Here are this week’s curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: •AG Coalition Challenges Proposed Emissions...more
Texas AG Ken Paxton has launched a coalition and pilot program to help Texas students dispose of unused opioids safely and conveniently. Called the “Friday Night Lights Against Opioids” program, the coalition will distribute...more
California’s Pharmaceutical and Sharps Waste Stewardship Act requires pharmaceutical companies doing business in the state to develop and submit a “stewardship plan” to CalRecycle, a branch of the state’s Environmental...more
The FDA is requesting public comments on a possible change to the Opioid Analgesic Risk Evaluation and Mitigation Strategy requiring opioid analgesics (OA) used in an outpatient setting to be dispensed with mail-back...more
Misuse of controlled substances continues to be a serious public health problem in the United States. The most commonly misused controlled substances include opioids (such as oxycodone), which are used to treat pain, and...more
On February 27, 2020, the U.S. Department of Agriculture (“USDA”) announced that it will delay the enforcement requirement of the Drug Enforcement Agency (“DEA”) laboratory certification process and reverse distributer...more
The United States Environmental Agency (“EPA”) released December 19, 2019 interpretive guidance titled: Manifesting Non-Creditable Hazardous Waste Pharmaceuticals – New Four Character Code (“Guidance”) - The document...more
The U.S. Environmental Protection Agency’s final rule governing management of hazardous waste pharmaceuticals became effective August 21, 2019. The new regulations apply to the management of hazardous waste pharmaceuticals by...more
Earlier this year, the Environment Protection Agency (“EPA”) adopted a final rule imposing new standards for the management of hazardous waste pharmaceuticals (“HWPs”) that goes into effect on August 21, 2019 (“Final Rule”)....more
Certain pharmaceuticals are regulated under the Resource Conservation and Recovery Act (RCRA) as “hazardous waste” when they are discarded. EPA recently finalized new management standards for hazardous waste pharmaceuticals...more
This Presentation addresses two of the issues relevant to the solid waste management industry associated with Arkansas’s enactment of the Medical Marijuana Amendment (“AMMA”): - Employee issues associated with the legal use...more
On February 22, 2019, EPA published its final rule governing standards for the management of pharmaceutical hazardous wastes in the Federal Register (Final Rule). The Final Rule’s publication in the Federal Register sets...more
On December 11, 2018, U.S. EPA Acting Administrator Andrew Wheeler signed a new hazardous waste pharmaceutical rule. The final rule retains a proposed requirement, opposed by industry, that prescription pharmaceuticals sent...more
On October 24, 2018, the SUPPORT for Patients and Communities Act (Pub. L. 115-271, the “Act”) was signed into law. Section 3222 of this sweeping federal opioid legislation amends the Controlled Substances Act to permit...more
Barnes Johnson, Director of the United States Environmental Protection Agency (“EPA”) Office of Resource Conservation and Recovery (“RCRA”) authored a September 11th memorandum titled: Management of Household...more
The California Senate enacted Senate Bill 212 (SB 212) which would create a statewide drug and needle take-back program. SB 212 would require entities that sell drugs or sharps in the state of California to individually...more
The State of New York enacted a law that requires certain manufacturers to operate a drug take back program. The Act signed into law by New York Governor Cuomo is denominated the “Drug Take Back Act” (“Act”). ...more
Governor Cuomo signed into law on Tuesday, July 10, 2018 the New York State Drug Take Back Act (“Act”). New York joins the State of Washington as the first two states to adopt statewide drug take back programs for unwanted...more
The national opioid crisis has led politicians and law enforcement to increase their focus on the regulation of controlled substances. Hospitals and other facilities should ensure that they are compliant with DEA rules on not...more
On March 22, 2018, the Governor of the State of Washington signed the Secure Drug Take-Back Act, which establishes the first statewide drug take-back program in the nation. The Act requires manufacturers of “covered drugs”...more
Los Angeles County, the nation’s largest County, has proposed a pharmaceutical take-back ordinance that would require businesses to finance a local government program for disposal of unwanted medications and potentially...more
The Environmental Protection Agency (EPA) has promulgated its proposed regulation of “hazardous waste pharmaceuticals,” i.e., pharmaceutical residues discarded from health care facilities which also meet EPA’s long-standing...more
The Environmental Protection Agency (EPA) recently issued a pre-publication Proposed Rule (40 C.F.R. part 266, subpart P) regulating the management and disposal of drugs deemed “hazardous waste pharmaceuticals” by healthcare...more
Questions remain about the U.S. Drug enforcement agency’s rules on secure disposal of controlled substances and exactly how they will be implemented with regard to the disposal of controlled substances by hospice personnel...more
On September 30, 2014, the Ninth Circuit affirmed the Northern District of California’s summary judgment that the Alameda Safe Drug Disposal Ordinance (the “Ordinance”) does not violate the dormant Commerce Clause of the...more