Correspondence - Item 27 - Laserfiche WebLink

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CDPH — HRI Recommendations May 10, 2023 Page 2 of 4 In my view, the current proposal submitted by HRI is lacking in adequate accountability for safe syringe disposal and syringe collection. The estimated number of syringes HRI expects to collect is only 60% of what the organization expects to distribute. While HRI participants may have other options for disposal, improperly disposed syringe needles will pose direct threats to both environmental health and public health. As with the OCNEP experience, inappropriately disposed syringes is likely and additional efforts to mitigate this risk should be put in place ahead of initiating the expansion of services to include syringe delivery. It is anticipated as in the past, the community will be concerned about the potential danger that syringe litter poses to children at risk of accidentally getting harmed by used needles improperly discarded in public parks and libraries and on sidewalks when traveling to and from school. Prior to reinstating this program, HRI must describe a clear, new, and effective method to prevent the secondary impacts of this needle distribution. Local Health Officer Recommendations Any syringe program that intends to initiate syringe services/exchange in Orange County will need to prioritize efforts to reduce improper needle disposal and demonstrate that the program is not contributing to a rise in inappropriately disposed syringe needles. Additionally, providing counseling, referrals, linkages to medical and behavioral health services, and resources with close follow up will be critical. To overcome the community's negative perceptions from its prior experience with syringe needle exchange programs, the Orange County Health Care Agency (HCA) recommends that CDPH require that HRI incorporate the following additional mitigation measures: 1. Demonstrate safe and effective methods of appropriate syringe disposal and collection. • Ongoing review of operations/logistics with HCA Environmental Health Services o Regular meetings with OC Environmental Health personnel should occur prior to opening the program and intermittently throughout the duration of the program to ensure operations/logistics meet regulatory standards for appropriate needle handling and disposal of medical waste. ■ HRI must maintain compliance with Medical Waste Management Act (MWMA) (Health & Safety Code Section 117904 etseq.) ■ Transport of sharps collected by HRI in a consolidation location will need to comply with MWMA Sections 117904(e) and 117945 ■ Medical waste must be handled in accordance with California Health and Safety Code HSC Section 118025 and transferred in compliance with Health & Safety Code Section 11800(a). Dispense syringes with enhanced safety measures and easy identification o Syringe should be single use, with a retractable needle. o Syringe should have markings that identify that the syringe was dispensed by HRI- Santa Ana. Example: CDPH should require manufacturer/distributor of the syringe needles to include a label or etching identifying that the syringe was dispensed by HRI-Santa Ana, with contact information in the event of improper disposal and emergency contact information in the event of a drug overdose.