[Pharmwaste] Liquid Pharmaceuticals

Jan Harris jharris at sharpsinc.com
Thu Mar 31 13:58:46 EDT 2016 

Schedules allowed is a posting requirement.

Jan Harris
Director, EHS
Sharps Compliance
Www.sharpsinc.com<http://www.sharpsinc.com>
Jharris at sharpsinc.com<mailto:Jharris at sharpsinc.com>
713-927-9956


Jan Harris | Director, Environmental Health & Safety

Sharps Compliance, Inc.
d- 713-927-9956 | o- 800-772-5657 | f- 713-660-3596

jharris at sharpsinc.com | <mailto:jharris at sharpsinc.com> http://www.sharpsinc.com

On Mar 31, 2016, at 12:00 PM, Volkman, Jennifer (MPCA) <jennifer.volkman at state.mn.us<mailto:jennifer.volkman at state.mn.us>> wrote:

Did you add that to help guide people or is there an actual DEA requirement to include that sort of indicator “Schedule II-V only” on the bins?

From: Ed Gottlieb [mailto:EGottlieb at cityofithaca.org]
Sent: Thursday, March 31, 2016 8:31 AM
To: Volkman, Jennifer (MPCA); pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: RE: Liquid Pharmaceuticals

Note:  To meet DEA requirements, we added stickers to the poster (not shown on the image I posted):
"Schedule II-V Controlled" for the "Yes" section and "Schedule I (illegal drugs)" for the "No" section.

The deposit door to our boxes have a decal with two universal red "NO" circles with diagonal lines.  One for sharps (image of syringe with needle), the other for mercury (image of thermometer).
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<mailto:pharmwaste-bounces at lists.dep.state.fl.us>] on behalf of Ed Gottlieb [EGottlieb at cityofithaca.org<mailto:EGottlieb at cityofithaca.org>]
Sent: Thursday, March 31, 2016 9:20 AM
To: Volkman, Jennifer (MPCA); pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: Re: [Pharmwaste] Liquid Pharmaceuticals
Ditto Jennifer and Deborah, there is no good reason for a program to not accept liquids.

Early on, I recall hearing an unsubstantiated concern that spilled liquids could react with other materials, causing the production of a hazardous gas.  The image of a police station being evacuated may have caused an excess of caution.  Such a scenario has never been reported and I've never read any theory of what theoretically might cause such an incident, even with the noted hydrogen peroxide.

Below is the poster that is mounted above our drop boxes.  Excerpts:
"Accepting: Liquid medication (leak proof containers)"
"Not Accepting:
Hydrogen Peroxide / Chemicals
Personal Care Products (Shampoo, lotions, etc.)"
[Probably should have used the word "moisturizers" rather than "lotions" since some lotions are medicated.]
<image003.jpg>

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<mailto:pharmwaste-bounces at lists.dep.state.fl.us>] on behalf of Volkman, Jennifer (MPCA) [jennifer.volkman at state.mn.us<mailto:jennifer.volkman at state.mn.us>]
Sent: Wednesday, March 30, 2016 7:34 PM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: Re: [Pharmwaste] Liquid Pharmaceuticals
I think someone said something once and a few people picked up on it and now we have conflicting messaging…who knows where it started.

There is no law against collecting liquids. There might be a presumption that they could get messy or leak, but all liquids should be in their original containers and inner totes should be lined if they are not leak proof.

There is no regulatory reason ointments/lotions/liquids/gels/creams can’t be collected. In MN, we allow unused syringes and inhalers to be collected, which are two other commonly prohibited items. DEA doesn’t care about liquids, they know that codeine cough syrup is in demand. I have commented on this before—that there are a couple of organizations that provide bins for free or purchase that are pre-printed with “no liquids”. Why? The MedReturns bins come with a pre-printed list of stuff that people shouldn’t put in bins (see picture below). Their website states that the list can be customized. The prohibition against hydrogen peroxide gets a nod due to incompatibility issues, but the vast majority of collectors don’t call that out. For MN, I prefer: no thermometers, no used sharps, no liquid chemo. If you look at images of medication bins on google, you will see that nearly every bin has a different list of prohibited materials. I encourage everyone to collect liquids. People like to dump liquids down the drain.

These two below appear to be made by the same manufacturer and they look like the free bins NADDI was giving out for a while that had a liquid prohibition printed on them. I originally thought they started it, but I don’t really know ☺ One prohibits mail, the other prohibits liquids. I’m not sure the biohazard sign is needed, maybe it makes people think they can put in IV’s and such...
<image004.jpg><image005.jpg><http://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&ved=0ahUKEwjdscCXw-nLAhVmhYMKHbcDAaAQjRwIBw&url=http%3A%2F%2Fwww.wxow.com%2Fstory%2F30283412%2F2015%2F10%2F16%2Fprescription-drug-drop-boxes-continue-to-provide-safe-disposal-of-medication&psig=AFQjCNGCs0O9qKCbhtR4g-wxTCg1xHGv8w&ust=1459463267653130>


<image006.jpg><http://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0ahUKEwi29ILJvunLAhWisIMKHYXGBDcQjRwIBw&url=http%3A%2F%2Fwww.newschannel10.com%2Fcategory%2F73756%2Fhealth-watch&psig=AFQjCNGCs0O9qKCbhtR4g-wxTCg1xHGv8w&ust=1459463267653130>

Pharms and sharps together! YES! ☺
<image007.jpg>

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of DeBiasi, Deborah (DEQ)
Sent: Wednesday, March 30, 2016 2:46 PM
To: Vickie Davis; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: Re: [Pharmwaste] Liquid Pharmaceuticals

            I have dealt with this issue in Virginia, and have found conflicting information as well.  Many of the metal drug collection boxes that law enforcement are using have “No Liquids” printed on them, along with other restrictions.  I suspect the ban on liquids was an attempt at preventing spills in the collection bags.  Law enforcement isn’t subject to a lot of the restrictions that DEA imposes, and certainly not subject to what’s printed on a collection box, so they can accept liquids if they want to.

            Law enforcement has the opportunity to see what citizens are dropping in the collection boxes during a drug collection event, whether it is DEA sponsored or local law enforcment sponsored.  The opportunity is there for the lids to be tightened on bottles of liquid medications to prevent leakage.  Most bottles are plastic these days, so that further reduces the potential for breakage.

            I have talked to the Covanta waste-to-energy incinerator folks enough to know that they don’t have a problem with getting liquids in the incinerators.  Knowing that, the only other issue that DEA may have is just to reduce cost on incinerating all the drugs collected at these take back events, since liquids add more weight than a similar volume of pills.

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 Vickie Davis
Sent: Wednesday, March 30, 2016 2:50 PM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] Liquid Pharmaceuticals

Hello,

My apologies if this has already been discussed as meds are not the major focus of my job, and I only skim the e-mails on pharmwaste.

I have someone who would like to dispose of pre-charged heparin syringes.  The police stations with daily take-back programs do not take liquid medicine.  This is understandable since it gets tossed into a box and glass could get broken or plastic squashed to splash medicine in the box.  So, I thought perhaps the annual DEA collections might be the answer.  I had already called the “big” pharmacy at our “big” hospital, and they are not going to take any meds, and it’s not legal in NH for them to do so.

I called DEA in Virginia and was told that the national DEA collections do not take liquid medicine.  The person I spoke with directed me to an EPA phone number.  I did not call as I assumed they would tell me to mix the liquid with something dry and throw it into the trash.  I then called the regional DEA office in New Hampshire and was told that the national program CAN take liquids.  I explained my previous conversation, and that it is not comfortable to share information if I don’t know for sure that everyone agrees that liquid can be taken.  I don’t want to send people to these annual or semi-annual collections with liquid medicine and have them turned away with not resolution about what to do with liquid meds.  I left a message for a guy at DEA who’s on vacation, but I suspect that my one voice is not going to make a change at DEA.

I then called a local police station to ask if they would accept liquids at the national collection.  This police station is in a little city (that’s all we have if they are cities at all in this rural neck of the woods) that services many towns.  The detective said that they already have a box through DEA and although they will participate in the national collection, the box states they cannot take liquid so they won’t take liquids at the national collection.  To get off the phone with me, he told me they would take liquid meds from this one person I’m trying to find a solution for.  This actually wasn’t helpful as the person lives away from here in Vermont.

My concern is not having a standard message at DEA which then gets shared with local police participating in the national collection.

Has anyone else encountered this issue?  It feels like a big hole in the drug takeback program.  I don’t think  the liquid meds should go in the landfill.  Is it possible to collectively or individually send a message to DEA or is it not a problem for you?  This type of unclear directive really frustrates me.

Thank you.

Vickie

Victoria Davis
Upper Valley Lake Sunapee Regional Planning Commission
10 Water Street, Suite 225
Lebanon, NH 03766
603-448-1680
603-448-0170 fax

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