unwanted drugs. Pharmacies were not allowed to accept controlled substances for disposal they could only collect non-controlled substances. Many states had rules and regulations in place that prohibited pharmacies from accepting Rx-Waste for disposal. In the past six years significant progress has been made. The Secure and Responsible Drug Disposal Act published by the Drug Enforcement Agency (DEA) on September 9, 2014 allows retail pharmacies to collect controlled substances from individuals for proper disposal.     GLCW had been collecting non-controlled substances with the Yellow Jug Old Drugs program. In order to collect controlled substances from pharmacies for disposal Great Lakes Clean Water Org had to be licensed as a Reverse Distributor with the DEA. GLCW recently received final approval, making it the newest of the 27 Reverse Distributors in the US and the only Reverse Distributor that is a non-profit organization. The Yellow Jug Old Drugs program is now available in Michigan, Illinois, Wisconsin, Indiana and Ohio and in New York and Pennsylvania soon.  Because of the success of the program in the Great Lakes region the organization is making plans to expand the scope of the program beyond the Great Lakes to other locations in the US. This new initiative will be operated by Great Lakes Clean Water Organization, also doing business as (DBA) US Clean Water Organization. www.USCleanWater.org       Go to www.SecureResponsibleDrugDisposal.org for more info. -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150226/4cbb7934/attachment.htm From EGottlieb at cityofithaca.org Thu Feb 26 14:01:38 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Thu Feb 26 14:11:20 2015 Subject: [Pharmwaste] RE: draft Letter to the Editor In-Reply-To: References: <65AC0C9A3A6A474EAD8D56070FED66983E6524E4@MAIL.cityofithaca.org> <54EF1ABB0200007B00080B02@TompkinsMail.tompkins-co.org>, Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E65262E@MAIL.cityofithaca.org> Thanks James. As I mentioned in my follow-up email, I now realize it is not my place to send this letter to the editor. I will, for the second time, suggest to the DEA that they consider doing outreach to law enforcement about the new rule. Sorry to have bothered all of you with this! 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: James Steinmetz [JSteinmetz@cayuga-heights.ny.us] Sent: Thursday, February 26, 2015 1:32 PM To: Kris Bennett; James Landon; Thomas Boyce; Dan Ramer; Ed Gottlieb; John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; David Honan; Jeffery Montesano; Kathy, Zoner; MargaretRyan; Jackie; Tom Ferretti; Kristin Stevens; Tim Williams; Terri, Stewart; pharmwaste@lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan Dunlop; Ann Rider Subject: RE: draft Letter to the Editor Ed, First I would ask what area you are responsible for. If these infractions are occurring under someone else?s responsibility then they should be the person making contact. Second, if these infractions have already been addressed once by you, or the appropriate chair, then I would contact the DEA since they are the enforcement agency. Just my $00.02, Jim James M. Steinmetz Chief of Police Cayuga Heights Police Department 836 Hanshaw Road Ithaca, NY 14850 607-257-1011 From: Kris Bennett [mailto:kmbennett@tompkins-co.org] Sent: Thursday, February 26, 2015 1:08 PM To: James Landon; James Steinmetz; Thomas Boyce; Dan Ramer; Ed Gottlieb; John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; David Honan; Jeffery Montesano; Zoner Kathy; MargaretRyan; Jackie; Tom Ferretti; Kristin Stevens; Tim Williams; Stewart Terri; pharmwaste@lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan Dunlop; Ann Rider Subject: Re: draft Letter to the Editor I saw both your emails Ed but will reply to this one since it contains your draft letter. I think it's a good idea to send the letter and to include the fact that people may not be aware of all the rules, especially about siting the boxes securely inside. I suggest you scale back the length of the letter and focus on your #1 & # 2 points. If all the rules are available electronically somewhere, include a link to them to make it easier for people to access them. Including the law and section number is less useful. Kris >>> Ed Gottlieb > 2/26/2015 10:00 AM >>> Inspired by yet another news story of a law enforcement drop box being installed outside their station, in violation of the new DEA rule, I wrote a letter to the editor (below.) After incorporating your good suggestions, I plan on sending it to two or three of the most widely read law enforcement publications. I'd welcome your editorial suggestions and your advice on which publications to submit it to. Publications I found: Police Chief Magazine; Police; Law & Order; Sheriff; Law Officer; APB Thanks! Ed Pharmaceutical Drop Box Programs Need Review Providing the public with convenient ways to dispose of unwanted medications, especially controlled substances, is an important public service. Removing unwanted pharmaceuticals from homes decreases the likelihood of illegal diversion, accidental overdose, and environmental contamination. After the DEA established the Take Back Initiative, what had been a small number of existing law enforcement collection events quickly multiplied. The ninth and final DEA event, on September 27, 4014 should be 2014, included 4,076 agencies collecting 309 tons of unwanted medications at 5,495 sites in just four hours! To increase disposal convenience, a steadily growing number of law enforcement agencies (and pharmacies, for non-controlled collection) have installed permanent drop boxes at their locations. Thanks to wide community support, and some limited funding from state agencies and others, new drop boxes continue to be installed. Kudos to all of you that have taken the lead on this important issue! Are you aware that your drop box program may need to be modified to be compliant with recent changes to federal take back rules? This letter was inspired by reading multiple stories of new drop boxes being installed that are in violation of a new federal rule. Late in 2014, the DEA issued a rule regulating the take back of controlled substances. The big change is that pharmacies can now apply to take back controlled pharmaceuticals. Since the rule does not require participation, and provides no funding, it may be quite some time before a pharmacy near you participates. Law enforcement programs remain the primary method for safe disposal. As an aside, I want to mention that once the new rule was in place, the DEA announced the end of the hugely successful Take Back Initiative. That decision has left many law enforcement agencies struggling to find the funding needed to keep their one day and/or drop box collection programs going. It is going to be a tough transition time. Back to the point...the rule also specifies how law enforcement collects controlled substances. Please take the time to make sure your program is in compliance with the new rule. Here are a few details, specific to law enforcement, which should be part of your review check list. 1. Boxes must be inside law enforcement buildings. They are looking for active monitoring. ? 1317.35 Collection by law enforcement. (3) Collection receptacles located inside law enforcement's physical address. Also: ? 1317.75 Collection receptacles (d) (1) Inside a collector's registered location, inside law enforcement's physical location, or at an authorized long-term care facility; 2. They must be securely placed so that they cannot be removed, typically bolted to the floor and/or wall from inside the box. [? 1317.75 (e) (1)] 3. Signage must indicate that Schedule II-V controlled and non-controlled substances are acceptable and that Schedule I controlled is not. [? 1317.75 (e) (4)]. (I had to add this wording to my programs signage using stickers.) 4. Collected medications must be, ?stored in a manner that prevents the diversion of controlled substances and is consistent with that agency's standard procedures?? [? 1317.35 (c)] (We wrote an SOP specifying that inventory of the contents was not necessary. It isn't practical to routinely identify and count all the controlled substances received from a take back program. This also clears to way to be in compliance with state accreditation rules.) 5. The box must contain an opaque inner liner that, upon removal, must be labeled as specified in your departments SOP. If custody is to be transferred to a reverse distributor, a specific list of labeling requirements must be followed. [? 1317.35] For those of you holding take back events, you can authorize non-law enforcement personnel to assist with required, and voluntary, activities including: receiving, weighing, separating controlled from non-controlled, removing unacceptable items (sharps, mercury), inventorying, etc. [Executive Summary: J. Prohibition on Handling, Sorting, and Inventorying Inner Liner Contents and Mail-Back Package Contents; Response to Issues 2 & 3,] If you have any questions about the rule, you should contact your DEA field office. I?d also be happy to try and answer your questions. Please let me know if your DEA field office says something in conflict with your reading of rule. Thanks! Keep up the good work! 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 -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150226/ae6f4acd/attachment.htm From EGottlieb at cityofithaca.org Thu Feb 26 14:58:44 2015 From: EGottlieb at cityofithaca.org (Ed Gottlieb) Date: Thu Feb 26 14:59:02 2015 Subject: [Pharmwaste] DEA needs to do outreach Message-ID: <65AC0C9A3A6A474EAD8D56070FED66983E6526A7@MAIL.cityofithaca.org> FYI, I just sent this letter to DEA Division Director Arnold. He supervised the writing of the new take back rule. Ed Dear Director Arnold, After seeing yet another news story about a new drop box being installed outside a law enforcement building, I wrote a letter to the editor (see below), with the intention of sending it to some widely read law enforcement publications. I realized that this sort of outreach really should come from the DEA. Please consider how you can effectively communicate the basic requirements of the new Controlled Take Back Rule to law enforcement agencies. If that includes the use of letters to the editor, you are welcome to copy any, or all, of my letter. Regarding a previously submitted question, I still hope for your response regarding the acceptability of a small, frosted Plexiglas view port to detect the fill level of a drop box without unlocking it. If personal information can't be read through the view port, is such a feature acceptable? Thanks for your consideration of both these issues! I look forward to your response. Sincerely, 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 Pharmaceutical Drop Box Programs Need Review Providing the public with convenient ways to dispose of unwanted medications, especially controlled substances, is an important public service. Removing unwanted pharmaceuticals from homes decreases the likelihood of illegal diversion, accidental overdose, and environmental contamination. After the US Drug Enforcement Agency (DEA) established the Take Back Initiative in 2010, what had been a small number of existing law enforcement collection events quickly multiplied. The ninth and final DEA event, on September 27, 2014, included 4,076 agencies collecting 309 tons of unwanted medications at 5,495 sites in just four hours! To increase disposal convenience, a steadily growing number of law enforcement agencies (and pharmacies, mainly for non-controlled collection[JPL1] ) have installed permanent drop boxes at their locations. Thanks to wide community support, and some limited funding from state agencies and others, new drop boxes continue to be installed. Kudos to all of you that have taken the lead on this important issue! But, are you aware that your drop box program may need to be modified to be compliant with recent changes to federal take back rules? This letter was inspired by reading multiple stories of new drop boxes being installed that are in violation of a new federal rule. Late in 2014, the DEA issued a rule regulating the take back of controlled substances. [http://www.deadiversion.usdoj.gov/drug_disposal/fact_sheets/disposal_public.pdf] The big change is that pharmacies can now apply to take back controlled pharmaceuticals. Since the rule does not require participation, and provides no funding, it may be quite some time before a pharmacy near you participates. Law enforcement programs remain the primary method for safe disposal. I want to mention that once the new rule was in place, the DEA announced the end of the hugely successful Take Back Initiative. That decision has left many law enforcement agencies struggling to find funding to keep their one day and/or drop box collection programs going. It is going to be a tough transition time. Back to my main point...the rule also specifies how law enforcement collects controlled substances. Please take the time to make sure your program is in compliance with the new rule. To find the references below, the full rule is located at: http://www.deadiversion.usdoj.gov/fed_regs/rules/2014/2014-20926.pdf Here are a few details, specific to law enforcement, which should be part of your review check list. 1. Boxes must be inside buildings. The DEA is looking for active monitoring. ? 1317.35 Collection by law enforcement. (3) Collection receptacles located inside law enforcement's physical address. Also: ? 1317.75 Collection receptacles (d) (1) Inside a collector's registered location, inside law enforcement's physical location, or at an authorized long-term care facility; 2. Signage must indicate that Schedule II-V controlled and non-controlled substances are acceptable and that Schedule I controlled is not. [? 1317.75 (e) (4)]. (I had to add this wording to my programs signage using stickers.) 3. Collected medications must be ?stored in a manner that prevents the diversion of controlled substances and is consistent with that agency's standard procedures?? [? 1317.35 (c)] (We wrote an SOP specifying that inventory of the contents was not necessary. Identifying and counting so many controlled substances isn?t practical. This also cleared to way to be in compliance with our state accreditation rules.) 4. The box must contain an opaque inner liner that, upon removal, must be labeled as specified in your departments SOP. If custody is to be transferred to a reverse distributor, a specific list of labeling requirements must be followed. [? 1317.35] For those of you holding take back events, you can authorize non-law enforcement personnel to assist with required, and voluntary, activities including: receiving, weighing, separating controlled from non-controlled, removing unacceptable items (sharps, mercury), inventorying, etc. [Executive Summary: J. Prohibition on Handling, Sorting, and Inventorying Inner Liner Contents and Mail-Back Package Contents; Response to Issues 2 & 3,] If you have any questions about the rule, you should contact your DEA field office. I?d also be happy to try and answer your questions. Please let me know if your DEA field office says something in conflict with your reading of the rule. Thank you. Keep up the good work! -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150226/3a71284c/attachment-0001.htm From jennifer.volkman at state.mn.us Thu Feb 26 15:24:26 2015 From: jennifer.volkman at state.mn.us (Volkman, Jennifer (MPCA)) Date: Thu Feb 26 15:27:21 2015 Subject: [Pharmwaste] RE: DEA needs to do outreach In-Reply-To: <65AC0C9A3A6A474EAD8D56070FED66983E6526A7@MAIL.cityofithaca.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E6526A7@MAIL.cityofithaca.org> Message-ID: Ed, you are awesome! Your dedication to getting the word out may be above and beyond your duty as a pretreatment coordinator, but is in line with your position as Chair of the Coalition for Safe Medicine Disposal. I'm glad you sent the letter to DEA and there is no reason you can't give programs in your state a heads up. We may have one situation like you describe and I have contact information for the sites, so I might check up vs. send info to DEA for follow up. It isn't my place to do that, but my coworker and I prepared the guidance and provided training to law enforcement when they began establishing sites. We register sites and receive annual reporting on the quantity collected. So...I think we all balance our interest in preserving programs by passing along knowledge vs. passing along a non-compliant situation for a potential hammer response. Especially in the case where it is more of an awareness issue than a blatant attempt to avoid regulation. Cheers, JV From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 26, 2015 1:59 PM To: pharmwaste@lists.dep.state.fl.us Subject: [Pharmwaste] DEA needs to do outreach FYI, I just sent this letter to DEA Division Director Arnold. He supervised the writing of the new take back rule. Ed Dear Director Arnold, After seeing yet another news story about a new drop box being installed outside a law enforcement building, I wrote a letter to the editor (see below), with the intention of sending it to some widely read law enforcement publications. I realized that this sort of outreach really should come from the DEA. Please consider how you can effectively communicate the basic requirements of the new Controlled Take Back Rule to law enforcement agencies. If that includes the use of letters to the editor, you are welcome to copy any, or all, of my letter. Regarding a previously submitted question, I still hope for your response regarding the acceptability of a small, frosted Plexiglas view port to detect the fill level of a drop box without unlocking it. If personal information can't be read through the view port, is such a feature acceptable? Thanks for your consideration of both these issues! I look forward to your response. Sincerely, 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 Pharmaceutical Drop Box Programs Need Review Providing the public with convenient ways to dispose of unwanted medications, especially controlled substances, is an important public service. Removing unwanted pharmaceuticals from homes decreases the likelihood of illegal diversion, accidental overdose, and environmental contamination. After the US Drug Enforcement Agency (DEA) established the Take Back Initiative in 2010, what had been a small number of existing law enforcement collection events quickly multiplied. The ninth and final DEA event, on September 27, 2014, included 4,076 agencies collecting 309 tons of unwanted medications at 5,495 sites in just four hours! To increase disposal convenience, a steadily growing number of law enforcement agencies (and pharmacies, mainly for non-controlled collection[JPL1] ) have installed permanent drop boxes at their locations. Thanks to wide community support, and some limited funding from state agencies and others, new drop boxes continue to be installed. Kudos to all of you that have taken the lead on this important issue! But, are you aware that your drop box program may need to be modified to be compliant with recent changes to federal take back rules? This letter was inspired by reading multiple stories of new drop boxes being installed that are in violation of a new federal rule. Late in 2014, the DEA issued a rule regulating the take back of controlled substances. [http://www.deadiversion.usdoj.gov/drug_disposal/fact_sheets/disposal_public.pdf] The big change is that pharmacies can now apply to take back controlled pharmaceuticals. Since the rule does not require participation, and provides no funding, it may be quite some time before a pharmacy near you participates. Law enforcement programs remain the primary method for safe disposal. I want to mention that once the new rule was in place, the DEA announced the end of the hugely successful Take Back Initiative. That decision has left many law enforcement agencies struggling to find funding to keep their one day and/or drop box collection programs going. It is going to be a tough transition time. Back to my main point...the rule also specifies how law enforcement collects controlled substances. Please take the time to make sure your program is in compliance with the new rule. To find the references below, the full rule is located at: http://www.deadiversion.usdoj.gov/fed_regs/rules/2014/2014-20926.pdf Here are a few details, specific to law enforcement, which should be part of your review check list. 1. Boxes must be inside buildings. The DEA is looking for active monitoring. ? 1317.35 Collection by law enforcement. (3) Collection receptacles located inside law enforcement's physical address. Also: ? 1317.75 Collection receptacles (d) (1) Inside a collector's registered location, inside law enforcement's physical location, or at an authorized long-term care facility; 2. Signage must indicate that Schedule II-V controlled and non-controlled substances are acceptable and that Schedule I controlled is not. [? 1317.75 (e) (4)]. (I had to add this wording to my programs signage using stickers.) 3. Collected medications must be "stored in a manner that prevents the diversion of controlled substances and is consistent with that agency's standard procedures..." [? 1317.35 (c)] (We wrote an SOP specifying that inventory of the contents was not necessary. Identifying and counting so many controlled substances isn't practical. This also cleared to way to be in compliance with our state accreditation rules.) 4. The box must contain an opaque inner liner that, upon removal, must be labeled as specified in your departments SOP. If custody is to be transferred to a reverse distributor, a specific list of labeling requirements must be followed. [? 1317.35] For those of you holding take back events, you can authorize non-law enforcement personnel to assist with required, and voluntary, activities including: receiving, weighing, separating controlled from non-controlled, removing unacceptable items (sharps, mercury), inventorying, etc. [Executive Summary: J. Prohibition on Handling, Sorting, and Inventorying Inner Liner Contents and Mail-Back Package Contents; Response to Issues 2 & 3,] If you have any questions about the rule, you should contact your DEA field office. I'd also be happy to try and answer your questions. Please let me know if your DEA field office says something in conflict with your reading of the rule. Thank you. Keep up the good work! -------------- next part -------------- An HTML attachment was scrubbed... URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150226/244fe2e4/attachment.htm From jharris at sharpsinc.com Thu Feb 26 14:16:50 2015 From: jharris at sharpsinc.com (Jan Harris) Date: Fri Feb 27 07:51:24 2015 Subject: [Pharmwaste] RE: draft Letter to the Editor In-Reply-To: <65AC0C9A3A6A474EAD8D56070FED66983E65262E@MAIL.cityofithaca.org> References: <65AC0C9A3A6A474EAD8D56070FED66983E6524E4@MAIL.cityofithaca.org> <54EF1ABB0200007B00080B02@TompkinsMail.tompkins-co.org>, <65AC0C9A3A6A474EAD8D56070FED66983E65262E@MAIL.cityofithaca.org> Message-ID: <986c53846cee4d6a9b1527bb6ac296f1@602538-dex2013.sharpsinc.local> Thank you Ed. There is lots of confusion about the DEA rule we hear every day from all the industries involved, including law enforcement. It helps to hear a clear explanation as often as possible. Jan Harris | Director, Environmental Health & Safety Sharps Compliance, Inc. d- 713-927-9956 jharris@sharpsinc.com | http://www.sharpsinc.com From: pharmwaste-bounces@lists.dep.state.fl.us [mailto:pharmwaste-bounces@lists.dep.state.fl.us] On Behalf Of Ed Gottlieb Sent: Thursday, February 26, 2015 1:02 PM To: James Steinmetz; Kris Bennett; James Landon; Thomas Boyce; Dan Ramer; John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; David Honan; Jeffery Montesano; Kathy, Zoner; MargaretRyan; Jackie; Tom Ferretti; Kristin Stevens; Tim Williams; Terri, Stewart; pharmwaste@lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan Dunlop; Ann Rider Subject: [Pharmwaste] RE: draft Letter to the Editor Thanks James. As I mentioned in my follow-up email, I now realize it is not my place to send this letter to the editor. I will, for the second time, suggest to the DEA that they consider doing outreach to law enforcement about the new rule. Sorry to have bothered all of you with this! 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: James Steinmetz [JSteinmetz@cayuga-heights.ny.us] Sent: Thursday, February 26, 2015 1:32 PM To: Kris Bennett; James Landon; Thomas Boyce; Dan Ramer; Ed Gottlieb; John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; David Honan; Jeffery Montesano; Kathy, Zoner; MargaretRyan; Jackie; Tom Ferretti; Kristin Stevens; Tim Williams; Terri, Stewart; pharmwaste@lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan Dunlop; Ann Rider Subject: RE: draft Letter to the Editor Ed, First I would ask what area you are responsible for. If these infractions are occurring under someone else?s responsibility then they should be the person making contact. Second, if these infractions have already been addressed once by you, or the appropriate chair, then I would contact the DEA since they are the enforcement agency. Just my $00.02, Jim James M. Steinmetz Chief of Police Cayuga Heights Police Department 836 Hanshaw Road Ithaca, NY 14850 607-257-1011 From: Kris Bennett [mailto:kmbennett@tompkins-co.org] Sent: Thursday, February 26, 2015 1:08 PM To: James Landon; James Steinmetz; Thomas Boyce; Dan Ramer; Ed Gottlieb; John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; David Honan; Jeffery Montesano; Zoner Kathy; MargaretRyan; Jackie; Tom Ferretti; Kristin Stevens; Tim Williams; Stewart Terri; pharmwaste@lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan Dunlop; Ann Rider Subject: Re: draft Letter to the Editor I saw both your emails Ed but will reply to this one since it contains your draft letter. I think it's a good idea to send the letter and to include the fact that people may not be aware of all the rules, especially about siting the boxes securely inside. I suggest you scale back the length of the letter and focus on your #1 & # 2 points. If all the rules are available electronically somewhere, include a link to them to make it easier for people to access them. Including the law and section number is less useful. Kris >>> Ed Gottlieb > 2/26/2015 10:00 AM >>> Inspired by yet another news story of a law enforcement drop box being installed outside their station, in violation of the new DEA rule, I wrote a letter to the editor (below.) After incorporating your good suggestions, I plan on sending it to two or three of the most widely read law enforcement publications. I'd welcome your editorial suggestions and your advice on which publications to submit it to. Publications I found: Police Chief Magazine; Police; Law & Order; Sheriff; Law Officer; APB Thanks! Ed Pharmaceutical Drop Box Programs Need Review Providing the public with convenient ways to dispose of unwanted medications, especially controlled substances, is an important public service. Removing unwanted pharmaceuticals from homes decreases the likelihood of illegal diversion, accidental overdose, and environmental contamination. After the DEA established the Take Back Initiative, what had been a small number of existing law enforcement collection events quickly multiplied. The ninth and final DEA event, on September 27, 4014 should be 2014, included 4,076 agencies collecting 309 tons of unwanted medications at 5,495 sites in just four hours! To increase disposal convenience, a steadily growing number of law enforcement agencies (and pharmacies, for non-controlled collection) have installed permanent drop boxes at their locations. Thanks to wide community support, and some limited funding from state agencies and others, new drop boxes continue to be installed. Kudos to all of you that have taken the lead on this important issue! Are you aware that your drop box program may need to be modified to be compliant with recent changes to federal take back rules? This letter was inspired by reading multiple stories of new drop boxes being installed that are in violation of a new federal rule. Late in 2014, the DEA issued a rule regulating the take back of controlled substances. The big change is that pharmacies can now apply to take back controlled pharmaceuticals. Since the rule does not require participation, and provides no funding, it may be quite some time before a pharmacy near you participates. Law enforcement programs remain the primary method for safe disposal. As an aside, I want to mention that once the new rule was in place, the DEA announced the end of the hugely successful Take Back Initiative. That decision has left many law enforcement agencies struggling to find the funding needed to keep their one day and/or drop box collection programs going. It is going to be a tough transition time. Back to the point...the rule also specifies how law enforcement collects controlled substances. Please take the time to make sure your program is in compliance with the new rule. Here are a few details, specific to law enforcement, which should be part of your review check list. 1. Boxes must be inside law enforcement buildings. They are looking for active monitoring. ? 1317.35 Collection by law enforcement. (3) Collection receptacles located inside law enforcement's physical address. Also: ? 1317.75 Collection receptacles (d) (1) Inside a collector's registered location, inside law enforcement's physical location, or at an authorized long-term care facility; 2. They must be securely placed so that they cannot be removed, typically bolted to the floor and/or wall from inside the box. [? 1317.75 (e) (1)] 3. Signage must indicate that Schedule II-V controlled and non-controlled substances are acceptable and that Schedule I controlled is not. [? 1317.75 (e) (4)]. (I had to add this wording to my programs signage using stickers.) 4. Collected medications must be, ?stored in a manner that prevents the diversion of controlled substances and is consistent with that agency's standard procedures?? [? 1317.35 (c)] (We wrote an SOP specifying that inventory of the contents was not necessary. It isn't practical to routinely identify and count all the controlled substances received from a take back program. This also clears to way to be in compliance with state accreditation rules.) 5. The box must contain an opaque inner liner that, upon removal, must be labeled as specified in your departments SOP. If custody is to be transferred to a reverse distributor, a specific list of labeling requirements must be followed. [? 1317.35] For those of you holding take back events, you can authorize non-law enforcement personnel to assist with required, and voluntary, activities including: receiving, weighing, separating controlled from non-controlled, removing unacceptable items (sharps, mercury), inventorying, etc. [Executive Summary: J. Prohibition on Handling, Sorting, and Inventorying Inner Liner Contents and Mail-Back Package Contents; Response to Issues 2 & 3,] If you have any questions about the rule, you should contact your DEA field office. I?d also be happy to try and answer your questions. Please let me know if your DEA field office says something in conflict with your reading of rule. Thanks! Keep up the good work! 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/20150226/14de8c2e/attachment.html From Deborah.Hauser at epa.ohio.gov Fri Feb 27 14:22:45 2015 From: Deborah.Hauser at epa.ohio.gov (Hauser, Deborah) Date: Fri Feb 27 14:23:05 2015 Subject: [Pharmwaste] dialysis waste Message-ID: Ok, I got a little-bit-different request for information... Has anyone had experience with dialysis waste? I've been asked what we suggest they do with the waste after they do dialysis during their day, at their job. From what I understand, it is mostly urine, with a bit of the solution used to flush the kidneys. Thank you, Deb [New Image] Deborah Hauser Environmental Specialist Division of Materials and Waste Management 614.728.5353 Please note that my name has changed (previously Hoffman). 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Name: image001.png Type: image/png Size: 6988 bytes Desc: image001.png Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20150227/eebe1609/image001.png From veoralittle at gmail.com Fri Feb 27 09:22:33 2015 From: veoralittle at gmail.com (veora little) Date: Mon Mar 2 07:30:05 2015 Subject: [Pharmwaste] RE: draft Letter to the Editor In-Reply-To: <986c53846cee4d6a9b1527bb6ac296f1@602538-dex2013.sharpsinc.local> References: <65AC0C9A3A6A474EAD8D56070FED66983E6524E4@MAIL.cityofithaca.org> <54EF1ABB0200007B00080B02@TompkinsMail.tompkins-co.org> <65AC0C9A3A6A474EAD8D56070FED66983E65262E@MAIL.cityofithaca.org> <986c53846cee4d6a9b1527bb6ac296f1@602538-dex2013.sharpsinc.local> Message-ID: I thank you too Ed. Often up at 3 am Ed always has something articulate and pertinent to say. He inspires and educates all of us. Repetition is good and so is our mission to make the world a cleaner place! Sincerely, Veora Little *veoralittle@gmail.com * *home 239-649-6042, cell 239-450-2883* On Thu, Feb 26, 2015 at 2:16 PM, Jan Harris wrote: > Thank you Ed. There is lots of confusion about the DEA rule we hear > every day from all the industries involved, including law enforcement. It > helps to hear a clear explanation as often as possible. > > > > Jan Harris | Director, Environmental Health & Safety > > Sharps Compliance, Inc. > d- 713-927-9956 > > jharris@sharpsinc.com | http://www.sharpsinc.com > > *From:* pharmwaste-bounces@lists.dep.state.fl.us [mailto: > pharmwaste-bounces@lists.dep.state.fl.us] *On Behalf Of *Ed Gottlieb > *Sent:* Thursday, February 26, 2015 1:02 PM > *To:* James Steinmetz; Kris Bennett; James Landon; Thomas Boyce; Dan > Ramer; John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; David > Honan; Jeffery Montesano; Kathy, Zoner; MargaretRyan; Jackie; Tom Ferretti; > Kristin Stevens; Tim Williams; Terri, Stewart; > pharmwaste@lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau > Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek > Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan > Dunlop; Ann Rider > *Subject:* [Pharmwaste] RE: draft Letter to the Editor > > > > Thanks James. > > As I mentioned in my follow-up email, I now realize it is not my place to > send this letter to the editor. > I will, for the second time, suggest to the DEA that they consider doing > outreach to law enforcement about the new rule. > > > Sorry to have bothered all of you with this! > > 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:* James Steinmetz [JSteinmetz@cayuga-heights.ny.us] > *Sent:* Thursday, February 26, 2015 1:32 PM > *To:* Kris Bennett; James Landon; Thomas Boyce; Dan Ramer; Ed Gottlieb; > John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; David Honan; > Jeffery Montesano; Kathy, Zoner; MargaretRyan; Jackie; Tom Ferretti; > Kristin Stevens; Tim Williams; Terri, Stewart; > pharmwaste@lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau > Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek > Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan > Dunlop; Ann Rider > *Subject:* RE: draft Letter to the Editor > > Ed, > > First I would ask what area you are responsible for. If these infractions > are occurring under someone else?s responsibility then they should be the > person making contact. Second, if these infractions have already been > addressed once by you, or the appropriate chair, then I would contact the > DEA since they are the enforcement agency. > > Just my $00.02, > > Jim > > > > James M. Steinmetz > > Chief of Police > > > > Cayuga Heights Police Department > > 836 Hanshaw Road > > Ithaca, NY 14850 > > 607-257-1011 > > > > *From:* Kris Bennett [mailto:kmbennett@tompkins-co.org > ] > *Sent:* Thursday, February 26, 2015 1:08 PM > *To:* James Landon; James Steinmetz; Thomas Boyce; Dan Ramer; Ed > Gottlieb; John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; > David Honan; Jeffery Montesano; Zoner Kathy; MargaretRyan; Jackie; Tom > Ferretti; Kristin Stevens; Tim Williams; Stewart Terri; > pharmwaste@lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau > Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek > Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan > Dunlop; Ann Rider > *Subject:* Re: draft Letter to the Editor > > > > I saw both your emails Ed but will reply to this one since it contains > your draft letter. > > > > I think it's a good idea to send the letter and to include the fact > that people may not be aware of all the rules, especially about siting the > boxes securely inside. I suggest you scale back the length of the letter > and focus on your #1 & # 2 points. If all the rules are available > electronically somewhere, include a link to them to make it easier for > people to access them. Including the law and section number is less > useful. > > > > Kris > > > > > > >>> Ed Gottlieb 2/26/2015 10:00 AM >>> > > Inspired by yet another news story of a law enforcement drop box being > installed outside their station, in violation of the new DEA rule, I wrote > a letter to the editor (below.) After incorporating your good suggestions, > I plan on sending it to two or three of the most widely read law > enforcement publications. > > I'd welcome your editorial suggestions and your advice on which > publications to submit it to. > > Publications I found: Police Chief Magazine; Police; Law & Order; > Sheriff; Law Officer; APB > Thanks! > > Ed > > > > *Pharmaceutical Drop Box Programs Need Review * > > > > Providing the public with convenient ways to dispose of unwanted > medications, especially controlled substances, is an important public > service. Removing unwanted pharmaceuticals from homes decreases the > likelihood of illegal diversion, accidental overdose, and environmental > contamination. > > > > After the DEA established the Take Back Initiative, what had been a small > number of existing law enforcement collection events quickly multiplied. > The ninth and final DEA event, on September 27, 4014 should be 2014, > included 4,076 agencies collecting 309 tons of unwanted medications at > 5,495 sites in just four hours! > > > > To increase disposal convenience, a steadily growing number of law > enforcement agencies (and pharmacies, for non-controlled collection) have > installed permanent drop boxes at their locations. Thanks to wide > community support, and some limited funding from state agencies and others, > new drop boxes continue to be installed. > > Kudos to all of you that have taken the lead on this important issue! > > > > Are you aware that your drop box program may need to be modified to be > compliant with recent changes to federal take back rules? This letter was > inspired by reading multiple stories of new drop boxes being installed that > are in violation of a new federal rule. > > > > Late in 2014, the DEA issued a rule regulating the take back of controlled > substances. The big change is that pharmacies can now apply to take back > controlled pharmaceuticals. Since the rule does not require participation, > and provides no funding, it may be quite some time before a pharmacy near > you participates. Law enforcement programs remain the primary method for > safe disposal. > > > > As an aside, I want to mention that once the new rule was in place, the > DEA announced the end of the hugely successful Take Back Initiative. That > decision has left many law enforcement agencies struggling to find the > funding needed to keep their one day and/or drop box collection programs > going. It is going to be a tough transition time. > > > > Back to the point...the rule also specifies how law enforcement collects > controlled substances. Please take the time to make sure your program is > in compliance with the new rule. Here are a few details, specific to law > enforcement, which should be part of your review check list. > > > > 1. Boxes must be *inside *law enforcement buildings. They are looking > for active monitoring. > > ? 1317.35 Collection by law enforcement. (3) Collection receptacles > located *inside law enforcement's physical address*. Also: > > ? 1317.75 Collection receptacles (d) (1) Inside a collector's registered > location, *inside law enforcement's physical location*, or at an > authorized long-term care facility; > > > > 2. They must be securely placed so that they cannot be removed, typically > bolted to the floor and/or wall from inside the box. [? 1317.75 (e) (1)] > > > > 3. Signage must indicate that Schedule II-V controlled and non-controlled > substances are acceptable and that Schedule I controlled is not. [? 1317.75 > (e) (4)]. *(I had to add this wording to my programs signage using > stickers.) * > > 4. Collected medications must be, ?stored in a manner that prevents the > diversion of controlled substances and is consistent with that agency's > standard procedures?? [? 1317.35 (c)] *(We wrote an SOP specifying that > inventory of the contents was not necessary. It isn't practical to > routinely identify and count all the controlled substances received from a > take back program. This also clears to way to be in compliance with state > accreditation rules.) * > > > > 5. The box must contain an opaque inner liner that, upon removal, must be > labeled as specified in your departments SOP. If custody is to be > transferred to a reverse distributor, a specific list of labeling > requirements must be followed. [? 1317.35] > > > For those of you holding take back events, you can authorize non-law > enforcement personnel to assist with required, and voluntary, activities > including: receiving, weighing, separating controlled from non-controlled, > removing unacceptable items (sharps, mercury), inventorying, etc. > [Executive Summary: J. Prohibition on Handling, Sorting, and Inventorying > Inner Liner Contents and Mail-Back Package Contents; Response to Issues 2 & > 3,] > > > > If you have any questions about the rule, you should contact your DEA > field office. I?d also be happy to try and answer your questions. Please > let me know if your DEA field office says something in conflict with your > reading of rule. Thanks! > > > > Keep up the good work! > > > > 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. > > > --- > Note: As a courtesy to other listserv subscribers, please post messages to > the listserv in plain text format to avoid the garbling of messages > received by digest recipients. > --- > TO SUBSCRIBE, go to: > http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste > TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. 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