[Pharmwaste] YES AND,
all of the above - Senators encourage reinstatement of DEA
Take-Back Events
Catherine Zimmer
zenllc at usfamily.net
Tue Jun 2 09:51:24 EDT 2015
Hi Margaret and all,
Senators and all of us also need to be encouraging practices that reduce
both the ingestion of medicines that are excreted and are leftover in
medicine cabinets for diversion. A concerted source reduction effort on the
part of providers and pharma would likely get us a long way to minimize the
need for collections of any sort. And, better protect public health and the
environment from air pollution associated with incineration and water
pollution associated with excretion and waste.
In 2008 I compiled a white paper for MN elected officials. Here is the
summary of steps needed. Reflecting on it today, seven years later, we have
made some incremental steps towards resolving the issue, but as I heard on
public radio this morning, we still have a problem.
§ At this time, household pharmaceutical collections indicate most waste is
due to drugs not taken because of side effects, allergies or interactions.
Changes to reimbursement and co-pay rules and policies to encourage trial
prescriptions and eliminate the waste associated with 30 and 90 day
prescriptions. CMS now requires pro-rated co-pays for new prescriptions,
but is this being practiced?
§ Changes to policies and rules to encourage non-drug treatments, such as
physical therapy, proper nutrition and other complementary and alternative
medicines. To what extent are providers encouraging alternatives? My
provider friends are still in the “take a pill” mode. One friend keeps a
stash of ibuprofen in the side pocket of her car.
§ Incentives for pharmaceutical manufacturers to develop drugs targeted to
the tissue/s or organ/s of choice, minimizing excretion potential.
§ Currently the costs of drug disposal are primarily borne by the
taxpayers. Changes to policies and rules to encourage product stewardship
for pharmaceuticals by manufacturers, insurance companies and health care
providers. Some movement here, but will the costs just be passed on to
users—as with the paint EPR—and no real effort made to source reduce?
§ Changes to DEA regulations to permit disposal of controlled substances by
methods other than the sanitary sewer. DEA didn’t provide good alternatives
for healthcare’s “wastage”, but source reduction opportunities exist.
Very truly yours,
Catherine Zimmer, MS, BSMT
Zimmer Environmental Improvement, LLC
Reducing and managing healthcare related waste and costs for fifteen years.
St. Paul, MN
Ph: 651.645.7509
<mailto:zenllc at usfamily.net> zenllc at usfamily.net
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Margaret
Shield
Sent: Tuesday, June 02, 2015 1:44 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] YES AND, all of the above - Senators encourage
reinstatement of DEA Take-Back Events
Hi folks,
I appreciate the passionate, thoughtful, and interesting comments about the
bipartisan push for more DEA National Take-back Events.
I encourage all to wear your “yes, add” thinking caps about the many truths
going on simultaneously. We’re all versatile and smart enough to see that
we need to keep our eye on the goal of having well-promoted, convenient,
efficient, ongoing medicine take-back system in all our communities.
Interim solutions are also needed, but the long-term goal cannot occur
without key investments from pharmaceutical companies who are the ones that
can work these relatively small costs of drug take-back into their business
models. There can be interim steps towards that goal without pitting any one
interim step against that long-term goal.
Yes, we need an immediate fix to provide drug take-back events in
communities without other options. Perhaps reinstating the successful
twice-a-year national DEA events is a good band-aid to help the situation.
But let’s support it for what it is, an interim step towards the real goal.
And let’s see if it can be done with greater understanding of the challenges
that law enforcement agencies face to make the events happen, for example
Saturday events may be awesome for DEA, but it means over-time shifts and
greater budgetary burdens for some local cops.
Do all the ongoing drop boxes at law enforcement offices and the law
enforcement collection events deserve more support? Yes, they do, and
that’s also an interim step towards the real goal. Various proposals of
short term funding through grant programs are circulating. Again, interim
fix, keep eyes on long-term goal.
Yes, what’s really needed is more convenient and secure drop off locations
for medicines - and that’s at retail pharmacies, not just at police stations
or occasional collection events. That’s why we worked so hard to pass the
federal bill in 2010 to change the Controlled Substances Act. Convenient
drop boxes at pharmacies and hospitals, supplemented by events and mail-back
as needed, will be most effective in getting potentially dangerous leftover
medicines out of people’s homes.
Our police and sheriffs have been tremendous in their support for medicine
take-back and their programs have been successful and impactful. Thank you
law enforcement!
And we all go to drug stores or supermarkets with pharmacies regularly,
which means secure drop boxes there will safely collect the largest volumes
of leftover medicines to protect our communities. I believe that retail
pharmacies, including the big chains like CVS, want to step up to help with
pharmaceutical stewardship but they shouldn’t be left holding the whole bag
of drugs. The manufacturers of the medicines need to be contributing to the
solution too. Which brings us back to the long-term goal.
The U.S. Supreme Court decision upholding the county-level law is important
and we’re now past the distraction of that legal challenge. Does producer
responsibility still seem hard to achieve given what seems to be ongoing
opposition from the powerful pharmaceutical industry, even after the Supreme
Court decision? Sure, it’s hard, but I think the professionals on this
pharmwaste listserv are used to accomplishing hard things when they know
it’s right. I suggest that before you assume it’s impossible, have some
serious conversations with your local elected leaders about why more
convenient, effective, long-term medicine take-back programs are needed, and
why the county laws in Alameda, King, San Francisco, San Mateo, and Santa
Clara that place reasonable responsibility on drug manufacturers make sense.
You might be surprised what you hear in response from your local electeds
who are committed to protecting their communities.
Margaret Shield
Seattle, WA
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Gilliam,
Allen
Sent: Monday, June 1, 2015 1:23 PM
To: Hauser, Deborah; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Senators encourage reinstatement of DEA Take-Back
Events
Knowing first hand (have brother who’s been a pharmacist for almost 30 yrs)
what pharmacists must do just to keep up with their day-to-day shelling out
hundreds of pills and doing with it utmost precision, it’s no wonder many
pharmacies do not want to add another regulated and time consuming work
project.
AR’s “take-back” program has ~100+ permanent drop boxes located at city
police/county sheriff’s offices which pretty well saturates the State (see
http://www.artakeback.org/Default.aspx?CCID=20447
<http://www.artakeback.org/Default.aspx?CCID=20447&FID=129895&ExcludeBoolFal
se=True&PageID=13761060#sthash.IOzK2dxj.dpbs>
&FID=129895&ExcludeBoolFalse=True&PageID=13761060#sthash.IOzK2dxj.dpbs [go
to “drop box type” and click on “permanent” and place “100” in the “distance
box and then click “search”]). It’s been a program that has exceeded all
expectations.
Don’t know if all sites care/are knowledgeable of DEA’s recent reg when
collecting OTC meds or controlled substances. They all end up at a licensed
haz waste incinerator.
Granted, the DEA’s 2/yr “take-back” days will be greatly missed because of
their connection which helps keep our permanent drop boxes busy, but with or
without pharmacies entering the picture, I’m still fearing we’ll see a drop
off in use of the permanent drop boxes without the big name DEA leading the
charge which is highly publicized throughout the State.
Allen g
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Hauser,
Deborah
Sent: Monday, June 01, 2015 1:47 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Senators encourage reinstatement of DEA Take-Back
Events
I guess I’m a little disappointed that nobody is even discussing the
possibility of retail pharmacies collecting. I had heard rumors about CVS
planning to start providing permanent collection boxes in their pharmacies.
Has anyone else heard anything? Because it sure is a lot more convenient
for the average resident to drop off old pharms at the corner drug store
than to find the local law enforcement drop box. I don’t even know where my
local sheriff’s office is located!
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). Please update
your address book.
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of DeBiasi,
Deborah (DEQ)
Sent: Monday, June 01, 2015 2:37 PM
To: Ed Gottlieb; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Senators encourage reinstatement of DEA Take-Back
Events
The nine DEA National Take-Back Initiatives were a bargain
because of a lot of volunteer time donations from Law Enforcement, the
National Guard, Public Utility staff, Environmental groups and DEA, and
because DEA picked up the tab for the destruction. The logistical
challenges were significant, as transporters gathered up collected drugs
from consolidation points at law enforcement locations across the state and
trucked them to the incinerators.
Virginia is looking at continuing the two Drug Take-Back events
on set Saturdays, maybe in April and September since the DEA events got
folks in the habit of expecting them. We haven’t seen much interest for
housing collection boxes or supporting the mail-back programs for a variety
of reasons. Even with Covanta Incinerators offering us free destruction of
the collected drugs, costs are estimated at $50,000-60,000 per event and
that still includes a lot of donated time. Funding must be present or we
can’t do it.
If Congress mandates that DEA resume sponsorship for the effort,
they need to provide the funding and resources for them to do it. The
Virginia DEA staff were great to work with, and they did an amazing job of
orchestrating the Take-Back events often with little advance notice of the
event dates, but it also tied up their agents, vehicles and facilities from
doing their primary functions.
Deborah L. DeBiasi, Virginia DEQ
Office of Water Permits
Email: Deborah.DeBiasi at deq.virginia.gov
PH: 804-698-4028
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Ed Gottlieb
Sent: Monday, June 01, 2015 1:54 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Senators encourage reinstatement of DEA Take-Back
Events
My answer to Jeff (below) is "yes", more consumers would be safely dispose
of unwanted medications if the DEA reinstated the Take Back Initiative.
I think it is a great idea for the DEA to reinstate the Take Back Initiative
on an interim basis. It was a hugely successful program that made it easy
for almost 4000 law enforcement departments to have more than 5200
collection sites at the last take back event. With the loss of DEA support,
many of these communities no longer have a safe disposal option.
The new DEA rule allows, but does not mandate or fund, authorized
distributors to apply to become a take back location. Only time will tell
how many pharmacies, reverse distributors, and narcotic treatment centers
sign up to pay for controlled substance take back.
Also, as far as I have been able to determine, there are still nine states
(AR, AZ, HI, IL, MN, MS, NY TX, CT) that have rules blocking authorized
distributors from doing take back of controlled substances. These states
will eventually change their rules to be in compliance with the new DEA
rule.
So far, I have not seen any evidence of large numbers of take back programs
for controlled substances being approved.
The Supreme Court decision (to let a Federal District Court decision
upholding the Alameda County EPR law stand) is encouraging and will
certainly lead to similar laws being passed in other communities. It is
hard to imagine that this decision will lead to a sudden, large surge in
similar laws. I don't see it having much of an impact on the nationwide
availability of safe disposal options in the near future.
Congress should direct the DEA to reinstate the Take Back Initiative. The
program should continue until there is evidence that ongoing programs (both
voluntary and EPR mandated) are widely available throughout the nation.
Removing unwanted pharmaceuticals from homes and safely disposing of them
helps address multiple problems of national significance:
illegal diversion
accidental overdoses
and
environmental contamination
The DEA supported program was effective, necessary, and a bargain! If we
help motivate Congress to act, it will be again.
Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY 14850
(607) 273-8381
fax: (607) 273-8433
_____
From: pharmwaste-bounces at lists.dep.state.fl.us
[pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Jim Clark
[jac20 at psu.edu]
Sent: Monday, June 01, 2015 12:58 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Senators encourage reinstatement of DEA Take-Back
Events
Does it make sense that we reinstate the DEA drug take back program and
given the recent supreme court decision, that we have the pharmaceuticals
pay for the DEA drug Take Back Program? What am I missing?
Jim Clark, Extension Educator
From: Gilliam, Allen [mailto:GILLIAM at adeq.state.ar.us]
Sent: Monday, June 01, 2015 8:58 AM
To: Jeff Hollar; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Senators encourage reinstatement of DEA Take-Back
Events
Very good point Jeff,
The domino effect will begin I’m afraid. Coming from 25+ yrs in
Pretreatment and watching the Feds (EPA) continual disinvestment in the
National Pretreatment Program over the last 15+ yrs, it’s already hit hard
here at the state level and now being felt at the City level: “If the Feds
see no importance in the program, why should we?” seems to be the wounded
wolf’s final cry.
A lot of people don’t want “big government” (like myself to an extent), but
without its presence in some worthwhile nat’l programs, those programs are
doomed to wither on the vine.
Allen Gilliam
ADEQ State Pretreatment Coordinator
501.682.0625
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jeff Hollar
Sent: Saturday, May 30, 2015 7:18 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Senators encourage reinstatement of DEA Take-Back
Events
Full Story:
http://www.capito.senate.gov/content/capito-and-manchin-call-reinstatement-n
ational-drug-take-back-days
Wouldn’t more consumer drugs be disposed if they reinstated the program?
Isn’t that a good thing?
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 <http://www.pwaste.com/>
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