HomeMy WebLinkAbout05. Pharmaceutical Disposal Costs5.
Central Contra Costa Sanitary District
April 14, 2015
TO: REAL ESTATE, ENVIRONMENTAL AND PLANNING COMMITTEE
VIA: JEAN -MARC PETIT, DIRECTOR OF ENGINEERING hP
DANEA GEMMELL, ENVIRONMENTAL SERVICES MANAGER 05C3
FROM: DAVID WYATT, HHW PROGRAM SUPERVISOR
SUBJECT: PHARMACEUTICAL DISPOSAL COSTS
At the February 10, 2015 Real Estate, Environmental and Planning Committee meeting,
the Committee requested that staff develop a proposal for consideration to re- establish
pharmaceutical collection at the Household Hazardous Waste Collection Facility
( HHWCF).
History
Prior to 2005, the District's HHWCF collected and properly disposed of
pharmaceuticals, though this service was not advertised. In 2004, District staff, along
with staff from the East and West Contra Costa HHW programs, developed a
countywide informational flyer that described where medications could be taken for
disposal. Soon after it was discovered that it was illegal for HHW programs to collect
and handle controlled substances, so all collection at the District's HHWCF ceased.
In order to continue collecting medications, the Board approved the current program,
which collects pharmaceuticals from thirteen law enforcement operated sites,
representing each major community in the service area.
Operations
The following describes how collecting medication at the HHWCF could operate:
• When a customer requests to drop off medications, staff will roll out a. locked
one -way collection bin to the vehicle so that the customer can drop their
medication into the bin. Current practice is for customers to remain in their
vehicles to minimize liability at the HHWCF.
• Only senior technicians or the supervisor will exchange the inner collection
container when it is full.
N:XEnvrSeckAdmin1Wyatt14 -14 -15 REEP Memo - Pharma Collection at HHWCF.doc 1 of 3
• The collection container will be sealed and placed inside a lockable loss
prevention cabinet. Keys for the collection bin and the loss prevention cabinet will
only be issued to the two senior technicians and the supervisor.
• Transportation and disposal can be arranged by using the existing medical waste
contractor.
Costs
A collection bin, similar to the ones at the collection sites and a Loss Prevention Cabinet
is needed to lock and store full containers of medications until picked up by our medical
waste contractor. The cost is approximately $3,500.
Considerations
There are a number of things to consider if non - controlled medications are collected at
the HHW Facility:
Diversion — Only the senior technicians and supervisor should be allowed to
handle medications. However, as the amount of medications increase over time,
so will the likelihood of finding medications at the bottom of boxes mixed with
other wastes such as batteries, paint or cleaners. This will provide opportunities
for diversion of all three classifications of pharmaceuticals by staff or contract
staff handling other wastes. Diversion is possible for (1) over the counter
medications such as antihistamines; (2) prescribed medications (non - controlled
substances) such as Viagra or antibiotics; and (3) controlled substances such as
Vicodin or morphine.
2. Inadvertent Possession - In September 2014, The Drug Enforcement Agency
DEA) released new rules regarding pharmaceutical collection and disposal. In
the Discussion of Comments portion of the Federal Register 1 the following
statement was made:
C. Types of Entities That May Operate a Collection Program (9 Issues)
[5] Issue: Eight commenters asked the DEA to permit non - registrants to collect non -
controlled substances for the purpose of disposal.
Response: The DEA's authority regarding drug disposal is specific to pharmaceutical
controlled substances. Non - registrants may collect non - controlled substances pursuant
to all applicable Federal, State, tribal, and local laws and regulations; however, all
regulations and laws relevant to controlled substances will apply if controlled substances
are collected, even inadvertent/y.
If controlled substances are inadvertently accepted at the HHWCF, the District
would be in violation of DEA rules.
'September 9, 2014 Federal Register pg. 53529 http: / /www.gpo. og v /fdsys/ kkg /FR- 2014- 09- 09/pdf/2014- 20926.pdf
N:1EnvrSecXAdmin1Wyatt14 -14 -15 REEP Memo - Pharma Collection at HHWCF.doc 2 of 3
3. Theft or Break -in — The risk of an after -hours break -in at the HHWCF would be
low, but if the medication collection is advertised, thieves could see the HHWCF
as an easier target than one of the police station collection sites.
4. It was mentioned by one of the Committee members that an HHWCF in the
county collects medications. In the last few months, this HHWCF was the only
pharmaceutical drop off location in that portion of the County. Recently two other
collection sites at two police stations were opened which brings the total drop off
locations to three.
5. The legality surrounding the Alameda ordinance will soon be resolved. The
District is providing support to the Contra Costa County staff with the goal of
enacting a manufacture sponsored ordinance in Contra Costa County. Once in
place, then collection at the HHWCF would no longer be needed. The original
program was envisioned to become a manufacturer sponsored stewardship
program that would enlist pharmacies and other retail outlets to provide a
convenient collection system for the public.
In summary, while re- establishing pharmaceutical collection at the HHWCF can be
done, it poses risks relative to diversion, inadvertent possession of a controlled
substance and theft. Staff suggests waiting to hear on a possible Contra Costa County
sponsored ordinance. Therefore, staff does not recommend pursuing collection of
pharmaceuticals at the HHWCF at this time.
N:1EnvrSeclAdmin1WyattW -14 -15 REEP Memo - Pharma Collection at HHWCF.doc 3 of 3