[Pharmwaste] FW: FDA's website guidance conflicts with ONDCP's new program

[Volkman, Jennifer (MPCA)]

These aren't the best messages I've written and I didn't take time to look up the best address for FDA (I took it from the source view of their web page), but I think more of us need to tell/ask ONDCP and FDA to get rid of FDA's guidance that emphasizes flushing of certain medications. There is consistency between ONDCP's and EPA's guidance, but FDA must still not be convinced that collection is favorable over flushing? Maybe they are working on it? Seems silly for ONDCP to launch this big media event to promote collection when their disposal guidance links to flushing.
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From: Volkman, Jennifer (MPCA)
Sent: Monday, September 08, 2014 7:34 PM
To: oipl at ondcp.eop.gov; druginfo at fda.hhs.gov
Subject: RE: FDA's website guidance conflicts with ONDCP's new program

Hello again,
I missed this link! It shows consistency between EPA and ONDCP, but still points to the FDA’s confusing flush disposal recommendations for certain prescription medications.
http://www.deadiversion.usdoj.gov/drug_disposal/index.html

I come at this from the perspective of trying (for 20 years) to get simple information out to families so they can do their part to reduce poisoning, abuse and environmental impacts. Telling people to put all of their medications in a bag and bring them to a collection box is the simplest way to get them to take action. If they find conflicting information on the label, websites or in the instructions that come with prescriptions, they are likely to put off trying to figure out how to do the right thing. The very best result of all of this is to raise awareness and get people to act.

Thanks for all of your hard work!
JV

From: Volkman, Jennifer (MPCA)
Sent: Monday, September 08, 2014 5:57 PM
To: 'oipl at ondcp.eop.gov'; 'druginfo at fda.hhs.gov'
Subject: FDA's website guidance conflicts with ONDCP's new program

Good afternoon,
I listened in on the stakeholder Q and A today and someone asked whether ONDCP was going to update its information on flushing drugs. The ONDCP’s website actually points to the FDA’s website for disposal instructions. It is the information on the FDA’s website that needs updating:

Here is where FDA instructs people to flush certain drugs:
http://www.fda.gov/Drugs/ResourcesForYou/Consumers/BuyingUsingMedicineSafely/EnsuringSafeUseofMedicine/SafeDisposalofMedicines/ucm186187.htm#MEDICINES

I understand the original impetus for the wording of the information back in 2009. It is just something that needs to be made consistent if at all possible.

The ONDCP site at this link http://www.whitehouse.gov/ondcp/prescription-drug-abuse still refers people to the FDA website link above. If you scroll down below the graphs, it is in this paragraph, highlighted:

“What You Can Do
·        Follow disposal guidelines: No matter who you are, you can help address this issue in your home. By following the guidelines, you reduce the risk of unintentional diversion or harm. Learn how to dispose of unused medicines<http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm101653.htm>, read the frequently asked questions<http://www.fda.gov/Drugs/ResourcesForYou/Consumers/BuyingUsingMedicineSafely/EnsuringSafeUseofMedicine/SafeDisposalofMedicines/ucm186188.htm> about safe drug disposal, and get information on drug poisoning<http://www.cdc.gov/HomeandRecreationalSafety/Poisoning/brief_full_page.htm>.”

The simplest thing might be for you to delete that paragraph because the one you have below it works just fine:
“Take advantage of community take-back programs: Call your city or county government's household trash and recycling service hazardous waste program, or your local police or sheriff's department to see if a take-back program is available in your community.”

You could update it with a note that you’ve revised rules so that pharmacies may be able to collect medications in the future, once state and local laws are sorted out. Don’t send people to pharmacies yet!!!

The FAQs posted by FDA are also in need of updating:
http://www.fda.gov/Drugs/ResourcesForYou/Consumers/BuyingUsingMedicineSafely/EnsuringSafeUseofMedicine/SafeDisposalofMedicines/ucm186188.htm

This is what the MPCA’s website tells people to do:
http://www.pca.state.mn.us/index.php/living-green/living-green-citizen/household-hazardous-waste/disposing-of-unwanted-medications.html

Please let me know what the plan is for an update.

Thank you!

Jennifer Volkman
Statewide HHW Program Coordinator
Minnesota Pollution Control Agency
651-757-2801
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