[Pharmwaste] Medsaway® references

[Ed Gottlieb]

I was asked to provide the documentation behind my questions to the employee, William Fowler, who did some of the research on Deterra's Medsaway® product.

It is a follow the links game:
http://www.prnewswire.com/news-releases/mallinckrodt-donates-one-million-drug-deactivation-pouches-to-support-us-fight-against-prescription-drug-abuse-300286092.html
to:
http://www.mallinckrodt.com/corporate-responsibility/safe-drug-disposal
to:
http://deterrasystem.com/
to:
http://deterrasystem.com/research/

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: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Ed Gottlieb
Sent: Thursday, June 30, 2016 2:00 PM
To: sales at verdeenvirotech.com
Cc: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Atten: William Fowler

Dear Mr. Fowler,

Thank you for providing documentation regarding the effectiveness of the Medsaway® product.  No other medication disposal product that I've seen provides nearly as much.  It is my opinion that having multiple, effective disposal methods is a very good thing!

I have a number of questions regarding the research done on Medsaway®, 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 Medsaway® 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 Medsaway® 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 Medsaway® 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 Medsaway® bag is totally filled with more than 30 pills?
13. Do you know why Medsaway® 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 Medsaway® bag.

Thank you very much for your assistance!

Sincerely,
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

________________________________

This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee(s), or the person responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this electronic mail message in error, please contact us immediately at (617) 646-7800 and take the steps necessary to delete the message completely from your computer system. Thank you,

Please visit ERM's web site: http://www.erm.com
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20160630/4d42ea73/attachment.html>