[Pharmwaste] New DOT requirement for authorized collectors

[Catherine Zimmer]

Hi Jeanie and all,

I just did a regulatory review for a client re: transport of waste
pharmaceuticals.  There may be some exemptions for your facility under
Materials of Trade or even under consumer commodity, but without knowing
more about the waste, I can’t say.  

 

Yes, employee training may or may not be free.  There are training modules
on the DOT’s PHMSA website.  

 

Very truly yours,

 

Catherine Zimmer, MS, BSMT

Reducing and managing healthcare related waste and costs for fifteen years.


Executive director, HEARRT Midwest

www.hearrtmidwest.wildapricot.org

Principal, Zimmer Environmental Improvement, LLC

St. Paul, MN 

Ph:  651.645.7509

 <mailto:zenllc at usfamily.net> zenllc at usfamily.net

 

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Jaramillo, Jeanie
Sent: Monday, July 11, 2016 10:55 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] New DOT requirement for authorized collectors

 

Hello All,

 

We have a permanent medication disposal receptacle at the pharmacy located
on our University campus. I assist with its management (and finding funding
for it!) We were recently notified that we are now required to obtain a DOT
permit in order to ship these med-containing boxes. I’m attaching a letter
from the DOT for your review and I’m hopeful that some of you are more
knowledgeable on this and can help. 

 

While the DOT permit has no related fee, the underlying theme seems to be
that the meds are considered “hazardous” and there is a statement that “Each
"Hazmat employee", as defined in § 171.8, who performs a function subject to
this special permit must receive training on the requirements and conditions
of this special permit in addition to the training required by §§ 172.700
through 172.704”. My guess is the training won’t be free. 

 

>From the DOT letter, it appears that this action has resulted from a request
by Stericycle. Yet, household generated pharmaceutical waste is exempt from
RCRA, so I’m at a loss. It also seems a conflict of interest that a medical
waste vendor has pushed for this. These are the same meds that mail order
companies are shipping to patients nationwide. 

 

This is yet another barrier to participation as “authorized collectors”. 

 

Any thoughts? 

 

Jeanie Jaramillo-Stametz, PharmD 

Managing Director, Texas Panhandle Poison Center

Asst. Professor, Texas Tech UHSC School of Pharmacy

Director, Medication Cleanout

1300 S. Coulter St., Suite 105

Amarillo, TX 79106

(voicemail): (806)414-9299

(poison center office): (806)414-9402; 9404

(mobile): (806)376-0039

 

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