[Pharmwaste] New DOT requirement for authorized collectors

[Jaramillo, Jeanie]

The wastes are pharmaceuticals from households. We actually can't characterize them because the DEA prohibits going through these items.

Thank you for your information. I'll do some more digging.

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

From: Catherine Zimmer [mailto:zenllc at usfamily.net]
Sent: Monday, July 11, 2016 11:13 AM
To: Jaramillo, Jeanie; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] New DOT requirement for authorized collectors

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<http://www.hearrtmidwest.wildapricot.org>
Principal, Zimmer Environmental Improvement, LLC
St. Paul, MN
Ph:  651.645.7509
zenllc at usfamily.net<mailto: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<mailto: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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