[text][html][heur] RE: [Pharmwaste] Federal Government issues drug disposal guidance -if not that, then what?

Pete Pasterz PAPasterz at cabarruscounty.us
Fri Feb 23 16:39:13 EST 2007


John--
 
I agree that we have to make a concrete recommendation when asked;
however IMHO, there are problems with both the federal guidelines AND
your recommendations.   
 
First, with the Federal guidelines, not everyone has a cat or drinks
coffee [I don't].  There is really no destruction of the pills, so they
are still readily identified.  There's a risk of inadvertent depositing
the grounds/pills mix in the backyard compost.  And I'm not sure that
coffee grounds are a sufficient deterrent to a prescription drug addict;
it would have to be WAY MORE disgusting [cat litter MAY be, if its USED,
but the Federal Guidelines do not specify].
 
With your FL guidelines, I also have concerns about patient
confidentiality if the information is just crossed out and the label NOT
removed.   And, although I'm sure prescription drug abusers know what
the pills they are targeting look like, I'm uncomfortable in having a
billboard on the containers saying "Oxycontin in Here".
 
I DO like your idea of dissolving the pills, but expanded more fully, so
that they are TOTALLY dissolved into newspaper, paper towel, shredded
paper, old rags, etc.    
 
I don't like the packaging from either the Federal or FL guidelines.
The problem with the FL recommendation is that the vial is not water
tight, and the duct or packaging tape will not make it so.  The amber PP
vials are also brittle, cracking easily under pressure when the coffee
can gets crushed around it, or the snap-on flimsy lid pops off and it
falls out [I DO like detergent bottle, but with more prep; see below].
This means it can LEAK into the rest of the trash, and thus become part
of the ooze coming out of the garbage truck onto streets and into
rivers, or become leachate in a landfill [obviously not an issue if your
community uses an incinerator, but most of US trash is still
landfilled].   Leachate is treated at POTWs, and we know they are
largely ineffective in treating drugs.
 
The problem with Fed guidelines is similar...the plastic bags break
easily under pressure of a compacting trash truck or the compaction
equipment at landfills, resulting in the same problems listed above.
And if the bag [or vial] should survive the compaction upon deposit,
they can still degrade and break over time under increasing pressure of
trash piled on top...the dirty little secret of "dry tomb
landfills"...EPA says they will all leak in time...maybe 30 - 60 years,
after the financial responsibility of the owner has ended, and long
after most remember that the land WAS and landfill.   This means a
encapsulate drug which has not leached upon deposit becomes a
"timed-release" drug dose to groundwater.
 
So, you're probably wondering what I suggest....here goes [while holding
my nose]:
 
1] Crush and mix all pills/liquids together onto absorbent such as
napkins, kleenex, papertowels, newspaper, shredded paper, cat litter,
rags, etc... with just enough water to dissolve them into paste.
2]Place absorbent/paste mix into a locking plastic bag, squeeze out
excess air, and seal.  3]Place bag into second plastic locking bag ,
squeeze excess air, seal   4]Place into old detergent bottle, squeeze
excess air, and replace cap  5]Discard inconspicuously in trash   DO NOT
FLUSH OR POUR DOWN DRAIN
 
Yes, this is also subject to breaking under pressure, but it's less
likely because of the toughness of the detergent bottle, the double
bagging and removing the "popping balloon" effect by squeezing out the
excess air.   It also addresses the issue of palatability of the drugs
by addicts or by children.   It still CAN leak, but this reduces the
risk/buys more time...
 
I'm not sure this passes the "Convenience Test"  that Rachel has raised
so that people would be deterred enough just to flush...but I see it as
an interim recommendation while we work toward Producer
Responsibility/changes in Drug Law to allow for better return and
recycling solutions.
 
Pete Pasterz
Cabarrus County HHW
Concord, NC


________________________________

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Price,
John L.
Sent: Friday, February 23, 2007 2:19 PM
To: rachel golden
Cc: pharmwaste at lists.dep.state.fl.us
Subject: [text][html][heur] RE: [Pharmwaste] Federal Government issues
drug disposal guidance -if not that, then what?



Rachel: I appreciate your critique and thoughts about this.  Not sure
I'm with you on the "First of all" but I would concur with you on the
"Second."  And I agree that this guidance does not completely
acknowledge or address this "enormous issue." I do find it to be a step
in the right direction, though.

 

May I ask, however, what DO you recommend as practical guidance to the
general public's inquiries if not this?  From where I sit, we cannot
answer inquiries about "What should I do with my unwanted
pharmaceuticals" with "Well, we aren't sure what you should do, but
don't do this."  That's an incomplete answer. People who want to do the
right thing, and ask us what that is, need to be given our best guidance
based on what we know that, while not perfect, easy, etc., allows them
to do SOMETHING positive or at least SOMETHING less negative.  In my
opinion, that's what fostering public buy-in to environmental protection
is all about - empowering people to help in some small or big way.

 

I have attached our agency's answer to inquiries about "What should I do
with my unwanted pharmaceuticals?"  Also, find at
http://www.dep.state.fl.us/waste/quick_topics/publications/shw/meds/DEPM
edicationDisposalFlyer111706Final.pdf. 

 

Thanks for the post and for any feedback to mine.

 

Jack.

 

John L. (Jack) Price

Environmental Manager

Hazardous Waste Management MS 4555

Florida Department of Environmental Protection

2600 Blair Stone Road

Tallahassee, FL  32399-2400

Phone:850.245.8751

Fax: 850.245.8811

john.l.price at dep.state.fl.us

www.dep.state.fl.us/waste

Please Note:  Florida has a very broad public records law.  Most written
communications to or from state officials regarding state business are
public records available to the public and media upon request.  Your
e-mail is communications and may therefore be subject to public
disclosure.

________________________________

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of rachel
golden
Sent: Friday, February 23, 2007 12:06 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Federal Government issues drug disposal
guidance

 

Concerning the Federal Government Drug Disposal Guidance...

I'm not quite sure where to begin...

First of all, the fact of the matter is that people just won't do this.
The folks who are calling our organizations and asking about how they
can safely dispose of their drugs are not representative of the overall
population, and I don't even think all of them would go through the
trouble of mixing their drugs in coffee grounds or cat litter.  This is
not a realistic solution, or even a realistic temporary solution.  It
might be a way to remove any responsibility from themselves, but it in
no way gets us closer to a solution.

Second, is this the actual guidance document that the public is supposed
to get their information from?  Please tell me it's not, and that the
writers of this guidance document are currently working with educators
to craft the actual public document.  The reading level is not
appropriate for the general public.  Most material for the public is
written at a 6th to 8th grade reading level.  The bulleted points in the
drug disposal guidance document are at a 12th grade reading level.  I
also would not recommend one of the bullet points reading, "Flush
prescription drugs down the toilet only if..."  This guidance document
is needed specifically to let people know NOT to flush their drugs, an
action that was once recommended, so giving guidance that phrases
flushing in positive terminology will only confuse people.

This is an enormous issue that I think will require law changes as well
as the public being educated to think about waste and disposal in an
entirely new framework.  I don't think the guidance document even begins
to acknowledge this.

Sincerely,
Rachel Golden

-- 
Rachel Golden
Adult Environmental Education Program Manager
Office of Environmental Education
NC Department of Environment and Natural Resources
1609 Mail Service Center, Raleigh, NC 27699-1609
919-733-0711 (phone) 919-733-1616 (fax)
rachel.golden at ncmail.net
www.eenorthcarolina.org

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