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GREGORY BLOUNT TROUTMAN TROUTMAN SANDERS LLP <br /> 404.885.32911 telephone Attorneys at Law <br /> 404.862.6510 facsimile Bank of America Plaza <br /> gregory.biount(altroulmansanders.com StreetSANDERS 600 Peachtree Atlanta, GeorgaE, Suite <br /> 3030822106 404.865.3000 telephone <br /> lroulmansanders.com <br /> March 13 , 2017 <br /> VIA ELECTRONIC MAIL <br /> Mr. Jonathan Blazo <br /> County of Santa Clara <br /> 1555 Berger Drive, Suite 300 <br /> San Jose, CA 95112-2716 <br /> RE: Retail Reverse Distribution of Pharmaceuticals <br /> Dear Jonathan. <br /> We understand that Santa Clara County is interested in better understanding our retail <br /> pharmacy management and disposal of pharmaceutical wastes . In particular, we understand <br /> from recent inspections by you and others that the County is interested in the reverse distribution <br /> of pharmaceuticals at retail and documentation relating to this process. <br /> We welcome an opportunity to meet and explain how reverse distribution is managed by <br /> our companies . We would also welcome the opportunity to describe how we ensure that reverse <br /> distribution is neither abused nor improperly used for waste disposal. We likewise seek to assure <br /> you that only pharmaceuticals meeting the manufacturers ' return criteria for condition and type, <br /> including credit potential, are shipped via reverse distribution for further evaluation and ultimate <br /> disposition by the manufacturer or manufacturer' s agent. Most importantly, we look forward to <br /> confirming for you our compliance with all State and Federal laws, rules and regulations . <br /> It may interest you to know that we have been working with U. S . EPA to help with a <br /> common understanding of these processes which can and do vary by company. Indeed, the <br /> variable and prospective nature of the process was acknowledged and captured by the U. S . EPA <br /> in the preamble to its proposed rulemaking on this subject. That recognition is as follows : <br /> Whether a pharmaceutical is eligible for manufacturer' s credit is <br /> determined solely by the manufacturer' s return policy. Based on <br /> comments received for the 2008 Universal Waste proposed rule and <br /> through discussions with various stakeholders, the Agency understands <br /> that the return policies of manufacturers change regularly. As a result, <br /> pharmacies are not always aware if a particular pharmaceutical will be <br /> creditable at the time that it is pulled from the shelves . However, the <br /> ATLANTA BEIJING CHARLOTTE CHICAGO HONG KONG NEW YORK ORANGE COUNTY PORTLAND RALEIGH <br /> RICHMOND SAN DIEGO SAN FRANCISCO SHANGHAI TYSONS CORNER VIRGINIA BEACH WASHINGTON , DC <br />