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

Thu Apr 19 11:19:57 EDT 2007

After talking to a NuCara pharmacist (www.nucara.com), they normally  
only do gels for transdermal delivery.  They have had a few requests  
for transdermal patches in the past, but do not make them due to a  
lack of efficacy data.
NuCara is a prominent compounding facility and coordinates multiple  
aspects of pharmacy, including newly conceived products which are then  
marketed to health specialists.

Hope that helps-,

Daniel Miller
-- 
Daniel R Miller
Student Pharmacist
737 Michael St #45
Iowa City, IA 52246
319-541-7638

Quoting gressitt at uninets.net:

> 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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>>
>>
>>
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>
>