Mark Caverly’s Post

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Sr. Consultant, U.S. Compliance Solutions (formerly BuzzeoPDMA) at IQVIA

Calling All Comments – DEA's Controlled Substance Destruction Alternatives ANPRM A quick check of regulations.gov this afternoon (2/22/2024) for DEA’s Advance Notice of Proposed Rulemaking (ANPRM) regarding controlled substance destruction alternatives revealed a scant thirty comments posted. As you may recall, DEA is “seeking information about destruction processes which may be used to render controlled substances to a non-retrievable state.”  DEA extended the comment period to the ANPRM until on or before April 1, 2024. Ten questions compose the bulk of the notice and help shape the issue, DEA’s interest, and your response. This is a challenging concept that has been under consideration for a long time. I strongly encourage those in industry, particularly the research and development community, to share your experience and practices to assist DEA in this issue. Comments can be made electronically, and any proprietary information redacted. Here's a link to the ANPRM with its blue “Comment” button: https://lnkd.in/ezp9jfjj. Don't pass up this opportunity to help DEA shape new regulations.

Regulations.gov

Regulations.gov

regulations.gov

Frank Younker

Retired DEA Diversion Supervisor

6mo

I’m sure we can all agree that incineration is the best method. However, obstacles for those that have local availability ( such as Funeral homes with cremation services, zoos that have incineration facilities for large animals, small scale or portable incinerators) are not allowed due to state EPA or federal EPA or other regulations). The availability of these would make it easier for destruction. Also somewhere as I was dealing with this issue in Ohio while a GS there is a document that said CDS will only burn at around 700-800 degrees, while most of these smaller facilities are around 400-600 degrees or a bit less. ( where that came from I have no idea) As a chief of police once told me if a funeral home can burn a body it sure as “heck” can burn my drugs I want to destroy. As he had a funeral home willing to assist him in that process. Maybe trying to expand how, and where a registrant can incinerate, working with EPA ( state or federal) is also a process that need to be looked at. Just my thoughts from experience.

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Jack DeCicco

EHS Manager at GSK, DGSA, Associate Fellow, STEM & DEI Advocate and Volunteer

6mo

We’re running a sub group discussion for industry next week. I’ll send you the invite if you’re interested

Scott Brinks

Retired DEA Regulatory Expert | Disclaimer: I am no longer employed with the DEA. Views are my own.

6mo

Thanks for adding this Mark, DEA wants as much input as possible from industry to draft a beneficial regulation that will work for everyone. Everyone comments do matter and they are seriously taken into consideration when a rule is drafted.

Jack DeCicco

EHS Manager at GSK, DGSA, Associate Fellow, STEM & DEI Advocate and Volunteer

6mo
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