[Pharmwaste] Comment on ONDCP's 2013 National Drug Control Strategy by 7/20

[Lucy, Burke]

Speaking of minimizing drug prescriptions...

FDA introduces new safety measures for extended-release and long-acting opioid medications
http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm310870.htm?source=govdelivery
"The U.S. Food and Drug Administration today approved a risk evaluation and mitigation strategy...part of a federal initiative to address the prescription drug abuse, misuse, and overdose epidemic."

Burke


Mr. Burke Lucy
Integrated Waste Management Specialist
Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street, PO Box 4025
Sacramento, CA 95812
Burke.Lucy at CalRecycle.ca.gov<mailto:Burke.Lucy at CalRecycle.ca.gov>
916.341.6592

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Zimmer, Catherine (PSC)
Sent: Monday, July 09, 2012 8:34 AM
To: Galvin, Dave; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Comment on ONDCP's 2013 National Drug Control Strategy by 7/20

Hi Dave and all,
Dave, thank you for the prompt and summary re: ONDCP's comment period.  I would add that the best way to minimize drug waste is to minimize drug prescriptions.  So, including language to support CMS' recent ruling regarding pro-rated copays for trial prescriptions and advocacy for non-drug interventions is a key tool to minimizing waste and the risk of diversion.


Very truly yours,

Catherine Zimmer, MS, BSMT
Industry Leader, Environmental and Regulatory
PSC Healthcare Services
Office:  651.645.7509
Mobile: 713.829.6365
www.pscnow.com<http://www.pscnow.com/>
Catherine.zimmer at pscnow.com<mailto:Catherine.zimmer at pscnow.com>

Live green now!
Reduce, reuse, repair, recycle.



From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us]<mailto:[mailto:pharmwaste-bounces at lists.dep.state.fl.us]> On Behalf Of Galvin, Dave
Sent: Monday, July 09, 2012 10:21 AM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] Comment on ONDCP's 2013 National Drug Control Strategy by 7/20

A reminder that the White House Office of National Drug Control Policy is soliciting input for its 2013 update to the National Drug Control Strategy.  Comments are due by July 20, 2012.  Comments can be entered on-line at  http://www.whitehouse.gov/ondcp/2013strategycomments or sent via email to 2013Strategy at ondcp.eop.gov<mailto:2013Strategy at ondcp.eop.gov> .

The 2012 National Drug Control Strategy (available here: http://www.whitehouse.gov/sites/default/files/ondcp/2012_ndcs.pdf ) references the separate Prescription Drug Abuse Prevention Plan issued in April 2011 (available here: http://www.whitehouse.gov/sites/default/files/ondcp/issues-content/prescription-drugs/rx_abuse_plan.pdf ).  This latter plan includes "proper medication disposal" as one of its four main elements for reducing prescription drug abuse.  In addition to supporting take-back activities and events, the plan recommends that the federal government "...engage PhRMA and others in the private sector to support community-based medication disposal programs."

I interpret such "support" to include producer responsibility for funding take-back programs following a product stewardship model.  Neither the Secure and Responsible Drug Disposal Act of 2010 nor the pending DEA regulations to implement it contains any funding for local take-back initiatives.   We need the support of the drug manufacturers in order to create a robust take-back network that will help to reduce prescription drug abuse and protect the environment.  That's Galvin's editorial comment.

The 2012 National Drug Control Strategy references the prescription drug abuse prevention plan in its final "policy focus" section, pages 47-50.  It's whole description of proper disposal is all of two short paragraphs on page 49.

I am going to submit a comment in order to reinforce this reference and the need for a robust (safe, secure, convenient, funded) system for the take-back and proper disposal of unused medicines.  I encourage you to consider adding your own voice during this brief comment period, so that the ONDCP hears loud-and-clear that safe, adequately-funded medicine take-back is an important component of the country's drug control policy.  It's time.  We've been talking about this for nearly ten years.


n  Dave Galvin

_________________________________________________________
Dave Galvin * King County Department of Natural Resources and Parks * 130 Nickerson Street, Seattle, WA 98109-1658 * (w) 206-263-3085 * (fax) 206-263-3070 * dave.galvin at kingcounty.gov<mailto:dave.galvin at kingcounty.gov> * Local Hazardous Waste Management Program in King County * www.lhwmp.org<http://www.lhwmp.org/>

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