[Pharmwaste] RE: draft Letter to the Editor

veora little veoralittle at gmail.com
Fri Feb 27 09:22:33 EST 2015


I thank you too Ed.  Often up at 3 am Ed always has something articulate
and pertinent to say.  He inspires and educates all of us.  Repetition is
good and so is our mission to make the world a cleaner place!  Sincerely,
Veora Little


*veoralittle at gmail.com <veoralittle at gmail.com>*
*home 239-649-6042, cell 239-450-2883*




On Thu, Feb 26, 2015 at 2:16 PM, Jan Harris <jharris at sharpsinc.com> wrote:

>   Thank you Ed. There is lots of confusion about the DEA rule we hear
> every day from all the industries involved, including law enforcement. It
> helps to hear a clear explanation as often as possible.
>
>
>
> Jan Harris | Director, Environmental Health & Safety
>
> Sharps Compliance, Inc.
> d- 713-927-9956
>
> jharris at sharpsinc.com | <jharris at sharpsinc.com>http://www.sharpsinc.com
>
>      *From:* pharmwaste-bounces at lists.dep.state.fl.us [mailto:
> pharmwaste-bounces at lists.dep.state.fl.us] *On Behalf Of *Ed Gottlieb
> *Sent:* Thursday, February 26, 2015 1:02 PM
> *To:* James Steinmetz; Kris Bennett; James Landon; Thomas Boyce; Dan
> Ramer; John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; David
> Honan; Jeffery Montesano; Kathy, Zoner; MargaretRyan; Jackie; Tom Ferretti;
> Kristin Stevens; Tim Williams; Terri, Stewart;
> pharmwaste at lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau
> Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek
> Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan
> Dunlop; Ann Rider
> *Subject:* [Pharmwaste] RE: draft Letter to the Editor
>
>
>
> Thanks James.
>
> As I mentioned in my follow-up email, I now realize it is not my place to
> send this letter to the editor.
> I will, for the second time, suggest to the DEA that they consider doing
> outreach to law enforcement about the new rule.
>
>
> Sorry to have bothered all of you with this!
>
> 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:* James Steinmetz [JSteinmetz at cayuga-heights.ny.us]
> *Sent:* Thursday, February 26, 2015 1:32 PM
> *To:* Kris Bennett; James Landon; Thomas Boyce; Dan Ramer; Ed Gottlieb;
> John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge; David Honan;
> Jeffery Montesano; Kathy, Zoner; MargaretRyan; Jackie; Tom Ferretti;
> Kristin Stevens; Tim Williams; Terri, Stewart;
> pharmwaste at lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau
> Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek
> Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan
> Dunlop; Ann Rider
> *Subject:* RE: draft Letter to the Editor
>
> Ed,
>
> First I would ask what area you are responsible for.  If these infractions
> are occurring under someone else’s responsibility then they should be the
> person making contact.  Second, if these infractions have already been
> addressed once by you, or the appropriate chair, then I would contact the
> DEA since they are the enforcement agency.
>
> Just my $00.02,
>
> Jim
>
>
>
> James M. Steinmetz
>
>    Chief of Police
>
>
>
> Cayuga Heights Police Department
>
> 836 Hanshaw Road
>
> Ithaca, NY 14850
>
> 607-257-1011
>
>
>
> *From:* Kris Bennett [mailto:kmbennett at tompkins-co.org
> <kmbennett at tompkins-co.org>]
> *Sent:* Thursday, February 26, 2015 1:08 PM
> *To:* James Landon; James Steinmetz; Thomas Boyce; Dan Ramer; Ed
> Gottlieb; John Barber; Josephine Flomerfelt; Mike Gray; Chuck Alridge;
> David Honan; Jeffery Montesano; Zoner Kathy; MargaretRyan; Jackie; Tom
> Ferretti; Kristin Stevens; Tim Williams; Stewart Terri;
> pharmwaste at lists.dep.state.fl.us; Melinda Case; William Finnerty; Beau
> Saul; Mike McLellan; Joyce Billing; Beth harrington; Cindy Schulte; Derek
> Osborne; Jody Coombs; Ken Lansing; Marcia Lynch; Patricia Buechel; Susan
> Dunlop; Ann Rider
> *Subject:* Re: draft Letter to the Editor
>
>
>
> I saw both your emails Ed but will reply to this one since it contains
> your draft letter.
>
>
>
> I think it's a good idea to send the letter and to include the fact
> that people may not be aware of all the rules, especially about siting the
> boxes securely inside.  I suggest you scale back the length of the letter
> and focus on your #1 & # 2 points.  If all the rules are available
> electronically somewhere, include a link to them to make it easier for
> people to access them.  Including the law and section number is less
> useful.
>
>
>
> Kris
>
>
>
>
>
> >>> Ed Gottlieb <EGottlieb at cityofithaca.org> 2/26/2015 10:00 AM >>>
>
> Inspired by yet another news story of a law enforcement drop box being
> installed outside their station, in violation of the new DEA rule, I wrote
> a letter to the editor (below.)  After incorporating your good suggestions,
> I plan on sending it to two or three of the most widely read law
> enforcement publications.
>
> I'd welcome your editorial suggestions and your advice on which
> publications to submit it to.
>
> Publications I found:  Police Chief Magazine; Police; Law & Order;
> Sheriff; Law Officer; APB
> Thanks!
>
> Ed
>
>
>
> *Pharmaceutical Drop Box Programs Need Review *
>
>
>
> Providing the public with convenient ways to dispose of unwanted
> medications, especially controlled substances, is an important public
> service.  Removing unwanted pharmaceuticals from homes decreases the
> likelihood of illegal diversion, accidental overdose, and environmental
> contamination.
>
>
>
> After the DEA established the Take Back Initiative, what had been a small
> number of existing law enforcement collection events quickly multiplied.
> The ninth and final DEA event, on September 27, 4014 should be 2014,
> included 4,076 agencies collecting 309 tons of unwanted medications at
> 5,495 sites in just four hours!
>
>
>
> To increase disposal convenience, a steadily growing number of law
> enforcement agencies (and pharmacies, for non-controlled collection) have
> installed permanent drop boxes at their locations.  Thanks to wide
> community support, and some limited funding from state agencies and others,
> new drop boxes continue to be installed.
>
> Kudos to all of you that have taken the lead on this important issue!
>
>
>
> Are you aware that your drop box program may need to be modified to be
> compliant with recent changes to federal take back rules?  This letter was
> inspired by reading multiple stories of new drop boxes being installed that
> are in violation of a new federal rule.
>
>
>
> Late in 2014, the DEA issued a rule regulating the take back of controlled
> substances.  The big change is that pharmacies can now apply to take back
> controlled pharmaceuticals.  Since the rule does not require participation,
> and provides no funding, it may be quite some time before a pharmacy near
> you participates.  Law enforcement programs remain the primary method for
> safe disposal.
>
>
>
> As an aside, I want to mention that once the new rule was in place, the
> DEA announced the end of the hugely successful Take Back Initiative.  That
> decision has left many law enforcement agencies struggling to find the
> funding needed to keep their one day and/or drop box collection programs
> going.  It is going to be a tough transition time.
>
>
>
> Back to the point...the rule also specifies how law enforcement collects
> controlled substances.  Please take the time to make sure your program is
> in compliance with the new rule.  Here are a few details, specific to law
> enforcement, which should be part of your review check list.
>
>
>
> 1. Boxes must be *inside *law enforcement buildings.  They are looking
> for active monitoring.
>
> § 1317.35 Collection by law enforcement. (3) Collection receptacles
> located *inside law enforcement's physical address*.   Also:
>
> § 1317.75 Collection receptacles (d) (1) Inside a collector's registered
> location, *inside law enforcement's physical location*, or at an
> authorized long-term care facility;
>
>
>
> 2. They must be securely placed so that they cannot be removed, typically
> bolted to the floor and/or wall from inside the box.  [§ 1317.75 (e) (1)]
>
>
>
> 3. Signage must indicate that Schedule II-V controlled and non-controlled
> substances are acceptable and that Schedule I controlled is not. [§ 1317.75
> (e) (4)].  *(I had to add this wording to my programs signage using
> stickers.) *
>
>  4. Collected medications must be, “stored in a manner that prevents the
> diversion of controlled substances and is consistent with that agency's
> standard procedures…” [§ 1317.35 (c)]  *(We wrote an SOP specifying that
> inventory of the contents was not necessary.  It isn't practical to
> routinely identify and count all the controlled substances received from a
> take back program.  This also clears to way to be in compliance with state
> accreditation rules.) *
>
>
>
> 5. The box must contain an opaque inner liner that, upon removal, must be
> labeled as specified in your departments SOP.  If custody is to be
> transferred to a reverse distributor, a specific list of labeling
> requirements must be followed. [§ 1317.35]
>
>
> For those of you holding take back events, you can authorize non-law
> enforcement personnel to assist with required, and voluntary, activities
> including: receiving, weighing, separating controlled from non-controlled,
> removing unacceptable items (sharps, mercury), inventorying, etc.
> [Executive Summary: J. Prohibition on Handling, Sorting, and Inventorying
> Inner Liner Contents and Mail-Back Package Contents; Response to Issues 2 &
> 3,]
>
>
>
> If you have any questions about the rule, you should contact your DEA
> field office.  I’d also be happy to try and answer your questions.  Please
> let me know if your DEA field office says something in conflict with your
> reading of rule.  Thanks!
>
>
>
> Keep up the good work!
>
>
>
> 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
>
>
>
>    [COLLECT/PROTECT/RESPECT]
>  Sharps Compliance repurposed an estimated 758 million syringes into a
> material powering over 250 homes per year and collected 320,000 pounds of
> unused medications, reducing potential harm to citizens and the earth.
>
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