[Pharmwaste] Re: Pharmwaste Digest, Vol 121, Issue 8

Tue Nov 10 15:36:11 EST 2015

FillAboxrecycling.com Larry Kenemore Jr. Inventor/Consultant to Board of Directors 10092 Bianchi Way #207 Cupertino CA. 95014 (855) 873-4965 A Woman Owned/ Minority Owned Business D&B #079463523 NAICS #562920 CAGE #079463523/7AKL Larrykenemorejr at fillaboxrecycling.com
Ed and others; Interesting reading, however it seems that you all have missed the point (or
the boat) so to speak. Why create a complete new system as the DEA has when
there are other safer alternatives that collect and dispose or more products
than anything you have done so far. Everyone seems to want to create something
new when there are products and programs that work more effectively.

On Tue, Nov 10, 2015 at 11:00 AM, < pharmwaste-request at lists.dep.state.fl.us > wrote:
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Today's Topics:

1. RE: any good data on diversion? (Ed Gottlieb)
2. Re: RE: any good data on diversion?
(Yellow Jug Old Drugs Account Support)

---------- Forwarded message ----------
From: Ed Gottlieb <EGottlieb at cityofithaca.org>
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>
Cc:
Date: Tue, 10 Nov 2015 15:44:57 +0000
Subject: [Pharmwaste] RE: any good data on diversion?
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 3 rd 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

Deborah Hauser

Environmental Specialist

Division of Materials and Waste Management

614.728.5353

---------- Forwarded message ----------
From: Yellow Jug Old Drugs Account Support <info at greatlakescleanwater.org>
To: Ed Gottlieb <EGottlieb at cityofithaca.org>
Cc: "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>
Date: Tue, 10 Nov 2015 11:49:05 -0500
Subject: Re: [Pharmwaste] RE: any good data on diversion?
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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