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A Product Stewardship Plan
For Unwanted Medicine from Households
Alameda County, California
February 15, 2019; Revised March 27, 2019
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Table of Contents
Introduction .................................................................................................................................................................. 6
Contact Information .................................................................................................................................................... 6
Plan Definitions ............................................................................................................................................................ 6
Unwanted Medicine ................................................................................................................................................... 8
Collection of Unwanted Medicine ........................................................................................................................... 8
A. Unwanted Medicine Collection Program .............................................................................................................. 8
1. Outreach ................................................................................................................................................................ 8
2. Implementation .................................................................................................................................................... 9
3. Convenience ......................................................................................................................................................... 9
4. Services .................................................................................................................................................................. 9
B. Kiosk Drop-Off Sites ................................................................................................................................................... 9
1. Kiosk Drop-Off Site Locations ........................................................................................................................ 10
2. Drop-Off Site Kiosk Placement and Maintenance Program .................................................................. 10
3. Kiosk Specifications .......................................................................................................................................... 10
4. Kiosk Collection .................................................................................................................................................. 11
a. Technician-Assisted Collection ............................................................................................................. 12
b. Host-Assisted Collection ......................................................................................................................... 12
5. Frequency of Pick-Up ....................................................................................................................................... 13
6. Procedures if a Kiosk is Full Prior to Scheduled Pick-Up ....................................................................... 13
7. Unplanned Event Preparedness ................................................................................................................... 14
C. Take-Back Events ...................................................................................................................................................... 14
1. Method.................................................................................................................................................................. 14
2. Procedures .......................................................................................................................................................... 15
D. Disposal of Unwanted Medicine from Kiosk Drop-Off Sites and Take-Back Events.............................. 15
E. Mail-Back Services for Unwanted Medicine ...................................................................................................... 16
1. Standard Mail-Back Services for Unwanted Medicine ............................................................................ 16
2. Inhaler Mail-Back Services for Inhalers ....................................................................................................... 17
3. Mail-Back Package Availability ...................................................................................................................... 17
4. Mail-Back Package Collection and Disposal ............................................................................................. 17
Plan and Collection Goals ....................................................................................................................................... 18
Patient Privacy ........................................................................................................................................................... 19
Call Center .................................................................................................................................................................. 19
Training ....................................................................................................................................................................... 19
A. Service Technician Training .................................................................................................................................. 20
Vendor, Transporter, and Disposal Facility Information .................................................................................... 21
Technician-Assisted Collection Kiosk Drop-Off Site and Take-Back Event Collection Services ..................... 21
A. Vendor for Technician-Assisted Collection Kiosk Drop-Off Sites and Take-Back Events .................... 21
B. Carrier for Technician-Assisted Collection Kiosk Drop-Off Sites and Take-Back Events ..................... 21
C. Reverse Distributor Facility & Transporters for Technician-Assisted Collection Kiosk Drop-Off Sites
and Take-Back Events ............................................................................................................................................ 22
1. Reverse Distributor Facility ............................................................................................................................ 22
2. Transporter 1 ...................................................................................................................................................... 22
3. Transporter 2 ..................................................................................................................................................... 22
4. Transporter 3 ..................................................................................................................................................... 23
D. Disposal Facilities for Technician-Assisted Collection Kiosk Drop-Off Sites and Take-Back Events23
1. Disposal Facility 1 .............................................................................................................................................. 23
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2. Disposal Facility 2 ............................................................................................................................................. 23
3. Disposal Facility 3 ............................................................................................................................................. 24
4. Disposal Facility 4 ............................................................................................................................................. 24
Host-Assisted Collection Kiosk Drop-Off Sites ...........................................................................................................24
E. Vendors for Host-Assisted Collection Kiosk Drop-Off Sites......................................................................... 24
1. Vendor 1 .............................................................................................................................................................. 24
2. Vendor 2 ............................................................................................................................................................. 24
F. Carrier for Host-Assisted Collection Kiosk Drop-Off Sites ............................................................................ 25
G. Reverse Distributor Facility & Transporter for Host-Assisted Collection Kiosk Drop-Off Sites .......... 25
1. Reverse Distributor Facility 1 ......................................................................................................................... 25
2. Reverse Distributor Facility 2 ........................................................................................................................ 25
3. Reverse Distributor Facility 3 ........................................................................................................................ 26
4. Transporter 1 ...................................................................................................................................................... 26
5. Transporter 2 ..................................................................................................................................................... 26
6. Transporter 3 ..................................................................................................................................................... 26
H. Disposal Facilities for Host-Assisted Collection Kiosk Drop-Off Sites ....................................................... 27
1. Disposal Facility 1 .............................................................................................................................................. 27
2. Disposal Facility 2 ............................................................................................................................................. 27
3. Disposal Facility 3 ............................................................................................................................................. 27
Standard Mail-Back Services ........................................................................................................................................ 28
I. Vendors for Standard Mail-Back Packages ...................................................................................................... 28
1. Vendor 1 .............................................................................................................................................................. 28
2. Vendor 2 ............................................................................................................................................................. 28
J. Carrier for Standard Mail-Back Packages .......................................................................................................... 28
K. Reverse Distributor Facilities and Transporter for Standard Mail-Back Packages ................................ 28
1. Reverse Distributor Facility ............................................................................................................................ 28
2. Transporter ......................................................................................................................................................... 29
L. Disposal Facilities for Standard Mail-Back Packages .................................................................................... 29
1. Disposal Facility 1 .............................................................................................................................................. 29
2. Disposal Facility 2 ............................................................................................................................................. 29
3. Disposal Facility 3 ............................................................................................................................................. 29
Inhaler Mail-Back Services ............................................................................................................................................. 30
M. Vendors for Inhaler Mail-Back Packages ........................................................................................................... 30
1. Vendor 1 .............................................................................................................................................................. 30
2. Vendor 2 ............................................................................................................................................................. 30
N. Carriers for Inhaler Mail-Back Packages ............................................................................................................ 30
1. Carrier 1 ................................................................................................................................................................ 30
2. Carrier 2 .............................................................................................................................................................. 30
O. Transfer Facility for Inhaler Mail-Back Packages .............................................................................................. 31
P. Transporter(s) for Inhaler Mail-Back Packages ................................................................................................. 31
1. Transporter 1 ....................................................................................................................................................... 31
2. Transporter 2 ...................................................................................................................................................... 31
Q. Disposal Facilities for Inhaler Mail-Back Packages .......................................................................................... 31
1. Disposal Facility 1 ............................................................................................................................................... 31
2. Disposal Facility 2 ............................................................................................................................................. 32
3. Disposal Facility 3 ............................................................................................................................................. 32
Unwanted Medicine Educational and Outreach Programming ....................................................................... 33
A. Overview ..................................................................................................................................................................... 33
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B. Audiences ................................................................................................................................................................... 33
C. Messages .................................................................................................................................................................... 33
D. Tools/Communications Channels ........................................................................................................................ 34
1. Phone ................................................................................................................................................................... 34
2. MED-Project Website ....................................................................................................................................... 34
3. Materials .............................................................................................................................................................. 35
4. Social Media ....................................................................................................................................................... 35
5. Broadcast Outreach ......................................................................................................................................... 35
E. Collaboration with County Officials and Community Organizations .......................................................... 35
F. Effectiveness .............................................................................................................................................................. 35
G. Disclaimer ................................................................................................................................................................... 35
Compliance with Applicable Laws, Regulations, and other Legal Requirements ........................................36
A. DEA Controlled Substances Act and Implementing Regulations ............................................................... 36
1. DEA Registration Modification ...................................................................................................................... 37
B. United States Department of Transportation (DOT) ....................................................................................... 37
C. California Board of Pharmacy ............................................................................................................................... 37
Annual Report ............................................................................................................................................................ 37
Appendix A ........................................................................................................................................................................ 38
MED-Project Participants ................................................................................................................................................ 38
Appendix B ........................................................................................................................................................................39
Contact List for Outreach and Education to the Community ............................................................................... 39
Appendix C ....................................................................................................................................................................... 40
Interested Sites and Participating Kiosk Drop-Off Sites ........................................................................................ 40
Appendix D ........................................................................................................................................................................45
Potential Additional Kiosk Drop-Off Sites .................................................................................................................. 45
Appendix E.........................................................................................................................................................................53
Kiosk Mock-Up .................................................................................................................................................................. 53
Kiosk Signage .................................................................................................................................................................... 54
Kiosk Signage .................................................................................................................................................................... 55
Kiosk Signage .................................................................................................................................................................... 56
Appendix F ......................................................................................................................................................................... 57
Media List ............................................................................................................................................................................ 57
Appendix G ........................................................................................................................................................................64
MED-Project Request for Approval of Disposal Process for Host-Assisted Collection Kiosk Drop-Off
Sites .............................................................................................................................................................................. 64
Appendix H ....................................................................................................................................................................... 68
A. Stericycle Standard Mail-Back Package ............................................................................................................ 68
B. Covanta Standard Mail-Back Package ............................................................................................................... 69
C. PureWay Inhaler Mail-Back Package Specifications ...................................................................................... 70
D. Stericycle Inhaler Mail-Back Package .................................................................................................................. 71
Appendix I .......................................................................................................................................................................... 72
MED-Project Request for Approval of Standard Mail-Back Package Disposal Process .............................. 72
Appendix J ......................................................................................................................................................................... 76
MED-Project Request for Approval of Inhaler Mail-Back Package Disposal Process ................................... 76
Appendix K ....................................................................................................................................................................... 80
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Stericycle, Inc., Indianapolis Facility Penalty Record .............................................................................................. 80
Veolia – Port Arthur Penalty Record ........................................................................................................................... 83
Heritage Thermal Services – Ohio Penalty Record ................................................................................................ 87
Clean Harbors Aragonite Enforcement Summary Fact Sheet .............................................................................. 91
Curtis Bay Energy LP Penalty Record ......................................................................................................................... 94
Daniels Sharpsmart, Inc. Fresno, California Transfer Facility Penalty Record ................................................ 95
Appendix L ....................................................................................................................................................................... 103
Education and Outreach Call Center Script .............................................................................................................103
Appendix M...................................................................................................................................................................... 106
MED-Project Website .................................................................................................................................................... 106
Appendix N ....................................................................................................................................................................... 115
Brochure ............................................................................................................................................................................. 115
Appendix O ....................................................................................................................................................................... 117
Digital and Local Social Networks ............................................................................................................................... 117
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Introduction
MED-Project LLC (“MED-Project”), on behalf of the participating companies identified in Appendix A,
submits this Product Stewardship Plan (“Plan”) for Unwanted Medicine to the Alameda County Department
of Environmental Health (“Department”) in compliance with the Alameda County Safe Drug Disposal
Ordinance, Title 6 of the Alameda County Health and Safety Code Sections 6.53.010 through 6.53.120, as
amended February 2, 2016 (“Ordinance”) and the Alameda County Safe Drug Disposal Regulations, as
amended October 16, 2013 (“Regulations”). The Ordinance requires pharmaceutical Producers1 to develop
a Product Stewardship Program to finance and manage the collection, transportation, and disposal of
Unwanted Medicine from Alameda County households.
Contact Information
The primary contact person for MED-Project is:
Dr. Victoria Travis, PharmD, MS, MBA
National Program Director
MED-Project LLC
1800 M Street NW, Suite 400 S
Washington, DC 20036
Phone: 1 (844) 677-6532
Fax: 1 (510) 686-8837
alamedacounty@med-project.org
Plan Definitions
Board of Pharmacy is the California State Board of Pharmacy.
Call Center is the MED-Project call center for Residents, which can be reached by callers at the toll-free
number of 1-844-MED-PROJECT or 1-844-633-7765.
Carrier is the common carrier used to transport Unwanted Medicine from Kiosk Drop-Off Sites and/or Take-
Back Events.
County means Alameda County, California.
DEA is the U.S. Drug Enforcement Administration.
DEA Rule is the DEA Final Rule, “Disposal of Controlled Substances,” 79 Fed. Reg. 53,520 et seq., adopted
on September 9, 2014.
DOT is the U.S. Department of Transportation.
FDA is the U.S. Food and Drug Administration.
Help Desk is the MED-Project call center and email-in database for Kiosk Drop-Off Sites that can be
reached by callers at a toll-free number and/or by email at alamedacounty@med-project.org.
Host-Assisted Collection Kiosk Drop-Off Site is a location that is accessible to the public, hosting a MED-
Project kiosk for the collection of Unwanted Medicine, where the Host-Assisted Collection Kiosk Drop-Off
Site Host employees will remove, seal, and package boxes and inner liners.
1 All capitalized terms used but not otherwise defined herein shall have their respective meanings set forth in the
Ordinance and Regulations.
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Host-Assisted Collection Kiosk Drop-Off Site Host is the designated contact person or persons at the Host-
Assisted Collection Kiosk Drop-Off Site.
Inhaler Mail-Back Services is the provision of pre-paid, pre-addressed packages for the collection and
disposal of inhalers (“Inhaler Mail-Back Packages”) by Vendor.
Kiosk Drop-Off Site is a location that is accessible to the public, hosting a MED-Project kiosk for the
collection of Unwanted Medicine, including Host-Assisted Collection Kiosk Drop-Off Sites and Technician-
Assisted Collection Kiosk Drop-Off Sites.
Kiosk Drop-Off Site Host is the designated contact person or persons at the Kiosk Drop-Off Site, including
Host-Assisted Collection Kiosk Drop-Off Site Hosts and Technician-Assisted Collection Kiosk Drop-Off Site
Hosts.
Law Enforcement Agency or LEA is a federal, state, tribal, or local law enforcement office or agency.
Mail-Back Services is the provision of pre-paid, pre-addressed containers, envelopes, or packages (“Mail-
Back Packages”) to disabled and home-bound Residents or to persons providing services to such
Residents for the collection and disposal of Unwanted Medicine by Vendor.
Maintenance Technicians are service personnel who are trained to provide services related to kiosks that
are part of the Program. This includes, but is not limited to, responding to damaged kiosks.
MED-Project Website is the Internet website located at www.med-project.org or www.medproject.org.
Plan or Product Stewardship Plan is the product stewardship plan presented in this submittal by MED-
Project.
Program or Product Stewardship Program is the product stewardship program set forth in this Product
Stewardship Plan.
Residents means human beings residing in the County. “Residents” does not include nonresidential
generators of pharmaceutical waste, such as businesses, hospitals, clinics, doctor’s offices, veterinary
clinics, pharmacies, or airport security and law enforcement drug seizures.
Service Technicians are personnel trained to service Program kiosks and/or Take-Back Events.
Standard Mail-Back Services is the provision of pre-paid, pre-addressed envelopes for the collection and
disposal of Unwanted Medicine (“Standard Mail-Back Packages”) by Vendor.
Specified Languages are English, Spanish, Chinese, Vietnamese, and Tagalog (Filipino).
Take-Back Event is a one-day event at a location accessible to the public, conducted by MED-Project, with
oversight by law enforcement, for the collection of Unwanted Medicine from Residents.
Technician-Assisted Collection Kiosk Drop-Off Site is a location that is accessible to the public, hosting a
MED-Project kiosk for the collection of Unwanted Medicine, where Service Technicians will assist in
removing, sealing, and packaging boxes and inner liners.
Technician-Assisted Collection Kiosk Drop-Off Site Host is the designated contact person or persons at the
Technician-Assisted Collection Kiosk Drop-Off Site.
Unwanted Medicine is defined in Section IV of this Plan.
Vendor is any vendor retained by MED-Project to carry out its obligations under the Program.
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Unwanted Medicine
For the purposes of the Plan, “Unwanted Medicine” includes all materials identified as “Covered Drugs”
under Ordinance § 6.53.030(3) that qualify as “Unwanted Products” under Ordinance § 6.53.030(21).
According to the Ordinance, Covered Drugs means “a Drug sold, offered for sale, or dispensed in Alameda
County in any form including prescription and nonprescription drugs, drugs in medical devices and
combination products, brand name and generic drugs, and drugs for veterinary use.” Unwanted Medicine
does not include the following:
i. Expired and/or undispensed samples direct from physicians’ offices;
ii. Unused or expired drugs from hospitals and institutions;
iii. Bulk animal pharmaceuticals from farms (business use);
iv. Vitamins or supplements;
v. Herbal-based remedies and homeopathic drugs, products, or remedies;
vi. Compressed cylinders and mercury containing thermometers;
vii. Cosmetics, shampoos, sunscreens, toothpaste, lip balm, antiperspirants, or other personal care
products that are regulated as both cosmetics and nonprescription drugs under the federal Food,
Drug, and Cosmetic Act (Title 21 U.S.C. Chapter 9);
viii. Hard surface and toilet disinfectant cleaners;
ix. Drugs administered in a healthcare setting;
x. Drugs for which Producers provide a pharmaceutical product stewardship or take-back program as
part of a FDA managed risk evaluation and mitigation strategy (Title 21 U.S.C. Sec. 355-1);
xi. Drugs that are biological products, as defined by 21 C.F.R. 600.3(h) as it existed on February 2,
2016, if the Producer already provides a pharmaceutical product stewardship or take-back
program;
xii. Medical devices or their component parts or accessories;
xiii. Used, empty containers, vials, and pouches;
xiv. Sharps (e.g., needles, auto-injectors); and
xv. Schedule I or other illicit drugs.
See Section XII.A for collection limitations imposed by the DEA Rule.
Collection of Unwanted Medicine
The Plan provides services to collect Unwanted Medicine, including controlled substances. The Program
will accept Unwanted Medicine regardless of who produced it, unless excused from this requirement by
the Department. The collection methods and any applicable legal requirements are described below.
A. Unwanted Medicine Collection Program
1. Outreach
MED-Project continues to periodically perform outreach to potential collection sites through calls, emails,
and/or site visits with the goal of establishing Kiosk Drop-Off Sites distributed throughout the County.
LEAs and Pharmacies that currently host kiosks in the County may transition into the Program upon
entering into an agreement with MED-Project.
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2. Implementation
MED-Project continues to implement the Program through executed agreements with Kiosk Drop-Off Site
Hosts. Take-Back Events will also be conducted in coordination with scheduled Alameda County
Department of Environmental Health Household Hazardous Waste (“HHW”)2 events throughout the
County.
Collection of Unwanted Medicine begins at Kiosk Drop-Off Sites once agreements have been executed
with each location, kiosks have been installed, sites have been trained, and, in the case of pharmacies, all
requirements of the DEA and Board of Pharmacy have been met.
3. Convenience
Mail-Back Services will be available upon request by disabled and home-bound Residents or persons
providing services to such Residents via the Call Center and MED-Project Website, thereby offering more
opportunities to dispose of Unwanted Medicine. Mail-Back Services will also be available to Residents in
underserved areas of the County until MED-Project has met its long-term kiosk installation goals
established in Section VI.
4. Services
MED-Project will routinely assess performance, gauge feedback, and revise its approach to services and
convenience as appropriate. As implementation proceeds, MED-Project shall continue to approach
organizations that may be available as future Kiosk Drop-Off Sites on a periodic basis, such as those listed
in Appendix B.
The Program will be implemented in a flexible manner, offering coverage to Residents through a
combination of Kiosk Drop-Off Sites, Mail-Back Services, and Take-Back Events. Over the course of
implementation, additional Kiosk Drop-Off Sites will be established to the extent that (1) additional eligible
LEAs and/or DEA-registered collector pharmacies agree to participate, and (2) contracts can be executed
with such entities. For every engagement with LEAs and pharmacies, including the establishment of Kiosk
Drop-Off Sites and/or the conducting of Take-Back Events, contracts outlining the responsibilities of all
involved parties will be drafted, reviewed by appropriate entities, and signed by all parties before MED-
Project installs kiosks and/or schedules Take-Back Events.
For more information regarding Take-Back Event scheduling, coverage, and frequency, see Section V.C.
Mail-Back Services will be available to disabled and home-bound Residents or to persons providing
services to such Residents and/or Residents in underserved areas of the County upon request and will be
reviewed routinely for availability and effectiveness. See Section V.E for more information about the
availability of Mail-Back Services.
B. Kiosk Drop-Off Sites
Kiosk Drop-Off Sites will continue to be strategically placed across the County in order to best serve
Residents. All Kiosk Drop-Off Site Hosts shall provide Residents with access to Program kiosks during
regular business hours.
2 http://stopwaste.org/recycling/residents/household-hazardous-waste/one-day-event
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1. Kiosk Drop-Off Site Locations
Kiosk Drop-Off Sites that are currently interested in and participating in the Program are identified in
Appendix C.
MED-Project will continue outreach to potential Kiosk Drop-Off Site Hosts that are not interested in or
participating in the Program, such as sites listed in Appendix D.
As required under Ordinance § 6.53.070(E), the Plan will include as a Kiosk Drop-Off Site any eligible site
willing to serve voluntarily as a Kiosk Drop-Off Site for Unwanted Medicine and able to meet all applicable
laws, regulations, and other legal requirements. Locations currently serving as a drop-off site may
participate in the MED-Project Program by signing agreements with MED-Project and modifying their DEA
registrations, if required. MED-Project will work with the Kiosk Drop-Off Site Host to transition to the
Program and Vendor.
2. Drop-Off Site Kiosk Placement and Maintenance Program
Kiosk installation shall be the responsibility of MED-Project at LEAs and pharmacy Kiosk Drop-Off Sites
when the Kiosk Drop-Off Site Host has identified a compliant placement location. All kiosks in the Program
must be securely placed and maintained inside a collector’s registered location or LEA’s physical location
in accordance with DEA Rule §§ 1317.75(d)(1) and 1317.35(a). At pharmacies, kiosks will be placed in the
immediate proximity of a designated area where controlled substances are stored and at which an
employee is present (i.e., can be seen from the counter), pursuant to DEA Rule § 1317.75(d)(2). Kiosk
placement will also comply with any applicable Board of Pharmacy requirements. Costs associated with
installation and maintenance will be paid by MED-Project per the contracts with the Kiosk Drop-Off Site
Hosts.
The maintenance program will address items such as:
• Periodic inspection of kiosks to monitor general wear and tear;
• Service Technician access to the kiosks at Technician-Assisted Collection Kiosk Drop-Off Sites
during the regularly scheduled pick-ups and notification of a Maintenance Technician if necessary;
and
• Reporting by the Kiosk Drop-Off Site Host of damage to a kiosk or requested maintenance service.
All Kiosk Drop-Off Site Hosts are able to notify MED-Project of the need for kiosk service or maintenance
via the Help Desk.
3. Kiosk Specifications
A kiosk will be offered to eligible host locations. Pursuant to DEA Rule § 1317.75, MED-Project kiosks at
pharmacies will:
• Be securely fastened to a permanent structure;
• Be securely locked, substantially constructed containers with a permanent outer container and
removable inner liner;
• Include a small opening in the outer container that allows contents to be added to the inner liner,
but does not allow removal of the inner liner’s contents;
• Prominently display a sign indicating that only Schedule II-V controlled and non-controlled
substances are acceptable to be placed in the kiosk; and
• Have the small opening in the outer container locked or made inaccessible to the public when a
Kiosk Drop-Off Site employee is not present.
The design of the pharmacy kiosk and signage (Appendix E) satisfies these requirements through the use
of heavy gauge steel; multiple locking mechanisms, including a locking mechanism on the drop-slot; a
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tamper-proof slot; and commercial hinges. The design increases the likelihood of consumer participation
by providing easy access to wheelchair users. The locking mechanism on the drop-slot prevents kiosk
overflow once the container has reached its maximum level and is locked by the Kiosk Drop-Off Site
employee. MED-Project pharmacy kiosks come with appropriate regulatory signage and instructions,
including an instruction to remove personal information from any Unwanted Medicine and packaging
before depositing them and language required under the DEA Rule3 and by the Board of Pharmacy. Kiosk
signage provides information about what is and is not accepted in the kiosk.
Additionally, under DEA Rule § 1317.60(a), MED-Project kiosk inner liners will:
• Be waterproof, tamper-evident, and tear-resistant;
• Be removable and sealable immediately upon removal without emptying or touching kiosk
contents;
• When sealed, make the contents of the inner liner not viewable from the outside;
• Clearly indicate the size of the inner liner; and
• Bear a permanent, unique identifier for tracking purposes.
MED-Project kiosks and inner liners will also comply with Board of Pharmacy requirements.
While the DEA Rule does not require LEA kiosks to meet these same requirements, MED-Project will offer
these kiosks and inner liners to LEAs. See Disposal of Controlled Substances, 79 Fed. Reg. 53,520, 53,531
(Sept. 9, 2014).
4. Kiosk Collection
Under DEA Rule § 1317.05(c)(2)(iv), pharmacy Kiosk Drop-Off Site Hosts must dispose of sealed inner liners
and their contents either on-site, through common or contract carrier delivery to, or pick-up by a reverse
distributor or distributor, or with DEA assistance.
DEA Rule § 1317.75(c) prohibits the counting, sorting, inventorying, or individual handling of any substances
deposited into a pharmacy kiosk. Additionally, DEA Rule § 1317.60 limits inner liner access to employees of
the collector and requires two employees to immediately seal the inner liner upon its removal from the
pharmacy kiosk’s permanent outer container. See DEA Rule § 1317.60(b), (c). DEA Rule § 1317.75(g) provides
that pharmacy kiosk inner liner installation or removal shall be performed “by or under the supervision of at
least two employees of the authorized collector.” The pharmacy kiosk sealed inner liner must not be
opened, x-rayed, analyzed, or otherwise penetrated. See DEA Rule § 1317.60(c).
At LEA Kiosk Drop-Off Sites, Vendor and/or LEA will maintain any records of removal, storage, or
destruction of the collected Unwanted Medicine in a manner consistent with the LEAs’ recordkeeping
requirements for illicit controlled substances evidence pursuant to DEA Rule § 1317.35. LEAs will record the
unique identifier and size of the sealed inner liner transferred to Vendor. See DEA Rule § 1317.35.
Additionally, any Unwanted Medicine will be stored in a manner to prevent the diversion of controlled
substances and consistent with the LEA’s standard procedures for storing illicit controlled substances.
Collected Unwanted Medicine will be transferred to the disposal facility in a manner to prevent the
diversion of Unwanted Medicine and consistent with the LEA’s standard procedures for transferring illicit
controlled substances. See DEA Rule § 1317.35.
MED-Project’s Kiosk Drop-Off Site collection system complies with these DEA requirements for pharmacy
and LEA Kiosk Drop-Off Sites. Vendor, pharmacies, and LEAs participating in the Program will keep all
records required under the DEA Rule, including those required under DEA Rule §§ 1304 and 1317.35.
Pharmacies participating in the Program will also keep all records required under Board of Pharmacy
3 Specifically, as required under DEA Rule § 1317.75(e)(4), all kiosks will prominently display a sign stating that: “Only
Schedule II-V controlled and non-controlled substances that are lawfully possessed by the ultimate user are
acceptable to be placed in the kiosk. Schedule I controlled substances, illicit or dangerous substances, and any
controlled substances not lawfully possessed by the ultimate user may not be placed in the kiosk.”
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requirements. Pharmacy Kiosk Drop-Off Sites and Vendor will be instructed never to count, sort, inventory,
or individually handle kiosk contents. MED-Project’s Kiosk Drop-Off Site collection system will also comply
with all applicable Board of Pharmacy requirements.
A Kiosk Drop-Off Site may elect to participate in the program via either the technician-assisted collection
method or host-assisted collection method. If a Kiosk Drop-Off Site elects to participate via the technician-
assisted collection method, a Service Technician will regularly come to the Technician-Assisted Collection
Kiosk Drop-Off Site to help prepare the inner liner for shipment and disposal. If a Kiosk Drop-Off Site elects
to participate via the host-assisted collection method, the Host-Assisted Collection Kiosk Drop-Off Site
employees will prepare the inner liner for shipment.
a. Technician-Assisted Collection
For Kiosk Drop-Off Sites that opt to participate via the technician-assisted collection method, pick-up of
Unwanted Medicine collected at the sites will be scheduled year-round, based on their regular business
hours and volume collected. After arriving at a Technician-Assisted Collection Kiosk Drop-Off Site, the
Service Technician will check the kiosk for any damage.
The inner liner and box will be securely removed from the kiosk by a Service Technician and Technician-
Assisted Collection Kiosk Drop-Off Site employees following procedures meeting all DEA requirements.
Specifically, two Technician-Assisted Collection Kiosk Drop-Off Site employees will hold the two keys to
unlock the kiosk. Once the kiosk is unlocked, the inner liner will be removed from the kiosk and
immediately sealed. The inner liner provided in the kiosk will be opaque to prevent visual recognition of
the contents. The sealed inner liner will not be opened, x-rayed, analyzed, or otherwise penetrated.
Under the supervision of two Technician-Assisted Collection Kiosk Drop-Off Site employees, the Service
Technician will prepare the liner for packaging and transport. The unique identifier of the inner liner will be
matched to the tracking number on the shipping label. The Service Technician will schedule a pickup from
the Carrier to be completed within two business days and leave the packaged, sealed inner liner with the
Technician-Assisted Collection Kiosk Drop-Off Site Host for storage in compliance with all applicable laws,
regulations, and other legal requirements until Carrier pickup. Vendor will prepare the materials for
shipment and perform applicable pre-transportation functions to comply with DOT Hazardous Materials
Regulations.
Any collection of controlled substances by LEA will be consistent with the LEA’s standard procedures for
transferring illicit controlled substances. See DEA Rule § 1317.35.
b. Host-Assisted Collection
Host-assisted collection will enable a site to directly control the timing for servicing the kiosk by allowing
the site employees to prepare the liner for packaging and transport at a time of their choosing. This
method will allow sites to avoid disruptions to operations that may result from Vendor-scheduled visits or
storage limitations. MED-Project will provide Host-Assisted Collection Kiosk Drop-Off Site Hosts with
information related to servicing kiosks and applicable laws, regulations, and other legal requirements when
installing the kiosks and upon request through the Help Desk.
Unwanted Medicine will be securely removed from the kiosk by Host-Assisted Collection Kiosk Drop-Off
Site employees following procedures meeting all DEA requirements. Specifically, two Host-Assisted
Collection Kiosk Drop-Off Site employees will hold the two keys to unlock the kiosk. Once the kiosk is
unlocked, the inner liner will be removed from the kiosk and immediately sealed. The inner liner provided
in the kiosk will be opaque to prevent visual recognition of the contents. The sealed inner liner will not be
opened, x-rayed, analyzed, or otherwise penetrated.
Following instructions provided by Vendor, the two Host-Assisted Collection Kiosk Drop-Off Site
employees will seal the inner liner for packaging and transport. The unique identifier of the inner liner will
13
be matched to the tracking number on the shipping label. The two Host-Assisted Collection Kiosk Drop-Off
Site employees will either schedule a pickup from the Carrier to be completed within two business days or
offer the packaging containing the sealed inner liner for pickup a routine Carrier service to the Host-
Assisted Collection Kiosk Drop-Off Site. If the package containing the sealed inner liner is prepared prior to
pick-up, the Host-Assisted Collection Kiosk Drop-Off Site Host will store the inner liner in compliance with
all applicable laws, regulations, and other legal requirements until Carrier pickup.
Following instructions provided by Vendor, the two Host-Assisted Collection Kiosk Drop-Off Site
employees will prepare the materials for shipment and perform applicable pre-transportation functions to
comply with DOT Hazardous Materials Regulations.
Following instructions provided by Vendor, the two Host-Assisted Collection Kiosk Drop-Off Site
employees will replace the removed inner liner and box with a replenishment inner liner and box, provided
by Vendor. Each inner liner and box provided by Vendor will be pre-paid and pre-addressed for transport
and disposal.
Any collection of controlled substances by LEA will be consistent with the LEA’s standard procedures for
transferring illicit controlled substances. See DEA Rule § 1317.35.
5. Frequency of Pick-Up
Initially, all Technician-Assisted Collection Kiosk Drop-Off Sites will be scheduled for a monthly pick-up
from the kiosk. The Vendor will communicate with MED-Project in the event that the frequency of pick-up
needs to be changed based on the volumes collected over time. As needed, MED-Project will
communicate with the Technician-Assisted Collection Kiosk Drop-Off Site Host in the event the frequency
of pick-up needs to be changed. Vendor will monitor the volumes per service to ensure that all sites are
receiving the appropriate service frequency. Vendor will manage pick-up services as frequently as
necessary to prevent overflow of the kiosk without providing unnecessary interruption to the participating
Technician-Assisted Collection Kiosk Drop-Off Site. Host-Assisted Collection Kiosk Drop-Off Sites will be
instructed to service the kiosk and request a pick-up by Carrier, as needed. Vendor will monitor the weight
of Unwanted Medicine generated at each participating Kiosk Drop-Off Site.
6. Procedures if a Kiosk is Full Prior to Scheduled Pick-Up
The Technician-Assisted Collection Kiosk Drop-Off Site Host shall be instructed to lock the drop-slot of the
kiosk and notify MED-Project of the need for service if prior to the scheduled date.
Vendor shall provide a network of trained Service Technicians. Vendor will communicate service requests
to field managers responsible for Service Technicians. Vendor will direct service to the trained Service
Technician who is in closest proximity to the Technician-Assisted Collection Kiosk Drop-Off Site requesting
the service. This process provides for a timely response to Technician-Assisted Collection Kiosk Drop-Off
Sites requiring service prior to the scheduled date.
Service timelines will be assessed based on the specific characteristics of the Technician-Assisted
Collection Kiosk Drop-Off Site’s need. If necessary, Vendor will be able to respond within hours of the
request. If the request does not require an urgent response, Vendor will respond within two business days
of the request. In the interim, pharmacy Technician-Assisted Collection Kiosk Drop-Off Site Hosts shall be
instructed to secure the kiosk and its contents in accordance with DEA requirements.
Host-Assisted Collection Kiosk Drop-Off Sites will be instructed to service the kiosk and request a pick-up
by Carrier, as needed.
14
7. Unplanned Event Preparedness
Vendor maintains a network of emergency responders that can be called on in the case of an emergency
or spill incident. Vendor ensures compliance of all service providers through a business confidential
qualification process. This process reviews the compliance history, management structure, financial
stability, and other key indicators of a reliable emergency response service provider. Emergency
responders will bring all necessary equipment in order to manage the specific needs of the Kiosk Drop-Off
Site requiring emergency response. Kiosk Drop-Off Site Hosts will be directed to call 911 in situations
posing an immediate threat to health or the environment.
A major event, such as a flood, earthquake or fire, may require response by a service team. This event can
jeopardize the security characteristics of the kiosk as well as the structural integrity of the participating
location. The team will assess the safety of the area along with the locations to be serviced. Once it is
determined the area is safe for access, the team will work to secure the kiosk and remove its contents.
Along with major event preparedness, Vendor provides timely responses to events that may cause an
inconvenience to the Kiosk Drop-Off Site Host. An example of this kind of event would be if the kiosk is
giving off an odor prior to the scheduled service date. The Kiosk Drop-Off Site Host will contact MED-
Project via the Help Desk. Vendor is able to respond within two to three hours in most cases when notified
of a need for emergency response. If the request is not an emergency that requires an immediate
response, Vendor will typically respond to a service location within two to three business days of the event.
An event may occur, such as a site requiring an emergency response or an LEA that is unwilling or unable
to securely store inner liners prepared for shipment, that necessitates a direct transport of a sealed inner
liner from a Kiosk Drop-Off Site to a disposal facility listed in Section X. In such cases, a Service Technician
will seal the kiosk inner liner for packaging and transport according to the process outlined in Section
V.B.4.a. The packaged inner liner will then be transported to one of the disposal facilities listed in Section
X.
In addition, any items that a Resident deposits into the kiosk will not be retrieved.
C. Take-Back Events
MED-Project will conduct Take-Back Events in coordination with HHW events throughout the County. MED-
Project may also conduct Take-Back Events upon request by LEAs. LEA employees shall oversee all Take-
Back Events. MED-Project will confirm and/or finalize the locations and dates to conduct Take-Back Events
once contracts with overseeing LEAs have been executed.
Due to the changing schedule of Take-Back Events, the list of dates and locations will be maintained on
the MED-Project Website as events are scheduled and confirmed.
1. Method
The conducting of Take-Back Events by MED-Project is contingent upon participation and oversight by
LEAs. MED-Project will work with participating LEAs to ensure Take-Back Events are compliant and
successful. Events will be promoted and communicated to the public through local communication
channels as outlined in Appendix F.
MED-Project Take-Back Events will meet all applicable laws, regulations, and other legal requirements.
MED-Project will contract with LEAs to oversee Take-Back Events. MED-Project will work with LEAs to
accommodate any reasonable requirements.
15
2. Procedures
MED-Project will partner with LEAs to ensure that at least one law enforcement officer oversees collection
at all Take-Back Events pursuant to DEA Rule § 1317.65(a), (b). The law enforcement officers will maintain
control and custody of all Unwanted Medicine collected at Take-Back Events from collection until secure
transfer, storage, or destruction of the Unwanted Medicine, as required by DEA Rule § 1317.65(b). Only
ultimate users and persons authorized to dispose of an ultimate user decedent’s property in lawful
possession of controlled substances in Schedules II-V may transfer these substances to the LEA during the
event. No other person will handle controlled substances at Take-Back Events under DEA Rule § 1317.65(e);
however, Vendor may assist LEAs in the collection of Unwanted Medicine at Take-Back Events. See
Disposal of Controlled Substances, 79 Fed. Reg. 53,520, 53,539 (Sept. 9, 2014).
Take-Back Events will typically be staffed by at least two Vendor employees. Vendor will work in
coordination with MED-Project, the County, and LEAs to monitor and ensure collection of all material at
Take-Back Events is compliant with all applicable laws, regulations, and other legal requirements and
meets the published expectations of the planned event. Vendor will work in conjunction with law
enforcement to ensure all material is placed in a compliant collection receptacle and securely shipped to
meet all applicable laws, regulations, and other legal requirements. Any material that is not Unwanted
Medicine or does not meet legal requirements will be rejected.
Vendor and the LEA will maintain all records of collection, storage, or destruction of the collected
Unwanted Medicine in a manner consistent with the LEA’s recordkeeping requirements for illicit controlled
substances evidence pursuant to DEA Rule § 1317.35. Any collected Unwanted Medicine will be stored to
prevent the diversion of controlled substances and consistent with the LEA’s standard procedures for
storing illicit controlled substances. Any storage of Unwanted Medicine by Vendor will also comply with the
applicable security requirements of DEA Rule §§ 1301 and 1317, including the requirement that Unwanted
Medicine is securely stored in a manner consistent with the security requirements for Schedule II
controlled substances.
Following the completion of each event, containers will be weighed, securely packaged, labeled,
transported from the event site to the LEA site, and shipped in compliance with all applicable laws,
regulations, and other legal requirements. Law enforcement officers will maintain control and custody of all
Unwanted Medicine collected at Take-Back Events while it is transported to the point of secure transfer,
storage or destruction. Containers and inner liners will be tracked via unique identifiers to a facility
identified in Section X, where they shall be incinerated. Vendor will ship the containers (and inner liners) in
accordance with the requirements outlined in Section XII.B.
D. Disposal of Unwanted Medicine from Kiosk Drop-Off Sites and Take-Back Events
Vendor and Carrier shall manage the Unwanted Medicine from Kiosk Drop-Off Sites and Take-Back Events
in compliance with all applicable laws, regulations, and other legal requirements. Carrier and/or Vendor
shall deliver Unwanted Medicine collected from Kiosk Drop-Off Sites and/or Take-Back Events to the
respective facilities identified in Section X.
All inner liners will be destroyed in accordance with all applicable laws, regulations, and other legal
requirements at the disposal facilities identified in Section X. MED-Project’s request for approval to dispose
of Host-Assisted Collection Kiosk Drop-Off Site inner liners at a municipal waste incinerator is included in
Appendix G.
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E. Mail-Back Services for Unwanted Medicine
MED-Project will provide two types of Mail-Back Services:
• Standard Mail-Back Services for disabled and home-bound Residents or persons providing
services to such Residents and to supplement kiosks until the convenience standard is met, as
described in Section V.E.1;
• Inhaler Mail-Back Services for the collection of inhalers for disabled and home-bound Residents or
persons providing services to such Residents as described in Section V.E.2.
Mail-Back Packages will be pre-paid and pre-addressed, and Mail-Back Services shall comply with all
applicable laws, regulations, and other legal requirements.
1. Standard Mail-Back Services for Unwanted Medicine
MED-Project will provide Standard Mail-Back Services at no cost to disabled and home-bound Residents or
to persons providing services to such Residents. Standard Mail-Back Packages will also be available to
Residents in underserved areas of the County until MED-Project has met its long-term kiosk installation
goals. The pre-paid shipping label will direct the Standard Mail-Back Package to the facility identified in
Section X. Standard Mail-Back Packages for Unwanted Medicine shall comply with all applicable laws,
regulations, and other legal requirements.
Pursuant to DEA Rule § 1317.70(c), the Standard Mail-Back Packages will be:
• Nondescript and without any markings or information potentially indicating that they contain
Unwanted Medicine, including controlled substances;
• Water and spill-proof, tamper-evident, tear-resistant, and sealable;
• Pre-addressed with and delivered to Vendor’s registered address;
• Pre-paid;
• Provided with a unique identifier enabling tracking; and
• Provided with instructions indicating the process for mailing back the packages, accepted
substances, a notice about mailing restrictions, and a notice that only packages provided by
Vendor will be accepted for destruction.
Ultimate users and persons lawfully entitled to dispose of an ultimate user decedent’s property will not be
required to provide any personally identifiable information when using Standard Mail-Back Services to
dispose of Unwanted Medicine. See DEA Rule § 1317.70(d). As required under DEA Rule § 1317.70(e),
Vendor will only accept Standard Mail-Back Packages it made available (or packages lawfully forwarded
under DEA requirements). Within three business days of receipt, Vendor will notify the DEA if it receives
Standard Mail-Back Packages likely containing controlled substances that Vendor did not make available
or did not agree to receive pursuant to DEA requirements. In accordance with DEA Rule § 1317.70(f), when
Standard Mail-Back Packages are received, only employees of Vendor will handle the Standard Mail-Back
Packages. Standard Mail-Back Packages will not be opened, x-rayed, analyzed, or otherwise penetrated
upon receipt by Vendor. See DEA Rule § 1317.70(f). Vendor will keep all records required under the DEA
Rule, including those identified in DEA Rule § 1304.22(f).
See Appendix H for Standard Mail-Back Package image and package specifications.
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2. Inhaler Mail-Back Services for Inhalers
For inhalers, MED-Project will offer disabled and home-bound Residents or persons providing services to
such Residents Inhaler Mail-Back Services via the Call Center and MED-Project Website. The pre-paid
shipping label will direct the Inhaler Mail-Back Packages to an approved facility identified in Section X. An
instruction sheet will be included with the Inhaler Mail-Back Package that describes how to properly
dispose of inhalers, explains what materials may be placed in the Inhaler Mail-Back Package, and how to
return the Inhaler Mail-Back Package.
See Appendix H for an Inhaler Mail-Back Package image and package specifications.
3. Mail-Back Package Availability
Disabled and home-bound Residents or persons providing services to such Residents may request
Standard Mail-Back Packages and/or Inhaler Mail-Back Packages by calling the Call Center or through a
link on the MED-Project Website. Upon request, such Residents will be provided Mail-Back Packages.
Standard Mail-Back Packages will also be available to Residents in underserved areas of the County until
MED-Project has met its long-term kiosk installation goals. Once the long-term kiosk installation goals have
been met, Standard Mail-Back Services will only be available to disabled and home-bound Residents or to
persons providing services to such Residents.
Each Mail-Back Package will contain an insert with instructions for use and information about other options
for disposing of Unwanted Medicine in the Specified Languages. See Appendix H for Mail-Back Package
images.
4. Mail-Back Package Collection and Disposal
Requests to receive Mail-Back Packages will be taken through the Call Center and the MED-Project
Website. Residents will be directed to follow the instructions provided in the Mail-Back Package and to
place their Unwanted Medicine in the pre-addressed, pre-paid package. The Mail-Back Package shall be
sent to an approved disposal facility in compliance with all applicable laws, regulations and other legal
requirements. Each Mail-Back Package will have a unique identifier for tracking.
For Standard Mail-Back Packages, upon arriving at the disposal facility, the Mail-Back Packages will be
scanned for receipt verification and incinerated at the disposal facilities listed in Section X. MED-Project’s
request for approval to dispose of Standard Mail-Back Packages at a municipal waste incinerator is
included in Appendix I. Any storage of filled Standard Mail-Back Packages by Vendor will comply with the
applicable security requirements of DEA Rule § 1317, including the requirement that Unwanted Medicine is
securely stored in a manner consistent with the security requirements for Schedule II controlled
substances. All Unwanted Medicine in Standard Mail-Back Packages will be destroyed promptly.
This Plan proposes to dispose of Inhaler Mail-Back Packages at a municipal waste combustor and/or a
medical waste incinerator. See the facilities identified in Section X. MED-Project’s request for approval to
use a municipal waste combustor to dispose of inhalers collected through Inhaler Mail-Back Packages is
included in Appendix J.
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Plan and Collection Goals
The short- and long-term goals of the Plan are described generally as follows. Additional detail on
implementation is provided in Section V.A.2.
Goal Area Short-Term Long-Term
Collection Within 90 days of Plan approval,
implement Mail-Back Services for
disabled and home-bound Residents,
persons providing services to such
Residents, and Residents in underserved
areas of the County.
Continue to increase retail chain pharmacy
participation through outreach, with a goal of
achieving up to a total of 100 Kiosk Drop-Off
Sites. Reduce collection via Take-Back
Events and Mail-Back Services by
establishing additional Kiosk Drop-Off Sites
throughout the County.
Education &
Public
Outreach
Within 90 days of Plan approval, include
Mail-Back Services for disabled and
home-bound Residents, persons
providing services to such Residents,
and Residents in underserved areas of
the County on the Call Center and MED-
Project Website.
Within 90 days of Plan approval,
implement the Specified Languages on
the Call Center and MED-Project
Website.
Within 90 days of Plan approval, release
a Public Service Announcement (“PSA”)
animation directed at Residents on social
media websites, digital media, print, and
broadcast (television). Within 90 days of
approval release audio PSA via radio.
See Section XI for more information
about education and outreach
programming.
On an ongoing basis, MED-Project may
revise and add communications materials
based on changes to the Plan.
Collector
Outreach
Periodic outreach to potential eligible
Kiosk Drop-Off Sites via site visits, calls,
and emails.
Ongoing communication with pharmacies
and LEAs. Periodic evaluation and monitoring
of participating Kiosk Drop-Off Sites.
MED-Project continues to implement Kiosk Drop-Off Sites in eligible locations that best serve the
demographics and distribution of Residents. See Section V.B for more information about Kiosk Drop-Off
Site collection.
In addition, MED-Project will conduct Take-Back Events throughout the year, in coordination with HHW
events.
MED-Project Mail-Back Packages will be made available to disabled and home-bound Residents, persons
providing services to such Residents, and Residents in underserved areas of the County by request
through the Call Center and MED-Project Website.
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Patient Privacy
Instructions at each Kiosk Drop-Off Site will inform people who deposit Unwanted Medicine that they
should completely cross out, remove, or otherwise make unreadable any and all personally identifiable
information on the drug containers and packaging before depositing them in the kiosk. In cases where
people follow the instructions, there will be no readable personally identifiable information.
In addition to kiosk signage, MED-Project instructions, promotional, and educational materials encourage
Residents to protect their information by ensuring that personally identifiable information is unreadable
when utilizing Mail-Back Services or depositing Unwanted Medicine into kiosks.
Materials to help Residents cross out any personally identifiable information will also be available at Take-
Back Events. This will ensure any patient information on drug packaging will be unreadable.
Vendor has additional protections available for keeping personally identifiable information safe and secure.
Service Technicians are trained in managing items containing sensitive patient information. Privacy training
is part of a Service Technician’s prerequisite for field services. As added protection, Mail-Back Packages
used for Mail-Back Services will be opaque rather than clear. In addition, inner liners used at Kiosk Drop-
Off Sites and Take-Back Events will be opaque rather than clear, in compliance with the DEA Rule. This will
prevent anyone, including the Service Technician, from seeing any information on the Unwanted Medicine
placed in the kiosks.
Any patient information on collected drug packaging will be promptly destroyed with the Unwanted
Medicine.
Call Center
MED-Project will operate a Call Center for Residents in the Specified Languages. Questions from Residents
will be managed through the Call Center with the support of an agent. All agents are trained to respond
based on the requirements set by MED-Project.
The agents will answer general questions, including questions on the following topics:
1. Items that can be disposed of;
2. Disposal options; and
3. Direction to the MED-Project Website for additional information.
Because the list of Kiosk Drop-Off Sites and Take-Back Events is subject to change, Residents will be
directed to the MED-Project Website or to an agent for detailed information about locations and contact
information.
Training
Operational procedures, including training, are the responsibility of the Kiosk Drop-Off Site Host. MED-
Project will support training if agreed to with the Kiosk Drop-Off Site Host. Additionally, MED-Project will
manage a help desk to answer questions and monitor comments for participating Kiosk Drop-Off Sites.
The help desk will support two general communication functions:
1. Answer questions and monitor comments from participating Kiosk Drop-Off Site Hosts; and
2. Support and direct service requests from participating Kiosk Drop-Off Sites.
20
Vendor will comply with all applicable laws, regulations, and other legal requirements. Vendor’s internal
training process will address the following:
• Onboarding & on-truck observation of job functions;
• DOT Training;
• DEA Training;
• United States Environmental Protection Agency (“EPA”) Waste Characterization;
• Occupational Safety and Health Administration (“OSHA”) Training;
• Waste Handling Demo;
• Truck Operation;
• DEA Handling Demo;
• Health Insurance Portability and Accountability Act (“HIPAA”) requirements;
• OSHA Bloodborne Pathogens Standard;
• Review & Written Test; and
• Perform work under supervision to demonstrate proficiency prior to certification to service client
accounts.
A. Service Technician Training
The Service Technicians collecting and packaging the Unwanted Medicine for transport from Technician-
Assisted Collection Kiosk Drop-Off Sites will complete comprehensive training. This training includes
instruction on:
• DOT hazardous materials requirements;
• EPA waste characterization requirements;
• Resource Conservation and Recovery Act (“RCRA”) hazardous waste requirements;
• DEA controlled substances transfer protocols;
• OSHA requirements; and
• HIPAA requirements.
Service Technicians must complete a 24 or 40-hour Hazardous Waste Operations and Emergency
Response Standard course. Additionally, Service Technicians must complete annual refresher training.
Finally, Service Technicians receive ongoing training through meetings and online refresher courses. All
Vendor employees servicing Technician-Assisted Collection Kiosk Drop-Off Sites, Mail-Back Services,
and/or Take-Back Events will have a training base similar to that of Service Technicians, with customized
training as needed.
21
Vendor, Transporter, and Disposal Facility Information
All Vendors, transporters, and disposal facilities utilized by the Program will operate in accordance with all
applicable laws, regulations, and other legal requirements.4
Technician-Assisted Collection Kiosk Drop-Off Site and Take-Back Event
Collection Services
A. Vendor for Technician-Assisted Collection Kiosk Drop-Off Sites and Take-Back Events
• Name: Stericycle Specialty Waste Solutions, Inc. (“Stericycle”) will service Technician-Assisted
Collection Kiosk Drop-Off Sites. Stericycle may also service Take-Back Events.
• Address: 2850 100th Court NE, Blaine, MN 55449
• Phone: (612) 285-9865
• Website: www.stericycleenvironmental.com
• US DOT No: 1348411, Status: Issued
• DOT ID No: MNS 000 110 924, Status: Issued
• Penalty Record (5 years): None
B. Carrier for Technician-Assisted Collection Kiosk Drop-Off Sites and Take-Back Events
• Name: United Parcel Service, Inc. may transport Unwanted Medicine from Technician-Assisted
Collection Kiosk Drop-Off Sites to the Stericycle, Inc., Indianapolis, Indiana Facility or the Stericycle,
Inc., Warren, Ohio Facility. United Parcel Service, Inc. may also transport Unwanted Medicine from
Take-Back Events to the Stericycle, Inc., Indianapolis, Indiana Facility or the Stericycle, Inc., Warren,
Ohio Facility.
• Address: 55 Glenlake Parkway NE, Atlanta, GA 30328
• Phone: (800) PICK-UPS
• Website: www.UPS.com/
• Type: Common Carrier
• U.S. Small Package DOT No: 21800, Status: Issued
• U.S. Freight DOT No: 121058, Status: Issued
• Penalty Record (5 years): For enforcement history, UPS advises that “all material government
investigation and enforcement activity is provided in our SEC filings at investors.ups.com”
4 Two witnesses of the registrant will witness destruction at the disposal facilities.
22
C. Reverse Distributor Facility & Transporters for Technician-Assisted Collection Kiosk Drop-
Off Sites and Take-Back Events
1. Reverse Distributor Facility
• Name: Stericycle, Inc., Indianapolis, Indiana Facility will receive Unwanted Medicine from United
Parcel Service, Inc.
• Address: 2670 Executive Drive, Suite A, Indianapolis, IN 46241-9901
• Phone: (317) 275-7530
• Website: www.stericycleenvironmental.com
• Type: DEA Registered Collector and Reverse Distributor & Permitted Hazardous Waste (RCRA)
Treatment, Storage, and/or Disposal Facility
• DEA Registration No: RS0331607, Status: Issued
• EPA ID No: INR000110197, Status: Issued
• TSDF (RCRA) Permit No: INR000110197, Status: Issued
• Solid Waste Processing Facility Permit No: FP 49-57, Status: Issued
• Air Quality Permit No: E097-28740-00671, Status: Issued
• Penalty Record (5 years): See Appendix K
2. Transporter 1
• Name: Heritage Transport may transport Unwanted Medicine from the Stericycle, Inc., Indianapolis,
Indiana Facility to Heritage Thermal Services-Ohio.
• Address: 1626 Research Way, Indianapolis, IN 46231
• Phone: (317) 486-2973
• Website: http://www.heritage-enviro.com/
• Type: Hazardous Waste Transporter
• EPA ID No: IND 058 484 114, Status: Issued
• US DOT No: 314460, Status: Issued
• Penalty Record (5 years): None
3. Transporter 2
• Name: Veolia – Port Arthur may be used to transport Unwanted Medicine from the Stericycle, Inc.,
Indianapolis, Indiana Facility to Veolia – Port Arthur.
• Address: 7665 Texas Highway 73, Beaumont, TX 77705
• Phone: (409) 736-2821
• Website: www.veolianorthamerica.com
• Type: Hazardous Waste Transporter
• EPA ID No: TXD000838896, Status: Issued
• State Title V Permit No: O-01509, Status: Issued
• Air Permit No: NSR Air, Status: Issued
• Water Permit No: TPDES02417, Status: Issued
• TSDF (RCRA) Permit No: HW-50212, Status: Issued
• Penalty Record (5 years): See Appendix K
23
4. Transporter 3
• Name: Stericycle Specialty Waste Solutions, Inc. may transport Unwanted Medicine from the
Stericycle, Inc., Indianapolis, Indiana Facility to Heritage Thermal Services – Ohio, Veolia-Port
Arthur, the Stericycle, Inc., Warren, Ohio Facility, and/or Clean Harbors – Aragonite. Stericycle
Specialty Waste Solutions, Inc. may also be used to transport Unwanted Medicine from Kiosk Drop-
Off Sites and/or Take-Back Events to any of the disposal facilities listed in Section X.D or Section
X.H.
• Address: 2850 100th Court NE, Blaine, MN 55449
• Phone: (612) 285-9865
• Website: www.stericycleenvironmental.com
• Type: Hazardous Waste Transporter
• US DOT No: 1348411, Status: Issued
• DOT ID No: MNS 000 110 924, Status: Issued
• Penalty Record (5 years): None
D. Disposal Facilities for Technician-Assisted Collection Kiosk Drop-Off Sites and Take-Back
Events
1. Disposal Facility 1
• Name: Heritage Thermal Services – Ohio may incinerate Unwanted Medicine received from the
Stericycle, Inc., Indianapolis, Indiana Facility.
• Address: 1250 Saint George Street, East Liverpool, OH 43920
• Phone: (800) 545-7655
• Website: http://www.heritage-thermal.com/
• Type: Permitted Hazardous Waste Incinerator
• DEA Registration No: RH0387628, Status: Issued
• RCRA Permit No: OHD980613541, Status: Issued
• EPA ID No: OHD 980 613 541, Status: Issued
• Ohio ID No: 02-15-0589, Status: Issued
• Penalty Record (5 years): See Appendix K
2. Disposal Facility 2
• Name: Veolia – Port Arthur may incinerate Unwanted Medicine received from the Stericycle, Inc.,
Indianapolis, Indiana Facility.
• Address: 7665 Texas Highway 73, Beaumont, TX 77705
• Phone: (409) 736-2821
• Website: www.veolianorthamerica.com
• Type: Permitted Hazardous Waste Incinerator
• EPA ID No: TXD000838896, Status: Issued
• State Title V Permit No: O-01509, Status: Issued
• Air Permit No: NSR Air, Status: Issued
• Water Permit No: TPDES02417, Status: Issued
• TSDF (RCRA) Permit No: HW-50212, Status: Issued
• Penalty Record (5 years): See Appendix K
24
3. Disposal Facility 3
• Name: Stericycle, Inc., Warren, Ohio Facility may incinerate Unwanted Medicine received from the
Stericycle, Inc., Indianapolis, Indiana Facility.
• Address: 1901 Pine Avenue, S.E., Warren, OH 44483
• Phone: (330) 393-0370
• Website: https://www.stericycle.com/service-locations/ohio/warren
• Type: Medical Waste Incinerator
• DEA Registration No: RS0498130, Status: Issued
• Solid Waste Operating Permit No: CID 41805, Status: Issued
• Final Air Pollution Control Title V Permit No: P0115341, Status: Issued
• Penalty Record (5 years): None
4. Disposal Facility 4
• Name: Clean Harbors - Aragonite may incinerate Unwanted Medicine received from the Stericycle,
Inc., Indianapolis, Indiana Facility.
• Address: 3 Miles E 7 Miles N of Knolls, Wendover, UT 84083
• Phone: (435) 884-8900
• Website: www.cleanharbors.com
• Type: Permitted Hazardous Waste Incinerator
• US EPA ID No: UTD981552177, Status: Issued
• TSDF (RCRA) Permit No: UTD981552177, Status: Issued
• State Title V Permit No: 4500048002, Status: Issued
• Air Permit No: DAQE-168-02, Status: Issued
• Penalty Record (5 years): See Appendix K
Host-Assisted Collection Kiosk Drop-Off Sites
E. Vendors for Host-Assisted Collection Kiosk Drop-Off Sites
1. Vendor 1
• Name: Covanta Environmental Solutions, LLC may provide boxes and inner liners for Host-Assisted
Collection Kiosk Drop-Off Sites.
• Address: 7326 E. Evans Road Suite B, Scottsdale, AZ 85620
• Phone: (855) 269-1750
• Website: www.covantaes.com
• DEA Registration No: RC0518160, Status: Issued
• Penalty Record (5 years): None
2. Vendor 2
• Name: Stericycle Specialty Waste Solutions, Inc. may provide boxes and inner liners for Host-
Assisted Collection Kiosk Drop-Off Sites.
• Address: 2850 100th Court NE Blaine, MN 55449
• Phone: (612) 285-9865
• Website: www.stericycleenvironmental.com
• US DOT No: 1348411, Status: Issued
• DOT ID No: MNS 000 110 924, Status: Issued
• Penalty Record (5 years): None
25
F. Carrier for Host-Assisted Collection Kiosk Drop-Off Sites
• Name: United Parcel Service, Inc. may transport Unwanted Medicine from Host-Assisted Collection
Kiosk Drop-Off Sites to the Covanta Environmental Solutions, LLC Scottsdale, Arizona Facility or
the Covanta Manheim, Pennsylvania Facility. United Parcel Service, Inc. may also transport
Unwanted Medicine from Host-Assisted Collection Kiosk Drop-Off Sites to the Stericycle, Inc.,
Indianapolis, Indiana Facility or the Stericycle, Inc., Warren, Ohio Facility.
• Address: 55 Glenlake Parkway NE, Atlanta, GA, 30328
• Phone: 800-PICK-UPS
• Website: www.UPS.com/
• Type: Common Carrier
• U.S. Small Package DOT No: 21800, Status: Issued
• U.S. Freight DOT No: 121058, Status: Issued
• Penalty Record (5 years): For enforcement history, UPS advises that “all material government
investigation and enforcement activity is provided in our SEC filings at investors.ups.com”
G. Reverse Distributor Facility & Transporter for Host-Assisted Collection Kiosk Drop-Off
Sites
1. Reverse Distributor Facility 1
• Name: Covanta Environmental Solutions, LLC Scottsdale, Arizona Facility may receive Unwanted
Medicine from United Parcel Service, Inc.
• Address: 7326 E. Evans Road, Suite B, Scottsdale, AZ 85620
• Phone: (855) 269-1750
• Website: www.covantaes.com
• Type: DEA Registered Collector and Reverse Distributor
• DEA Registration No: RC0518160, Status: Issued
• Special Permit No: DOT-SP 20255, Status: Issued
• Penalty Record (5 years): None
2. Reverse Distributor Facility 2
• Name: Covanta Manheim, Pennsylvania Facility may receive Unwanted Medicine from United
Parcel Service, Inc.
• Address: 190 Shellyland Road, Manheim, PA 17545
• Phone: (717) 653-8882
• Website: www.covantaes.com
• Type: DEA Registered Collector and Reverse Distributor
• DEA Registration No: RC0322595, Status: Issued
• Penalty Record (5 years): None
26
3. Reverse Distributor Facility 3
• Name: Stericycle, Inc., Indianapolis, Indiana Facility may receive Unwanted Medicine from United
Parcel Service, Inc.
• Address: 2670 Executive Drive, Suite A, Indianapolis, IN 46241-9901
• Phone: (317) 275-7530
• Website: www.stericycleenvironmental.com
• Type: DEA Registered Collector and Reverse Distributor & Permitted Hazardous Waste (RCRA)
Treatment, Storage, and/or Disposal Facility
• DEA Registration No: RS0331607, Status: Issued
• EPA ID No: INR000110197, Status: Issued
• TSDF (RCRA) Permit No: INR000110197, Status: Issued
• Solid Waste Processing Facility Permit No: FP 49-57, Status: Issued
• Air Quality Permit No: E097-28740-00671, Status: Issued
• Penalty Record (5 years): See Appendix K
4. Transporter 1
• Name: Transchem Environmental, LLC may transport Unwanted Medicine from the Covanta
Environmental Solutions, LLC Scottsdale, Arizona Facility to the Covanta Long Beach, California
Facility Solid Waste Combustor.
• Address: 542 East 27th Street, Tucson, AZ 85713
• Phone: (602) 344-4536
• Website: www.tcenv.com
• Type: Contract Carrier
• US EPA ID No: AZD982484578, Status: Issued
• US DOT No: 1341480, Status: Issued
• Penalty Record (5 years): None
5. Transporter 2
• Name: Doncin Transport, Inc. may transport Unwanted Medicine from the Covanta Manheim,
Pennsylvania Facility to the Curtis Bay Energy, LP Medical Waste Incinerator.
• Address: 3478 Sunnyside Rd., Manheim, PA 17545
• Phone: (602) 344-4536
• Website:
http://www.truckdrivingcdljobs.com/in/Pennsylvania/Manheim/DONCIN%20TRANSPORT%20INC.p
hp
• Type: Contract Carrier
• US DOT Number: 001625457, Status: Issued
• Penalty Record (5 years): None
6. Transporter 3
• Name: Stericycle Specialty Waste Solutions, Inc. may transport Unwanted Medicine from the
Stericycle, Inc., Indianapolis, Indiana Facility to the Stericycle, Inc., Warren, Ohio Facility.
• Address: 2850 100th Court NE, Blaine, MN 55449
• Phone: (612) 285-9865
• Website: www.stericycleenvironmental.com
• Type: Hazardous Waste Transporter
• US DOT No: 1348411, Status: Issued
• DOT ID No: MNS 000 110 924, Status: Issued
• Penalty Record (5 years): None
27
H. Disposal Facilities for Host-Assisted Collection Kiosk Drop-Off Sites
1. Disposal Facility 1
• Name: Covanta Long Beach will incinerate Unwanted Medicine received from Transchem
Environmental, LLC.
• Address: 118 Pier S Ave, Long Beach, CA 90802
• Phone: (562) 436-0636
• Website: www.covantaes.com
• Type: Municipal Solid Waste Combustor
• Solid Waste Permit: 19-AK-0083. County of Los Angeles Public Health, Status: Issued
• Title V Air Permit No: D47903. South Coast Air Quality Management District, Status: Issued
• US EPA ID No: CAD982520066, Status: Issued
• Penalty Record (5 years): None
2. Disposal Facility 2
• Name: Curtis Bay Energy, LP will incinerate Unwanted Medicine received from Doncin Transport,
Inc.
• Address: 3200 Hawkins Point Road Baltimore, MD 21226
• Phone: (855) 228-1715
• Website: www.curtisbayenergy.com
• Type: Permitted Medical Waste Incinerator
• Title V Air Permit No.: 24-510-02975, Status: Issued
• Maryland Department of the Environment Refuse Disposal Permit No.: 2017-WMI-0036, Status:
Issued
• US EPA ID No.: MDD985404318, Status: Issued
• Penalty Record (5 years): See Appendix K
3. Disposal Facility 3
• Name: Stericycle, Inc., Warren, Ohio Facility may incinerate Unwanted Medicine received from
Stericycle Specialty Waste Solutions, Inc or United Parcel Service, Inc.
• Address: 1901 Pine Avenue, S.E., Warren, OH 44483
• Phone: (330) 393-0370
• Website: https://www.stericycle.com/service-locations/ohio/warren
• Type: Medical Waste Incinerator
• DEA Registration No: RS0498130, Status: Issued
• Solid Waste Operating Permit No: CID 41805, Status: Issued
• Final Air Pollution Control Title V Permit No: P0115341, Status: Issued
• Penalty Record (5 years): None
28
Standard Mail-Back Services
I. Vendors for Standard Mail-Back Packages
1. Vendor 1
• Name: Stericycle Specialty Waste Solutions, Inc. may provide Standard Mail-Back Packages.
• Address: 2850 100th Court NE, Blaine, MN 55449
• Phone: (612) 285-9865
• Website: www.stericycleenvironmental.com
• US DOT No: 1348411, Status: Issued
• DOT ID No: MNS 000 110 924, Status: Issued
• Penalty Record (5 years): None
2. Vendor 2
• Name: Covanta Environmental Solutions, LLC may provide Standard Mail-Back Packages.
• Address: 7326 E. Evans Road, Suite B, Scottsdale, AZ 85620
• Phone: (855) 269-1750
• Website: www.covantaes.com
• DEA Registration No: RC0518160, Status: Issued
• Penalty Record (5 years): None
J. Carrier for Standard Mail-Back Packages
• Name: United States Postal Service may ship Standard Mail-Back Packages to the Stericycle, Inc.,
Warren, Ohio Facility. United States Postal Service may also ship Standard Mail-Back Packages to
the Covanta Manheim, Pennsylvania Facility.
• Address: 475 L’Enfant Plaza, S.W. Washington, DC 20260
• Phone: (202) 268-2000
• Website: www.USPS.com/
• Type: Common Carrier
• Penalty Record (5 years): For enforcement history, see USPS SEC filings
K. Reverse Distributor Facilities and Transporter for Standard Mail-Back Packages
1. Reverse Distributor Facility
• Name: Covanta Manheim, Pennsylvania Facility will receive Standard Mail-Back Packages from
Covanta Environmental Solutions, LLC via United States Postal Service.
• Address: 190 Shellyland Road, Manheim, PA 17545
• Phone: (717) 653-8882
• Website: www.covantaes.com
• Type: DEA Registered Collector and Reverse Distributor
• DEA Registration No: RC0322595, Status: Issued
• Penalty Record (5 years): None
29
2. Transporter
• Name: Doncin Transport, Inc. will transport Standard Mail-Back Packages from the Covanta
Manheim, Pennsylvania Facility to Covanta Lancaster and/or Covanta York.
• Address: 3478 Sunnyside Rd., Manheim, PA 17545
• Phone: (602) 344-4536
• Website:
http://www.truckdrivingcdljobs.com/in/Pennsylvania/Manheim/DONCIN%20TRANSPORT%20INC.p
hp
• Type: Contract Carrier
• US DOT Number: 001625457, Status: Issued
• Penalty Record (5 years): None
L. Disposal Facilities for Standard Mail-Back Packages
1. Disposal Facility 1
• Name: Stericycle, Inc. Warren, Ohio will incinerate Standard Mail-Back Packages received from
United States Postal Service.
• Address: 1901 Pine Avenue, S.E., Warren, OH 44483
• Phone: (330) 393-0370
• Website: www.stericycle.com/service-locations/ohio/warren
• Type: Medical Waste Incinerator
• DEA Registration No: RS0498130, Status: Issued
• Solid Waste Operating Permit No: CID 41805, Status: Issued
• Final Air Pollution Control Title V Permit No: P0115341, Status: Issued
• Penalty Record (5 years): None
2. Disposal Facility 2
• Name: Covanta Lancaster will incinerate Standard Mail-Back Packages received from the Covanta
Manheim, Pennsylvania Facility.
• Address: 1911 River Road, Bainbridge, PA 17502
• Phone: (717) 397-9968
• Website: www.covanta.com
• Type: Municipal Solid Waste Combustor
• Solid Waste Permit: 400592 PaDEP, Status: Issued
• Title V Operating Permit: 36-05013, Status: Issued
• US EPA ID No: CAD982520066, Status: Issued
• Penalty Record (5 years): None
3. Disposal Facility 3
• Name: Covanta York will incinerate Standard Mail-Back Packages received from the Covanta
Manheim, Pennsylvania Facility.
• Address: 2651 Blackbridge Road, York, PA 17406
• Phone: (717) 843-2902
• Website: www.covanta.com
• Type: Municipal Solid Waste Combustor
• Solid Waste Permit: 400561 PaDEP, Status: Issued
• Title V Operating Permit: 67-05006, Status: Issued
• Penalty Record (5 years): None
30
Inhaler Mail-Back Services
M. Vendors for Inhaler Mail-Back Packages
1. Vendor 1
• Name: PureWay Compliance Inc. may provide Inhaler Mail-Back Packages.
• Address: 20501 Katy Freeway, Suite 206, Katy, TX 77450
• Phone: (877) 765-3030
• Website: http://pureway.com/
• Penalty Record (5 years): None
2. Vendor 2
• Name: Stericycle Specialty Waste Solutions, Inc. may provide Inhaler Mail-Back Packages.
• Address: 2850 100th Court NE, Blaine, MN 55449
• Phone: (612) 285-9865
• Website: www.stericycleenvironmental.com
• US DOT No: 1348411, Status: Issued
• DOT ID No: MNS 000 110 924, Status: Issued
• Penalty Record (5 years): None
N. Carriers for Inhaler Mail-Back Packages
1. Carrier 1
• Name: United Parcel Service, Inc. will transport Inhaler Mail-Back Packages provided by PureWay
Compliance Inc. to Daniels Sharpsmart, Inc. Fresno, California Transfer Facility.
• Address: 55 Glenlake Parkway NE, Atlanta, GA 30328
• Phone: (800) PICK-UPS
• Website: www.UPS.com/
• Type: Common Carrier
• U.S. Small Package DOT No: 21800, Status: Issued
• U.S. Freight DOT No: 121058, Status: Issued
• Penalty Record (5 years): For enforcement history, UPS advises that “all material government
investigation and enforcement activity is provided in our SEC filings at investors.ups.com”
2. Carrier 2
• Name: United States Postal Service will transport Inhaler Mail-Back Packages provided by
Stericycle to the Stericycle, Inc. Warren, Ohio Facility.
• Address: 475 L’Enfant Plaza, S.W. Washington, DC 20260
• Phone: (202) 268-2000
• Website: www.USPS.com/
• Type: Common Carrier
• Penalty Record (5 years): For enforcement history, see USPS SEC filings
31
O. Transfer Facility for Inhaler Mail-Back Packages
• Name: Daniels Sharpsmart, Inc. Fresno, California Transfer Facility will receive Inhaler Mail-Back
Packages provided by PureWay Compliance Inc. and provide for transport to the Covanta
Huntsville, Inc. or Covanta Marion, Inc. Municipal Waste Combustors.
• Address: 4144 East Therese Avenue, Fresno, CA 93725
• Phone: (559) 834-6252
• Website: http://danielsinternational.com/
• Type: Medical Waste Treatment Facility
• Medical Waste Permit No: TS-OST-55, Status: Issued
• CA EPA ID No: CAL000344393, Status: Issued
• US DOT No: 1295076, Status: Issued
• Penalty Record (5 years): See Appendix K
P. Transporter(s) for Inhaler Mail-Back Packages
1. Transporter 1
• Name: Lula Logistics Inc. may transport Inhaler Mail-Back Packages provided by PureWay
Compliance Inc. and received from the Daniels Sharpsmart, Inc. Fresno, California Transfer Facility
to the Covanta Huntsville, Inc. or Covanta Marion, Inc. Municipal Waste Combustors.
• Address: 8268 Nelson Ridge Ln, Las Vegas, NV 89178
• Phone: (352) 346-6219
• Email: https://www.lulalogisticsinc.com/
• Type: Contract Carrier
• US DOT No: 2335002, Status: Issued
• Penalty Record (5 years): None
2. Transporter 2
• Name: GPB Logistics Inc. may transport Inhaler Mail-Back Packages provided by PureWay
Compliance Inc. and received from the Daniels Sharpsmart, Inc. Fresno, California Transfer Facility
to the Covanta Huntsville, Inc. or Covanta Marion, Inc. Municipal Waste Combustors.
• Address: 2115 W Farwell Ave #103, Chicago, IL 60645
• Phone: (773) 968-7210
• Website: www.gpblogistics.com
• Type: Contract Carrier
• US DOT No: 2783871, Status: Issued
• Penalty Record (5 years): None
Q. Disposal Facilities for Inhaler Mail-Back Packages
1. Disposal Facility 1
• Name: Covanta Huntsville, Inc. will incinerate Inhaler Mail-Back Packages provided by PureWay
Compliance Inc. and received from Daniels Sharpsmart, Inc. Fresno, California Transfer Facility.
• Address: 5251 Triana Blvd SW, Huntsville, AL 35805
• Phone: (256) 882-1019
• Website: https://www.covanta.com/Our-Facilities/Covanta-Huntsville
• Type: Municipal Waste Combustor
• Title V Air Permit No: 709-1104, Status: Issued
• US EPA ID No: AL0000266726, Status: Issued
• Penalty Record (5 years): None
32
2. Disposal Facility 2
• Name: Covanta Marion, Inc. will incinerate Inhaler Mail-Back Packages provided by PureWay
Compliance Inc. and received from Daniels Sharpsmart, Inc. Fresno, California Transfer Facility.
• Address: 4850 Brook Lake Rd. NE, Brooks, OR 97305
• Phone: (503) 393-0890
• Website: https://www.covanta.com/Our-Facilities/Covanta-marion
• Type: Municipal Waste Combustor
• Conditionally Exempt Small Quantity Generator: ORD987179470, Status: Issued
• Title V Air Permit No: 24-5398-TV-01, Status: Issued
• NPDES Permit No: 1200-Z, Status: Issued
• Solid Waste Permit No: 364, Status: Issued
• Penalty Record (5 years): None
3. Disposal Facility 3
• Name: Stericycle, Inc. Warren, Ohio will incinerate Inhaler Mail-Back Packages provided by
Stericycle and received from the United States Postal Service.
• Address: 1901 Pine Avenue, S.E., Warren, OH 44483
• Phone: (330) 393-0370
• Website: www.stericycle.com/service-locations/ohio/warren
• Type: Medical Waste Incinerator
• DEA Registration No: RS0498130, Status: Issued
• Solid Waste Operating Permit No: CID 41805, Status: Issued
• Final Air Pollution Control Title V Permit No: P0115341, Status: Issued
• Penalty Record (5 years): None
33
Unwanted Medicine Educational and Outreach Programming
A. Overview
MED-Project will perform public education and outreach to educate Residents about the collection and
disposal of Unwanted Medicine from households.
B. Audiences
To effectively educate the public about the Program, MED-Project will continue to implement a
comprehensive communications campaign featuring both broad communications tactics as well as
targeted outreach to audiences directly involved in the distribution and use of medicines to Residents.
These audiences may include:
• General public;
• Pharmacies, including education for dispensers of Unwanted Medicine;
• Retailers of Unwanted Medicine;
• Health care providers and their patients;
• Veterinary providers and animal owners;
• Public health facilities; and/or
• LEAs.
The Program will include efforts to reach the varied cultural, linguistic, geographic, and age demographics,
including through outreach to ethnic, community, and alternate-language media; outreach to community
organizations serving a broad range of audiences; availability of alternate language phone lines (Section
XI.D.1); and availability of educational information through a broad range of media platforms.
Demographic information from the US Census Bureau, including race, ethnicity, language, age, and
geographic data, will be analyzed in the survey (see Section XI.F) in order to appropriately direct outreach
and create educational materials to best serve the unique needs of identified demographics.
C. Messages
MED-Project anticipates that messaging will:
• Educate Residents about the appropriate use, storage, and disposal of Unwanted Medicine;
• Educate Residents about available Mail-Back Services; and
• Provide Residents with information about available locations and events in their area that offer
disposal of Unwanted Medicine.
Key points of emphasis might include:
• The importance of taking medicines as prescribed by your health care provider;
• The importance of adhering to and completing your provider-prescribed therapy;
• The importance of properly and securely storing medicines;
• The importance of promptly and properly disposing of Unwanted Medicine;
• How to find and use Kiosk Drop-Off Sites;
• How to properly dispose of Unwanted Medicine; and
• Privacy issues (removing personally identifiable information from labeled prescription containers).
34
D. Tools/Communications Channels
The MED-Project Program will include a number of components designed to reach consumers and provide
consistent access to timely and relevant information. Distribution of materials will likely include audiences
such as LEAs, retail pharmacies, health care providers and systems, health associations, local government
agencies, and other community organizations.
MED-Project will evaluate media and public outreach against the goal of a combined target reach percent
of 50% at a 2+ frequency for the duration of one month, at least three times per year for years 2 through 4
of the Program. MED-Project intends to meet this target with a combination of digital media campaigns,
print ads, and traditional broadcast media. The quantity and frequency will be confirmed as activities are
completed.
MED-Project expects that the tools and communication channels will include:
1. Phone
The Program will provide a toll-free telephone number for Residents to obtain information about Kiosk
Drop-Off Sites, Take-Back Events, Mail-Back Services, educational materials, and other aspects of the
Program for the take-back of Unwanted Medicine from households. The toll-free number will provide:
• Call Center in the Specified Languages. The telephone line will also provide an option for callers to
be transferred to a staffed Call Center.
• Basic information about the Program, such as where to obtain more information (e.g., the MED-
Project Website) and an option to talk with an agent to find or utilize Kiosk Drop-Off Sites, Mail-
Back Services, and/or Take-Back Events, if applicable, in the caller’s zip code or local area.
• A recorded call script directing callers with medical emergencies to call 911 and directing callers
with medication-related questions to contact their health care provider(s).
Please see Appendix L for the call script.
2. MED-Project Website
MED-Project will update the mobile-friendly MED-Project Website with translations in the Specified
Languages. MED-Project expects information available to users will include pages to help Residents find
locations of Kiosk Drop-Off Sites, Mail-Back Services, as well as educational materials, frequently asked
questions and responses, and Take-Back Event dates and locations.
• The Plan currently includes a mockup of the types of information a MED-Project Website and its
supporting pages might contain. Appendix M provides a proof of concept example for a possible
MED-Project Website with subpages.
• The MED-Project Website may also include access to a public relations toolkit in a downloadable
format (see Section XI.D.3) and contact information for Residents. A toolkit could include items
such as a flyer/brochure (See Appendix N for an example) and a frequently asked questions (FAQ)
document. Translations of the brochure and FAQ will be available in the Specified Languages.
• Community and government organizations and other public interest groups seeking materials to
promote the Program will be encouraged to access these resources.
35
3. Materials
Educational materials about the Program and how to properly dispose of Unwanted Medicine will be
available through the MED-Project Website, through potential third-party partners, community
organizations, and at Kiosk Drop-Off Sites.
The Plan includes the information and educational brochure (Appendix N). Educational materials will use
plain language and explanatory images to promote consumer education and collection options to
Residents with limited English proficiency.
4. Social Media
MED-Project will continue the social media campaign consisting of Facebook and Twitter. These social
media portals (Appendix O) are used to communicate the latest information to Residents. Outreach is
based on the establishment of Kiosk Drop-Off Sites and the scheduling of Take-Back Events. Posts are
scheduled on a weekly basis to reflect the most up-to-date information available.
5. Broadcast Outreach
Outreach through local print, online, radio, and television outlets, including through outlets specifically
targeting the diverse demographic communities within the County, will continue upon Plan approval.
Please see Appendix F for a media list of key outlets. Broadcast outreach will be scheduled on a quarterly
basis to reflect real time implementation developments.
E. Collaboration with County Officials and Community Organizations
MED-Project expects that the Program will work in collaboration with the County as appropriate to build on
existing community outreach resources, such as local organizations, media lists, available public media
outlets, etc. Activities like the following will continue upon Plan approval:
• Briefing Materials Provided to Support Coordination with County Officials:
o The Program will provide access to updated educational and outreach materials, including
the brochure (see Appendix N), to relevant departments and officials.
• Outreach through Community Organizations:
o The Program will engage relevant stakeholders and community organizations by providing
selected community organizations identified in Appendix B with the updated brochure
included in Appendix N.
F. Effectiveness
MED-Project will conduct a biennial survey of Residents and pharmacists, veterinarians, and health
professionals in the County who interact with patients to measure Program awareness and to evaluate the
effectiveness of its education and outreach activities. The survey will be conducted in conjunction with the
biennial survey conducted under MED-Project’s stewardship program for the collection of sharps from
households. The first survey will be conducted after the first full year of operation of MED-Project’s
program for sharps.
G. Disclaimer
The written and verbal educational materials and public outreach tools that are required by the Ordinance
and disseminated under this Product Stewardship Plan will include a disclaimer similar to the following:
“This material has been provided for the purpose of compliance with legislation and does not necessarily
reflect the views of MED-Project or the Producers participating in the MED-Project Product Stewardship
Plan.”
36
Compliance with Applicable Laws, Regulations, and other Legal Requirements
As described in more detail below, the Plan is designed such that all entities participating in the Program
shall comply with all applicable laws, regulations, and other legal requirements.
A. DEA Controlled Substances Act and Implementing Regulations
On October 12, 2010, the United States Congress enacted the Secure and Responsible Drug Disposal Act
of 2010 (“Disposal Act”) as amendments to the Controlled Substances Act (“CSA”). The Disposal Act
amended the CSA to allow for the expansion of entities to which users can deliver pharmaceutical
controlled substances for disposal, subject to regulations to be promulgated. On September 9, 2014, the
DEA adopted a rule entitled “Disposal of Controlled Substances” (referred to herein as the “DEA Rule”) to
implement the Disposal Act.
Under the DEA Rule, collection of controlled substances is limited to Schedule II, III, IV, or V controlled
substances that are lawfully possessed by an ultimate user or person entitled to dispose of an ultimate
user decedent’s property. See DEA Rule §§ 1317.75(b) (Kiosk Drop-Off Sites)5; 1317.65(d) (Take-Back Events);
1317.70(b) (Mail-Back Services). Schedule I controlled substances, controlled substances that are not
lawfully possessed as described above, and other illicit or dangerous substances will not be collected.
Additionally, as these provisions of the DEA Rule limit collection of controlled substances to those lawfully
possessed by an ultimate user or certain other persons, pharmacies are prohibited from disposing their
own inventory or stock through the MED-Project Program. See also DEA Rule § 1317.05.
The DEA Rule provides that LEAs can continue to accept controlled substances for disposal. However, the
DEA Rule also provides that pharmacies, reverse distributors, hospitals/clinics with on-site pharmacies, and
certain other entities, can register with the DEA as “collectors” and become authorized at their discretion
on a voluntary basis to accept controlled substances. The DEA Rule:
• Provides for the collection of controlled substances at Kiosk Drop-Off Sites at LEAs, pharmacies,
and hospitals with on-site pharmacies;
• Provides for collection of controlled substances at Take-Back Events;
• Provides for the use of mail-back programs to collect controlled substances;
• Allows for the commingling of controlled and non-controlled substances;
• Establishes detailed collection, recordkeeping, security, and other measures for all approved
collection methods; and
• Provides that all collected pharmaceutical products be destroyed so that the products are
rendered non-retrievable.
The Plan is designed such that all entities that are part of the Program, including Vendor, are individually
responsible to comply with their respective compliance obligations under the DEA Rule. Vendor will ensure
that the collection, transportation, and disposal of Unwanted Medicine collected from Kiosk Drop-Off Sites,
Mail-Back Services, and Take-Back Events, including controlled substances, complies with all DEA
requirements, including those in DEA Rule § 1317.
Controlled substances collected pursuant to the Plan may be commingled with non-controlled substances
at Kiosk Drop-Off Sites, Take-Back Events, and through Mail-Back Services per the DEA Rule. See DEA
Rule §§ 1317.75(b) (Kiosk Drop-Off Sites); 1317.65(d) (Take-Back Events); 1317.70(b) (Mail-Back Services).
5 For Kiosk Drop-Off Site collection, only certain substances “that are lawfully possessed by an ultimate user or other
authorized non-registrant person may be collected.” DEA Rule § 1317.75(b). This language is similar to, but slightly
different than, provisions limiting collection at Take-Back Events and through Mail-Back Services to ultimate users or
other persons (lawfully) entitled to dispose of an ultimate user decedent’s property. See DEA Rule §§ 1317.65(d);
1317.70(b).
37
1. DEA Registration Modification
Pursuant to DEA Rule § 1301.51(b), pharmacies may modify their registrations to become authorized
collectors by submitting a written request to the DEA or online at www.DEAdiversion.usdoj.gov. This
request must contain:
• The registrant’s name, address, and registration number (as printed on the registration certificate);
• The collection methods the registrant intends to conduct; and
• A signature in accordance with 21 C.F.R. § 1301.13(j).
See DEA Rule § 1301.51(b). MED-Project will consult with participating pharmacies, as requested, regarding
how to modify DEA registrations to become authorized collectors.
B. United States Department of Transportation (DOT)
When preparing Unwanted Medicine for transport and transporting Unwanted Medicine, Vendor or the
Host-Assisted Collection Kiosk Drop Off-Site will ensure compliance with the DOT Hazardous Materials
Regulations (HMR).
C. California Board of Pharmacy
On June 8, 2017, the Board of Pharmacy adopted the Board of Pharmacy Regulations, Article 9.1 of Division
17 of Title 16 of the California Code of Regulations. Largely based on the DEA Rule, the Board of Pharmacy
Regulations establish requirements applicable to pharmacies, hospitals/clinics with on-site pharmacies,
distributors, and reverse distributors conducting certain drug take-back services. Among other things, the
Board of Pharmacy Regulations provide:
• That California-licensed pharmacies and hospitals/clinics with on-site pharmacies must be in good
standing with, and notify, the Board of Pharmacy to host a drug kiosk. See 16 CCR §§ 1776, 1776.1(i).
• That pharmacies must “know and adhere” to all applicable “federal, state, and local requirements
governing the collection and destruction of dangerous drugs” when operating a drug take-back
program. See 16 CCR § 1776.1(b).
• Drug kiosk placement and monitoring requirements. See 16 CCR §§ 1776.3(b)–(d).
• Drug kiosk inner liner, container, and signage requirements. See 16 CCR §§ 1776.3(f), (h), (m).
• Inner liner handling, storage, and destruction requirements for drug kiosks. See, e.g., 16 CCR §§
1776.3(h)–(j), 1776.5(a)–(c).
• Pharmacy and reverse distributor recordkeeping requirements. See 16 CCR §§ 1776.5(e)–(f), 1776.6.
• Pharmacy drug mail-back program requirements. See 16 CCR § 1776.2.
The Plan is designed such that all entities that are part of the Program, including Vendor, are individually
responsible for complying with their respective compliance obligations under the Board of Pharmacy
Regulations.
Annual Report
An annual report will be provided to the Director on or before the date set by the Department and annually
thereafter. Ordinance § 6.53.080. This report will be provided in the format required by the Ordinance §
6.53.080 and Regulations § 15. The total amount by weight collected by a Mail-Back Program will be
provided using an average weight per Mail-Back Package, as provided by Vendor.
38
Appendix A
MED-Project Participants
The list of participating Producers in MED-Project’s Program in the County is provided to the County on a
periodic basis to satisfy Ordinance requirements.
39
Appendix B
Contact List for Outreach and Education to the Community
The following are Associations, Agencies, and Organizations that may be contacted for assistance with
outreach and education to the community.
Health Systems:
Alameda County Medical Center
Alameda Hospital
Alta Bates Summit Medical Center
Children’s Hospital and Research Center
Eden Medical Center
Fremont Hospital
Kaiser Foundation Hospital
Kindred Hospital
Mpi Chemical Dependency Recovery Hospital
San Leandro Hospital
St. Rose Hospital
Telecare Heritage Psychiatric Health Facility
Telecare Willow Rock Center
Thunder Road Chemical Dependency Recovery
Hospital
Valley Memorial Hospital
Valleycare Medical Center
Washington Hospital
Health Associations and Societies:
California State Board of Pharmacy
California Pharmacists Association
The Medical Board of California
California Nurses Association
National Association of Social Workers California
Chapter
California Board of Registered Nursing
California Board of Vocational Nursing
California Department of Health Care Services
California Health and Human Services Agency
Alameda-Contra Costa Medical Association
Organizations, Districts, and Agencies:
Alameda County Public Health Department
Alameda County Department of Environmental
Health
Alameda County Public Works Agency
Health Program of Alameda County
Alameda County Board of Supervisors
Alameda County Fire Department
American Medical Response Alameda County
CalRecycle
Recyclewhere.org
40
Appendix C
Interested Sites and Participating Kiosk Drop-Off Sites
MED-Project will provide the County with a list of participating Kiosk Drop-Off Sites on a periodic basis.
Site Name Address City Zip
Code
Status
ALAMEDA HOSPITAL 2070 CLINTON AVENUE ALAMEDA 94501 ACTIVE
ALAMEDA POLICE
DEPARTMENT
1555 OAK ST. ALAMEDA 94501 ACTIVE SITE
BART POLICE
DEPARTMENT
101 8TH ST OAKLAND 94607 ACTIVE SITE
BERKELEY POLICE
DEPARTMENT
2100 MARTIN LUTHER KING
JR. WAY
BERKELEY 94704 ACTIVE SITE
CAPSULE PHARMACY 2557 MOWRY AVE FREMONT 94538 ACTIVE SITE
CITY OF NEWARK POLICE
DEPARTMENT
37101 NEWARK ST. NEWARK 94560 ACTIVE SITE
CVS/PHARMACY #0331 2000 DRISCOLL RD FREMONT 94539 ACTIVE SITE
CVS/PHARMACY #0414 14869 E 14TH ST SAN LEANDRO 94578 ACTIVE SITE
CVS/PHARMACY #0816 22501 FOOTHILL BLVD HAYWARD 94541 ACTIVE SITE
CVS/PHARMACY #09397 4405 1ST ST LIVERMORE 94551 ACTIVE SITE
CVS/PHARMACY #09494 35080 NEWARK BLVD NEWARK 94560 ACTIVE SITE
CVS/PHARMACY #09553 4349 SAN PABLO AVENUE EMERYVILLE 94608 ACTIVE SITE
CVS/PHARMACY #09600 35720 FREMONT BLVD FREMONT 94536 ACTIVE SITE
CVS/PHARMACY #09622 243 W JACKSON ST HAYWARD 94544 ACTIVE SITE
CVS/PHARMACY #09635 1550 E 14TH STREET SAN LEANDRO 94577 ACTIVE SITE
CVS/PHARMACY #09678 1500 1ST ST LIVERMORE 94550 ACTIVE SITE
CVS/PHARMACY #09876 699 LEWELLING BLVD SAN LEANDRO 94579 ACTIVE SITE
41
Site Name Address City Zip
Code
Status
CVS/PHARMACY #09904 3667 CASTRO VALLEY BLVD CASTRO
VALLEY
94546 ACTIVE SITE
CVS/PHARMACY #09941 1451 SHATTUCK AVE BERKELEY 94709 ACTIVE SITE
CVS/PHARMACY #09942 1401 WASHINGTON AVE SAN LEANDRO 94577 ACTIVE SITE
CVS/PHARMACY #09957 344 THOMAS L BERKLEY WAY OAKLAND 94612 ACTIVE SITE
CVS/PHARMACY #10119 6750 BERNAL AVE PLEASANTON 94566 ACTIVE SITE
CVS/PHARMACY #10121 2655 TELEGRAPH AVE BERKELEY 94704 ACTIVE SITE
CVS/PHARMACY #10199 26059 MISSION BLVD HAYWARD 94544 ACTIVE SITE
CVS/PHARMACY #10475 2964 BROADWAY OAKLAND 94611 ACTIVE SITE
CVS/PHARMACY #10924 3010 BERNAL AVE PLEASANTON 94566 ACTIVE SITE
CVS/PHARMACY #3024 7201 REGIONAL ST DUBLIN 94568 ACTIVE SITE
CVS/PHARMACY #3026 2300 SHATTUCK AVE BERKELEY 94704 ACTIVE SITE
CVS/PHARMACY #8431 7200 BANCROFT AVE OAKLAND 94605 ACTIVE SITE
CVS/PHARMACY #9099 4020 FREMONT HUB FREMONT 94538 ACTIVE SITE
CVS/PHARMACY #9128 2314 SANTA CLARA AVE ALAMEDA 94501 ACTIVE SITE
CVS/PHARMACY #9130 175 41ST ST OAKLAND 94611 ACTIVE SITE
CVS/PHARMACY #9226 3320 FRUITVALE AVE OAKLAND 94602 ACTIVE SITE
CVS/PHARMACY #9234 46445 MISSION BLVD FREMONT 94539 ACTIVE SITE
CVS/PHARMACY #9250 885 ISLAND DR STE A ALAMEDA 94502 ACTIVE SITE
CVS/PHARMACY #9251 3999 SANTA RITA ROAD PLEASANTON 94588 ACTIVE SITE
CVS/PHARMACY #9255 931 MARINA VILLAGE PKWY ALAMEDA 94501 ACTIVE SITE
CVS/PHARMACY #9378 4100 REDWOOD RD OAKLAND 94619 ACTIVE SITE
DUBLIN POLICE SERVICES 100 CIVIC PLAZA DUBLIN 94568 ACTIVE SITE
42
Site Name Address City Zip
Code
Status
EDEN HOSPITAL (1ST
KIOSK)
20103 LAKE CHABOT ROAD CASTRO
VALLEY
94546 INTERESTED
EDEN HOSPITAL (2ND
KIOSK)
20103 LAKE CHABOT ROAD CASTRO
VALLEY
94546 INTERESTED
EMERYVILLE POLICE
DEPARTMENT
2449 POWELL ST EMERYVILLE 94608 ACTIVE SITE
HALLER'S PHARMACY AND
MEDICAL SUPPLY
37323 FREMONT BLVD. FREMONT 94536 ACTIVE SITE
HIGHLAND HOSPITAL
OUTPATIENT PHARMACY
(1ST KIOSK)
1411 E 31ST ST OAKLAND 94602 ACTIVE SITE
HIGHLAND HOSPITAL
OUTPATIENT PHARMACY
(2ND KIOSK)
1411 E 31ST ST OAKLAND 94602 ACTIVE SITE
JADE PHARMACY 34460 FREMONT BLVD, SUITE
B
FREMONT 94555 ACTIVE SITE
KAISER FDN HLT PLAN
FABIOLA 1 PHY 115
3801 HOWE ST. OAKLAND 94511 ACTIVE SITE
KAISER HEALTH PLAN
OHLONE PHY 162
39400 PASEO PADRE PKWAY FREMONT 94538 ACTIVE SITE
KAISER HEALTH PLAN
PEDIATRIC PHY 118
3505 BROADWAY OAKLAND 94611 ACTIVE SITE
KAISER HEALTH PLAN
SOUTH 1 PHY 471
7601 STONERIDGE PLEASANTON 94588 ACTIVE SITE
KAISER PERMANENTE
PHARMACY #102
3701 BROADWAY OAKLAND 94611 ACTIVE SITE
KAISER PERMANENTE
PHARMACY #105
3600 BROADWAY OAKLAND 94611 ACTIVE SITE
KAISER PERMANENTE
PHARMACY #241
3000 LOS POSITAS LIVERMORE 94551 ACTIVE SITE
43
Site Name Address City Zip
Code
Status
KAISER PERMANENTE
PHARMACY NO 101
2417 CENTRAL AVE. ALAMEDA 94501 ACTIVE SITE
KAISER UNION CITY MAIN
MOB 2 PHY #132
3553 WHIPPLE RD. UNION CITY 94587 ACTIVE SITE
MISSION PHARMACY 22138 MISSION BLVD. HAYWARD 94541 ACTIVE SITE
MOWRY MEDICAL
PHARMACY
1999 MOWRY AVE., STE A FREMONT 94538 ACTIVE SITE
NEW OAKLAND
PHARMACY - LAKE
MERRITT
250 E. 18TH ST. OAKLAND 94606 ACTIVE SITE
NEW OAKLAND
PHARMACY #2
388 9TH ST. OAKLAND 94607 ACTIVE SITE
NEW OAKLAND
PHARMACY_#1
333 9TH ST. OAKLAND 94607 ACTIVE SITE
PIEDMONT POLICE
DEPARTMENT
403 HIGHLAND AVE PIEDMONT 94611 ACTIVE SITE
PLEASANTON POLICE
DEPARTMENT
4833 BERNAL AVE. PLEASANTON 94566 ACTIVE SITE
RITE AID 05918 3744 MOWRY AVENUE FREMONT 94538 INTERESTED
RITE AID 05920 31091 MISSION BOULEVARD HAYWARD 94544 INTERESTED
RITE AID 05922 3848 CASTRO VALLEY
BOULEVARD
CASTRO
VALLEY
94546 INTERESTED
RITE AID 05925 968 MURRIETA BOULEVARD LIVERMORE 94550 INTERESTED
RITE AID 05937 1355 MACARTHUR
BOULEVARD
SAN LEANDRO 94577 INTERESTED
RITE AID 05942 31836 ALVARADO
BOULEVARD
UNION CITY 94587 INTERESTED
RITE AID 05943 1650 DECOTO ROAD UNION CITY 94587 INTERESTED
44
Site Name Address City Zip
Code
Status
RITE AID 05944 2819 HOPYARD ROAD PLEASANTON 94588 INTERESTED
RITE AID 05952 1991 MOUNTAIN BOULEVARD OAKLAND 94611 INTERESTED
RITE AID 06456 1350 NORTH VASCO ROAD LIVERMORE 94551 INTERESTED
SAN LEANDRO HOSPITAL 13855 EAST 14TH ST SAN LEANDRO 94578 ACTIVE SITE
STANFORD EMERYVILLE
HEALTH CENTER
PHARMACY
5800 HOLLIS ST. EMERYVILLE 94608 ACTIVE SITE
TEDS DRUGS 27453 HESPERIAN HAYWARD 94545 ACTIVE SITE
TENNYSON PHARMACY 589 W. TENNYSON HAYWARD 94544 ACTIVE SITE
UNITED PHARMACY 2929 TELEGRAPH AVE BERKELEY 94705 ACTIVE SITE
VITACARE PHARMACY 2775 TELEGRAPH AVE OAKLAND 94612 ACTIVE SITE
WASHINGTON HOSPITAL
PHARMACY
2000 MOWRY AVE FREMONT 94538 ACTIVE SITE
WELLSPRING PHARMACY 4184 C PIEDMONT AVE OAKLAND 94611 ACTIVE SITE
45
Appendix D
Potential Additional Kiosk Drop-Off Sites
Site Name Address City Zip
AHF PHARMACY 400 THIRTIETH ST STE 300 OAKLAND 94609
ALAMEDA PHARMACY LLC 1555 DOOLITTLE DRIVE #160 SAN
LEANDRO
94577
ALTA BATES SUMMIT MED CTR-HERRICK
CAMPUS
2001 DWIGHT WY BERKELEY 94704
ALTA BATES SUMMIT MEDICAL CENTER -
ALTA BATES CAMPUS
2450 ASHBY AVE BERKELEY 94705
ALTA BATES SUMMIT MEDICAL CENTER -
SUMMIT CAMPUS
350 HAWTHORNE AVE OAKLAND 94609
ALTA BATES SUMMIT OUTPATIENT
PHARMACY
2001 DWIGHT WAY STE 2182 BERKELEY 94704
BRADFORD PHARMACY INC. 445 8TH STREET OAKLAND 94607
CALIFORNIA STATE UNIVERSITY, EAST BAY 25800 CARLOS BEE BLVD HAYWARD 94542
CENTRAL ADMIXTURE PHARMACY SERVICES
INC
48006 FREMONT BLVD FREMONT 94538
CHILDREN'S HOSPITAL & RESEARCH CENTER
AT OAKLAND
747 52ND ST OAKLAND 94609
CHILDREN'S HSP MED CTR AMBULATORY
CARE
744 52ND ST OAKLAND 94609
CHILDRENS CLINIC PHARMACY 747 52ND STREET OAKLAND 94609
CLEAR CHOICE PHARMACY 3059 HOPYARD RD STE C PLEASANTON 94588
COMMUNITY A WALGREENS PHARMACY
#16477
3009 BROADWAY OAKLAND 94611
CORAM CVS/SPECIALTY INFUSION
SERVICES
3160 CORPORATE PLACE HAYWARD 94545
COSTCO PHARMACY #1061 28505 HESPERIAN BLVD HAYWARD 94545
COSTCO PHARMACY #146 2800 INDEPENDENCE DRIVE LIVERMORE 94550
COSTCO PHARMACY #778 43621 PACIFIC COMMONS
BLVD
FREMONT 94538
46
COSTCO PHARMACY 118 1900 DAVIS STREET SAN
LEANDRO
94577
CPP PET CARE 3157 CORPORATE PL HAYWARD 94545
CRESCENT HEALTHCARE 2547 BARRINGTON CT HAYWARD 94545
CVS/PHARMACY # 16116 7200 AMADOR PLAZA RD DUBLIN 94568
CVS/PHARMACY # 16275 4300 LAS POSITAS RD LIVERMORE 94551
CVS/PHARMACY # 16764 15555 E 14TH ST STE 400 SAN
LEANDRO
94578
CVS/PHARMACY # 16804 2499 WHIPPLE RD HAYWARD 94544
CVS/PHARMACY # 17044 1057 ESTSHORE HWY ALBANY 94710
CVS/PHARMACY # 17265 19661 HESPERIAN BLVD HAYWARD 94541
CVS/PHARMACY # 17592 43950 PACIFIC COMMONS
BLVD
FREMONT 94538
CVS/PHARMACY # 17624 1555 40TH STREET EMERYVILLE 94608
CVS/PHARMACY # 17628 2800 DUBLIN BLVD DUBLIN 94568
CVS/PHARMACY # 17657 2700 5TH ST ALAMEDA 94501
CVS/PHARMACY # 17673 2187 SHATTUCK AVE BERKELEY 94704
DOLPHIN HEALTH PHARMACY 7400 MACARTHUR BLVD NO A OAKLAND 94605
DRATE PHARMACY 3219 ADELINE STREET BERKELEY 94703
EAST BAY AIDS CENTER OUTPATIENT
PHARMACY
3100 SUMMIT ST OAKLAND 94609
ENTIRELYPETS PHARMACY 34571 SEVENTH ST UNION CITY 94587
FAIRMONT HOSPITAL PHARMACY 15400 FOOTHILL BOULEVARD SAN
LEANDRO
94578
FOODMAXX PHARMACY #484 3100 EAST 9TH ST OAKLAND 94601
FREMONT HOSPITAL 39001 SUNDALE DR FREMONT 94538
FRUITVALE AVENUE PHARMACY 2693 FRUITVALE AVE OAKLAND 94601
47
GARFIELD BEACH CVS LLC CVS/PHARMACY
#10475
2964 BROADWAY OAKLAND 94611
GARFIELD BEACH CVS LLC D/B/A
CVS/PHARMACY # 17712
1414 UNIVERSITY AVE BERKELEY 94702
HALLER'S LTC PHARMACY 4067 PERALTA BLVD FREMONT 94536
HAYWARD SISTERS HOSPITAL DBA ST ROSE
HOSPITAL
27200 CALAROGA AVE RM A1-
108
HAYWARD 94545
HERRICK CAMPUS PHARMACY 2100 DWIGHT WAY RM 2113 BERKELEY 94704
HIGH STREET PHARMACY 4248 MACARTHUR BLVD OAKLAND 94619
INTEGRATED MEDICAL ASSOCIATES
PHARMACY INC
10500 MACARTHUR BLVD
#103
OAKLAND 94605
JOHN GEORGE PSYCHIATRIC PAVILION PHY 2060 FAIRMONT DRIVE SAN
LEANDRO
94578
KAISER FDN HSP INP PHY 16A 39400 PASEO PADRE
PARKWAY
FREMONT 94538
KAISER FOUNDATION CPP PHARMACY 251 300 G PULLMAN STREET LIVERMORE 94550
KAISER FOUNDATION HOSPITAL PHARMACY
#10A
275 W MACARTHUR BLVD OAKLAND 94611
KAISER FOUNDATION HOSPITAL PHARMACY
#92A
2500 MERCED ST HOSPITAL
BLDG
SAN
LEANDRO
94577
KAISER FOUNDATION HOSPITAL PHY #47B 7601 STONERIDGE DR RM 218 PLEASANTON 94588
KAISER HEALTH PLAN NILES 3 PHY 164 39400 PASEO PADRE
PARKWAY
FREMONT 94538
KAISER HEALTH PLAN NILES PHY 161 39400 PASEO PADRE
PARKWAY
FREMONT 94538
KAISER HEALTH PLAN NORTH 1 PHY 473 5600 STONERIDGE MALL
ROAD
PLEASANTON 94588
KAISER HEALTH PLAN SOUTH 2 PHY 472 7601 STONERIDGE DR PLEASANTON 94588
KAISER HLTH PLAN SLEEPY HOLLOW PHY
143
27303 SLEEPY HOLLOW
AVENUE SOUTH
HAYWARD 94545
KAISER ONCOLOGY PHARMACY #104 3701 BROADWAY FLR 3 OAKLAND 94611
KAISER ONCOLOGY PHARMACY #165 39400 PASEO PADRE PKWY
NILES BLDG 2ND FL
FREMONT 94538
48
KAISER PERMANENTE PHARMACY #181 1795 SECOND ST, SUITE B BERKELEY 94710
KAISER PERMANENTE PHARMACY #921 2500 MERCED ST FL 1 SAN
LEANDRO
94577
KAISER PERMANENTE PHARMACY #922 2500 MERCED ST 2ND FL RM
2966
SAN
LEANDRO
94577
KINDRED HSP-SAN FRANCISCO BAY 2800 BENEDICT DR SAN
LEANDRO
94577
LA CLINICA DE LA RAZA 3451 E 12TH ST OAKLAND 94601
LA CLINICA DE LA RAZA, INC. 1030 INTERNATIONAL BLVD OAKLAND 94606
LIFESCRIPT PHARMACY 7700 EDGEWATER DR #220 OAKLAND 94621
LIRX 1860 MOWRY AVE STE 102 FREMONT 94538
LUCKY PHARMACY #711 40055 MISSION BLVD FREMONT 94539
LUCKY PHARMACY #712 34101 FREMONT BLVD FREMONT 94555
LUCKY PHARMACY #714 5000 MOWRY AVE FREMONT 94538
LUCKY PHARMACY #715 22555 MISSION BLVD HAYWARD 94541
LUCKY PHARMACY #716 25151 SANTA CLARA ST HAYWARD 94544
LUCKY PHARMACY #721 2000 PORTOLA AVE LIVERMORE 94550
LUCKY PHARMACY #722 1951 HOLMES ST LIVERMORE 94550
LUCKY PHARMACY #736 247 E 18TH ST OAKLAND 94606
LUCKY PHARMACY #744 6155 W LAS POSITAS BLVD PLEASANTON 94588
LUCKY PHARMACY #767 1300 FAIRMONT DR SAN
LEANDRO
94578
LUCKY PHARMACY #768 15840 HESPERIAN BLVD SAN
LORENZO
94580
LUCKY PHARMACY #782 32300 DYER ST UNION CITY 94587
MASONIC HOME PHARMACY 34400 MISSION BLVD UNION CITY 94587
MAXOR CORRECTIONAL PHARMACY
SERVICES
C/O SANTA RITA JAIL DUBLIN 94568
49
MAXOR CORRECTIONAL PHARMACY
SERVICES
C/O GLENN DYER DETENTION
FACILITY
OAKLAND 94607
MEDICAL ARTS PHARMACY 13847 E 14TH ST STE 103 SAN
LEANDRO
94578
MOWRY PLAZA PHARMACY 668 MOWRY AVE FREMONT 94536
MY LAN PHARMACY 401 EAST 18TH STREET - SUITE
B
OAKLAND 94606
NEW CHINA TOWN PHARMACY 719 EAST 12TH STREET OAKLAND 94606
NEW TIBURCIO VASQUEZ HEALTH CENTER
PHY
33255 9TH STREET UNION CITY 94587
NICHOLS HILL PRESCRIPTION PHARMACY 2844 SUMMIT STREET OAKLAND 94609
OAKLAND CLINIC PHARMACY 5220 CLAREMONT AVE OAKLAND 94618
OMNICARE OF HAYWARD 20967 CABOT BLVD HAYWARD 94545
PACIFIC PHARMACY 650 INTERNATIONAL BLVD OAKLAND 94606
PERALTA OUTPATIENT PHARMACY 3300 WEBSTER ST, GROUND
FL
OAKLAND 94609
PHARMACA INTEGRATIVE PHARMACY INC 5729 COLLEGE AVE OAKLAND 94618
PHARMACA INTEGRATIVE PHARMACY INC 1744 SOLANO AVE BERKELEY 94707
PHARMERICA 32980 ALVARADO NILES RD
STE 836
UNION CITY 94587
PLEASANT CARE PHARMACY 1652 B ST HAYWARD 94541
RALEYS PHARMACY #315 39200 PASEO PADRE
PARKWAY
FREMONT 94538
RALEYS PHARMACY #316 5420 SUNOL BLVD. PLEASANTON 94566
REDWOOD LTC PHARMACY 3160 CASTRO VALLEY BLVD
STE 101
CASTRO
VALLEY
94546
SAFEWAY PHARMACY #0676 1500 SOLANO AVE ALBANY 94706
SAFEWAY PHARMACY #0691 1444 SHATTUCK PLACE BERKELEY 94709
SAFEWAY PHARMACY #0768 20629 REDWOOD RD CASTRO
VALLEY
94546
50
SAFEWAY PHARMACY #0908 3550 FRUITVALE AVE OAKLAND 94602
SAFEWAY PHARMACY #0951 867 ISLAND DR ALAMEDA 94502
SAFEWAY PHARMACY #0971 22280 FOOTHILLS BLVD HAYWARD 94541
SAFEWAY PHARMACY #0993 3902 WASHINGTON BLVD FREMONT 94538
SAFEWAY PHARMACY #1197 1790 DECOTO RD UNION CITY 94587
SAFEWAY PHARMACY #1257 4495 FIRST ST LIVERMORE 94551
SAFEWAY PHARMACY #1931 46848 MISSION BLVD FREMONT 94539
SAFEWAY PHARMACY #1932 4440 TASSAJARA RD DUBLIN 94568
SAFEWAY PHARMACY #1953 7499 DUBLIN BLVD DUBLIN 94568
SAFEWAY PHARMACY #2708 2227 S SHORE CENTER ALAMEDA 94501
SAFEWAY PHARMACY #2856 6790 BERNAL AVE PLEASANTON 94566
SAFEWAY PHARMACY #2870 6310 COLLEGE AVE OAKLAND 94618
SAFEWAY PHARMACY #3125 3889 SAN PABLO AVE EMERYVILLE 94608
SAFEWAY PHARMACY #3132 5100 BROADWAY OAKLAND 94611
SAFEWAY PHARMACY #3281 2600 5TH ST ALAMEDA 94501
SKILLED NURSING PHARMACY 21150 CABOT BLVD HAYWARD 94545
SOLEO HEALTH INC 1324 W WINTON AVE HAYWARD 94545
STONERIDGE PROFESSIONAL PHARMACY 5720 STONERIDGE MALL RD
STE 150
PLEASANTON 94588
SUTTER INFUSION & PHARMACY SERVICES 1105 ATLANTIC AVE STE 102 ALAMEDA 94501
TIB PHARMACY LLC 5886 MOWRY SCHOOL RD NEWARK 94560
UNIVERSITY HEALTH SERVICE PHARMACY 2222 BANCROFT AVE RM 1115 BERKELEY 94702
VALLEY MEMORIAL HOSPITAL PHARMACY 1111 EAST STANLEY
BOULEVARD
LIVERMORE 94550
VALLEYCARE MEDICAL CENTER PHARMACY 5555 W LAS POSITAS BLVD
1ST FL
PLEASANTON 94588
51
VERSAILLES PHARMACY 2801 ENCINAL ALAMEDA 94501
VIBRANT CARE PHARMACY INC 7400 MACARTHUR BLVD STE
B
OAKLAND 94605
WAL MART PHARMACY 10 2031 30600 DYER STREET UNION CITY 94587
WAL-MART PHARMACY 10-1972 2700 LAS POSITAS RD LIVERMORE 94551
WAL-MART PHARMACY 10-5434 15555 HESPERIAN BLVD SAN
LEANDRO
94579
WAL-MART PHARMACY 10-5611 3112 SANTA RITA RD PLEASANTON 94566
WALGREEN CO D/B/A WALGREENS #15330 5809 FOOTHILL BLVD OAKLAND 94605
WALGREENS #00101 3382 CASTRO VALLEY BLVD CASTRO
VALLEY
94546
WALGREENS #01536 3434 HIGH STREET OAKLAND 94619
WALGREENS #01537 3232 FOOTHILL BLVD OAKLAND 94601
WALGREENS #01625 5055 TELEGRAPH AVE OAKLAND 94609
WALGREENS #02150 1763 SANTA RITA RD PLEASANTON 94566
WALGREENS #02306 1138 W TENNYSON_RD HAYWARD 94544
WALGREENS #02314 1050 GILMAN ST BERKELEY 94710
WALGREENS #02366 3860 DECOTO ROAD FREMONT 94555
WALGREENS #02401 21463 FOOTHILL BLVD HAYWARD 94541
WALGREENS #02426 15500 WASHINGTON AVE SAN
LEANDRO
94579
WALGREENS #02609 2995 SAN PABLO AVE BERKELEY 94702
WALGREENS #02660 41400 BLACOW RD FREMONT 94538
WALGREENS #03170 3400 TELEGRAPH AVE OAKLAND 94609
WALGREENS #03295 8102 INTERNATIONAL BLVD OAKLAND 94621
WALGREENS #04050 1916 WEBSTER ST ALAMEDA 94501
WALGREENS #04517 2600 MOWRY AVE FREMONT 94538
52
WALGREENS #04614 2801 ADELINE ST BERKELEY 94703
WALGREENS #04659 164 W JACKSON ST HAYWARD 94544
WALGREENS #06502 23958 HESPERIAN BLVD HAYWARD 94541
WALGREENS #07274 1456 136TH AVE SAN
LEANDRO
94578
WALGREENS #09248 2300 OTIS DRIVE ALAMEDA 94501
WALGREENS #10045 2310 TELEGRAPH AVE BERKELEY 94704
WALGREENS #10526 3250 LAKESHORE AVE SUITE
B
OAKLAND 94610
WALGREENS #11706 301 EAST 18TH STREET OAKLAND 94606
WALGREENS #13595 1333 BROADWAY OAKLAND 94612
WALGREENS #13858 1607 SHATTUCK AVE BERKELEY 94709
WALGREENS #15025 2190 SHATTUCK AVE BERKELEY 94704
WALGREENS #15163 1620 FIRST STREET LIVERMORE 94550
WALGREENS #15666 1600 PARK ST ALAMEDA 94501
WALMART PHARMACY #10-2989 44009 OSGOOD RD FREMONT 94539
WALMART PHARMACY #10-5426 40580 ALBRAE ST FREMONT 94538
WALMART PHARMACY 10 2161 4501 ROSEWOOD DRIVE PLEASANTON 94588
WALMART PHARMACY NO 10 2648 1919 DAVIS STREET SAN
LEANDRO
94577
WELLSPRING COMPOUNDING PHARMACY 2320 WOOLSEY ST. #105 BERKELEY 94705
WEST OAKLAND HEALTH CENTER PHARM 700 ADELINE ST OAKLAND 94607
53
Appendix E
Kiosk Mock-Up
54
Kiosk Signage1
Drop-Slot Panel Kiosk Art
1 Household Hazardous Waste facilities do not accept illicit drugs.
55
Kiosk Signage
Front Door Panel Kiosk Art
56
Kiosk Signage
Side Panel Kiosk Art
57
Appendix F
Media List
The following is a representative list of key media outlets to help educate Residents about proper disposal
of expired or Unwanted Medicine. The list includes local print, online, television, and radio outlets, as well
as outlets specifically targeting the diverse demographic communities within the County.
Print Outlets Coverage Area Website
Alameda Sun Alameda County http://alamedasun.com/
Berkeley Daily Planet Berkeley http://berkeleydailyplanet.com
Berkeley Voice Berkeley https://www.eastbaytimes.com/location/berkeley/
Berkeleyside Berkeley http://www.berkeleyside.com
California Magazine Berkeley https://alumni.berkeley.edu/california-magazine
Castro Valley Forum (Weekly
newspaper)
Alameda County http://castrovalleyforum.com/home.html
Castro Valley News Alameda County https://castrovalleynewsgroup.com/category/castro-
valley/
Castro Valley Times Castro Valley https://www.eastbaytimes.com/location/castro-valley/
Center for Investigative
Reporting
Berkeley
Contra Costa Times Alameda County http://www.eastbaytimes.com/
Dublin Tri Valley Herald Dublin https://www.eastbaytimes.com/location/tri-valley/
E'ville Eye Community News Alameda County http://www.evilleeye.com/
Nichi Bei Times
(Japanese/English)
Alameda County http://www.EastBayExpress.com/
East Bay Express Oakland https://www.eastbayexpress.com
East Bay Times Alameda County https://www.eastbaytimes.com
East Bay Express Alameda County https://www.eastbayexpress.com
Fremont Bulletin Alameda County http://www.mercurynews.com/fremont
58
Print Outlets Coverage Area Website
Fremont Tribune Alameda County http://www.fremonttribune.com/
Hayward Daily Review (SEE
Oakland Tribune)
Alameda County http://haywardnews.ca/
The Independent Dublin, Livermore,
Pleasanton
http://www.independentnews.com
Inter-City Express Oakland www.intercityexpress.news
La Opinion (Spanish) Alameda County http://www.laopinion.com/
Oakland Local Oakland http://oaklandlocal.com/
Oakland Post Alameda County http://www.oaklandpost.org
Oakland Tribune Alameda County https://www.eastbaytimes.com
Pleasanton Weekly Alameda County https://www.pleasantonweekly.com
San Francisco Chronicle Alameda County https://www.sfchronicle.com
San Leandro Times Alameda County http://sanleandrotimes.com/home.html
The Alamedan Alameda County http://thealamedan.org
The Argus Alameda County https://www.eastbaytimes.com/location/fremont/
The Daily Californian (UC
Berkeley)
Alameda County http://www.dailycal.org
The Montclarion Oakland http://themontclarion.org
The Piedmont Post Piedmont http://www.piedmontportal.org/the-piedmont-post/
Tri-Valley Times Pleasanton https://www.eastbaytimes.com/location/tri-valley/
Tri-City Voice Alameda County http://www.tricityvoice.com/
Vision Hispana Oakland,
Hayward
http://www.visionhispanausa.com
Your Town Monthly Alameda County http://yourtownmonthly.com
59
Television Outlets Network
BAVC Public Access
KDTV Univision
KEMO Azteca America
KGO ABC
KNTV NBC
KPIX CBS
KQED PBS
KRON Media General
KSTS Telemundo
KTVU FOX
60
Radio Outlets City/County/Coverage Area
KALW FM 91.7 San Francisco
KCBS AM 740 San Francisco
KCSF (College app radio) San Francisco
KGO AM 810 San Francisco
KQED FM 88.5 San Francisco
KSFO AM 560 San Francisco
KUSF (College online radio) San Francisco
KPFB FM 89.3 Berkeley
KALX FM 90.7 Berkeley
KNGY FM 92.7 Alameda
KPFA FM 94.1 Berkeley
KKIQ FM 101.7 Livermore
KBLX FM 102.9 Berkeley
KNEW AM 910 Oakland
KKGN AM 960 Oakland
KMKY AM 1310 Oakland
KVTO AM 1400 Berkeley
KPIG AM 1510 Piedmont
KACR FM 96.1 Alameda
KCRH FM 89.9 Hayward
KPOO 89.5 San Francisco
KSMC 89.5 Moraga
KCSM 91.1 San Mateo
61
Radio Outlets City/County/Coverage Area
KKDV 92.1 Walnut Creek
KRZZ 93.3 San Francisco
KYLD 94.9 San Francisco
KBWF 95.7 San Francisco
KOIT 96.5 San Francisco
KLLC 97.3 San Francisco
KISQ 98.1 San Francisco
KSOL 98.9 San Francisco
KMVQ 99.7 San Francisco
KBRG 100.3 San Jose
KVVZ 100.7 San Rafael
KIOI 101.3 San Francisco
KDFC 102.1 San Francisco
KKSF 103.7 San Francisco
KFOG 104.5 San Francisco
KITS 105.3 San Francisco
KVVF 105.7 Santa Clara
KMEL 106.1 San Francisco
KFRC 106.9 San Francisco
KSTN 107.3 Stockton
KSAN 107.7 San Mateo
KSFO 560 AM San Francisco
KEAR 610 AM San Francisco
62
Radio Outlets City/County/Coverage Area
KSTE 650 AM Rancho Cordova
KNBR 680 AM San Francisco
KFIA 710 AM Carmichael
KCBC 770 AM Riverbank
KTRB 860 AM San Francisco
KATD 990 AM Pittsburg
KIQI 1010 AM San Francisco
KTCT 1050 AM San Mateo
KFAX 1100 AM San Francisco
KHTK 1140 AM Sacramento
KLOK 1170 AM San Jose
KDYA 1190 AM Vallejo
KNTS 1220 AM Palo Alto
KSRO 1350 AM Santa Rosa
KZSF 1370 AM San Jose
KEST 1450 AM San Francisco
KTOB 1490 AM Petaluma
KFBK 1530 AM Sacramento
KYCY 1550 AM San Francisco
KLIV 1590 AM San Jose
KDIA 1640 AM Vallejo
KEBR 88.1 Sacramento
KECG 88.1 El Cerrito
63
Radio Outlets City/County/Coverage Area
KXPR 88.9 Sacramento
KOHL 89.3 Fremont
KREV 92.7 Alameda
KSFN 1510 AM Piedmont
64
Appendix G
MED-Project Request for Approval of Disposal Process for Host-Assisted Collection Kiosk
Drop-Off Sites
MED-PROJECT REQUEST FOR APPROVAL OF DISPOSAL PROCESS FOR HOST-ASSISTED
COLLECTION KIOSK DROP-OFF SITES
February 15, 2019
65
MED-PROJECT REQUEST FOR APPROVAL OF DISPOSAL PROCESS FOR HOST-ASSISTED
COLLECTION KIOSK DROP-OFF SITES
Pursuant to Alameda County Safe Drug Disposal Ordinance (“Ordinance”) § 6.53.060(A) and Alameda County Safe
Drug Disposal Regulations (“Regulations”) § 17, MED-Project LLC (“MED-Project”) requests the Alameda County
Department of Environmental Health’s (the “Department’s”) approval to use a municipal waste combustor for the
disposal of materials collected at Host-Assisted Collection Kiosk Drop-Off Sites (as defined in the MED-Project
Product Stewardship Plan (“Plan”) § III). As described below, exercising discretion to allow for the disposal of
materials collected at Host-Assisted Collection Kiosk Drop-Off Sites would achieve the objectives of the Ordinance
and Regulations and should be approved under Ordinance § 6.53.060(A) and Regulations § 17.
I. THE PROCESS FOR THE DISPOSAL OF MATERIALS FROM HOST-ASSISTED
COLLECTION KIOSK DROP-OFF SITES AT COVANTA LONG BEACH
To provide effective and uninterrupted collection from Host-Assisted Collection Kiosk Drop-Off Sites, MED-
Project has identified two vendors that it may use to provide and dispose of unwanted medicine. This request for
approval concerns Covanta Environmental Solutions, LLC (“Covanta”).
MED-Project is proposing that materials collected at Host-Assisted Collection Kiosk Drop-Off Sites be delivered by
United Parcel Service, Inc. to the Covanta Environmental Solutions, LLC facility in Scottsdale, Arizona. See Plan §
X. From there, the materials will be transported by Transchem Environmental, LLC to the Covanta Long Beach
Renewable Energy1 facility in Long Beach, California (“Covanta Long Beach”)2 for destruction via incineration. Id.
Two DEA witnesses from Covanta will monitor delivery from the reverse distribution vault to Covanta Long Beach.
A DEA witness will then confirm the destruction of the collected materials in the tracking system and upload the
DEA certificate of destruction.
Covanta Long Beach is a municipal waste combustor. Covanta Long Beach is a waste-to-energy facility that
processes up to 1,380 tons of municipal solid waste per day, generating up to 36 megawatts of electricity. Covanta
Long Beach also has a Clean Air Act Title V permit, which establishes air emissions limits for particulate matter,
carbon monoxide, sulfur dioxide, nitrogen oxides, lead, mercury, and fluorides, among other chemicals. To control
air pollution, Covanta Long Beach employs semi-dry flue gas scrubbers injecting lime, fabric filter baghouses, a
nitrogen oxide control system, a mercury control system, activated carbon filter units, and a continuous emissions
monitoring system.
II. STANDARD FOR DEPARTMENT TO APPROVE THE USE OF COVANTA LONG BEACH
FOR THE DISPOSAL OF MATERIALS FROM HOST-ASSISTED COLLECTION KIOSK
DROP-OFF SITES
The Regulations allow the “Plan Liaison” (as defined in Regulations § 2) to request an “exception, exemption, or
allowance from any requirement of the Ordinance or Regulations,” which the “Department shall have the discretion
to grant or deny . . ..” Regulations § 17. Any disposal of unwanted medicine must comply with the overarching
Ordinance disposal requirement that “[e]ach Product Stewardship Program must comply with all local, state, and
federal laws and regulations applicable to its operations, including laws and regulations governing the disposal of
medical waste and Controlled Substances.” Ordinance § 6.53.060(A); cf. Ordinance § 6.53.120(B) (“This Chapter
shall be construed so as not to conflict with applicable federal or state laws, rules or regulations.”).
1 The Southeast Resource Recovery Facility is operating as Covanta Long Beach Renewable Energy. See Covanta, Covanta Long Beach,
https://www.covanta.com/Our-Facilities/Covanta-Long-Beach (last visited Aug. 19, 2018). 2 Covanta Long Beach’s mailing address is 118 pier S Avenue, Long Beach, CA 90802.
66
III. THE USE OF COVANTA LONG BEACH TO DISPOSE OF MATERIALS FROM HOST-
ASSISTED COLLECTION KIOSK DROP-OFF SITES SHOULD BE APPROVED
The Department should approve the use of Covanta Long Beach for disposal of materials from Host-Assisted
Collection Kiosk Drop-Off Sites under Ordinance § 6.53.060(A) and Regulations § 17 because disposal at Covanta
Long Beach would comply with federal and state law, improve MED-Project unwanted medicine collection services
for residents, and protect and preserve the environment and the public health, safety, and welfare of Alameda
County residents.
A. Disposal at Covanta Long Beach Complies with Federal and State Law.
There are no other laws or requirements, outside of the Ordinance, that would require MED-Project to dispose of
unwanted medicine collected from Host-Assisted Collection Kiosk Drop-Off Sites at a hazardous waste incinerator
or medical waste incinerator or preclude MED-Project from disposing of these materials at a municipal waste
combustor like Covanta Long Beach. Any unwanted medicine collected at Host-Assisted Collection Kiosk Drop-
Off Sites under this Plan is considered “household waste” excluded from regulation as hazardous or medical waste.
Therefore, disposal of unwanted medicine at Covanta Long Beach in accordance with DEA requirements complies
with all applicable federal and state laws, regulations, and other legal requirements. In fact, municipal waste
combustors like Covanta Long Beach are one of the disposal methods the United States Environmental Protection
Agency directs law enforcement agencies to use for the destruction of collected pharmaceutical products. See
United States Environmental Protection Agency, Management of Household Pharmaceuticals Collected by Law
Enforcement During Take-Back Events and Programs at 2, 4 (Sept. 11, 2018).
B. Disposal of Unwanted Medicine at Covanta Long Beach Improves MED-Project Services for Residents.
MED-Project requests approval to use Covanta Long Beach to create redundancy in its unwanted medicine
collection and disposal services. By adding Covanta as a Host-Assisted Collection Kiosk Drop-Off Site vendor and
Covanta Long Beach as a disposal facility, MED-Project can protect against service interruptions. Should Covanta
or MED-Project’s other vendor servicing Host-Assisted Collection Kiosk Drop-Off Sites, Stericycle Specialty Waste
Solutions, Inc., experience an incident requiring it to temporarily suspend services, MED-Project can continue to
rely on the other vendor to provide service for Alameda County residents.
C. Disposal at Covanta Long Beach Would Protect and Preserve the Environment and the Public Health,
Safety, and Welfare of Alameda County Residents.
The Department should exercise its authority to approve the use of Covanta Long Beach for disposal of unwanted
medicine from Host-Assisted Collection Kiosk Drop-Off Sites under Ordinance § 6.53.060(A) and Regulations § 17
because disposal at Covanta Long Beach would protect and preserve the environment and the public health, safety,
and welfare of Alameda County residents in furtherance of the objectives of the Ordinance. Municipal waste
combustors like Covanta Long Beach are subject to stringent environmental requirements, as well as worker health
and safety standards like other incinerators. Covanta Long Beach is subject to a Clean Air Act Title V permit for air
emissions, and the facility has extensive air pollution controls in place, including semi-dry flue gas scrubbers
injecting lime, fabric filter baghouses, a nitrogen oxide control system, a mercury control system, activated carbon
filter units, and a continuous emissions monitoring system.
The permits and other requirements that apply to Covanta Long Beach provide for and promote the health, safety,
and welfare of the general public. Accordingly, the Department should exercise its discretion under Regulations §
17 to approve Covanta Long Beach as a disposal site for materials collected at Host-Assisted Collection Kiosk
Drop-Off Sites.
67
IV. CONCLUSION
For the reasons described above, the Department should approve the disposal of unwanted medicine from Host-
Assisted Collection Kiosk Drop-Off Sites as proposed by MED-Project under Ordinance § 6.53.060(A) and
Regulations § 17. Please contact the Plan Liaison, identified below, with any questions about this request.
Dr. Victoria Travis, PharmD, MS, MBA
National Program Director
MED-Project LLC
1800 M Street NW, Suite 400 S
Washington, DC 20036
Phone: 1 (844) 677-6532
Fax: 1 (510) 686-8837
alamedacounty@med-project.org
68
Appendix H
A. Stericycle Standard Mail-Back Package
Description:
Plastic envelope with return label and instructional flyer
Package Size:
Outer dimensions: 8.25” x 12”
Inner dimensions: 7.375” x 10.375”
MED-Project may choose to change its Vendor for Mail-Back Services at any time. Any proposed changes
to Vendor will be submitted in writing to the Department and approved by the Department in writing prior
to implementation of any change.
69
B. Covanta Standard Mail-Back Package
MED-Project may choose to change its Vendor for Mail-Back Services at any time. Any proposed changes
to Vendor will be submitted in writing to the Department and approved by the Department in writing prior
to implementation of any change.
70
C. PureWay Inhaler Mail-Back Package Specifications
Description:
Inhaler Mail-Back Package including container with mail-back packaging, return label, and instructional
flyer.
Package Sizes:
2.5-gallon mail-back system
Mail-back solutions are an example of complete, turnkey systems to provide for the safe return of inhaler
waste through Carrier.
MED-Project may choose to change its Vendor for Mail-Back Services at any time. Any proposed changes
to Vendor will be submitted in writing to the Department and approved by the Department in writing prior
to implementation of any change.
71
D. Stericycle Inhaler Mail-Back Package
Description:
Inhaler Mail-Back Package including container with mail-back packaging, return label, and instructional
flyer.
Package Sizes:
Outer dimensions: 8.75”x 11.25”x 3”
Mail-back solutions are an example of complete, turnkey systems to provide for the safe return of inhaler
waste through Carrier.
MED-Project may choose to change its Vendor for Mail-Back Services at any time. Any proposed changes
to Vendor will be submitted in writing to the Department and approved by the Department in writing prior
to implementation of any change.
72
Appendix I
MED-Project Request for Approval of Standard Mail-Back Package Disposal Process
MED-PROJECT REQUEST FOR APPROVAL OF STANDARD MAIL-BACK PACKAGE DISPOSAL
PROCESS
February 15, 2019
73
MED-PROJECT REQUEST FOR APPROVAL OF STANDARD MAIL-BACK PACKAGE DISPOSAL
PROCESS
Pursuant to Alameda County Safe Drug Disposal Ordinance (“Ordinance”) § 6.53.060(A) and Alameda County Safe
Drug Disposal Regulations (“Regulations”) § 17, MED-Project LLC (“MED-Project”) requests the Alameda County
Department of Environmental Health’s (the “Department’s”) approval to use permitted municipal waste combustors
for the disposal of “Standard Mail-Back Packages” for unwanted medicine (as defined in the MED-Project Product
Stewardship Plan (“Plan”) § III). As described below, exercising discretion to allow for the disposal of Standard
Mail-Back Packages at municipal waste combustors would achieve the objectives of the Ordinance and Regulations
and should be approved under Ordinance § 6.53.060(A) and Regulations § 17.
I. THE PROCESS FOR THE DISPOSAL OF STANDARD MAIL-BACK PACKAGES
To provide effective and uninterrupted “Standard Mail-Back Services” (as defined in Plan § III), MED-Project has
identified two vendors that it may use to provide and dispose of Standard Mail-Back Packages. This request for
approval concerns Covanta Environmental Solutions, LLC (“Covanta”).
A. The Covanta Process
Standard Mail-Back Packages provided by Covanta would be pre-addressed and pre-paid for delivery to the Covanta
Manheim, Pennsylvania United States Drug Enforcement Agency (“DEA”) registered collector and reverse
distributor facility (“Manheim Facility”). From the Manheim Facility, the mail-back packages are transported by
Doncin Transport, Inc. to one of two Covanta facilities—the Covanta York Renewable Energy, LLC facility in
York, Pennsylvania (“Covanta York”)1 and the Covanta Lancaster, Inc. facility in Lancaster, Pennsylvania
(“Covanta Lancaster”)2 (together, the “Covanta Facilities”)—for destruction via incineration. See Plan § X. The
Covanta Facilities will scan the unique identifier on each Standard Mail-Back Package to record receipt of the
package before incinerating it and will confirm the materials have been properly incinerated.
a. Covanta York
Covanta York is a permitted large municipal waste combustor. As an “energy-from-waste” facility, Covanta York
uses solid waste, like Standard Mail-Back Packages, to generate electricity.3 The facility processes over 1,300 tons
of solid waste per day, generating up to 40 megawatts of electricity, enough to power over 20,000 homes, according
to its website. To control air pollution, Covanta York employs a niro spray drying atomizer, a Western Pacific filter
baghouse, and Norit Americas carbon injection. Covanta York also operates under a Title V Clean Air Act permit4
and a solid waste permit.5 Additionally, Covanta York has been designated as a Voluntary Protection Program
(“VPP”) Star facility by the U.S. Occupational Safety and Health Administration (“OSHA”), recognizing the
facility’s employer’s and employees’ exemplary achievement in the prevention and control of occupational safety
and health hazards. Covanta York has also been awarded ISO-140001 certification for the facility’s environmental
management system.
1 Covanta York’s mailing address is 2651 Blackbridge Road, York, PA 17406.
2 Covanta Lancaster’s mailing address is 1911 River Road, Bainbridge, PA 17502.
3 See Covanta, Covanta York, https://www.covanta.com/Our-Facilities/Covanta-York.
4 See Title V Operating Permit # 67-05006, http://files.dep.state.pa.us/Air/AirQuality/AQPortalFiles/Permits/PermitDocuments/1141655[67-
05006]_Issued_v1.pdf. 5 See Solid Waste Permit # 400561 PaDEP, https://www.ahs.dep.pa.gov/eFACTSWeb/searchResults_singleFacility.aspx?FacilityID=471124.
74
b. Covanta Lancaster
Covanta Lancaster is also a permitted large municipal waste combustor. Covanta Lancaster is an “energy-from-
waste” facility that incinerates waste and generates 35.7 megawatts per day from a condensing steam turbine that
provides energy to GPU Energy.6 Covanta Lancaster employs semi-dry flue gas scrubbers injecting lime, fabric
filter baghouses, a furnace dry-lime injection system, a nitrogen oxide control system, a mercury control system, and
a continuous emissions monitoring system. Covanta Lancaster also operates under a Title V Clean Air Act permit7
and a solid waste permit.8 Covanta Lancaster is a “zero discharge” facility, meaning that the wastewater generated
on-site is treated and reused in the waste management process, according to the facility’s website. Covanta
Lancaster has also been designated as a VPP Star facility by OSHA.
II. STANDARD FOR DEPARTMENT TO APPROVE THE USE OF THE PROPOSED
INCINERATORS FOR THE DISPOSAL OF STANDARD MAIL-BACK PACKAGES
The Regulations allow the “Plan Liaison” (as defined in Regulations § 2) to request an “exception, exemption, or
allowance from any requirement of the Ordinance or Regulations,” which the “Department shall have the discretion
to grant or deny . . ..” Regulations § 17. Any disposal of Standard Mail-Back Packages must comply with the
overarching Ordinance disposal requirement that “[e]ach Product Stewardship Program must comply with all local,
state, and federal laws and regulations applicable to its operations, including laws and regulations governing the
disposal of medical waste and Controlled Substances.” Ordinance § 6.53.060(A); cf. Ordinance § 6.53.120(B)
(“This Chapter shall be construed so as not to conflict with applicable federal or state laws, rules or regulations.”).
III. THE USE OF THE PROPOSED INCINERATORS TO DISPOSE OF STANDARD MAIL-
BACK PACKAGES SHOULD BE APPROVED
The Department should approve the use of the proposed incinerators for disposal of Standard Mail-Back Packages
under Ordinance § 6.53.060(A) and Regulations § 17 because disposal at the proposed incinerators would comply
with federal and state law, improve MED-Project unwanted medicine collection services for residents, and protect
and preserve the environment and the public health, safety, and welfare of Alameda County residents.
A. Disposal at the Covanta Facilities Complies with Federal and State Law
There are no other laws or requirements, outside of the Ordinance, that would require MED-Project to dispose of
Standard Mail-Back Packages at a hazardous waste incinerator or medical waste incinerator or preclude MED-
Project from disposing of these materials at a municipal waste combustor like the Covanta Facilities. Any unwanted
medicines collected via Standard Mail-Back Packages under this Plan are considered “household waste” excluded
from regulation as hazardous or medical waste. Therefore, disposal of Standard Mail-Back Packages at the Covanta
Facilities in accordance with DEA requirements complies with all applicable federal and state laws, regulations, and
other legal requirements. In fact, municipal waste combustors like the Covanta Facilities are one of the disposal
methods the United States Environmental Protection Agency directs law enforcement agencies to use for the
destruction of collected pharmaceutical products. See United States Environmental Protection Agency,
Management of Household Pharmaceuticals Collected by Law Enforcement During Take-Back Events and
Programs at 2, 4 (Sept. 11, 2018).
6 See Covanta, Covanta Lancaster, https://www.covanta.com/Our-Facilities/Covanta-Lancaster.
7 See Title V Operating Permit # 36-05013, http://files.dep.state.pa.us/Air/AirQuality/AQPortalFiles/Permits/PermitDocuments/1130890[36-
05013]_Issued_v1.pdf. 8 See Solid Waste Permit # 400592 PaDEP, https://www.ahs.dep.pa.gov/eFACTSWeb/searchResults_singleFacility.aspx?FacilityID=255039.
75
B. Disposal of Standard Mail-Back Packages at the Covanta Facilities Improves MED-Project Services for
Residents
MED-Project requests approval to use the proposed incinerators to create redundancy in its Standard Mail-Back
Services. By adding Covanta as a Standard Mail-Back Services vendor, MED-Project can protect against Standard
Mail-Back Service interruptions. Should Covanta or MED-Project’s other vendor for Standard Mail-Back Services,
Stericycle Specialty Waste Solutions, Inc., experience an incident requiring it to temporarily suspend Standard Mail-
Back Services for any reason, MED-Project can continue to rely on the other vendor to provide service for Alameda
County residents.
C. Disposal at the Proposed Facilities would Protect and Preserve the Environment and the Public Health,
Safety, and Welfare of Alameda County Residents.
The Department should exercise its authority to approve the use of the proposed incinerators for disposal of
Standard Mail-Back Packages under Ordinance § 6.53.060(A) and Regulations § 17 because disposal at the
proposed incinerators would protect and preserve the environment and the public health, safety, and welfare of
Alameda County residents in furtherance of the objectives of the Ordinance.
Covanta York has extensive pollution control technologies in place, including its use of a niro spray drying
atomizer, a Western Pacific filter baghouse, and Norit Americas carbon injection. It has also been recognized for its
workplace safety achievements, as evidenced by its status as a VPP Star facility. Covanta Lancaster has extensive
pollution control technologies in place, including semi-dry flue gas scrubbers injecting lime, fabric filter baghouses,
a nitrogen oxide control system, a mercury control system, and a continuous emissions monitoring system. It has
also been recognized for its workplace safety achievements, as evidenced by its status as a VPP Star facility. The
use of Covanta York and Covanta Lancaster would protect and preserve the environment and the public health,
safety, and welfare of Alameda County residents in furtherance of the objectives of the Ordinance.
IV. CONCLUSION
Accordingly, the Department should approve the disposal of Standard Mail-Back Packages via incineration at
Covanta York and Covanta Lancaster as proposed by MED-Project under Ordinance § 6.53.060(A) and Regulations
§ 17. Please contact the Plan Liaison, identified below, with any questions about this request.
Dr. Victoria Travis, PharmD, MS, MBA
National Program Director
MED-Project LLC
1800 M Street NW, Suite 400 S
Washington, DC 20036
Phone: 1 (844) 677-6532
Fax: 1 (510) 686-8837
alamedacounty@med-project.org
76
Appendix J
MED-Project Request for Approval of Inhaler Mail-Back Package Disposal Process
MED-PROJECT REQUEST FOR APPROVAL OF INHALER MAIL-BACK PACKAGE DISPOSAL
PROCESS
February 15, 2019
77
MED-PROJECT REQUEST FOR APPROVAL OF INHALER MAIL-BACK PACKAGE DISPOSAL
PROCESS
Pursuant to Alameda County Safe Drug Disposal Ordinance (“Ordinance”) § 6.53.060(A) and Alameda County Safe
Drug Disposal Regulations (“Regulations”) § 17, MED-Project LLC (“MED-Project”) requests the Alameda County
Department of Environmental Health’s (the “Department’s”) approval to use permitted municipal waste combustors
for the disposal of “Inhaler Mail-Back Packages” (as defined in the MED-Project Product Stewardship Plan (“Plan”)
§ III). As described below, exercising discretion to allow for the disposal of Inhaler Mail-Back Packages at a
permitted municipal waste combustor would achieve the objectives of the Ordinance and Regulations and should be
approved under Ordinance § 6.53.060(A) and Regulations § 17.
I. THE PROCESS FOR THE DISPOSAL OF INHALER MAIL-BACK PACKAGES
To provide effective and uninterrupted “Inhaler Mail-Back Services” (as defined in Plan § III), MED-Project has
identified two vendors that it may use to provide and dispose of Inhaler Mail-Back Packages. This request concerns
PureWay Compliance, Inc. (“PureWay”).
The Inhaler Mail-Back Packages provided by PureWay will be pre-addressed and pre-paid for delivery to the
Daniels Sharpsmart, Inc. facility in Fresno, California (the “Daniels Facility”) for transport to one of two
incinerators for disposal: the Covanta Huntsville, Inc. facility (the “Covanta Huntsville Facility”)1 or the Covanta
Marion, Inc. facility (the “Covanta Marion Facility”).2 See Plan § X. The Daniels Facility will scan the unique
identifier on each Inhaler Mail-Back Package to record receipt of the package before sending it for incineration to
one of these two facilities. These facilities will receive and dispose of the Inhaler Mail-Back Packages and provide
confirmation that the materials have been properly incinerated and disposed of.
A. Covanta Huntsville Facility
The Covanta Huntsville Facility is a permitted large municipal waste combustor. The furnaces at the Covanta
Huntsville Facility are operated at temperatures exceeding 1800 degrees Fahrenheit.3 As a “waste-to-energy”
facility, the Covanta Huntsville Facility uses municipal solid waste, like Inhaler Mail-Back Packages, to generate
steam used for the U.S. Army’s nearby Redstone Arsenal’s heating and air conditioning needs.4 To control air
pollution, the Covanta Huntsville Facility employs semi-dry flue gas scrubbers injecting lime, fabric filter
baghouses, a nitrogen oxide control system, a mercury control system, and a continuous emissions monitoring
system. Additionally, the Covanta Huntsville Facility has been designated as a Voluntary Protection Program
(“VPP”) Star facility by the U.S. Occupational Safety and Health Administration (“OSHA”), recognizing the
facility’s employer’s and employees’ exemplary achievement in the prevention and control of occupational safety
and health hazards.5
1 Covanta Huntsville’s mailing address is 5251 Triana Blvd SW, Huntsville, AL 35805.
2 Covanta Marion’s mailing address is 4850 Brooklake Road, NE, Brooks, OR 97305.
3 See Solid Waste Disposal Authority of the City of Huntsville, Waste to Energy, http://swdahsv.org/waste-to-energy/.
4 See Covanta, Covanta Huntsville, https://www.covanta.com/Our-Facilities/Covanta-Huntsville.
5 Id.; U.S. Occupational Health and Safety Administration, All About VPP, https://www.osha.gov/dcsp/vpp/all_about_vpp.html.
78
B. Covanta Marion Facility
The Covanta Marion Facility is also a permitted large municipal waste combustor. The Covanta Marion Facility is a
“waste-to-energy” facility that incinerates waste and generates 13.1 megawatts per day from a condensing steam
turbine generator.6 Like the Covanta Huntsville Facility, the Covanta Marion Facility employs semi-dry flue gas
scrubbers injecting lime, fabric filter baghouses, a nitrogen oxide control system, a mercury control system, and a
continuous emissions monitoring system.7 The Covanta Marion Facility is a member of the Safety and Health
Achievement Recognition Program (“SHARP”), Oregon’s safety and health recognition program.8 The Covanta
Marion Facility has also been designated as a VPP Star facility by OSHA.9
II. STANDARDS FOR THE DEPARTMENT TO APPROVE THE USE OF THE PROPOSED
INCINERATORS FOR THE DISPOSAL OF INHALER MAIL-BACK PACKAGES
The Regulations allow the “Plan Liaison” (as defined in Regulations § 2) to request an “exception, exemption, or
allowance from any requirement of the Ordinance or Regulations,” which the “Department shall have the discretion
to grant or deny . . ..” Regulations § 17. Any disposal of Mail-Back Packages must comply with the overarching
Ordinance disposal requirement that “[e]ach Product Stewardship Program must comply with all local, state, and
federal laws and regulations applicable to its operations, including laws and regulations governing the disposal of
medical waste and Controlled Substances.” Ordinance § 6.53.060(A); cf. Ordinance § 6.53.120(B) (“This Chapter
shall be construed so as not to conflict with applicable federal or state laws, rules or regulations.”).
III. THE USE OF THE PROPOSED INCINERATORS TO DISPOSE OF INHALER MAIL-BACK
PACKAGES SHOULD BE APPROVED
The Department should approve the use of the Covanta Huntsville Facility and Covanta Marion Facility for disposal
of Inhaler Mail-Back Packages under Ordinance § 6.53.060(A) and Regulations § 17 because disposal at these
facilities would comply with federal and state law, improve MED-Project Inhaler Mail-Back Services for residents,
and protect and preserve the environment and the public health, safety, and welfare of Alameda County residents.
A. Disposal at the Covanta Huntsville Facility and Covanta Marion Facility Complies with Federal and State
Law.
There are no other laws or requirements, outside of these Regulations, that would require MED-Project to dispose of
Inhaler Mail-Back Packages at a hazardous waste incinerator or medical waste incinerator or preclude MED-Project
from disposing of these materials at a municipal waste combustor like the Covanta Huntsville Facility or Covanta
Marion Facility. Any Inhaler Mail-Back Packages collected under this Plan are considered “household waste”
excluded from regulation as medical or hazardous waste. Therefore, disposal of unwanted medicines at these
facilities complies with all applicable federal and state laws, regulations, and other legal requirements. In fact,
municipal waste combustors like the Covanta Huntsville Facility and Covanta Marion Facility are one of the
disposal methods the United States Environmental Protection Agency directs law enforcement agencies to use for
the destruction of collected pharmaceutical products. See United States Environmental Protection Agency,
Management of Household Pharmaceuticals Collected by Law Enforcement During Take-Back Events and
Programs at 2, 4 (Sept. 11, 2018).
6 See Covanta, Covanta Marion, https://www.covanta.com/Our-Facilities/Covanta-Marion.
7 Id.
8 Id. 9 Id.; U.S. Occupational Health and Safety Administration, All About VPP, https://www.osha.gov/dcsp/vpp/all_about_vpp.html.
79
B. Disposal of Inhaler Mail-Back Packages at the Covanta Huntsville Facility and Covanta Marion Facility
Improves MED-Project Inhaler Mail-Back Services for Residents.
MED-Project requests approval to use the Covanta Huntsville Facility and Covanta Marion Facility to create
redundancy in its Inhaler Mail-Back Services. By adding PureWay as an Inhaler Mail-Back Services vendor and the
Covanta Huntsville Facility and Covanta Marion Facility as disposal facilities, MED-Project can protect against
service interruptions. Should PureWay or MED-Project’s other Inhaler Mail-Back Services vendor, Stericycle
Specialty Waste Solutions, Inc., experience an incident requiring it to temporarily suspend services for any reason,
MED-Project can continue to rely on the other vendor to provide Inhaler Mail-Back Services for Alameda County
residents.
C. Disposal at the Proposed Facilities Would Protect and Preserve the Environment and the Public Health,
Safety, and Welfare of Alameda County Residents.
The Covanta Huntsville Facility and the Covanta Marion Facility have extensive pollution control technologies in
place, including semi-dry flue gas scrubbers injecting lime, fabric filter baghouses, a nitrogen oxide control system,
a mercury control system, and a continuous emissions monitoring system. They have also been recognized for their
workplace safety achievements, as evidenced by their status as VPP Star facilities. The use of these facilities would
protect public health and prevent unwanted medicine from being disposed of in a manner that can adversely affect
the environment in furtherance of the objectives of the Ordinance.
IV. CONCLUSION
Accordingly, the Department should approve the disposal of Inhaler Mail-Back Packages via incineration at the
Covanta Huntsville Facility and the Covanta Marion Facility as proposed by MED-Project under Ordinance §
6.53.060(A) and Regulations § 17. Please contact the Plan Liaison, identified below, with any questions about this
request.
Dr. Victoria Travis, PharmD, MS, MBA
National Program Director
MED-Project LLC
1800 M Street NW, Suite 400 S
Washington, DC 20036
Phone: 1 (844) 677-6532
Fax: 1 (510) 686-8837
alamedacounty@med-project.org
80
Appendix K
Stericycle, Inc., Indianapolis Facility Penalty Record
Date Type Summary Violation Detail Return to
Compliance
Corrective Action
6/15/2017 RCRA Inventory weight
discrepancy
Discrepancy on
the hazardous
waste inventory
log
6/15/2017 Violation corrected during
audit, no further action
required
3/29/2017 RCRA Inventory weight
discrepancy
Discrepancy on
the hazardous
waste inventory
log
3/29/2017 Violation corrected during
audit, no further action
required
3/29/2017 RCRA Hazardous
waste labeling
Containers
missing date
3/29/2017 Violation corrected during
audit, no further action
required
7/25/2016 RCRA Inventory dates Inventory dates
and physical
dates on
containers did
not match
10/25/2016 Responded to Indiana
Department of Environmental
Management (“IDEM”) with
corrective action plan; issue
closed with Return to
Compliance Letter
7/17/2015 RCRA Hazardous
waste labeling
Unlabeled
universal waste
pallets
11/17/2015 Responded to IDEM with
corrective action plan; issue
closed with Return to
Compliance Letter
7/17/2015 RCRA Contingency
Plan
Contingency Plan
list of emergency
coordinators not
updated with
current contact
information
11/17/2015 Responded to IDEM with
corrective action plan; issue
closed with Return to
Compliance Letter
81
Date Type Summary Violation Detail Return to
Compliance
Corrective Action
7/31/2014 RCRA Inventory weight
discrepancy
Discrepancies
regarding the
quantity (weight)
of waste stored in
permitted areas
compared to the
weights listed on
the physical
containers
9/8/2014 Responded to IDEM with
corrective action plan; issue
closed with Return to
Compliance Letter
6/5/2014 Air Annual report
not submitted
Did not submit
Annual
Compliance
Certification for
period covering
1/1/13 to 12/31/13
6/9/2014 Report submitted to IDEM;
issue closed with Return to
Compliance Letter
3/26/2014 RCRA Satellite
Accumulation
violation
Two containers
exceeded the 3-
day limit for
moving satellite
accumulation
area to the
container storage
area
6/17/2014 Responded to IDEM with
corrective action plan; issue
closed with Return to
Compliance Letter
3/26/2014 RCRA Inventory weight
discrepancy
Discrepancies
regarding the
quantity (weight)
of waste stored in
permitted areas
compared to the
weights listed on
the physical
containers
6/17/2014 Responded to IDEM with
corrective action plan; issue
closed with Return to
Compliance Letter
3/26/2014 RCRA Container
storage
One container of
hazardous waste
located outside
of the permitted
area
6/17/2014 Responded to IDEM with
corrective action plan; issue
closed with Return to
Compliance Letter
82
Date Type Summary Violation Detail Return to
Compliance
Corrective Action
6/28/2013 RCRA Satellite
Accumulation/W
aste
Accumulation
Labeling;
Inventory Log
discrepancy
Missing satellite
accumulation and
UW label; Missing
Accumulation
Date and Waste
Type;
Discrepancy on
container storage
locations
10/16/2013 Responded to IDEM with
corrective action plan; issue
closed with Return to
Compliance Letter
83
Veolia – Port Arthur Penalty Record
Inspectio
n Date
Type of
inspecti
on
Name of
inspector
and
Regulatory
Agency
Alleged Violations VEOLIA Responses and/or
Corrective Actions Taken
3/9/2017 Clean
Air Act
(“CAA”)
Texas
Commissi
on on
Environme
ntal
Quality
(“TCEQ”)
1) Failure to maintain the Carbon
Monoxide emission rate of 17.10
pounds per hour at the
incinerator.
2) Failure to maintain Carbon
Monoxide emissions of 100
parts per million by volume
(ppmv) at the incinerator.
3) Failure to maintain incinerator
minimum combustion
temperatures.
4) Failure to maintain Arsenic and
Chromium emission rates at the
Incinerator.
5) Failure to maintain combined
Cadmium-Lead and combined
Arsenic-Beryllium-Chromium
emissions at the Incinerator.
6) Failure to maintain the Carbon
Monoxide emission rate of 17.10
pounds per hour during start-up
at the Incinerator.
4/18/2017: Received NOV.
5/27/2017: Submitted
Corrective Action Plan.
9/29/2017: Received a letter
from the TCEQ stating
adequate compliance
documentation was received
and no further action
required.
5/16/2016 RCRA TCEQ 1) Failure to maintain hazardous
waste tanks inspection records.
2) Failure to maintain a current
NOR status of INACTIVE for
hazardous waste tanks
inspection records.
3) Failure to include on the
emergency equipment list, One
Self Contained Breathing
Apparatus located at the onsite
Response Office.
4) Failure to have legible posted
signs with the legend Danger-
Unauthorized Personnel Keep
Out.
5) Failure to have adequate
security to prevent unknowing
site entry.
7/26/2016: Received NOV.
8/25/2016: Submitted
Corrective Action Response.
3/1/2017: Received a letter
from the TCEQ stating no
further action required.
84
Inspectio
n Date
Type of
inspecti
on
Name of
inspector
and
Regulatory
Agency
Alleged Violations VEOLIA Responses and/or
Corrective Actions Taken
1/26/2016 CAA
Title
V/New
Source
Review
(“NSR”)
Air
TCEQ 1) Failure to maintain the Carbon
Monoxide emission rate of 17.10
pounds per hour at the
Incinerator.
2) Failure to maintain Carbon
Monoxide emissions of 100
ppmv at the Incinerator.
3) Failure to maintain Incinerator
minimum combustion
temperatures.
4) Failure to maintain Arsenic,
Beryllium, Cadmium, Chromium
and Nickel emission rates at the
Incinerator.
5) Failure to maintain combined
Cadmium-Lead and combined
Arsenic-Beryllium-Chromium
emissions at the Incinerator.
6) Failure to prevent visible
emissions at Tank T102.
7) Failure to make a first attempt at
repair no later than 5 days after
a leak is detected and failed to
repair a leak no later than 15
days after a leak is detected.
4/27/2016: Received NOV
from the TCEQ
6/3/2016: Submitted a
response to the TCEQ.
9/20/2016: Received a letter
from the TCEQ stating no
further action required.
4/22/201
5
Texas
Pollutant
Dischar
ge
Eliminati
on
System
(“TPDES
”)
TCEQ 1) Failure to collect ammonia-
nitrogen sample at the
frequency specified in the Water
Quality Discharge Permit for
Outfall 001.
2) Failure to comply with test
procedures specified in 30 TAC
319.11-319.12.
3) Failure to properly calculate the
daily average for E. coli.
4) Failure to correctly report
effluent data on the discharge
monitoring report.
5/20/2015: Submitted a
response to TCEQ
6/10/2015: Received a letter
from the TCEQ stating no
further action is required.
1/30/2015 Drinking
Water
TCEQ 1) Received NOV for failure to
Provide or Report Public Notice.
2/20/2015: Submitted a
response to TCEQ.
12/31/2015: No further
correspondence received.
85
Inspectio
n Date
Type of
inspecti
on
Name of
inspector
and
Regulatory
Agency
Alleged Violations VEOLIA Responses and/or
Corrective Actions Taken
1/16/2015 Drinking
Water
TCEQ 1) Failure to have an accurate and
up to date plant operations
manual.
2) Failure to inspect the interior of
the 5,000-gallon pressure tank
at least once every 5 years.
3) Failure to notify TCEQ prior to
making any significant change
or addition to the system's
production, treatment, storage,
pressure maintenance, or
distribution facilities.
4) Failure to record the amount of
chemicals used at least once a
week.
5/29/2015: Submitted a
response to TCEQ
7/30/2015: Received a
request from the TCEQ for
additional information.
11/3/2015: Submitted a
response to TCEQ
12/30/2015: Received a letter
from the TCEQ stating the
drinking water project was
approved.
1/6/2015 Air TCEQ 1) Failure to maintain the Carbon
Monoxide emission rate at the
Incinerator for the period of
April 4, 2014 through August 18,
2014.
3/6/2015: Submitted a
response to the TCEQ.
6/24/2015: Received a letter
from TCEQ stating no further
action is required.
11/3/2014 Drinking
Water
TCEQ Received an NOV for failure to
submit Disinfectant Level
Quarterly Operating Report.
9/26/201
4
RCRA TCEQ 1) Failure to document inspector's
full name on daily inspection
logs.
2) Failure to include a notation of
the observations made during
daily & weekly inspections
10/22/2014: Submitted
Response to TCEQ.
2/9/2015: Received
documentation stating no
further action is required.
86
Inspectio
n Date
Type of
inspecti
on
Name of
inspector
and
Regulatory
Agency
Alleged Violations VEOLIA Responses and/or
Corrective Actions Taken
2/20/201
3
CAA TCEQ 1) Failure to maintain a minimum
power of 15 Kilovolt Amps to the
Wet Electrostatic Precipitator
(EPN INCINSTK).
2) Failure to conduct the 4th
quarter Cylinder Gas Audits on
the Hydrogen Chloride and
Sulfur Dioxide CWMS.
3) Failure to maintain carbon
monoxide emission rate at the
Incinerator (EPN INCINSTK).
5/24/2013: Submitted
Response to TCEQ for
Alleged Violations 1. and 2.
6/21/2013: Received letter
from the TCEQ stating no
further action is required for
Alleged Violations 1. and 2.
5/2/2013: Received Notice of
Enforcement for Alleged
Violation 3.
9/12/2013: Received Revised
Proposed Agreed Order
Assessing Penalty
9/16/2013: Submitted
Payment of Penalty
2/20/2014: Received Final
Agreed Order
3/25/2014: Submitted written
certification and documents
to demonstrate compliance.
8/22/2014: Received Notice
of Compliance with Agreed
Order
87
Heritage Thermal Services – Ohio Penalty Record
Type of
Action
Date Address Regulatory
Body/Agency
Description of
Alleged Violation
Fine
Amount
Final Disposition
Notice of
violation
(“NOV”)
5/26/17 Division of Air
Pollution
Control
(“DAPC”)
Heritage Thermal
Services (“HTS”)
exceeded total
hydrocarbons 1-hr
rolling average on
March 25, 2017 (Title
V).
NA Closed – Ohio EPA
(“OEPA”) issued
resolution of
violation letter on
7/11/17.
NOV 2/12/16 OSHA Failure to ensure
employee was
wearing proper
personal protective
equipment (“PPE”).
$27,720 Closed – HTS
settled this matter
on October 14,
2016.
NOV 1/21/16 DAPC HTS exceeded NOx
3hr block average
on June 28, 2015
(Title V).
NA Closed - NOV
resolved in letter
dated 02/25/16;
HTS responded
with action plan in
a letter dated
February 5, 2016.
Director’s
Final
Findings
& Orders
4/2/2015 1250
Saint
George
Street
East
Liverpool,
Ohio,
43920
OEPA, DAPC
and Ohio
Division of
Materials and
Waste
Management
(“DMWM”)
NOVs issued to HTS
due to the 7/13/13
Incident:
Dust Nuisance
(DAPC)
Unlawful disposal of
hazardous waste
and improper
maintenance and
operation of
equipment (DMWM)
$34,000 HTS is in
discussions with
OEPA
Finding of
Violation
3/25/2015 1250
Saint
George
Street
East
Liverpool,
Ohio,
43920
US EPA HTS exceeded
Maximum
Achievable Control
Technology
standard and Title V
Operating
Parameter Limits on
several occasions.
TBD HTS is in
discussions with
US EPA
88
Type of
Action
Date Address Regulatory
Body/Agency
Description of
Alleged Violation
Fine
Amount
Final Disposition
NOV 9/16/2014 1250
Saint
George
Street
East
Liverpool,
Ohio,
43920
DMWM Violation of Ohio
Administrative Code
(“OAC”) 3745-55-
75(b)
Bulk waste container
stored outside of
secondary
containment.
NA Closed – Return to
compliance (“RTC”)
received in a letter
dated December 8,
2014. September
16, 2014 letter
acknowledged that
issue had been
corrected on date
of inspection.
NOV 9/16/2014 1250
Saint
George
Street
East
Liverpool,
Ohio,
43920
DMWM Violation of OAC
3745-54-15(c)
Immediate action
had not been taken
to prevent further
incident following
discovery of
equipment damage.
NA Closed – RTC
received in a letter
dated December 8,
2014, September
16, 2014 letter
acknowledged that
issue had been
corrected on date
of inspection.
NOV 9/16/2014 1250
Saint
George
Street
East
Liverpool,
Ohio,
43920
DMWM Violation of Permit
Condition C.6(c)
Spills not cleaned up
in a timely manner.
NA Closed – RTC
received in a letter
dated December 8,
2014, September
16, 2014 letter
acknowledged that
issue had been
corrected on date
of inspection.
89
Type of
Action
Date Address Regulatory
Body/Agency
Description of
Alleged Violation
Fine
Amount
Final Disposition
NOV 10/2/2013 1250
Saint
George
Street
East
Liverpool,
Ohio,
43920
DMWM Ash release on
7/13/13 was an
unlawful Disposal of
Hazardous Waste.
Failure of proper
Operation and
Maintenance of
equipment/facility
NA HTS responded in
a letter dated
October 21, 2013.
HTS met with
OEPA on 9/22/14
to provide update.
HTS provided
written update and
request for RTC in
letter dated
10/17/14.
HTS 2nd request for
RTC in letter dated
12/12/14.
HTS 3rd request for
RTC in letter dated
2/3/2015.
HTS has
completed
requirements for
RTC and is actively
pushing OEPA for
RTC.
90
Type of
Action
Date Address Regulatory
Body/Agency
Description of
Alleged Violation
Fine
Amount
Final Disposition
NOV 8/5/13 1250
Saint
George
Street
East
Liverpool,
Ohio,
43920
DAPC Ash release
determined to be a
public nuisance in
violation of OAC
3745-15-07
NA HTS responded in
a letter dated
August 22, 2013.
HTS met with
OEPA on 9/22/14
to provide update.
HTS provided
written update and
request for RTC in
letter dated
10/17/14.
HTS 2nd request for
RTC in letter dated
12/12/14.
HTS 3rd request for
RTC in letter dated
2/3/2015.
HTS has
completed
requirements of
RTC and is actively
pushing OEPA for
RTC.
NOV 6/21/2013 1250
Saint
George
Street
East
Liverpool,
Ohio,
43920
OSHA Violation of various
standards –
decontamination,
improper storage of
water reactives, not
identifying hazards.
$11,802 Closed – HTS
settled this matter
on 8/30/13.
HTS and OSHA
met for informal
conference on
7/16/13.
Agreement
reached. Penalty
reduced to
$11,802.
91
Clean Harbors Aragonite Enforcement Summary Fact Sheet
Clean Harbors Aragonite is subject to regulatory inspections by multiple agencies. While our goal is 100%
compliance with all permits and regulatory requirements, inspections can result in alleged violations. This
document is a summary from those inspections.
Although the company does not necessarily concur with these findings, consistent with the company’s
standard policy it has agreed to take all steps necessary to comply with the orders and to take such other
corrective measures so as to ensure that the facility is in full compliance with its federal and state operating
permits.
In 2015 the facility resolved a notice of violation with USDEA. Alleged violations are listed below followed
by the facility response in bold italicized text.
1. Failure to maintain a current license required by the state of Utah. A former compliance manager
did not renew one of two state licenses. This was discovered during an internal audit and self-
reported to both Utah and DEA. The facility voluntarily discontinued acceptance of controlled
substances until the permit was obtained.
2. Failure to maintain separate biennial reports for Schedule I/II and III/IV/V controlled substances.
The facility had zero inventory and reported that on one form. We disagreed with this allegation. If
there was any inventory to report it would have been done on separate forms as required by the
regulations.
3. Failure to maintain complete and accurate records. Information was contained on Form 41’s as
required by regulation but would not fit in the column DEA considered appropriate. The facility
began to use revised DEA form 41’s (that includes more space) to address the issue.
This was resolved by a consent order that included a $63,000 penalty.
In 2015 the facility resolved a notice of violation with Utah Board of Pharmacy for the same issue as #1
above.
This was resolved by an administrative order that included a $20,000 penalty.
In 2014 the facility resolved a notice of violation with USDEA. Alleged violations are listed below followed
by the facility response in bold italicized text.
1. Failure to complete an accurate biennial inventory. The facility had zero inventory and reported
that on a Clean Harbors letterhead. We disagreed with this violation. If there was any inventory to
report it would have been done on forms as required by the regulations.
2. Failure to document the number of items received and the date items were received on a copy 3
of DEA form 222. This information was documented on a transfer form but not copied to a form
222. Facility personnel were retrained to address the issue.
3. Failure to execute a form 222 to transfer substances to another registered entity. A shipment
count did not match and was rejected back to the generator. The facility did not include rejection
using a form 222. Facility personnel were retrained to address the issue.
4. Failure to report the required documents in ARCOS in a complete and accurate manner. We
disagreed with this violation. All reports were submitted to ARCOS. There were several errors not
yet corrected at the time of the inspection. All errors were subsequently corrected.
92
This was resolved by a consent order that included a $190,000 penalty.
In 2013 the facility resolved a notice of violation with UDEQ. This pertains to an annual RCRA inspection
conducted in 2012. Alleged violations are listed below followed by the facility response in bold italicized
text.
1. The facility self-reported a permit condition to record times each backup carbon adsorber is used
was not followed. During an internal audit it was discovered a PLC that records backup carbon
usage was rounding minutes incorrectly and slightly underreported usage. The programming was
corrected.
2. The facility self-reported that a water reactive labpack in excess of four liters was accepted and
incinerated, in violation of permit conditions. The material is acceptable but not in excess of four
liters per container. The person responsible for the mistake was disciplined.
3. UDEQ alledged that weekly emergency shower and eyewash inspections were not noted in
inspection tags. We disagreed with this violation. Inspections were performed and documented on
an inspection log.
4. UDEQ alleged that a leaking roof repair was not completed within 72 hours as required by permit.
We disagreed with this violation. During a January storm, ice accumulated on a roof over Building
E-2. Once it warmed above freezing a small leak was discovered. Due to the dangers of roofing
contractors on frozen roofs, this was not repaired until May
5. UDEQ alleged the facility did not report a fire as required by the permit. We disagreed with this
violation. Heat tracing under pipe insulation shorted arced and melted wire insulation. There was
not a fire and as such was not reportable.
6. UDEQ alleged that a RCRA air subpart BB/CC database and associated drawings were not kept
updated. The database was accurate but drawings were not current.
7. UDEA alleged that an incoming container tested positive for oxidizers and that container should
have been reclassified as a DOT oxidizer. We disagreed with this violation. The container held
mixed acids, some of which do test positive for oxidizers. This was not an oxidizer per DOT
standards.
8. The facility self-reported that an inbound trailer was not offloaded within 10 days as required by
permit. No comment. This was self-reported.
This was resolved by a consent order that included a $31,155 penalty.
In 2012 the facility resolved a notice of violation with UDEQ. This pertains to an annual RCRA inspection
conducted in 2011. Alleged violations are listed below followed by the facility response in bold italicized
text.
1. UDEQ alleged there was a calibration problem with the oxygen analyzer in the hydrocarbon vent
system. We disagreed with this violation. The facility inspection program found and corrected the
problem prior to the inspection. This was corrected by installing a condensation trap and filter prior
to the analyzer.
2. The facility self-reported to UDEQ that the direct burn flow meter was incorrectly calibrated. This
was immediately corrected when discovered.
3. UDEQ alleged the facility did not properly describe a waste being accepted on the waste receiving
report. We disagreed with this violation. The waste was profiled with a range (IE: yellow liquid 0-
25%) so the waste received description can seem subjective compared to the profile.
4. UDEQ alleged 2 drums of site generated waste were incinerated without burn chemistry
documentation. The facility believes this was done but documentation could not be produced.
Personnel involved were retrained.
5. There were seven additional examples of improper burn chemistry documentation violations. To
address the issues, the waste analysis plan was recently modified that will allow burn chemistry
93
matrixes to be applied based on sampling and analysis of each waste stream. This information is
documented in the operating record.
6. UDEQ alleged the facility did not properly completed inspection logs. During this timeframe, a new
electronic inspection log was implemented. One day the log would indicate an issue and the next
day it passed. The problem was attributed to a pop up warning that did not properly function. This
was promptly corrected.
7. UDEQ alleged that crack repairs to a secondary containment system was a violation. We disagreed
with this violation. The cracks were found during an inspection. They could not be repaired within
72 hours as required by permit due to weather. UDEQ was notified prior to 72 hours as required
by the permit. The cracks were promptly repaired when the weather was dry and >50⁰F. (needed
for the epoxy to cure)
8. UDEQ alleged the facility did not report a fire as required by the permit. We disagreed with this
violation. A hose connected to a propane torch became disconnect causing an incidental fire. The
permit requires any fire in an area where waste is managed to be reported. The fire did not meet
reporting required by the permit.
9. UDEQ alleged an instrument calibration log was not signed by the technician who did the
calibration. The person did not sign the log as required. He was retrained.
This was resolved by a consent order that included a $35,017 penalty.
In 2012 EPA issued a warning letter alleging seven instances of TRI reporting errors from 2007 through
2010. These mistakes were made by a former employee who is no longer employed by Clean Harbors.
This was resolved by a consent order that included a $39,900 penalty.
Questions associated with this fact sheet should be directed to Mike Crisenbery, VP Compliance (513-823-
2280).
94
Curtis Bay Energy LP Penalty Record
Date Type Summary Detail Fine Amount Return to
Compliance
Date
Corrective Action
March
2015
Air HCI Emissions failure was caused
by incomplete Trona injection, CO
Emissions failure was caused by
incomplete combustion of the
waste, and Opacity Emission.
Failure was caused by bag
malfunction
Hydrogen Chloride
(HCl), Carbon
Monoxide (CO), and
opacity limit
exceedance
fine amount
$125,000,
settlement
$50,000
January 2016 i. HCl Emissions failure was
addressed Installation of a DSI
(Dry Sorbent Injection System)
ii. CO failure was addressed by
implementing better engineering
practices and installing a new
conveyor system for providing
enhanced blended for better
emissions control.
iii. Opacity Emissions Failure was
corrected with ongoing
preventive maintenance of the
bags.
95
Daniels Sharpsmart, Inc. Fresno, California Transfer Facility Penalty Record
Date Address Regulatory
Body/Agency
Finding
5/28/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Failed to provide tracking documents which show the name, address, and telephone number of the
medical waste generator, for purpose of tracking the generator medical waste when the waste is
transported to the final medical waste treatment facility.
5/28/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Containers to be reused were not thoroughly washed and decontaminated by a method approved
by the Department and maintained in a clean and sanitary condition.
5/28/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Tracking documents are not staying with the waste and are being signed off as treated by the office
staff.
5/28/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Unregistered haulers are used to transport waste out of the state for incineration.
8/26/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Waste is not being held at 32°F or below.
96
Date Address Regulatory
Body/Agency
Finding
8/26/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Containers to be reused were not thoroughly washed and decontaminated by a method approved
by the Department and maintained in a clean and sanitary condition.
8/26/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
The facility shall immediately clean the ground around the treatment area to a well-maintained
condition. Any enclosure or designated accumulation area used for storage of medical waste prior to
transportation or treatment shall provide medical waste protection from animals and natural
elements and shall not provide a breeding place for insects or rodents.
11/20/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Failed to provide tracking documents which show the name, address, and telephone number of the
medical waste generator, for purpose of tracking the generator medical waste when the waste is
transported to the final medical waste treatment facility.
11/20/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Waste is not being treated within the required timeframe.
11/20/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Containers to be reused were not thoroughly washed and decontaminated by a method approved
by the Department and maintained in a clean and sanitary condition.
97
Date Address Regulatory
Body/Agency
Finding
11/20/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
A new operations manual must be submitted within 30 days.
11/20/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Tracking documents are not staying with the waste and are being signed off as treated by the office
staff.
11/20/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Unregistered haulers are used to transport waste out of the state for incineration.
11/20/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Not all incineration waste is being treated by incineration.
11/20/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Not all pathology waste is being treated in a mixture of 25% pathology and 75% biohazardous waste
as required.
98
Date Address Regulatory
Body/Agency
Finding
11/20/2014 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Non-compliances with the conditions of the permit were not reported to the Department within 24
hours.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Failed to provide tracking documents which show the name, address, and telephone number of the
medical waste generator, for purpose of tracking the generator medical waste when the waste is
transported to the final medical waste treatment facility.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Waste is not being treated within the required timeframe.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Waste is not being held at 32°F or below.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Containers to be reused were not thoroughly washed and decontaminated by a method approved
by the Department and maintained in a clean and sanitary condition.
99
Date Address Regulatory
Body/Agency
Finding
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Some waste containers are being compromised and pose an environmental risk.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Some pharmaceutical waste containers, individual, secondary or the fiberboard boxes did not have
the proper labeling.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Autoclavable waste in the recycled sharps program was not treated within the required seven days.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Tracking documents are not staying with the waste and are being signed off as treated by the office
staff.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Not all incineration waste is being treated by incineration.
100
Date Address Regulatory
Body/Agency
Finding
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Not all pathology waste is being treated in a mixture of 25% pathology and 75% biohazardous waste
as required.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Did not request both the shipping and tracking documents from the transporters delivering waste to
the transfer station.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Tracking documents do not meet the requirements of the Code of Federal Regulations (CFR) for the
DOT shipping documents.
4/10/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
The findings by the Department on November 20, 2014 that the autoclave computer was not
consistently printing the time/temperature readings have not been corrected.
5/20/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Some pharmaceutical waste containers, individual, secondary or the fiberboard boxes did not have
the proper labeling.
101
Date Address Regulatory
Body/Agency
Finding
5/20/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Develop a process for ensuring that all documents are completely and accurately filled out and that
it is clear where the waste is being transferred for out of state treatment.
5/20/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Did not request both the shipping and tracking documents from the transporters delivering waste to
the transfer station.
5/20/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Tracking documents do not meet the requirements of the Code of Federal Regulations (CFR) for the
DOT shipping documents.
5/20/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
The findings by the Department on November 20, 2014 that the autoclave computer was not
consistently printing the time/temperature readings have not been corrected.
11/2/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
A few sharpsmart transport carts were missing from the facility.
102
Date Address Regulatory
Body/Agency
Finding
11/2/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Sanitec totes used to store and transport pathology waste to Healthwise for treatment were not
labeled nor had tight fitting lids.
11/2/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Tracking documents are not staying with the waste and pharmaceutical containers were not secure.
11/2/2015 4144
Therese
Ave
Fresno,
CA 93725
California
Department of
Public Health
Develop a process to ensure that documentation is as accurate as possible.
103
Appendix L
Education and Outreach Call Center Script
Thank you for calling the information line for the Medication Education and Disposal Project, or MED-
Project.
Call Script:
• If you are experiencing a medical emergency, please hang up and dial 9-1-1.
• If you are experiencing a non-emergency but suspect that you or a family member has ingested
something poisonous, please call Poison Control at 800-222-1222.
• Unwanted Medicine Kiosks are located throughout your local area and provide convenient options
for disposing of expired or Unwanted Medicines. Press 3 for more information about convenient
kiosks.
• Mail-Back Services are available to Residents. Press 4 for more information.
• Take-Back Events may be scheduled throughout the year and offer residents a free and
convenient way to dispose of expired or Unwanted Medicine. Press 5 for more information.
104
• A Sharps Program is available in your local area and provides convenient options for disposing of
unwanted sharps. Press 6 for more information.
• You may press 0 at any time to speak with an operator about disposal options.
• MED-Project is a consumer education campaign dedicated to proper medication use and
consumer disposal.
• MED-Project reminds you that taking your medicine as directed by your health care provider is
important to your health.
• If you have questions about your medication, please hang up and call your health care provider.
• For additional questions about the proper disposal of expired or unwanted medications from
households, please go to www.med-project.org or press 0 to talk to an operator.
• To hear this menu again, please press 1.
• Thank you for calling MED-Project.
Unwanted Medicine Kiosk Script for when Option 3 is selected:
• Kiosk Drop-Off Sites for Unwanted Medicine are located conveniently throughout your local area.
To locate the site nearest you, or for precise information about hours of operation, press 0 to
speak with an operator or visit www.med-project.org to search by your zip code.
• Kiosks accept medications in any dosage form in their original container or sealed bag. Items that
are not accepted include herbal remedies, vitamins, supplements, cosmetics or other personal
care products; medical devices; batteries; mercury-containing thermometers; sharps; and illicit
drugs.
• If you transfer your medications to a sealed bag before placing it into a kiosk, please be sure to
recycle all remaining packaging.
• To protect your privacy, remove or black out all personally identifiable information before
disposing of your medications or recycling your drug packaging.
• To repeat this information, press 3.
• To return to the main menu, please press 1.
• Thank you for calling MED-Project.
Unwanted Medicine Mail-Back Services Script for when Option 4 is selected:
• Mail-Back Services for unwanted medicine and inhalers are available to disabled and home-bound
Residents, persons providing services to such Residents, and Residents in underserved areas of
the County.
• Unwanted Medicine Mail-Back Packages accept medications in any dosage form in their original
container or sealed bag. Items that are not accepted include herbal remedies, vitamins,
supplements, cosmetics or other personal care products; medical devices; batteries; mercury-
containing thermometers; sharps; and illicit drugs.
• To request a Mail-Back Package, please press 0 to talk to the operator or visit www.med-
project.org.
• If you transfer your medications to a sealed bag, please be sure to recycle all remaining
packaging.
• To protect your privacy, remove or black out all personally identifiable information before
disposing of your medications or recycling your drug packaging.
• To repeat this information, press 4.
• To return to the main menu, please press 1.
• Thank you for calling MED-Project.
105
Unwanted Medicine Take-Back Event Script for when Option 5 is selected:
• MED-Project may be working with local law enforcement and other community organizations to
offer regular expired and Unwanted Medicine Take-Back Events in your area. For a complete list of
Take-Back Events, please press 0 to speak to the operator or visit www.med-project.org.
• Take-Back Events accept medications in any dosage form in their original container or sealed bag.
Items that are not accepted include herbal remedies, vitamins, supplements, cosmetics or other
personal care products; medical devices; batteries; mercury-containing thermometers; sharps; and
illicit drugs.
• If you transfer your medications to a sealed bag, please be sure to recycle all remaining
packaging.
• To protect your privacy, remove or black out all personally identifiable information before
disposing of your medications or recycling your drug packaging.
• To repeat this information, press 5.
• To return to the main menu, please press 1.
• Thank you for calling MED-Project.
Sharps Program Script for when Option 6 is selected:
• Kiosks to collect unwanted sharps are located throughout your local area. To locate the kiosk site
nearest you, or for information about kiosk locations, press 0 to speak with an operator, or visit
MED-Project.org to search by zip code.
• Sharps Mail-Back Services1 for sharps are available to disabled and home-bound Residents or to
persons providing services to such Residents. To request a Sharps Mail-Back Package, press 0 to
talk to the operator or visit MED-Project.org.
• Sharps such as hypodermic needles, pen needles, intravenous needles, pre-loaded sharps, auto
injectors, intravenous needles, lancets and other devices used to penetrate the skin for drawing
blood, or for the delivery of medications or drugs contained in approved sharps containers may be
turned in at kiosks or placed in a Sharps Mail-Back Package.
• MED-Project cannot accept controlled substances, shaving razors, loose needles, unwanted
medicine not contained in sharps, or loose sharps that are not contained in approved sharps
containers. Approved sharps containers must be made of a heavy-duty plastic; able to close with a
tight-fitting, puncture-resistant lid, without sharps being able to come out; upright and stable during
use; leak-resistant; and properly labeled as “sharps waste” or with the biohazard symbol and the
word “BIOHAZARD”.
• MED-Project is working with community organizations to offer Sharps take-back events in your
area. For a complete list of take-back events, please press 0 to speak to the operator or visit MED-
Project.org.
• To protect your privacy, remove or black out all personally identifiable information before
disposing of your medications.
• To repeat this information, press 6.
• To return to the main menu, press 1.
• Thank you for calling MED-Project.
1 Sharps Mail-Back Services is the provision of pre-paid, pre-addressed packages to disabled and home-bound
Residents for the collection and disposal of Sharps (“Sharps Mail-Back Packages”) by Vendor.
Sharps as defined in Section 6.54.030 of the Alameda County Safe Consumer-Generated Sharps Disposal Ordinance,
Alameda County Code Chapter 6.54 are “devices with sharp points or edges that can cut or puncture the skin and
includes needles, pen needles, syringes, lancets, auto-injectors, infusion sets, intravenous catheters, connection
needles/sets, and other devices.”
106
Appendix M
MED-Project Website
107
108
109
110
111
112
113
114
115
Appendix N
Brochure
116
117
Appendix O
Digital and Local Social Networks
The following is a representative list of local organizations and their social media networks in the County.
MED-Project will reach out to relevant groups to help promote the Program.
OUTLET FACEBOOK TWITTER
510 Families https://www.facebook.com/510Families @510families
Alameda Alliance https://www.facebook.com/alamedaallianceforhealth @AlamedaAlliance
Alameda Blogs @Alamedans
Alameda Buzz @AlamedaBuzz
Alameda County https://www.facebook.com/AlamedaCounty @Alameda County
Alameda County
Fair
https://www.facebook.com/alamedacountyfair @ACFair
Sutter Health https://www.facebook.com/SutterHealth @SutterHealth
Alameda Health
Consortium
https://www.facebook.com/alamedahealthconsortium
Alameda Health
System
https://www.facebook.com/AlamedaHealthSystem @AlamedaHealth
Alameda Patch https://www.facebook.com/AlamedaPatch @AlamedaPatch
Alameda Rotary
Club
https://www.facebook.com/RotaryClubofAlameda @alamedarotaryclub
Alameda-Contra
Costa Medical
Association
https://www.facebook.com/Alameda-Contra-Costa-Medical-
Association-148916421860535/?ref=br_rs
@EastBayDocs
Albany Patch https://www.facebook.com/AlbanyCAPatch/?ref=br_rs @AlbanyPatch
CA Medical Assn https://www.facebook.com/cmaphysicians @cmaphysicians
City of Fremont https://www.facebook.com/cityoffremont @Fremont_CA
California
Pharmacist
Association
https://www.facebook.com/CAPharm @CAPharm
118
California Nurses
Association
https://www.facebook.com/nationalnurses @NationalNurses
National
Association of
Social Workers
California
https://www.facebook.com/naswca @naswca
City of Hayward https://www.facebook.com/cityofhayward @cityofhayward
City of Livermore https://www.facebook.com/cityoflivermore @cityoflivermore
City of Oakland https://www.facebook.com/oakland/ @CityofOakland
City of Union City https://www.facebook.com/CityofUnionCity @UnionCity_Gov
Downtown
Oakland
Association
https://www.facebook.com/downtownoak/
East Bay Loop https://www.facebook.com/eastbayloop/ @EastBayLoop
Eastmont
Wellness Center
https://www.facebook.com/pages/Eastmont-Wellness-
Center/131624876909152?ref=br_tf
Fremont Patch
Foundation
https://www.facebook.com/FremontCAPatch @FremontPatch
Livermore Library https://www.facebook.com/pages/Livermore-Public-
Library/99365063645
@livlibrary
Oakland Local https://www.facebook.com/oaklocal @oaklandlocal
Oakland Magazine https://www.facebook.com/oaklandmagazine @eastbay365
Oakland Police
Department
https://www.facebook.com/oaklandpoliceca/ @oaklandpoliceca
Oakland Public
Library
https://www.facebook.com/oaklibrary @oaklibrary