Thanks, Christine!

 

 

 

The expired unused epinephrine auto injector pens are a dual waste or mixed medical waste that has special challenges because there aren’t many vendors authorized to handle the dual hazards presented by the waste.  It a dual waste because it has both the drug waste (hazardous waste unless proven exempted [CESQG] or partially exempted {universal waste], in which case it’s a liquid industrial by-product) and the sharps (medical waste).

 

I have been suggesting that schools consider purchasing their supplies through vendor who provide for proper disposal as part of their contract so they don’t have this end of life issue/cost that is not included in their budget.  It’d provide them with an immediately accessible disposal option to ensure compliance given these vendor provide reverse distribution to all of health care.

 

To help simplify management for schools for the initial year (where certain pharmaceutical companies gave free supplies), we (DEQ hazardous waste and medical waste program staff) jointly developed guidance specific to epinephrine auto injectors that MDE was to have distributed to their ISDs to help facilitate compliance.  Other resources that may be helpful for this topic are at www.michigan.gov/deqdrugdisposal.  Specifically, our pharmaceutical waste tutorial helps people understand the different regulations that apply to drug waste.  MDE makes this resource available on their School Health Web page (see medication management). 

 

If anyone has questions after reviewing the materials, please give me a call. 

 

Regards,

 

Christine Grossman, Compliance Assistance Specialist

Training and Outreach Unit, Office of Environmental Assistance, Michigan Department of Environmental Quality

Direct Phone: 517-284-6860

Environmental Assistance Center: 1-800-662-9278 or deq-assist@michigan.gov

 

 

     

 

 

 

                                                                                                                                                                                

 

 

 

 

 

Hello Everyone:

 

I have a question for all of you. I have been approached by schools twice in the past year about disposal of the unused EpiPens. Both schools have had about 15 left over which have become expired.

 

If they are used, then we would make an exception and direct them to our Sharps disposal program. However, that program wasn’t really intended for the disposal of unused EpiPens which still contain the drug and has potential to end up landfilled.

 

In the past we have not taken unused EpiPens through our Take Back Medications Program. I’m looking through the Federal Register now to see if this may be an option. Or if the reasoning is that it is a risk to the collection personal for the program.

 

It seems impractical to ask the schools to contract with a sharps disposal company for 15 EpiPens a year. My main question is what have you all directed the schools to do in this situation? As well as, have you heard anything about the manufacturers accepting the expired unused EpiPens back?

 

Your help would be appreciated.

 

Thank you,

 

Megan Kretz

Resource Recovery Specialist

616.632.7941 direct

616.644.3116 cell

616.632.7925 fax

 

 

 

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