Pharmwaste Digest, Vol 122, Issue 2 -Subject: [Pharmwaste] How Should Drug Take-Back Work?

Copeland, Stephen Copeland.Stephen at epa.gov
Thu Dec 3 12:41:15 EST 2015


I, too, strongly disagree with John Murphy ( Assistant general counsel, Pharmaceutical Research and Manufacturers of America), especially:
"mandated take-back programs will increase the burden on the environment, because individuals will have to travel to drop-off sites and a completely new waste disposal infrastructure will have to be created. Collecting medicines in identifiable drop-off sites will also increase the risk for diversion of medicines for drug use disorders."

If Mr. Murphy is referencing climate change effects of persons driving to drop-off sites being more environmentally harmful than effects on our water by pharmaceuticals that cannot be treated at existing wastewater treatment plants, I believe that there is no comparison.  If this is what he is referencing, he is sadly mistaken.  As Ed Gottlieb correctly stated;-

 1. With EPR, most drop offs will be at pharmacies where the environmental burden of travel will generally be non-existent since drop off will almost always be combined with shopping trips.
2. Infrastructure costs, such as drop boxes and warehouses, will be moderate and can be amortized over many years.
3. Collecting medications in identifiable drop-off sites will decrease the risk of diversion. It is well established that the majority of prescription medications that are illegally diverted are obtained from homes. As take back programs reach additional communities and become more convenient, increasing amounts of unwanted medications will be removed from homes and easy access.

Stephen G. Copeland
NPDES Permits Branch (3WP41)
Water Protection Division
1650 Arch Street
Philadelphia, PA 19103-2029

(215) 814-5792
e-mail:- copeland.stephen at epa.gov

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of pharmwaste-request at lists.dep.state.fl.us
Sent: Thursday, December 03, 2015 12:05 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: Pharmwaste Digest, Vol 122, Issue 2

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Today's Topics:

   1. Re: Pharmwaste Digest, Vol 122, Issue 1 (Lawernce Kenemore Jr.)


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Message: 1
Date: Wed, 02 Dec 2015 17:45:01 +0000
From: "Lawernce Kenemore Jr." <ldkjr100 at gmail.com>
Subject: [Pharmwaste] Re: Pharmwaste Digest, Vol 122, Issue 1
To: pharmwaste at lists.dep.state.fl.us
Message-ID: <1449078302707-af3bb0cb-87e129ae-18e35c19 at mixmax.com>
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Recent study shows strengthening state tools prevents drug abuse. Great read: Strengthening state tools to prevent prescription drug abuse PDMPs are state-run electronic databases that provide data on controlled substance prescriptions, which can be used to identify drug-seeking behaviors (e.g. catalyst.phrma.org


On Tue, Dec 1, 2015 at 11:01 AM, < pharmwaste-request at lists.dep.state.fl.us > wrote:
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Today's Topics:

1. How Should Drug Take-Back Work? (Ed Gottlieb) 2. Re: How Should Drug Take-Back Work? ( hksanborn at comcast.net )


---------- Forwarded message ----------
From: Ed Gottlieb <EGottlieb at cityofithaca.org>
To: "pharmwaste at lists.dep.state.fl.us" <pharmwaste at lists.dep.state.fl.us>
Cc:
Date: Mon, 30 Nov 2015 19:36:41 +0000
Subject: [Pharmwaste] How Should Drug Take-Back Work?
California Healthline "Think Tank" discussion: How Should Drug Take-Back Work?
http://www. californiahealthline.org/ think-tank/2015/how-should- drug-takeback-work

Overview story then three panelists provide their opinions.

I strongly disagree with John Murphy ( Assistant general counsel, Pharmaceutical Research and Manufacturers of America), especially:
"mandated take-back programs will increase the burden on the environment, because individuals will have to travel to drop-off sites and a completely new waste disposal infrastructure will have to be created. Collecting medicines in identifiable drop-off sites will also increase the risk for diversion of medicines for drug use disorders."
I venture to say that the other panelists would have offered rebuttals, similar to the following, if they had been given the chance.

1. With EPR, most drop offs will be at pharmacies where the environmental burden of travel will generally be non-existent since drop off will almost always be combined with shopping trips.
2. Infrastructure costs, such as drop boxes and warehouses, will be moderate and can be amortized over many years.
3. Collecting medications in identifiable drop-off sites will decrease the risk of diversion. It is well established that the majority of prescription medications that are illegally diverted are obtained from homes. As take back programs reach additional communities and become more convenient, increasing amounts of unwanted medications will be removed from homes and easy access.

Ed Gottlieb
Chair, Coalition for Safe Medication Disposal Industrial Pretreatment Coordinator Ithaca Area Wastewater Treatment Facility
525 3 rd Street Ithaca, NY 14850 (607) 273-8381 fax: (607) 273-8433

---------- Forwarded message ----------
From: hksanborn at comcast.net
To: Ed Gottlieb <EGottlieb at cityofithaca.org>
Cc: "pharmwaste at lists.dep.state.fl.us" <pharmwaste at lists.dep.state.fl.us>
Date: Mon, 30 Nov 2015 11:45:46 -0800
Subject: Re: [Pharmwaste] How Should Drug Take-Back Work?
Ed- we did not know who else was asked to respond and I agree with your response to the pharma quote. I hope people post this comments on the Healthline website as that is where health industry workers will see them. Heidi

Sent from my iPhone
On Nov 30, 2015, at 11:36 AM, Ed Gottlieb < EGottlieb at cityofithaca.org > wrote:

California Healthline "Think Tank" discussion: How Should Drug Take-Back Work?
http://www. californiahealthline.org/ think-tank/2015/how-should- drug-takeback-work

Overview story then three panelists provide their opinions.

I strongly disagree with John Murphy ( Assistant general counsel, Pharmaceutical Research and Manufacturers of America), especially:
"mandated take-back programs will increase the burden on the environment, because individuals will have to travel to drop-off sites and a completely new waste disposal infrastructure will have to be created. Collecting medicines in identifiable drop-off sites will also increase the risk for diversion of medicines for drug use disorders."
I venture to say that the other panelists would have offered rebuttals, similar to the following, if they had been given the chance.

1. With EPR, most drop offs will be at pharmacies where the environmental burden of travel will generally be non-existent since drop off will almost always be combined with shopping trips.
2. Infrastructure costs, such as drop boxes and warehouses, will be moderate and can be amortized over many years.
3. Collecting medications in identifiable drop-off sites will decrease the risk of diversion. It is well established that the majority of prescription medications that are illegally diverted are obtained from homes. As take back programs reach additional communities and become more convenient, increasing amounts of unwanted medications will be removed from homes and easy access.

Ed Gottlieb
Chair, Coalition for Safe Medication Disposal Industrial Pretreatment Coordinator Ithaca Area Wastewater Treatment Facility
525 3 rd Street Ithaca, NY 14850 (607) 273-8381 fax: (607) 273-8433 ---
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End of Pharmwaste Digest, Vol 122, Issue 2
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