[Pharmwaste] 20,000 drug disposal pouches for WNY

Thu Aug 18 10:21:33 EDT 2016

Ed,

I applaud the effort for the UB Pharmacy School in helping the public to
alleviate unused/unwanted substances, however, I truly feel the public would
be better served by the utilization of drug collection kiosk receptacles at
local pharmacies authorized to collect and/or law enforcement due to the
process of incineration for end stage disposal.  Assured Waste Solutions
offers this type of service as well as a few other companies across the US.
The key is the state funding of this type of program as I am not aware of
any NY programs offering incentives to pharmacies for the installation of
kiosk receptacles.  I believe the majority of retail pharmacies would
participate in a drug collection kiosk receptacle program if there was
available funding, however, it is hard for a smaller pharmacy to justify
paying to get rid of ultimate users waste.

If ultimate users use the Deterra pouches, do they have to pay for
additional pouches when they have more unused/unwanted substances?  The
point is offering the public through state funding the ability to seemingly
"participate in a take back day everyday" at authorized collectors vs.
having to wait on additional pouches to include having to purchase these.  I
am certainly not advocating for the non-use of Deterra pouches as again,
this may make sense in certain circumstances, however, the public needs to
be offered additional options on a larger scale.

Best Regards,

Doug Bowman

cid:image001.png at 01D04167.051E8EB0

V.P. Operations

704-884-0008 Office

704-616-9528 Cell

704-865-7519 Fax

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Ed Gottlieb
Sent: Wednesday, August 17, 2016 4:04 PM
To: pharmwaste at lists.dep.state.fl.us
Cc: jmulcahy at Verdeenvirotech.com; marcener at buffalo.edu
Subject: [Pharmwaste] 20,000 drug disposal pouches for WNY

UB pharmacy school & Mallinckrodt partner to provide 20,000 Deterra drug
disposal pouches to Buffalo, NY.

http://www.buffalo.edu/news/releases/2016/08/021.html

I don't recall seeing this claim (in linked story above) before:

"With 30 seconds and a little warm water, the environmentally friendly
pouches deactivate pills, patches or liquid medications, rendering them safe
for landfills and easy to dispose."

On June 30th, I sent a long list of questions (below) to Verde Technologies,
the manufacturer of the Deterra (previously, "Medsaway") pouch.  On July 20,
the VP of Sales with Verde, told me he would have the answers sent right
over.  I emailed him a reminder a couple of days ago.  Still hoping to
receive documentation showing that this activated carbon adsorption system
is a viable disposal option that meets DEA requirements.  

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

I have a number of questions regarding the research done on MedsawayR, and
activated carbon in general, that I hope you can answer:

1.  You report deactivation results, for a number of medications, from
94.3-100% after seven days.  For Oxycontin, you report 99% within four days,
with the majority within one day.  Is day-by-day deactivation information
for the full range of tested medications available?  This relates to
questions 2, 3, & 5 below.  
2. Do the directions for MedsawayR instruct the user to place it in the
trash after it is sealed or do they suggest storing it securely for a period
of time before disposal?
3. Do you know of any ANSI, or similar, standard that applies to products
trying to meet the DEA definition of non-recoverable?  If a MedsawayR
package is diverted from the trash soon after it is filled, at least some
drugs will be recoverable.  Without an accepted standard, and with DEA being
on record as not willing to evaluate products, how can compliance with the
DEA standard be determined in such a situation?     
4. Is the once per day mixing methodology used in your experiments
representative what would be expected from the actual use of the product
(mixed when: first used, placed and transported in a garbage truck, dumped
at the land fill, and during trash compaction)? 

5. If the MedsawayR bag is torn before deactivation is complete, wouldn't
the medication containing liquid drain away from the activated carbon?  And,
in a landfill, wouldn't medication dissolved by rainfall flow downward, away
from the activated carbon?  In other words, is it reasonable to conclude
that in real world conditions, the product is not likely to deactivate a
significant amount of any remaining medication once the bag is broken and
the liquid drained?
6. Do the tested medications include examples of all pill/capsule types or
might there be some untested varieties that are slower to dissolve in water?
7. You report that "little of the original drug [Fentanyl] content was
recovered from activated carbon using water and alcohol.  Can you please
tell me what percent is a "little"?  
8. Would pulverizing the activated carbon effect the amount of drug
recovered?
9. Did you try to extract drugs other than Fentanyl and, if so, what were
the results?  
10. Is it possible that other solvents would be more effective at
extraction?
11. Has it been established that there are no drugs that can be extracted
from activated carbon by heating?  Your description of the carbon
reactivation process seems to indicate that if a drug becomes volatile when
heated to 100-649 degrees C, it could be extracted.         
12. The amount of activated carbon provided has obviously been calculated to
be more than enough to deactivate 30 pills, the number tested.  Apparently
[http://www.mallinckrodt.com/corporate-responsibility/safe-drug-disposal],
the directions say it is designed to inactivate 10-15 pills.  If usage
directions are not followed, have you determined the percent deactivation
for a worst case scenario, where the MedsawayR bag is totally filled with
more than 30 pills?
13. Do you know why MedsawayR was scaled to this capacity?  It is my
experience, from running take back events, that even regular take back users
bring, on average, more that one pound of drugs for disposal.  This is
clearly many times the capacity of a MedsawayR bag. 

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