[Pharmwaste] RE: Federal Government (& Florida) drug disposal
guidance - room for modification; landfill fate and risk uncertainty
Price, John L.
John.L.Price at dep.state.fl.us
Mon Feb 26 11:06:44 EST 2007
Pete: Thanks for the feedback. You raise several familiar and thorny issues
that are subject to ongoing research and discussion. Your post furthers
those important discussions.
As you emphasize, the important thing is to have the best answer -and a
concrete one - for someone inquiring about "What do I do with these pills?"
There is plenty of room in for tweaking or even significantly modifying
disposal guidance to meet local, state or regional concerns and disposal
options. Like better privacy protection, e.g., remove the label instead of
crossing/scratching out patient name. Maybe more complete, bombproof
rendering the medications unrecognizable, unusable. Coffee grinds and kitty
litter are just examples of what could be used to do this. USED kitty litter
isn't among the ones I thought of but ...yeah, that would work! Crushing,
mixing and holding your nose would definitely eliminate the possibility of
intentional or unintentional misuse.
There is still work to be done to understand the fate of pharmaceuticals in a
landfill. I don't think we can assume that the pharms stay in their original
chemical forms during their entire landfill lifetime and report directly to
the leachate. Or that their landfill transformations would be as harmful as
their original formulations. There is research going on right now to look at
the biochemical transformations (or lack thereof) in a simulated landfill;
whether the pharms or their transformations actually report to the leachate
and, if so, what fraction gets there (5%, 95%?) or whether some fraction is
sequestered (immobilized) in the landfill. See Musson/Townsend's work at
http://www.dep.state.fl.us/waste/quick_topics/publications/shw/meds/FateOfPha
rmaceuticalsInLandfillTownsendandMusson1206.pdf.
There is also ongoing uncertainty about what concentrations of which
compounds in our surface water or drinking water have adverse impacts on our
species and other species. We do need to consider the possibility that we
and other species can live with certain concentrations of certain compounds
in our surface and drinking water. We need to have risk analysis
methodologies that permit us to set these maximum concentrations with a
comfortable level of certainty. And to evaluate the risks of combinations -
chemical cocktails. I have seen some work on this very complex problem.
Absent a robust risk analysis that tells us that we can live with the
compound/combination/concentration, we do need to use caution - also known as
precaution - and assume there could be a risk. We also need to understand
that we will never get to zero. By disposing of unused medications in the
trash (landfill or combustion), we at least are not adding to the
environmental burden as quickly or directly as flushing does. That concept of
"don't add to the problem" is the genesis of our guidance on disposal. It is
a simple and cost effective step that we can take until we know whether we
need to adjust wastewater treatment standards and technologies or modify
wastewater treatment sludge disposal, e.g., prohibit or restrict land
application of sludge. Or whether we need to push harder for medication
delivery modifications that ensure more efficient uptake of the pharm and
less pass through when we take them. Another tough issue in these "next
steps" considerations is which of these much harder steps give us the best
return on the investment of our limited resources. And which can we actually
afford to do, given the competing demands for governmental funds.
If you want to discuss further, please give me a call. I would appreciate
hearing your thoughts. It's a bit clunky doing that via email and, as you
see, I can get longwinded.
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 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
issuesdrug 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/DEPMedica
tionDisposalFlyer111706Final.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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