[Pharmwaste] DEA limits drugs?

Fri Jul 29 09:59:45 EDT 2016

Heidi,

In response to the customer you noted in Citrus Heights, CA, the pharmacy
staff should be responsible for monitoring the fill levels of the kiosk
receptacle.  The bigger question is once filled, how is the closed liner/box
being shipped for destruction to the reverse distributor.  If the customer
is utilizing a reverse distributor that offers receptacle mail back via
common carrier (UPS), then the pharmacy staff should be able to package the
full liner/box by sealing the container, then place a UPS return label on
provided by the Reverse Distributor and send back same day or next day to
alleviate storage issues.  The pharmacy would order a plethora of additional
bundles (box, liner, etc.) so there is always back up to place in the kiosk
receptacle thus alleviating the frustration from the public (ultimate
consumers) which should not be turned away.  I currently have pharmacy
customers in CA that have no issues with turning consumers away due to
overfill.

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 Heidi Sanborn
Sent: Thursday, July 28, 2016 7:40 PM
To: Volkman, Jennifer (MPCA); Seery, Scott, Env. Health;
pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] DEA limits drugs?

Walgreen's deserves a LOT of credit for stepping up but be careful and
monitor the bins before you promote them!

One in Citrus Heights CA  just northeast of Sacramento is locking the bin up
12 days out of 14 because they are being emptied every other week and the
bin is filling every two days according to the pharmacy staff.   Pharmacy
staff say they have no control when the bin is emptied. That leaves a lot of
frustrated customers getting turned away and we are getting calls and
complaints about it.  I let Walgreen's know but without more participation
by other retailers or more Walgreen's stores, these bins are being
overwhelmed even with minimal promotion.

Heidi

Heidi Sanborn | Executive Director

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        916-706-3420  | c: 916-402-3911 

                        heidi at calpsc.org 

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From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Volkman, Jennifer (MPCA)
Sent: Thursday, July 28, 2016 2:04 PM
To: Seery, Scott, Env. Health <scott.seery at acgov.org>;
pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] DEA limits drugs?

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
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
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

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
Subject: [Pharmwaste] DEA limits drugs?

The story linked here:
http://www.thevwindependent.com/news/2016/07/dea-limits-drugs-that-can-be-tu
rned-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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