[Pharmwaste] White House Drug Disposal Policy with list ofdrugstobe flushed

Wed Apr 18 18:08:32 EDT 2007

I looked at the list that the drug policy people advocate for continued flushing and I don't know what all of them are, but I knew enough of them to ass(u)me that the list included the most abused controlled substances.  My brain decided that the arguement for potential risk to fish wouldn't move anyone at ONDCP to change their mind when they are looking at serious abuse potential and its consequences.  I'm thinking they established their list more from connecting with the DEA than with manufacturers.  Flushing is the best "away", unless we can convince them otherwise.  A rebuttal needs to contain more than "mix with kitty litter or coffee grounds" because apparently kids will eat a mouthful of those just to get the drug.

The drug manufacturers think us waste managers are goofy in the head for worrying about the "minute" amount that might be flushed vs. the large amount that is excreted.  This is what I clearly remember from a conference call sponsored by the Product Stewardship Institute about a year ago (not the recent pharm call they sponsored).  The manufacturers didn't understand that we have to answer calls every day and recommend best management options based on human health and environmental impacts, even if the results are considered by some to be minimal.  

SO, given all that, what is the best option to protect human health for seriously abused drugs?  HEY!  We know the answer!  It is for the DEA and the ONDCP to cut us some regulatory slack and partner with us to get manufacturers and retailers etc. involved in providing free, accessible collection programs.

This is the plan that many, maybe the majority, of us waste managers feel is a few years out for many areas of the country.  Thankfully we have brave pioneers who've established great models to build from.  I am willing to get in on the letter writing, but we need a specific, consistent response to this guidance that outlines better options, interim and final.  In the meantime, in MN we'll continue to promote the no sewering guidance we've widely spread over the past 2 years.  I'm not sure how the ONDCP guidance will be distributed.  We should find that out also.  If it is just on their website and EPAs, I'm not as concerned.  We have a lot of links to our guidance from our HHW Programs, our website and MDH's website.  We've distributed thousands of flyers which were jointly created with our Dept. of Health and which are being given out by hospitals.  I guess I should check in with them to see if they are still following the guidance we jointly created!  They haven't brought it up.  Back again to that...would our Health department side with ONDCP on poison and abuse potential and backslide into flushing or will they stick with us on trashing and collection?

I think I just tied myself into a knot again.  

________________________________

From: pharmwaste-bounces at lists.dep.state.fl.us on behalf of Gilliam, Allen
Sent: Wed 4/18/2007 3:27 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] White House Drug Disposal Policy with list ofdrugstobe flushed

[For Mark:
http://www.whitehousedrugpolicy.gov/publications/pdf/prescrip_disposal.p
df make sure the pdf is still connected to your url.  (And it's
attached).  Deb's saying the same thing].

The "cat's outta the box" so they say.

I'm with Karin in responding to the ONDCP, FDA and EPA that this
"policy" (with a list of "flushables") is unacceptable.  It seems to
only compound the pre-existing consumer confusion. 

How many cities, counties, etc out there have already prohibited
disposal of ANY unused meds into their sewer systems, only to have this
fed office come out with a statement that seems to say, "well, there's
some phamaceuticals that are 'ok' to flush" (which like Karin mentioned,
translates to "ok, I guess all meds are ok to flush")?

If that list was provided by the manufacturers, I seriously doubt there
was any thought given to their fate and transport, not to mention
potential toxicity to aquatic life given.  The challenge has just been
given to those manufacturers.  Aren't y'all amongst us already?

Allen Gilliam
ADEQ State Pretreatment Coordinator  

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of North,
Karin
Sent: Wednesday, April 18, 2007 2:06 PM
To: drmille at blue.weeg.uiowa.edu; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] White House Drug Disposal Policy with list
ofdrugsto be flushed

Based on a conversation I had with Dr. Steven Gressit.  The list was
originally provided by the manufacturers. 

Since I work for a wastewater treatment plant we do not want anything
flushed down the toilet.  If you give people a list, they will
automatically flush everything.  I think we need to send multiple
letters of concern to FDA regarding their disposal recommendations. City
of Palo Alto has already sent a letter to ONDCP, now we plan on writing
a letter to FDA as well.  Palo Alto also plans on sending a letter to
EPA with the hope that EPA may help convince ONDCP and FDA to modify
their guidelines. 

Best,
Karin North
650-494-7629

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
drmille at blue.weeg.uiowa.edu
Sent: Tuesday, April 17, 2007 11:48 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] White House Drug Disposal Policy with list
ofdrugs to be flushed

I am concerned that an antibiotic like gatifloxacin is on the list of 
flushables.  Does anyone know of a way to learn the logic behind the 
guideline decisions?

-Daniel

--
Daniel R Miller
Student Pharmacist
Iowa City, IA 52246
319-541-7638

Quoting gressitt <gressitt at uninets.net>:

> Round one of "further evolution" of the guidelines now evident. And
fairly
> quickly for a federal agency. I suggest it is a good sign. Stevan
>
> -----Original Message-----
> From: pharmwaste-bounces at lists.dep.state.fl.us
> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
> DeBiasi,Deborah
> Sent: Thursday, April 05, 2007 4:45 PM
> To: pharmwaste at lists.dep.state.fl.us
> Subject: [Pharmwaste] White House Drug Disposal Policy with list of
drugs to
> be flushed
>
>
http://www.whitehousedrugpolicy.gov/publications/pdf/prescrip_disposal.p
> df
>
>
>
> Deborah L. DeBiasi
> Email:   dldebiasi at deq.virginia.gov
> WEB site address:  www.deq.virginia.gov
> Virginia Department of Environmental Quality
> Office of Water Permit Programs
> Industrial Pretreatment/Toxics Management Program
> Mail:          P.O. Box 1105, Richmond, VA  23218 (NEW!)
> Location:  629 E. Main Street, Richmond, VA  23219
> PH:         804-698-4028
> FAX:      804-698-4032
>
> _______________________________________________
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