[Pharmwaste] Collection Receptacles/Inner Liners New DEA Regs

Ed Gottlieb egottlieb at cityofithaca.org
Wed Jan 30 08:50:57 EST 2013

I'm wondering if anyone else would join me in requesting a tweak to the proposed new regulations for inner liners?
We line our drop-boxes reusable, removable tote with a black plastic bag.  When full, the bag is lifted out, taped shut, and placed inside a hinged lid plastic storage container.  This container is sealed with a numbered zip-tie.  
Though our system meets the spirit of the proposed new regulations, the current wording would require us to change procedures so the bag rather that the bin is labeled.  I will be requesting a wording change to broaden the securely sealed and uniquely ID'ed requirements.
If current wording remains, do you think our numbered zip-tie could be used to seal the bag closed?  Then we would leave the storage bin unsealed.  Or, would it be better to shop for a non-removable bar code or numbered sticker large enough to seal the plastic bag or we could seal the bag with evidence tape and attach a separate ID sticker for each bag.
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

>>> "Chris Angel" <info at greatlakescleanwater.org> 1/29/2013 5:29 PM >>>
Regarding Collection Receptacles. In addition to the New Proposed DEA Regulations for receptacles mentioned previously, DEA is proposing New Regulations for the inner liner of containers. Details can be found on pages 125-127 of the proposed Rules. Entities looking at purchasing collection receptacles should inquire with collection receptacle manufacturers how their products address those new requirements for inner liners as well as the new requirements for  the Collection Receptacles.

Our system will be using barcode identification and tracking of all Jugs/inner liners with an outer container meeting all  requirements of the proposed rules.

Chris Angel,President
Great Lakes Clean Water Organization
Yellow Jug Old Drugs program

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