[Pharmwaste] RE: any good data on diversion?

[Yellow Jug Old Drugs Account Support]

To all,

While diversion may be an issue cited by some pharmacies as a reason not to participate in an Rx-Waste Collection program its likely more misinformation about the DEA regs in place to limit diversion and specific methods of collection that further reduce the potential for diversion.

The DEA regs for the collection of controlled substances do minimize the potential for diversion. Primarily the regs. require customers place Rx-waste in lockable container and not pass to a pharmacy employee. The two pharmacy staff signature requirement also limits diversion potential.

The regulation that speaks to Rx-Waste not being handled by pharmacy staff should be clearly indicated on the collection container in addition to other pertinent info.


The Yellow Jug Old Drugs Program utilizes a system of gel in the collection containers that render the medications irretrievable according to DEA standards. This very much minimizes the potential for diversion

We believe that the biggest barrier to pharmacies is the potential cost for a pharmacy to participate in an Rx-Waste Collection Program. Great Lake Clean Water/US Clean Water is committed to keeping costs low to encourage more pharmacies to participate resulting in more communities keeping their
water clean and their communities safe through proper collection and disposal of Rx-Waste.
Chris Angel, President
www.GreatLakesCleanWater.org   www.USCleanWater.org

---------------------------- Original Message ----------------------------
Subject: [Pharmwaste] RE: any good data on diversion?
From:    "Ed Gottlieb" <EGottlieb at cityofithaca.org>
Date:    Tue, November 10, 2015 10:44 am
To:      "Deborah.Hauser at epa.ohio.gov" <Deborah.Hauser at epa.ohio.gov>
         "pharmwaste at lists.dep.state.fl.us" <pharmwaste at lists.dep.state.fl.us>
--------------------------------------------------------------------------

> Debbie,
>
> Illegal diversion will always be an issue, at pharmacies, police stations, and in homes.
>
> For awhile, I collected news reports about such occurrences.  These stories are powerful reminders of the temptation of easy money and the desperation of addicts.
>
> They are also anecdotal accounts.  However many of them are collected, I suspect they will be of limited use in determining what percent of controlled substances received in take back programs are illegally diverted.  I'd be surprised if there is any real data on this.  The DEA probably has data
on diversion from pharmacies stock of controlled substances.>
> I'd suggest that pharmacies who have concerns should to be reminded that the detailed procedures for take back were written by the DEA, an agency that is completely committed to the prevention of illegal diversion.  They need to understand and follow the DEA procedures.
>
> What are the specific concerns that you are hearing?  If it is robbery, a double locked take back box has more security than their stock of controlled substances, which are more concentrated and easier to access.  If the concern is an employee stealing from the un-inventoried contents in a return
box, DEA procedure is that no single employee have both keys to access collected medications.  The odds of collusion to commit a felony between two employees is small.>
> I'm interested to see what others have to say on 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: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Deborah.Hauser at epa.ohio.gov [Deborah.Hauser at epa.ohio.gov]
> Sent: Tuesday, November 10, 2015 9:39 AM
> To: pharmwaste at lists.dep.state.fl.us
> Subject: [Pharmwaste] any good data on diversion?
>
> Good morning,
>
> One of the biggest arguments I’ve heard against participating in the collection of unwanted pharms at pharmacies is the possibility of diversion.  It seems like a valid argument, so I’d like to see if there is any anecdotal evidence to that effect.
>
> I’ve contacted Iowa to find out what they have experienced since they’ve had the TakeAway program in place for a number of years.  They still do not collect controlled substances, so I understand any diversion (or lack thereof) they experience could be attributed to that.
>
> I’d like to hear from other states, especially ones that are collecting at pharmacies, to see if there is any data on diversion.
>
> Thank you,
> Debbie
>
>
> [http://epaintra.epa.ohio.gov/portals/11/Documents/Templates/standard_logo_color_email.gif]
>
> Deborah Hauser
> Environmental Specialist
> Division of Materials and Waste Management
> 614.728.5353
>
>
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