[Pharmwaste] DEA limits drugs?

Thu Jul 28 17:03:30 EDT 2016

There was a bit of discussion on this a few months ago. Someone suggested no liquids was based on transport restrictions, but that isn't the case according to DOT or DEA. In our most recent guidance for pharmacies, we note that the collector needs to understand what the end facility can or cannot accept. Sometimes the transporter and end facility are the same company and it is possible they can't accept liquids, aerosols and/or sharps. I have argued to be as inclusive as possible to make it less complicated for HH. I also understand that some may need to limit volume, but since there are liquid CS and antibiotics/endocrine disruptors, I'd suggest educating people to mix all of their solid OTC medications together in a baggie to save space and I think those containers are more often recyclable than prescription containers. Lotsa ways to build a road, I guess.

Walgreens has contacted us and is filing their paperwork to establish collection bins in MN. They are being very aggressive at getting these set up, so that is super great! We've also had good response from our HMO's. I'm hoping the others follow, we'll see.

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Ed Gottlieb
Sent: Thursday, July 28, 2016 2:21 PM
To: Seery, Scott, Env. Health; 'DeBiasi, Deborah (DEQ)'; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] DEA limits drugs?

The Sheriff wrote to clarify:
We were provided information about the DEA and what they would accept as part of the National Prescription Drug Take Back Initiative and what they will [not] accept.
Some of the information in the release that was put out involves operational changes I wanted made due to the significant increase in the amount of time my Office was spending going through everything that was being dropped off.

I surveyed many other Ohio Sheriffs' and what they were doing in regard to accepting meds.  I then used all the information I received from all agencies and determined the best way for my Office to proceed.
It seems his operational changes were mistakenly reported as changes to the DEA rule.  I thanked the Sheriff for clarifying.

Sent him documentation showing that the DEA does not require, "going through everything that was being dropped off."  Without that burden, maybe the new restrictions will not be necessary.

It is possible he does the inventory to meet State Accreditation rules.  That was the case in NY until we lobbied to have the rule clarified to exempt take back from the inventory requirement.

It is also possible that Scott is correct and the changes, "reflect limitations of their service provider to ship certain items, or concerns about costs due to the weight of liquids".

Yesterdays excellent PSI webinar, "New Department of Transportation Special Permit for Collected Pharmaceuticals"* made it clear how easy the DOT has made shipping unwanted pharmaceuticals, with minimal "limitations", using common carrier.  Some states may still have more stringent requirements.

* PSI has made this webinar available at: http://www.productstewardship.us/page/20160727_NDOTSPFCP

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
________________________________
From: Seery, Scott, Env. Health [scott.seery at acgov.org]
Sent: Thursday, July 28, 2016 2:39 PM
To: 'DeBiasi, Deborah (DEQ)'; Ed Gottlieb; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: RE: DEA limits drugs?
Might it reflect limitations of their service provider to ship certain items, or concerns about costs due to the weight of liquids?

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of DeBiasi, Deborah (DEQ)
Sent: Thursday, July 28, 2016 10:48 AM
To: Ed Gottlieb; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: Re: [Pharmwaste] DEA limits drugs?

            My contacts at the DEA said that there have been no changes mandated by the DEA.  The sheriff mentioned in the article collects medications with a static drug collection box and may have storage space constraints.  It's unfortunate that his recommendations were attributed to the DEA.

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 Ed Gottlieb
Sent: Wednesday, July 27, 2016 3:36 PM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] DEA limits drugs?

The story linked here:
http://www.thevwindependent.com/news/2016/07/dea-limits-drugs-that-can-be-turned-in/
says the Van Wert Co. (OH) Sheriff, "announced new limitations to the U.S. Drug Enforcement Agency's (DEA) Prescription Drug Turn-In program."

"The sheriff's office will no longer be able to accept liquid medications, new or used needles or syringes, or other non-pill forms of medication, although Sheriff Riggenbach said his office would continue to accept medications in pill form."  Has anyone else heard of any changes (no liquid medications, or other non-pill forms of medication) to the DEA rule or is someone there misinterpreting it?  The DEA rule didn't permit sharps in the first place so that change couldn't have come from them.

The Sheriff is also asking that pills be removed from bottles and blister packs.  That request might be the result of limited storage space.  Sadly, any additional limits, mandatory or requested, will likely discourage participation.  I know from experience that removing a large number of pills from blister packs can be quite onerous.

I've left the Sheriff a message thanking him for doing take back and asking where he got this new information.  I haven't heard back.

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
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