[Pharmwaste] re: do flush list

[Volkman, Jennifer]

I agree with Jen, I heard the FDA representative talk during the
national dialogue and it was clear that they didn't base the list on any
science and they have not responded, to my knowledge, to the request by
that group to provide methodology.  In MN we also stick by our own
guidance-sewer nothing.  

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jackson,
Jennifer
Sent: Wednesday, January 14, 2009 12:40 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] re: do flush list


Hi everyone,

Just a note that the "do flush" list was not based on any science that
it is environmentally preferable to flush those compounds. In fact,
wastewater agencies were not consulted when that original guidance was
developed. The list results from the FDA, based on those pharmaceuticals
for which the manufacturer was required to label the bulk packaging (not
on the dispensed consumer prescription bottle but the package going to
the pharmacy) with a flush message, mostly due to addictive or toxic
properties. 

The many stakeholders participating in the National Dialogue on
Pharmaceuticals in the Environment through the Product Stewardship
Institute agreed that as a group we would request that ONDCP remove the
list from the guidance, as ONDCP, FDA and EPA (maybe others?) are
reviewing the guidance together and there may be changes to it in the
near future. Your agency may wish to send a letter, too.

Furthermore, the guidance is just that -- guidance -- and not law. There
is no requirement that those meds be flushed. California wastewater
agencies are not using the guidance and have embraced a No Drugs Down
the Drain message and then encourage disposal at special events, ongoing
collection sites or the trash.

Jen Jackson  |  Resource Recovery & Pollution Prevention Programs | East
Bay Municipal Utility District  |  510.287.0818 | jacksonj at ebmud.com  
 
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