                        Notes from Meeting with USAPHC
                                       
                                       
Attended by:
USAPHC:		Lisa Strutz, Richard Price, Sandy Toscano	
	
EPA Staff:	Kristin Fitzgerald, Charlotte Mooney, Lisa Lauer, Jessica Young

Date:			November 28, 2012


EPA met with representatives of the US Army Public Health Command's (USAPHC) Army Institute of Public Health.

They inquired about the progress of the pharmaceuticals proposed rule.  They raised the following issues that they hope the proposed rule will address:

   1. P-listed hazardous waste pharmaceuticals containers
   2. Reverse distribution
   3. Floor sweepings
   4. Off-post transport/consolidation from satellite pharmacies
   5. Controlled substances
   6. Amnesty Turn-ins/residential take-backs
They discussed their operations pertaining to reverse distribution and said that certain pharmaceuticals never get credit:  loose pills, partially dispensed liquids and drugs with sole manufacturers. 

During the discussion, the Army indicated that their off-post clinics are generally CESQGs.
