[Pharmwaste] Liquid Pharmaceuticals

Sat Apr 2 17:00:56 EDT 2016

On 2016-04-02 14:44, Chris Angel wrote:
> 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>
>> 
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> 
> 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

One thing to note some states do have less stringent requirements. The 
strictest requirements would  be those from the NUP (referenced in link) 
or LIB if operating out of MI. Transporters of Liquid Waste including 
potentially liquid Rx-waste should follow the strictest of regulations.

Also note that while GLCW/USCW does take extra precautions to ensure 
that Rx-Waste liquid is made non liquid waste with the gel we are still 
credentialed under LIB to carry liquid waste. It's always best in our 
opinion to adhere to the strictest standards that exist. The credentials 
also provide for handling Haz waste as some states solid waste laws 
consider some Rx-Waste Haz. MN is one example so in order to transport 
Rx-waste in MN a Transporter must be credentialed  by NUP or LIB if 
operating out of MI.

Sincerely Yours

Chris Angel, President

Upon issuance of the Uniform Credentials, whether through the National 
Uniform Program or Michigan LIB (formerly LIW) Uniform Program, a copy 
of the credentials must be carried in all motor vehicles. The National 
Uniform Credentials must be carried when transporting hazardous waste or 
hazardous materials in the other states participating in the National 
Uniform Program.

-- 
Chris Angel, President

www.GreatLakes-US-CleanWater.org

www.YellowJugOldDrugsProgram.com