[Pharmwaste] Liquid Pharmaceuticals

Sat Apr 2 16:44:04 EDT 2016

On 2016-04-02 09:39, Volkman, Jennifer (MPCA) wrote:
> Thanks Margaret, I agree. Less prohibitions also simplifies the
> message to the public, which is important. I was interested to read
> that liquids are regulated more stringently because I have worked in
> the field for many years and hadn't heard they were. I asked our local
> HW contractor who is also utilized as a reverse distributor, if there
> were regulatory differences between shipping liquids and solids. I
> received this response:
> 
> Hello Jennifer.
> 
> We are unaware of more stringent RCRA regulations for liquid vrs.
> solid pharms. The only change would be per DOT with change in shipping
> name to LIQUID designation. Please let us know if you have any
> specific examples and we would be happy to evaluate.
> 
> So, I think it gets back to possible common carrier restrictions for
> the amount of liquids in a package? I don't know if there is such a
> thing, but others have mentioned it. Can someone from a mail back
> program comment with specifics vs. generalities? Otherwise, I could
> look up what USPS, FedEx, UPS or others require. I'd really like to
> know details because you know they must be shipping liquids to people
> all the time (wine of the month club, no I'm not a member:). It might
> be different for "wastes". Clearly I think collection of liquids is
> important and I'd like to get the facts so people can be more
> inclusive if they'd like to be.
> 
> Have a great weekend all!
> Jennifer Volkman
> Statewide HHW Program Manager
> MN Pollution Control Agency
> 
> 
> ________________________________________
> From: Pharmwaste [pharmwaste-bounces at lists.dep.state.fl.us] on behalf
> of Margaret Shield [margaret.shield at cehstrategies.com]
> Sent: Friday, April 01, 2016 9:13 PM
> To: pharmwaste at lists.dep.state.fl.us
> Subject: Re: [Pharmwaste] Liquid Pharmaceuticals
> 
> An interesting dialogue as always.  In my experience in the Northwest
> corner of the country, most medicine take-back programs accept
> medicines in any form including liquid, gels, and creams.  It’s the
> exception that exclude liquids. For all the reasons cited, it’s good
> practice to accept liquid medicines.
> 
> I would like to add the public health rationale for WHY it is very
> important to collect liquid medicines to help reduce the ongoing and
> growing abuse of both over-the-counter and prescription cough syrups.
> If you’re not aware of this problem, talk to your local substance
> abuse prevention groups, especially those that work with youth. And
> see this info on NIDA’s website:
> https://www.drugabuse.gov/publications/drugfacts/cough-cold-medicine-abuse
> If NIDA’s info surprises you – google for “purple drank” or “lean” and
> you’ll be further surprised about this very real problem in our
> communities.
> 
> A number of states have passed laws prohibiting the sale to minors of
> OTC cough syrups containing dextromethorphan. That’s an important
> measure to combine with making medicine take-back options for both
> prescription and over-the-counter medicines more available.
> 
> Margaret Shield, PhD
> Community Environmental Health Strategies, LLC
> margaret.shield at CEHstrategies.com<mailto:margaret.shield at CEHstrategies.com>
> mobile:  206-499-5452
> 
> 
> From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On
> Behalf Of DeBiasi, Deborah (DEQ)
> Sent: Wednesday, March 30, 2016 12:46 PM
> To: Vickie Davis <vdavis at uvlsrpc.org>; pharmwaste at lists.dep.state.fl.us
> Subject: Re: [Pharmwaste] Liquid Pharmaceuticals
> 
>             I have dealt with this issue in Virginia, and have found
> conflicting information as well.  Many of the metal drug collection
> boxes that law enforcement are using have “No Liquids” printed on
> them, along with other restrictions.  I suspect the ban on liquids was
> an attempt at preventing spills in the collection bags.  Law
> enforcement isn’t subject to a lot of the restrictions that DEA
> imposes, and certainly not subject to what’s printed on a collection
> box, so they can accept liquids if they want to.
> 
>             Law enforcement has the opportunity to see what citizens
> are dropping in the collection boxes during a drug collection event,
> whether it is DEA sponsored or local law enforcment sponsored.  The
> opportunity is there for the lids to be tightened on bottles of liquid
> medications to prevent leakage.  Most bottles are plastic these days,
> so that further reduces the potential for breakage.
> 
>             I have talked to the Covanta waste-to-energy incinerator
> folks enough to know that they don’t have a problem with getting
> liquids in the incinerators.  Knowing that, the only other issue that
> DEA may have is just to reduce cost on incinerating all the drugs
> collected at these take back events, since liquids add more weight
> than a similar volume of pills.
> 
> Deborah DeBiasi
> 804-698-4028
> Deborah.DeBiasi at deq.virginia.gov<mailto:Deborah.DeBiasi at deq.virginia.gov>
> 
> From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On
> Behalf Of Vickie Davis
> Sent: Wednesday, March 30, 2016 2:50 PM
> To: 
> pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
> Subject: [Pharmwaste] Liquid Pharmaceuticals
> 
> Hello,
> 
> My apologies if this has already been discussed as meds are not the
> major focus of my job, and I only skim the e-mails on pharmwaste.
> 
> I have someone who would like to dispose of pre-charged heparin
> syringes.  The police stations with daily take-back programs do not
> take liquid medicine.  This is understandable since it gets tossed
> into a box and glass could get broken or plastic squashed to splash
> medicine in the box.  So, I thought perhaps the annual DEA collections
> might be the answer.  I had already called the “big” pharmacy at our
> “big” hospital, and they are not going to take any meds, and it’s not
> legal in NH for them to do so.
> 
> I called DEA in Virginia and was told that the national DEA
> collections do not take liquid medicine.  The person I spoke with
> directed me to an EPA phone number.  I did not call as I assumed they
> would tell me to mix the liquid with something dry and throw it into
> the trash.  I then called the regional DEA office in New Hampshire and
> was told that the national program CAN take liquids.  I explained my
> previous conversation, and that it is not comfortable to share
> information if I don’t know for sure that everyone agrees that liquid
> can be taken.  I don’t want to send people to these annual or
> semi-annual collections with liquid medicine and have them turned away
> with not resolution about what to do with liquid meds.  I left a
> message for a guy at DEA who’s on vacation, but I suspect that my one
> voice is not going to make a change at DEA.
> 
> I then called a local police station to ask if they would accept
> liquids at the national collection.  This police station is in a
> little city (that’s all we have if they are cities at all in this
> rural neck of the woods) that services many towns.  The detective said
> that they already have a box through DEA and although they will
> participate in the national collection, the box states they cannot
> take liquid so they won’t take liquids at the national collection.  To
> get off the phone with me, he told me they would take liquid meds from
> this one person I’m trying to find a solution for.  This actually
> wasn’t helpful as the person lives away from here in Vermont.
> 
> My concern is not having a standard message at DEA which then gets
> shared with local police participating in the national collection.
> 
> Has anyone else encountered this issue?  It feels like a big hole in
> the drug takeback program.  I don’t think  the liquid meds should go
> in the landfill.  Is it possible to collectively or individually send
> a message to DEA or is it not a problem for you?  This type of unclear
> directive really frustrates me.
> 
> Thank you.
> 
> Vickie
> 
> Victoria Davis
> Upper Valley Lake Sunapee Regional Planning Commission
> 10 Water Street, Suite 225
> Lebanon, NH 03766
> 603-448-1680
> 603-448-0170 fax
> 
> Visit our Household Hazardous Waste web site at
> http://hhw.uvlsrpc.org<http://hhw.uvlsrpc.org/>
> Visit our Waste web site at 
> http://waste.uvlsrpc.org<http://waste.uvlsrpc.org/>
> Visit the Healthy Home Facebook Page at
> www.Facebook.com/HealthyHomeProgram<http://www.facebook.com/HealthyHomeProgram>
> 
> Join our Mailing
> List<http://visitor.r20.constantcontact.com/d.jsp?llr=7jf5uhcab&p=oi&m=1101915952444>
> [facebook]<http://www.facebook.com/UVLSRPC>
> ü Please consider the environment before printing this e-mail. P
> 
> 
> 
> ---
> 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

See link below for Michigan's regs for handling liquid  waste. This is 
just one state example. And yes there is a great deal of difference in 
handling and shipping waste as opposed to  product that is not 
considered waste

And of course handled appropriately Rx-Waste liquid can and should be 
collected even if transporters need to meet certain requirements state 
and federal.

https://www.michigan.gov/deq/0,4561,7-135-3312_7235-8840--,00.html
-- 
Chris Angel, President

www.GreatLakes-US-CleanWater.org

www.YellowJugOldDrugsProgram.com