[Pharmwaste] Do people leave meds outside your bins?

Lucy, Burke@CalRecycle Burke.Lucy at CalRecycle.ca.gov
Wed Mar 16 13:04:26 EDT 2016


Thanks Ed - great feedback!

Good point on HIPAA rules.  I know at least one pharmacy in California's Bay Area provided ziplock baggies on the collection bin to encourage people to consolidate their pills and reduce the volume but you're still not likely to get 100% of your drugs in baggies any more than you'll prevent all bullets, toys, and trash from getting dumped in.  I think the question is whether you codify that standard or leave it up to the individual location to follow their own best management practices like the DEA has allowed - in law enforcement locations for instance.

Burke

From: Ed Gottlieb [mailto:EGottlieb at cityofithaca.org]
Sent: Wednesday, March 16, 2016 5:05 AM
To: Lucy, Burke at CalRecycle <Burke.Lucy at CalRecycle.ca.gov>; 'DeBiasi, Deborah (DEQ)' <Deborah.DeBiasi at deq.virginia.gov>; 'pharmwaste at lists.dep.state.fl.us' <pharmwaste at lists.dep.state.fl.us>
Subject: RE: [Pharmwaste] Do people leave meds outside your bins?

Hi Burke,

1. I have read at least one news story about medications being left beside a full box.
2. You are correct that law enforcement doesn't have to follow all of the DEA rules.  They must follow their own procedures.  They can choose to use clear plastic inner liners or otherwise screen what has been collected.
3. Law enforcement is bound by HIPPA.  Unless access to the box was restricted to law enforcement, any view port must not allow personal information to be read on a prescription bottle.
4. Though labor intensive, the system you describe of having the police receptionist prescreen deposits sounds like a very effective way to keep unwanted items out and to encourage recycling.

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 [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Lucy, Burke at CalRecycle [Burke.Lucy at CalRecycle.ca.gov]
Sent: Tuesday, March 15, 2016 8:48 PM
To: 'DeBiasi, Deborah (DEQ)'; 'pharmwaste at lists.dep.state.fl.us'
Subject: Re: [Pharmwaste] Do people leave meds outside your bins?
Thanks Deborah, that's helpful.

I'm sure programs are limited by the collection bins they already have but as I'm reading them, the DEA regs seem to allow for collection receptacle view ports<http://cdn6.bigcommerce.com/s-hmxp9/product_images/uploaded_images/dvc0024-7-top.jpg?t=1410467249> at least so you can see how full it is and potentially what's in there.  The DEA says once they're deposited, drugs shall not be individually handled [§1317.75(c)<http://www.deadiversion.usdoj.gov/fed_regs/rules/2014/2014-20926.pdf>] but that's in the context of collectors, which excludes law enforcement.  The DEA discussion section says, "Law enforcement are encouraged to follow the guidance in 21 CFR 1317.35; however, they are not required to do so."  Otherwise, the DEA regs just say, "The contents of the inner liner shall not be viewable from the outside when sealed" [§1317.60(a)(3)<http://www.deadiversion.usdoj.gov/fed_regs/rules/2014/2014-20926.pdf>].  So, if they could see bad stuff through view ports, I suspect law enforcement could pick them out before the liner is sealed (although I'd be careful of sharps).

Burke

From: DeBiasi, Deborah (DEQ) [mailto:Deborah.DeBiasi at deq.virginia.gov]
Sent: Tuesday, March 15, 2016 3:56 PM
To: Lucy, Burke at CalRecycle <Burke.Lucy at CalRecycle.ca.gov<mailto:Burke.Lucy at CalRecycle.ca.gov>>; 'pharmwaste at lists.dep.state.fl.us' <pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>>
Subject: RE: [Pharmwaste] Do people leave meds outside your bins?

Hello, Burke -

    I'm not familiar with any pharmacies that have had this problem, but that doesn't mean it isn't happening.  I'm mostly familiar with the issues law enforcement have been having.

    A couple of the police stations that have collection boxes only allow for them to be accessed during normal business hours.  The box is located in their lobby and is locked, so the procedure is for a person to come into the lobby and tell the receptionist they want to drop off drugs.  The receptionist comes out with a clear plastic bin for the person to put their drugs in, so that the receptionist can make sure that only drugs are being disposed of.  The bin is then emptied into the collection box and the box is re-locked.

    When the police had the collection box accessible to the public without nearby scrutiny, they discovered that a lot of non-drug things were being tossed in.  They found trash, some garbage, kid's toys, and even ammo in the collection bag when they spot-checked it.  In the interest of safety, this was the procedure they came up with.   I have heard a lot of grumbling about the DEA requirement to use an opaque bag in the collection box, since the contents can't be visually screened for unacceptable and possibly dangerous items.
________________________________
From: Pharmwaste [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Lucy, Burke at CalRecycle [Burke.Lucy at CalRecycle.ca.gov]
Sent: Tuesday, March 15, 2016 5:59 PM
To: 'pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] Do people leave meds outside your bins?
Hi all,


1.       Do you know of any instances where customers left a bag of pills outside a collection receptacle if it's locked (e.g., because it's full or it's after hours in a grocery store pharmacy for instance)?

2.       How many pharmacies do you know this does and/or does not happen in?

Feel free to email me directly if you prefer.  California's Board of Pharmacy proposed regulations allowing pharmacies to accept take-back drugs, which includes this: "In hours when the pharmacy is closed, the collection receptacle shall not be accessible to the public for deposit of drugs. The pharmacy shall lock the deposit slot on the collection receptacle and physically block patients from access to the collection receptacle by some means" [§1776.3(a)<http://www.pharmacy.ca.gov/laws_regs/1776_proposed.pdf>].  I'm wondering how necessary or potentially onerous this requirement may be and their comment period is closing soon.

Thanks,

Burke


Mr. Burke Lucy
Environmental Scientist
Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street, PO Box 4025
Sacramento, CA 95812
Burke.Lucy at CalRecycle.ca.gov<mailto:Burke.Lucy at CalRecycle.ca.gov>
916.341.6592
[California Department of Resources Recycling and Recovery (CalRecycle)]<http://www.calrecycle.ca.gov/>
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