[Pharmwaste] FW: Drug Dispose All

Ed Gottlieb EGottlieb at cityofithaca.org
Wed Jan 14 12:19:50 EST 2015


Passing on Mike's reply...

From: mmiller at disposaltechnologies.com [mmiller at disposaltechnologies.com]
Sent: Wednesday, January 14, 2015 12:08 PM
To: Ed Gottlieb
Subject: RE: Drug Dispose All Test Results

Ed,
The DEA became aware of us last fall. They were very uncomfortable then. They did an onsite visit and took our testing for evaluation. They did not ask us to do a peer review. We told them we were doing one and offered to send a copy for their file. They are smart enough to know we would not be doing one if we were trying to hide something. It was only when a major reverse distributor asked about using us for destruction versus incineration that someone in Washington asked to talk to our chemist. That discussion has taken place and he told us he would make a positive recommendation. So there is no reason not to be optimistic. We actually are starting to sell increasing amounts of product to hospitals and pharmacies across the country. In fact we talked to NY Presbyterian today from your state. Cardinal is putting us in due to customer demand. I really don't know if we will get anything in writing from the DEA. That would be awesome if they did but might appear tantamount to an endorsement. We are pleased they are aware of us in Washington. That means we are making progress.
I see you are involved in water treatment. Some of the states are telling hospitals that they can't waste medications into the sink or toilet anymore after procedures. We of course applaud that stance. Prior to our product there were not allot of good alternatives.
Mike

-------- Original Message --------
Subject: Drug Dispose All Test Results
From: Ed Gottlieb <EGottlieb at cityofithaca.org<mailto:EGottlieb at cityofithaca.org>>
Date: Tue, January 13, 2015 12:25 pm
To: "mmiller at disposaltechnologies.com<mailto:mmiller at disposaltechnologies.com>"
<mmiller at disposaltechnologies.com<mailto:mmiller at disposaltechnologies.com>>
Cc: "pharmwaste-owner at lists.dep.state.fl.us<mailto:pharmwaste-owner at lists.dep.state.fl.us>"
<pharmwaste-owner at lists.dep.state.fl.us<mailto:pharmwaste-owner at lists.dep.state.fl.us>>

Hi Mike,

Thanks for the prompt reply.

I understand the DEA can't endorse a product.  Isn't that different than them saying a process or product destroys or sequesters medications rendering them non-recoverable?

You sound confident that the DEA will decide that the Drug Dispose All meets their non-recoverable standard.  When they do, I imagine your product will sell well.

Please let me know if I understand you correctly...
the DEA has seen the test results you sent me (3 attachments) and
they want to see a peer review of Dr. Shug's study before deciding if the Drug Dispose All unit meets their non-recoverable standard.

You mention being, "told that the only way the carbon will release the medications is extreme heat...like 5000 degrees."  This information was not in Dr. Shug's study.  Isn't it key to making a determination about recoverability?  Is there another study documenting this that the DEA has seen?

It seems that my understanding on extracting compounds from activated carbon is wrong.  Or, maybe, medications bind to it differently, making the methods I mentioned ineffective.

I assume that the high temperature release you mention can only happen in an oxygen free environment.  The MSDS for activated carbon shows ignition being greater than 400 C (752 F).  Some studies show that used activated carbon can ignite at temperatures significantly less that listed in the MSDS.

Could you please send me (or the listserv, cc'ed here) a copy of the DEA's response after they receive the peer review?  Is there a date you expect the peer review to be completed?

Thank you very much!

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: mmiller at disposaltechnologies.com<mailto:mmiller at disposaltechnologies.com> [mmiller at disposaltechnologies.com<mailto:mmiller at disposaltechnologies.com>]
Sent: Tuesday, January 13, 2015 1:14 PM
To: Ed Gottlieb
Subject: RE: Test Results


Ed,
You certainly may pass this along. You will be interested to know that the DEA in Washington is well aware of us. In fact Dr. Shug has talked to their chemist. We know they will never endorse a product. We just don't want them to get in the way.  After some initial reservations they now seem comfortable with our technology. The testing and the peer review are key.

I am told that the only way the carbon will release the medications is extreme heat...like 5000 degrees. So short of a nuclear holocaust the medications are sequestered. Of course I am not a chemist but that is the only way I am aware of. I'll leave those discussions to Dr. Shug and the DEA chemist.
Mike

-------- Original Message --------
Subject: RE: Test Results
From: Ed Gottlieb <EGottlieb at cityofithaca.org<mailto:EGottlieb at cityofithaca.org>>
Date: Tue, January 13, 2015 8:18 am
To: "mmiller at disposaltechnologies.com<mailto:mmiller at disposaltechnologies.com>"
<mmiller at disposaltechnologies.com<mailto:mmiller at disposaltechnologies.com>>

Hi Mike,

Impressive removal numbers!  May I pass them along to the FL pharm waste listserv?

Kevin Suhug, the author of the Texas U. study, states, "It is worth mentioning that certain types of activated charcoal, in general, is [sic] extremely efficient in the uptake of chemical compounds; once adsorbed, it is very difficult to reverse the sequestration process."  He doesn't actually say which type of activated carbon is used in the Drug Dispose All.

More importantly, I don't think that "very difficult to reverse" meets the DEA's non-retrievable standard.  Can you please provide additional information regarding the Drug Dispose All’s ability to meet the non-retrievable standard?

It is my understanding that some combination of techniques, (including: heat, pressure, steam, solvents, and physical pulverization) can be used to extract many compounds absorbed by activated carbon.  Other methods, such as precipitation and distillation, can then used to isolate specific extracted compounds.

Thank you.

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

________________________________
From: mmiller at disposaltechnologies.com<mailto:mmiller at disposaltechnologies.com> [mmiller at disposaltechnologies.com<mailto:mmiller at disposaltechnologies.com>]
Sent: Tuesday, January 13, 2015 9:23 AM
To: Ed Gottlieb
Subject: [FWD: Test Results]

 I butchered Ithaca. Here you go

-------- Original Message --------
Subject: Test Results
From: <mmiller at disposaltechnologies.com<mailto:mmiller at disposaltechnologies.com>>
Date: Fri, January 09, 2015 3:28 pm
To: egottlieb at cityofithica.org<mailto:egottlieb at cityofithica.org>

Ed,
Here are the confidential test results done at the University of Texas at Arlington with the confidential info redacted out. As you can see we have tested a great variety of medications including some of the most abused. In addition to this testing the University is conducting a peer review of their results to further validate their conclusions. I can understand your being skeptical about the validity of our claims. There are several competitive products that have no such testing. This stuff actually works. I am also attaching third party environmental testing we had done on our end waste that shows it to be harmless to the environment. Thanks for the heads up on our webpage. I will have those checked out next week. We are a start up and just started shipping last March. Our website was done by a marketing group over in Dallas when we were just getting started. Frankly it needs some clean up. Please feel free to call me with any other questions or concerns. Thanks for your interest and I hope you have a great weekend.

Mike Miller
Disposal Technologies
817-980-5266 (c)
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