[text][html][heur] RE: [Pharmwaste] Federal Government
issues drug disposal guidance -if not that, then what?
gressitt
gressitt at uninets.net
Sat Feb 24 19:11:12 EST 2007
Here's what the Guidance does. It brings the topic up to a higher level of
public discussion if not awareness. It helps legitimize concern about the
subject. It provides a solution that begs for the 2 year time frame to get
used constructively. It serves as a challenge for us to "provide better." It
also leaves open the fact that there may very well be no one single
solution. I for one do not believe there is one singular cookie cutter
solution. They have offered encouragement for local communities to engage in
collaboration with police in addressing the drug problem with collaborative
takebacks. That is a very good thing to get the police and community not
just talking but doing something together. Too many programs of the police
initiated type get little take up in the community. This is one where the
community will bring them along. I believe that is healthy.
When I go into Irving to pay for gas there is a coffeepot with some genuine
never-seen-a-cow "flavoring cream" I can put in my coffee. So it seems to
me a little Oxycontin in with the ground is just another, might just be a
new recipe for variety. Who knows maybe Starbucks might experiment in their
labs.
What I am more concerned is the raccoon that rips up my garbage, the mice or
the failure of the landfill and the fact that the leachate is going to plow
right through our current level water treatment plants.
It will take some time to get fully organized, but a debate on the
guidelines is needed, an open debate, with more than just governmental
agencies. Though we had some initial plans for next year's conference, we
have talked and will suggest that given that there is some time for
preparation, that a significant amount of the 4th Annual Unused Drug
Disposal Conference be set up to offer that discussion with the ONDCP. We
need a review of thoughts, folks will have had time to consult within their
own local organizations and come up with a considered reply/proposal by then
( End of October in Portland Maine.) Other Federal agencies will need to be
involved, but these guidelines need the input of a broad swath of those who
have been working on this. I will be formalizing this, but ONDCP will need
feedback as well. This is an opportunity for all of us to move forward I
believe. If we approach this as more of a "congress" than a "conference" we
will be more constructive. If we recognize that last year feedback for our
conference included that there was too little time for networking and
conversation, and we do, we plan to curtail the "classroom sessions" in
order to have more dialogue, but now perhaps it should be more consensus
building as well. I welcome response to this idea either on list or
privately.
I truly believe ONDCP has given us, ourselves, 2 years ahead to do better.
To be constructive. I will continue with a few more conversational items,
not solutions.
Looking at the guidelines themselves, they don't even look like an official
document with the weight of a finished product. I trust the Drug Strategy
Document. I do not believe that the level of support for that guideline
meets what is needed for Federal cross departmental needs. Fish and Wildlife
for instance, OSHA, DOT, and I'll include the US Postal Service. SAMHSA has
it's own iron as does NIDA in this conflagration. And as the numbers on
prescription drug abuse soar from some Federal policies themselves, in my
personal opinion, there may be inter-federal agency issues that need to be
resolved. As an example I point to eh unintended ( and I do believe
unintended) consequences of Medicare Part D, with no more take backs to
pharmacies that some states had put in place and no interest to date by the
Prescription Management Programs to initiate any similar process.
I also wonder if there isn't a dearth of landfill types as opposed to water
types and hazardous waste folks ( Now I use my MD to claim ignorant outsider
status) who have spoken up on the proposals to solve the problem? I actually
don't know, but I seem to think there are more "water people" or "Household
Hazardous Waste" people writing on this list, but I'm not sure. I wonder if
Laurie knows what the balance is? I just wonder if the landfill "types" have
had their fair time to talk?
I have lost track of some people who have become disillusioned by the
unresponsiveness of one agency or another, and when I've contacted them
there is a sense of failure. A sense that the bureaucracy has tamped down
their efforts. ( I am a psychiatrist after all.) And I would like to suggest
we take this for what it is, a step in the awkward ungainly process of
maturing a project, developing a plan, and making progress.
And I take full responsibility for all I just wrote, if I offended anyone,
but I didn't mean to.
Stevan Gressitt, M.D.
207-441-0291
www.mainebenzo.org
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Pete Pasterz
Sent: Friday, February 23, 2007 4:39 PM
To: Price, John L.; rachel golden
Cc: pharmwaste at lists.dep.state.fl.us
Subject: RE: [text][html][heur] RE: [Pharmwaste] Federal Government issues
drug disposal guidance -if not that, then what?
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/DEPMedic
ationDisposalFlyer111706Final.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
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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
Check out the EcoSmart Consumer MySpace page
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