[Pharmwaste] what federal agencies actually say about medicine disposal

Mon Apr 11 12:44:27 EDT 2016

Good news that it appears that contradictory program has quietly been phased
out.

In the past, the USFWS had an educational program called SMARxT Disposal
that was a partnership with PhRMA and APhA.  Many members of this listserv
will remember that a large number of agencies and organizations joined in a
sign-on comment letter sent to U.S. FWS in 2011 asked them to promote the
use of medicine take-back programs to align their disposal guidance with
that of other federal agencies as well as state and local agencies.

A December 2011 letter <http://www.takebackyourmeds.org/usfws-letter>  from
an Assistant Director at U.S. Fish & Wildlife Services, responding to our
comment letter, confirmed:

"...we have always maintained that the campaign's existing guidance should
be considered interim due to new potential advances in science and new
policy developments.  As you have accurately described, our sister agencies
are now promoting the use of medicine take-back programs as the safest
method for disposal of leftover medications, and they recommend trash
disposal only if a take-back program is not available.  Given these
developments and the fact that the Administration has elevated the
medication disposal issue as a public health concern, we are bringing the
SMARxT Disposal campaign up-to-date with the current guidance and encourage
the use of medicine take-back programs where available, while clarifying
that disposal of unwanted medicines in the household trash is a transitional
measure until drug take-back systems are available to all communities."

The American Pharmacists Association website
<http://www.pharmacist.com/apha-advocacy-issues>  also recommends medicine
take-back to combat prescription drug abuse:

APhA supports legislative, regulatory, and private sector efforts that
address prescription drug abuse, misuse and treatment.  We acknowledge that
any effort must balance the need for patient/consumer access to medications
for legitimate medical purposes with the need to prevent diversion and
abuse.  Pharmacists' knowledge, accessibility, and expertise, puts them in a
unique position to help combat this epidemic.  APhA believes prescription
drug abuse should be addressed using multipronged approach that includes
medication-assisted treatment, abuse-deterrent formulations, access to
treatment, integrated prescription drug monitoring programs, guidelines, and
access to prescription drug take back receptacles and programs.

Interestingly and confusingly, the domain name
http://www.smarxtdisposal.net/  has been taken over by a Japanese marketing
firm.  In recent months, it's been advertising steroids for body building
(ironically) and now loans for debt relief.  

Margaret Shield, PhD

Community Environmental Health Strategies, LLC

 <mailto:margaret.shield at CEHstrategies.com>
margaret.shield at CEHstrategies.com

mobile:  206-499-545

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Susan Boehme
Sent: Monday, April 11, 2016 9:04 AM
To: Tenace, Laurie <Laurie.Tenace at dep.state.fl.us>;
'pharmwaste at lists.dep.state.fl.us' <pharmwaste at lists.dep.state.fl.us>
Subject: Re: [Pharmwaste] what federal agencies actually say about medicine
disposal

The summary of advice from the federal government is interesting.  At one
point USFWS also had advice (contradictory to EPA).  Is that still the case?
My quick search didn't reveal it.  And does USGS also post advice?  

Susan E. Boehme Ph.D.

Principal Consultant
ERM

Sediment and Watershed Integrated Management Practice (SWiM)

295 Madison Avenue, Suite 8A

New York, NY  10017

T: +1 212 803 0206 

F: +1 212 447 1904

M: +1 917 345 4514 
 <mailto:susan.boehme at ERM.com> susan.boehme at ERM.com 

 <http://www.erm.com/> www.erm.com

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Tenace, Laurie
Sent: Monday, April 11, 2016 8:01 AM
To: 'pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] what federal agencies actually say about medicine
disposal

Please note this did not originate with me and please always contact me if
your posts do not go through - Laurie

From: margaret.shield at cehstrategies.com
<mailto:margaret.shield at cehstrategies.com>
[mailto:margaret.shield at cehstrategies.com] 
Sent: Thursday, April 7, 2016 4:14 PM
To: 'Pharmwaste' <pharmwaste-bounces at lists.dep.state.fl.us
<mailto:pharmwaste-bounces at lists.dep.state.fl.us> >
Subject: what federal agencies actually say about medicine disposal

Good afternoon,

There's persistent incomplete information circulating about federal medicine
disposal guidances pertaining to trash disposal, aka "in home disposal" of
medicines. 

None of the federal agencies recommend trash disposal as the way to dispose
of medicines. 

All federal agencies recommend medicine take-back programs as better than
"in-home disposal".  

It's easy to verify this, but to make it easier, see the attached 3 page
handout showing the current medicine disposal positions of EPA, DEA, and FDA
for clarification in cases of confusion.  Please apply as needed until the
symptoms are gone.

I hope the FDA will listen to the comments it is receiving and soon remove
its guidance to flush certain medications.  Interestingly, even for those
especially dangerous medicines, FDA recommends use of a medicine take-back
program first.

Flushing of Certain Medicines 

There is a small number of medicines that may be especially harmful and, in
some cases, fatal with just one dose if they are used by someone other than
the person for whom the medicine was prescribed. To prevent accidental
ingestion of these potentially dangerous medicines by children, or pets, it
is recommended that these medicines be disposed of quickly through a
medicine take-back program or by transferring them to a DEA-authorized
collector. If these disposal options are not readily available, it is
recommended that these medicines be flushed down the sink or toilet as soon
as they are no longer needed. Click here for a
<http://www.fda.gov/drugs/resourcesforyou/consumers/buyingusingmedicinesafel
y/ensuringsafeuseofmedicine/safedisposalofmedicines/ucm186187.htm#Flush_List
> list of medicines recommended for disposal by flushing.

Margaret Shield, PhD

Community Environmental Health Strategies, LLC

 <mailto:margaret.shield at CEHstrategies.com>
margaret.shield at CEHstrategies.com

mobile:  206-499-5452

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