[Pharmwaste] Pharma industry complaint against Alameda County

Fri Dec 14 12:11:32 EST 2012

Thanks Fred, I appreciate the move to a professional discourse.  Attached
is a nice little ditty on how many stakeholders are involved really.  My
organization has personally worked with more then half of these and our
primary program, http://greenpharmedu.org/home.php  is for health
professionals- docs, nurses, and pharmacists.  That is upstream waste
minimization emphasis to prescribers.   That being said. most folks on this
list serve are not of that stakeholder group, rather, the issue has been
driven from much closer to the end of the life product cycle, how to get
waste out of the system once it is waste.  So basically, that has been the
emphasis of the conversation. For better or for worse, having conversations
that focus on the more "healthcare' set of stakeholders would better
include more representation in this group, which is currently not our
constituency.

I agree wholeheartedly with your point about 'blended' approaches. In this
case the blending happens across stakeholder groups and thus is hard to get
the view from 50,000 ft.  This product stewardship initiative is really
just a small piece of a much larger conversation, and it is hard to get a
room big enough to fit all the stakeholders.  (back to that attachment).

Have a nice weekend.

Joel

On Thu, Dec 13, 2012 at 9:43 AM, Fred Miller <millerfl at tricity.wsu.edu>wrote:

> Joel,****
>
> I fully support and work with many stakeholder communities to foster
> cradle-to-grave stewardship.****
>
> ** **
>
> Here’s what I’ve learned over the course of my employment in the
> environmental stewardship business****
>
> **1.       **An unchallenged assumption is an unproven assumption.  The
> intent of my original post was and is to stimulate critical thought
> regarding the methods and motives which drive effective hazard mitigation,
> and human health and environmental protection with respect to
> pharmaceutical materials manufacturing, distribution, and consumption.  One
> thing I know about unchallenged assumptions is they cost money and
> sometimes things more precious than money.  Where I see a specific weakness
> in the discussion to date is assumption manufacturer funded take back is
> the best way to attack the problem.  My question to one and all is whether
> that theory has been tested or whether it’s just an assumption.  If it’s
> been tested I withdraw my objections.****
>
> **2.       **When personal feelings and emotions are allowed to direct
> the conversation things usually go wrong.  I freely admit, like everyone
> else, I occasionally allow my prejudices to steer me off course. ****
>
> ** **
>
> In my years in the industry I’ve had occasion to work with systems which
> funded waste management in various ways.  Some choose to pass 100% of the
> cost to the consumer in the form of a direct charge per-unit of waste
> disposed.  Some choose to “hide” the cost by operating a “free” collection
> system where the end user has no knowledge of or control over the costs of
> the program.  Still others take a blended approach where end users pay at
> the point of purchase for waste management, and roll other related costs
> for environmental management/health protection into the “tax” levied at the
> point of sale.****
>
> ** **
>
> By far, the most effective systems I’ve ever encountered are those which
> use the blended approach.  They invest in education (product
> selection/substitution, inventory control, waste minimization, pollution
> prevention, safety, etc.), inform the consumer of the costs and explain why
> those costs are what they are, and enlist the  consumer as a member of the
> team.  They have incentives built in to encourage waste minimization while
> still providing adequately for the needs of the consumer.  What they don’t
> have are disincentives which encourage sloth and/or illicit dumping.  They
> comport with the concepts of the ISO 14000 environmental management
> standards, best management practices, and sustainability.****
>
> ** **
>
> Servus****
>
>
> Fred****
>
> ****
>
> ** **
>
> ** **
>
> *From:* pharmwaste-bounces at lists.dep.state.fl.us [mailto:
> pharmwaste-bounces at lists.dep.state.fl.us] *On Behalf Of *Joel Kreisberg
> *Sent:* Wednesday, December 12, 2012 5:16 PM
> *To:* Fred Miller
> *Cc:* pharmwaste at lists.dep.state.fl.us
> *Subject:* Re: [Pharmwaste] Pharma industry complaint against Alameda
> County****
>
> ** **
>
> I have to agree with Heidi. I'm not sure what is informing your
> "definitive" tone.    Indeed currently the "company" called consumers are
> paying for this service.  So they are invested at this point.  While the
> are many more stakeholders in healthcare then in electronics and paint, and
> indeed no one prescribes paint or cell phones, the stakeholder making the
> largest profit here is the manufacturer.  As well, pharm sales continue to
> rise about 6% a year, in part because of the for profit system.   In a
> closed system such as Kaiser, the corporation is actively working on
> reducing waste in terms of prescribing patterns and adherence patterns.  In
> the free market system, the incentive to consume and dispose begins with
> the publicly traded pharmaceutical manufacturer (look at those numbers
> Fred).  Sure the profits move down the line, but again, the biggest profit
> is up front and the smallest is sales at retail.   Yep, creating incentives
> for improving compliance and reducing overprescribing is necessary, perhaps
> these would be better invested in a for profit system if the biggest money
> makers had a cradle-to-cradle design system.  This ordinance is an attempt
> to create that structure.
>
> Its actually easier then you and manufacturers are making it out to be.
> That's why when I check with three economists I get three different
> answers, so your point isn't clear.  And your point about human
> nature--thank you for your sharing--It's helps us all in understanding what
> we are up against in our collective attempt to create an equitable system
> of ecological health.
>
> I think Heidi's point was that to date, most on this list serve were in
> support of cradle-to-cradle solutions to ecological issues.  Product
> stewardship is the current best practice, not the only solution.  At least
> for me, I'm glad you are reminding me of the hubris of human nature that is
> never far off.
>
> We'll keep working on it.
>
> Joel****
>
> On Tue, Dec 11, 2012 at 9:07 AM, Fred Miller <millerfl at tricity.wsu.edu>
> wrote:****
>
> Jennifer,****
>
> In my second paragraph I was speaking not to product stewardship but
> rather law, politics, and human nature. ****
>
>  ****
>
> You provided “Companies faced with managing their own waste invest in ways
> to reduce it” and I couldn’t agree more.  Where we differ is what
> constitutes a “company” in this problem.  I see the pool of prescribing
> professionals, dispensing outlets, and consumers as the “company” and fates
> of their wastes to be something THEY must invest in before anything else
> matters.  Where’s their incentive to do better if they’re not paying for
> waste management in a tangible way?  Hidden costs rarely influence behavior
> of such a “company” because it soon gets shuffled into the background as an
> unavoidable cost of doing business.  When it’s turned into a cost center
> they must deal with, management (consumers, physicians, pharmacists)
> suddenly start paying attention because it’s something they can control
> directly.  Don’t take my word for it.  Ask any economist.****
>
>  ****
>
> As I said, mileage may vary.****
>
>
> Servus****
>
>  ****
>
> *From:* Volkman, Jennifer (MPCA) [mailto:jennifer.volkman at state.mn.us]
> *Sent:* Tuesday, December 11, 2012 8:46 AM
> *To:* Heidi; Fred Miller; pharmwaste at lists.dep.state.fl.us****
>
>
> *Subject:* RE: [Pharmwaste] Pharma industry complaint against Alameda
> County****
>
>  ****
>
> I think Fred's first paragraph is interesting and I'm curious to see how
> this plays out.  ****
>
>  ****
>
> I don't have the energy to point out everything wrong with the second
> paragraph, but if you have no understanding of the concept of product
> stewardship, then the argument is lost anyway. Alameda was brave to stand
> up to big PhRMA. They did something that many other states and local units
> of government have been trying to do for several years. There is national
> legislation that I've heard is not likely to go anywhere, but it is there
> because people are tired of industry dumping on government and the
> taxpayers. We all know everybody pays for this, there is no away, be it
> through taxes or user fees. ****
>
>  ****
>
> Please consider the real benefits of a great product stewardship program,
> programs that are in place in other nations: the cradle to cradle system
> between manufacturers, retail and customer is maintained with no government
> "out". Companies faced with managing their own waste invest in ways to
> reduce it, to make products and components that are less toxic and which
> can be better recycled; they learn what doesn't work (over-prescription or
> wasting of certain less tolerable drugs), in this case, they develop better
> ways to deliver drugs/target a problem; they develop transport
> efficiencies. Those interested in less government should be interested in
> helping companies get their resources back to the point of manufacture for
> reuse. I've been in solid waste for 25+ years and government can no longer
> manage the waste burden. Private industry needs to step up and apply their
> fabulous brains and resources to this problem. ****
>
>  ****
>
> Nice way to step up PhRMA. They will spend more on this lawsuit than they
> would have spent on giving the program a try.****
> ------------------------------
>
> *From:* pharmwaste-bounces at lists.dep.state.fl.us [
> pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Heidi [
> Heidi at calpsc.org]
> *Sent:* Monday, December 10, 2012 6:25 PM
> *To:* Fred Miller; pharmwaste at lists.dep.state.fl.us
> *Subject:* RE: [Pharmwaste] Pharma industry complaint against Alameda
> County****
>
> Fred – wow.  Calling Supervisor Miley and the county supervisors pandering
> politicians is completely irresponsible and unprofessional.  I’m sorry this
> type of post is allowed on this listserv.****
>
>
> Heidi****
>
>  ****
>
> *From:* pharmwaste-bounces at lists.dep.state.fl.us [
> mailto:pharmwaste-bounces at lists.dep.state.fl.us<pharmwaste-bounces at lists.dep.state.fl.us>]
> *On Behalf Of *Fred Miller
> *Sent:* Monday, December 10, 2012 1:24 PM
> *To:* pharmwaste at lists.dep.state.fl.us
> *Subject:* RE: [Pharmwaste] Pharma industry complaint against Alameda
> County****
>
>  ****
>
> After reading the filing I believe the plaintiffs will prevail on
> constitutional grounds.  Some of their other claims are suspect but the
> challenge is based upon constitutional law where they stand on fairly firm
> and clear ground.  To go back up the channel beyond the party who imports
> into a jurisdiction is clearly a violation of the ICC, and even that step
> is very likely to be slapped down.   They can’t even give
> manufacturers/distributor the option of not doing business in the
> jurisdiction without violation of the ICC.  Political subdivisions may tax
> activities which occur within their jurisdiction but they can’t reach
> beyond those geographical bounds.  To implement such a program would
> require federal action to keep from running afoul of the ICC.****
>
>  ****
>
> I believe these programs should be a function of government.  That allows
> a tax to be imposed upon retail sales within each jurisdiction which is
> clearly allowed.  As this ordinance stands, Alameda County is trying to
> grab a free ride off the rest of the nation.  Their pandering politicians
> lack the courage to tell people we all bear responsibility for what we
> consume.****
>
>  ****
>
> Fred****
>
>  ****
>
> *From:* pharmwaste-bounces at lists.dep.state.fl.us [
> mailto:pharmwaste-bounces at lists.dep.state.fl.us<pharmwaste-bounces at lists.dep.state.fl.us>]
> *On Behalf Of *Scott Cassel
> *Sent:* Sunday, December 09, 2012 4:08 AM
> *To:* pharmwaste at lists.dep.state.fl.us
> *Subject:* [Pharmwaste] Pharma industry complaint against Alameda County**
> **
>
>  ****
>
> Thanks to one of our members for the attached  11-page complaint filed in
> federal court by PhRMA, GPhA, and BIO against Alameda County's Safe Drug
> Disposal Ordinance. The lawsuit provides a concise summary of the law. It
> is also a broad rebuttal against the concept of producer responsibility,
> arguing that drug-take back programs should be a government function. ****
>
>  ****
>
>  ****
>
> ____________________________
> *Scott Cassel*****
>
> Chief* *Executive Officer/Founder
> *Product Stewardship Institute, Inc.*
> 29 Stanhope Street
> Boston, MA 02116
> 617-236-4822 (ph)
> 617-236-4766 (fax)
> scott at productstewardship.us
> www.productstewardship.us****
>
> P Please consider the environment before printing this email****
>
> *Click to follow us on **Facebook*<http://www.facebook.com/pages/Product-Stewardship-Institute/224328115936?ref=ts>
> * and **Twitter* <http://twitter.com/productsteward> *and* *Blog<http://productstewardshipinstitute.wordpress.com/>
> * ****
>
>
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>
> -- ****
>
> Dr. Joel Kreisberg, DC, MA, CCH
> drkreisberg.com
> teleosis.org <http://www.teleosis.org>
> foundation.metaintegral.org/centers/integral-health-medicine-center
> drkreisberg at teleosis.org
> 510-558-7285 Ext 102****
>
> ** **
>

-- 
Dr. Joel Kreisberg, DC, MA, CCH
drkreisberg.com
teleosis.org <http://www.teleosis.org>
<http://www.teleosis.org/>
foundation.metaintegral.org/centers/integral-health-medicine-center
<drkreisberg at teleosis.org>drkreisberg at teleosis.org
510-558-7285 Ext 102
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