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

Thu Apr 19 10:24:42 EDT 2007

Dan, Thanks for providing this. Hazarding a comment, the fact that
hydrocodone is not mentioned is that it is "generic" and the package
insert of Oxycontin and the publicity around the abuse of a brand name
drug are what singled it out. On pharmacological grounds the only
difference might be something you could comment on, the impact of
excipients, dyes and binders as well as coatings. Those have not realy
been addressed, nor the transfer agents in patches ( that move the API
across the dermal barrier.) It is h ard for me to think that the transfer
agents haven't some significance since they have such a significant role
in the drug deliver system ( thepatch regardless of active ingredient.)
And now for fun, there has been explosive growth in compounding
pharmacies, do they generate any patch formulations?

Stevan Gressitt, M.D.
207-441-0291

> Hi everyone!
>
> I thought I would try to give back to the list-serve with this
> information regarding the products and possibly why they want to flush
> them.
>
> Oxycodone and Hydrocodone are the most abused Rx drugs in the US (to
> my knowledge from the many substance abuse lectures I've dealt with).
> Oxycodone tablets are mentioned but NOT hydrocodone.  I'm unsure why.
>
> The transdermals are listed due to the fact that if one doesn't fold
> up the patch EXACTLY right, it can get onto a pet/wildlife/child and
> legal issues would ensue.  Flushing is an easy-out for the drug
> companies.  But I'm pretty sure the patches aren't meant to be
> biodegradable, seeing as the Duragesic patch alone must stay on a
> person for 3 whole days, showers and everything.
>
> Xyrem is quite rare.  Limited clinical use for a GHB-derivative.
>
> The others are newer oral dosage forms of some very strong opiates.
> The DEA obviously wants no risk with those items.
>
> Now the interesting part:
>
> Gatifloxacin is a high-potency antibiotic pretty new to the market,
> with very little resistance reported so far.  Fluoroquinolones are
> highly effective antibiotics, but drug-class resistance is a problem
> and occurs quickly in the bugs.  This drug is like a big-gun and
> dumping it down the toilet goes against resistance-prevention logic.
> However, it is primarily excreted unchanged in the urine, so using the
> medicine at all pretty much puts it in the sewers...
>
> Baraclude Tablets (entecavir), Reyataz Capsules (atazanavir sulfate),
> Zerit for Oral Solution (stavudine) are all anti-HIV meds.  I can't
> even guess why they should be flushed.
>
> So I agree that the list is lacking in cohesion.  Thank you, everyone
> who is working to get this list altered or removed.
>
>
> -Daniel Miller
>
> --
> Daniel R Miller
> Student Pharmacist
> 737 Michael St #45
> Iowa City, IA 52246
> 319-541-7638
>
>
> Quoting "Volkman, Jennifer" <Jennifer.Volkman at state.mn.us>:
>
>> 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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>>>
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>>
>>
>>
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