[Pharmwaste] Fwd: Your Safer Alternative to the DEA Rule

Lawernce Kenemore Jr. ldkjr100 at gmail.com
Tue Nov 10 16:58:57 EST 2015


---------- Forwarded message ----------
From: Lawernce Kenemore Jr. <ldkjr100 at gmail.com>
Date: Tue, Nov 10, 2015 at 3:51 PM
Subject: Re: Your Safer Alternative to the DEA Rule
To: Ed Gottlieb <EGottlieb at cityofithaca.org>, Bill Shepherd <
billshep3 at yahoo.com>, Vi Brown <seniorvi1234 at gmail.com>, Steve Kenemore <
cadrefinancial at sbcglobal.net>, Ryan Steck <steck2003 at gmail.com>, David
Brace <dgbrace at gmail.com>, Ryan Steck <steck2003 at hotmail.com>, Corey
Schneider <mrccim at yahoo.com>, Brittany Kenemore <bkenemore at yahoo.com>,
Jenny Lange <jennyskyelange at gmail.com>, Jenny Lange <
jlangefillabox at gmail.com>, Cheryl Hill Kenemore <mimisweetdarlin at gmail.com>,
Helen Bearden <maliabearden at yahoo.com>, Milton Dallas <
m.dallas at c2r-globalmfg.com>


Ed
thanks for the input.  Yes you are right in looking at the website not
having the info.  As you saw though we by Friday should have the news
release available and the website up dated with the info.  However I can
tell you that the destruction by burning in our product has already
received qualification for Carbon Credit Exchange.
Yes you may be in an awkward position but inventors and private business is
not.  That is we have taken a different approach to this issue/problem.
That is the research shows that the pharmaceuticals-OTC-vitamins are
converted to an un-useable product and this product when burned for
electricity (which is already being accomplished) qualifies for carbon
credits.
The issue here is removing (as large a quantity as possible) from the
water/waste supply which is the looming problem.  As you know the EPA has
no current regulations for removal or even placing these items in the waste
stream or water supply.  THAT IS THE PROBLEM.  Saying that narcotics is the
problem is good press but those are only a small percentage of the problem
as you well know.  The percentages in the water supply is increasing daily,
 which affects everyone.
The product we are using has research and patent protection which is
provided.  With that said you will note that we also target OTC and
vitamins something your city water supply is grappling with.  Thanks for
your input and we do have you on our announcement list as soon as we have
the news release ready.



On Tue, Nov 10, 2015 at 3:33 PM, Ed Gottlieb <EGottlieb at cityofithaca.org>
wrote:

> Hi Larry,
>
> You protest listserv discussion of the DEA rule stating that, "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."  I presume you are referring to your disposal product.
>
> The DEA rule leaves us in an awkward position.  They mandate an
> non-recoverable standard, mentioning that incineration and chemical
> digestion meet the standard and flushing and trash disposal do not.  They
> go on to say they will not evaluate other technologies (or is it products?).
>
> Though reading research papers may have convinced me that activated
> carbon, used in the proper ratio and given enough time, will meet the DEA
> standard, most folks will only have a companies assurance that their
> product does.
>
> Looking at the FillAbox website, I didn't see a specific claim that it
> meets the DEA standard.  Did I overlook it?  If so, do you think FillAbox
> would consider offering a guarantee?  Perhaps a promise to pay all legal
> fees and fines should the government take action, on the basis of improper
> disposal of pharmaceuticals, against any home or corporate consumer using
> your product?  A guarantee might help close sales with potential
> customers.
>
> I (somewhat cynically) venture to say that even without any consideration
> of your products performance, a guarantee is probably a low risk action.
> The DEA has already told us they won't be checking.  What other agency
> will?  The longstanding lack of government resources for environmental
> protection/enforcement makes a challenge unlikely, in my opinion.
>
> 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
>
> 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 Lawernce Kenemore
> Jr. [ldkjr100 at gmail.com]
> *Sent:* Tuesday, November 10, 2015 3:36 PM
> *To:* pharmwaste at lists.dep.state.fl.us
> *Subject:* [Pharmwaste] Re: Pharmwaste Digest, Vol 121, Issue 8
>
> [image: New Box Logo 5-1_edited-1.jpg]
> *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:
>
>> Send Pharmwaste mailing list submissions to
>>         pharmwaste at 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 at lists.dep.state.fl.us
>>
>> You can reach the person managing the list at
>>         pharmwaste-owner at 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. 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 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
>>
>>
>>
>>
>>
>> [image:
>> 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 <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
>> >
>> >
>> > ---
>> > 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 at 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 at dep.state.fl.us
>> > SEND MAIL to the list server at:  pharmwaste at lists.dep.state.fl.us
>> >
>>
>>
>>
>>
>>
>>
>> ---
>> 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 at 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 at dep.state.fl.us
>> SEND MAIL to the list server at:  pharmwaste at lists.dep.state.fl.us
>>
>
>
-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20151110/cb293f92/attachment-0001.htm
-------------- next part --------------
A non-text attachment was scrubbed...
Name: attachment-1.jpeg
Type: image/jpeg
Size: 105127 bytes
Desc: not available
Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20151110/cb293f92/attachment-1-0001.jpeg
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image001.gif
Type: image/gif
Size: 6386 bytes
Desc: not available
Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20151110/cb293f92/image001-0001.gif


More information about the Pharmwaste mailing list