[Pharmwaste] FW: New York Times Article on Alameda County Ordinance and Pharma Disposal

Volkman, Jennifer (MPCA) jennifer.volkman at state.mn.us
Tue Dec 11 16:34:48 EST 2012


Hey, I got this from a friend and I'm not sure if the list serve has seen it...apologies if it is old news...

Hi Jennifer,

If you haven't already seen it, this study (attached) from the "start" project in Germany takes a good comprehensive look at the problem - providing some good indications on how to attack the issue on the front and back of the product lifecycle.

As you mentioned, there are up-front issues with the 1-year expiration windows and we would be wise to stem  unnecessary creation of waste through providing greater quantities than are needed. The take-away is that it is a system of interventions that will rein in the problem, and end-of-life handling is of course part of that - it will always be there.

The important thing I noted (on page 7) is that active ingredients that are completely metabolized in the body take an express route into the water system when improperly disposed. The claim that excretion is the primary path for introduction is used to justify inaction on take-back. The rebuttal to that is, even though only a few percent of pharmaceuticals reach the environment through the household toilet or sink - those that are disposed in that way have an outsize impact because they have not been degraded by metabolism. It strikes me as a dereliction of duty to turn a blind eye a clear waste issues that can be addressed with endeavor (witness the very successful Canadian pharma take-back programs - it can be done).

Regarding the overall sentiment of industry that correlation is a pretext for action ("there's no proof it works") the discussion of the precautionary principle (on pages 15-16) is profound. As it pertains to take-back programs, their validity certainly can be judged by their cost relative to potential harm, even if knowledge is developing - take-back programs in all 50 states funded fully by the pharmaceutical industry would create a yearly tab equal to 0.5% of the industry's $19 billion annual MARKETING budget.  (I arrived at this number by taking the per capita cost of the British Columbia program, and then Doubled it for good measure). Put in this context, I think taking this ounce of prevention is a worthwhile minimum endeavor to pursue while advancing the science and a comprehensive strategy concurrently.

Urged on by government, the industry takes action in Canada and the EU (the largest single market in the world) to address end-of-life, yet healthy profit margins endure. To portray it (as the industry attempts in CA) as something specious, onerous, full of unintended consequences, etc. - is just not supported by the facts.

----------------------------------------------
Subject:	RE: New York Times Article on Alameda County Ordinance and Pharma Disposal

Sarah and all,

It is highly unlikely that we'll ever have information that directly correlates collection to a reduction in measurable pharms in the environment. We do know that excretion is a large and continuous source of contamination. We cannot ferret out a percentage related directly to intentional sewering by households. Manufacturers and the healthcare industry are allowed to sewer pharms/metabolites/chemicals.

Then we have animal use to consider, which could also be a substantial source since they consume 70% of the antibiotics/growth enhancers sold in the US. I've read varying reports showing that composting manure results in a reduction of pharms and metabolites being present in land applied manure, but there is plenty that isn't captured or composted. There is a study from the U of M that shows measurable levels of pharms in root vegetables that have received manure from medicated livestock.

People on the national Pharm Waste list serve have been asking this question for years and we can't get to it. There are conflicting estimates of how many pharms are wasted by people: from 5% to 50%. Now that it is popular to give everything a one year expiration date, there will be more wasted.

This is a typical problem we encounter when we try to justify separate management and education related to any toxic or dangerous wastes--you can't show who didn't die because you raised awareness and collected several thousand pounds of drugs or mercury or gasoline. You can't show that all of the education you've done has made people store and manage pharms differently to make everyone safer and to reduce what is sewered. You can get at behavior change with surveys (before and after), but they are costly and rarely done. The best option might be to look at whether pharm related poisonings start to go down since they are well documented. Fighting against that is our increased consumption/storage of all types of OTC and prescribed pharms...

We should get some really good data in February, if people report as we've directed them to... Collection took off at the end of 2011 and 2012, so reports should show that thousands of pounds of pharms were captured and properly incinerated. This data is also limited. Because drop boxes are unattended, we can't show the number of people who have used them. Because no one sorts the collected pharms, we can't show how many pound of CS vs. non-CS are captured. We do have national averages that we can apply to total pounds collected to get rough estimates.

There was a study commissioned by one of the manufacturers to do an assessment of the carbon footprint or overall environmental benefit of separate collection of pharms compared to trash disposal.  Surprise, it said trash disposal was better. I believe it treated drop offs as individual events vs.
just one of the many errands you are out and doing. I actually like this type of a study because it does get you thinking about all we do to separately manage wastes and it points back to retail and greater planning needing to be done between retail and manufacturers to coordinate an efficient cradle to cradle management system.

Anyway, here in MN we laid out all of the cards and we did that from the start. Because not every county has collection available and because some garbage goes straight to incinerators, we still include trashing in our guidance. It is better than sewering or keeping them in cabinets till kids/neighbors/relatives find them. And yes I know the website still needs work.

We deliberately involved the DEA and Board of Pharmacy in our discussions to develop a program for MN that would allow collection of all pharms. We were also lucky that we had the Champion to talk law enforcement into the benefits of collection. We developed a reasonable level of regulation and registration process for collectors that allows us to continue to communicate with them. We were also very aware of the data from poison control on the high percentage of poisoning related to pharms. By considering all of these issues, we (everyone involved) created a collection system in MN that, to the best of our abilities, does the following:

1) Educates the public on safe storage: prevent poisoning, theft and get rid of what you don't need.
2) Educates the public on best disposal options: some people have been hoarding for years while waiting for a disposal option that seemed right.
3) Provides an infrastructure that allows for nearly 24/7 collection in 200+ locations for ALL pharms.
4) Provides for data collection on number of pounds collected and number of opportunities available.
5) Reduces the likelihood of poisoning, abuse and sewering of drugs as people are better educated and provided with collection opportunities.

Personally, I feel good about all of this. I feel like it was the right approach, a better approach than what many states could muster. But alas, I can't say the fish are safe yet either.

JV

oh, and, my opinion, the sentence on collection points becoming targets is just another unsubstantiated party line from those who will not share the burden. Right now people are getting ripped off in their own homes and pharmacies are being robbed for their fresh and neatly sorted supplies. law enforcement centers... well, hmmm.  No problems have been noted in several years of drop box collection activities in several states, most located at pharmacies.


From: Sarah Hellekson 

Do we have documentation in MN yet that the take-back programs (in Hennepin County, Dakota County or the other counties) have reduced pharmaceuticals in the water?  Or to what extent the programs have reduced pharmaceuticals in the waste stream or as a public safety issue (which wouldn’t need to be the same measurement).

Did you read the last two paragraphs?

"It is also unclear whether take-back programs will help. Experts generally agree that the bigger source of pollution is urine and feces containing the remnants of drugs that are ingested, not the unused pills flushed down the toilet."

"PhRMA also argues that take-back programs will not help much with the problem of drug abuse either. Mr. Spears said that it was better to have consumers tie up unused pills in a plastic bag and throw them in the trash. That is more effective, he said, because people would not have to travel to a collection point. Such collection points could become targets for thieves and drug abusers."


Sarah Hellekson | Transit / Solid Waste Manager City of Plymouth
http://www.nytimes.com/2012/12/07/business/drug-makers-challenge-pill-disposal-law-in-california.html?emc=tnt&tntemail0=y 
New York Times
December 6, 2012
Unused Pills Raise Issue of Disposal and Risks

By ANDREW POLLACK


Brand name drug makers and their generic counterparts rarely find themselves on the same side of an issue, but now they are making an exception. They have teamed up to fight a local law in California, the first in the nation, that makes them responsible for running — and paying for — a program that would allow consumers to turn in unused medicines for proper disposal.


Such so-called drug take-back programs are gaining in popularity because of a growing realization that those leftover pills in your medicine cabinet are a potential threat to public health and the environment.


Small children might accidentally swallow them and teenagers will experiment with them, advocates of the laws say. Prescription drug abusers can, and are, breaking into homes in search of them. Unused pills are sometimes flushed down the toilet, so pharmaceuticals are now polluting waterways and even drinking water. One study found the antidepressant Prozac in the brains of fish.


Most such take-back programs are run by local or other government agencies. But increasingly there are calls to make the pharmaceutical industry pay.


“We feel the industry that profits from the sales of these products should have the financial responsibility for proper management and disposal,” said Miriam Gordon, California director of Clean Water Action, an advocacy group.


In July, Alameda County, Calif., which includes Oakland and Berkeley, became the first locality to enact such a requirement. Drug companies have to submit plans for accomplishing it by July 1, 2013.


But the industry plans to file a lawsuit in United States District Court in Oakland on Friday, hoping to have the law struck down. The suit is being filed by the Pharmaceutical Research and Manufacturers of America, or PhRMA, which represents brand-name drug companies, the Generic Pharmaceutical Association and the Biotechnology Industry Organization.


James M. Spears, general counsel of PhRMA, said the Alameda ordinance violated the Constitution in that a local government was interfering with interstate commerce, a right reserved for Congress.


“They are telling a company in New Jersey that you have to come in and design and implement and pay for a municipal service in California,” he said in an interview.


“This program is one where the cost is shifted to companies and individuals who are not located in Alameda County and who won’t be served by it.”


Mr. Spears, who is known as Mit, said that the program would cost millions of dollars a year to run and that pharmaceutical companies were “not in the waste disposal business.” He said it would be best left to sanitation departments and law enforcement agencies, which must be involved if narcotics, like pain pills, were to be transported.


Nathan A. Miley, the president of the Alameda County Board of Supervisors and the champion of the legislation, said late Thursday, “It’s just unfortunate that PhRMA would fight this because it would be pennies for them.”


“We will win legally and will win in the court of public opinion as well,” Mr. Miley said.


The battle in Alameda could set the direction for other states and localities. Legislators in seven states have introduced bills to require drug companies to pay for take-back programs in the last few years, said Scott Cassel, founder and chief executive of the Product Stewardship Institute, a nonprofit group that advocates such programs. But none of the bills have passed.


Mr. Cassel said about 70 similar “extended producer responsibility” laws have been enacted in 32 states for other products, like electronic devices, mercury-containing thermometers, fluorescent lamps, paint and batteries. He said he was not aware that any had been struck down on constitutional grounds.


The pharmaceutical industry already pays for take-back programs in some other countries. The law in Alameda is modeled partly on the system in British Columbia and two other Canadian provinces. There, the industry formed the Post-Consumer Pharmaceutical Stewardship Association, which runs the programs.


Consumers can take unused drugs back to pharmacies, from which they are periodically collected. Drug companies pay for the program in proportion to their market share, said Ginette Vanasse, executive director of the association. The program for British Columbia, with a population over four million, costs about $500,000 a year, she said.


The extent of the problem of unused pills and how best to handle them are matters of debate.


The United States Geological Survey has found various drugs, including antidepressants, antibiotics, heart medicines and hormones, in waterways it has sampled. Sewage treatment plants and drinking water treatment plants are not meant to remove pharmaceuticals.


Still, it is not known what effect the chemicals might have. “It’s a hard-to-pin-down problem,” said Sonya Lunder, a senior analyst at the Environmental Working Group, an advocacy group. It is thought that trace amounts in drinking water are probably not harmful. But larger amounts found in wastewater could be having an impact on wildlife.


It is also unclear whether take-back programs will help. Experts generally agree that the bigger source of pollution is urine and feces containing the remnants of drugs that are ingested, not the unused pills flushed down the toilet.


PhRMA also argues that take-back programs will not help much with the problem of drug abuse either. Mr. Spears said that it was better to have consumers tie up unused pills in a plastic bag and throw them in the trash. That is more effective, he said, because people would not have to travel to a collection point. Such collection points could become targets for thieves and drug abusers.

Disclaimer: Information in this message or an attachment may be government data and thereby subject to the Minnesota Government Data Practices Act, Minnesota Statutes, Chapter 13, may be subject to attorney-client or work product privilege, may be confidential, privileged, proprietary, or otherwise protected, and the unauthorized review, copying, retransmission, or other use or disclosure of the information is strictly prohibited. If you are not the intended recipient of this message, please immediately notify the sender of the transmission error and then promptly delete this message from your computer system.   
-------------- next part --------------
A non-text attachment was scrubbed...
Name: start_Practical_Guide.pdf
Type: application/pdf
Size: 1490759 bytes
Desc: start_Practical_Guide.pdf
Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20121211/5978fac0/start_Practical_Guide-0001.pdf


More information about the Pharmwaste mailing list