[Pharmwaste] RE: Story on FDA don't flush letter & EPR

[Ed Gottlieb]

Heidi,

Can you please let us know what you did to be able to comment?  Someone wrote to tell me they joined Environmental Reader and still got an error message when they tried to comment.  The publication hasn't responded to this question.

You encouraged others to respond.  Here are two other points that could be made (there are certainly others!):

It is easy to contest PhRMA's claim that collection will not be environmentally friendly because of the additional trips to the pharmacy.  This prediction ignores the strong probability that drop-offs will only happen when someone needs something from the pharmacy.  Combined trips = no additional transportation.

PhRMA's claim that trash disposal is "ecologically sustainable" ignores research showing that landfill leachate contains many medications.  Leachate is normally trucked to POTWs, where only a small percent is typically removed.

An additional source of data to help estimate the cost of a national collection program is the Kaiser Family Foundation.   http://kff.org/other/state-indicator/total-sales-for-retail-rx-drugs/
"Total Retail Sales for Prescription Drugs Filled at Pharmacies"

2014 US total $259,092,876,285
2014 CA total   $29,716,410,437

Note: These amounts are smaller than listed below (US $308.6 B, CA 37.31 B) probably because they do not include OTC or mail order.  The numbers below seem to be total sales, which should include both OTC and mail order.  My common sense check says that OTC & mail order should add a higher percent to the total.  If my assumption is correct, the small difference might be explained if the cited data is older (2010?), when sales were lower.

I find it interesting that Kaiser is confident enough in their data to list results to the nearest dollar.  It certainly creates a strong impression of accuracy!

Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY  14850
(607) 273-8381
fax: (607) 273-8433
________________________________
From: Heidi Sanborn [Heidi at calpsc.org]
Sent: Wednesday, February 10, 2016 12:20 PM
To: Ed Gottlieb; pharmwaste at lists.dep.state.fl.us
Subject: RE: Story on FDA don't flush letter & EPR

I just posted this response and encourage more of you to do the same as there are so many problems with this piece I cannot address them all in one post:
In response to the PhRMA comment that they don’t have any estimates to the national cost of the program we respond by highlighting that PhRMA stipulated to the fact in the Alameda Case that the Alameda program would cost 1 cent for every $10 of meds sold, and since they sold almost a billion dollars of drugs into Alameda in 2010, the cost was going to be $1 million a year for the program in Alameda County. Here is how it breaks down in 2010 numbers for the US to get $245 million per year cost for a national program run by producers:
$878.9 Billion in Global Sales (Reuters, April 20, 2010)
$308.6 Billion in US Sales (Supreme Court Filings)
$37.31 Billion in California Sales (Population proportion)
$950.0 Million in Alameda County Sales (Supreme Court Filings)
11.76% Average Net Profit in 2010 for nearly all Pharma companies (14.74% in 2014)
$36.28 Billion in Net Profit for US
$4.386 Billion in Net Profit for California
$111.7 Million in Net Profit for Alameda County
$0.126/$100 of Prescription Cost for EPR ($950M divided by $1.2M) x $100
$244.8 Million in Cost for US EPR Program
http://www.environmentalleader.com/2016/02/04/pharmaceutical-waste-management-flush-take-back-laws-or-something-else/comment-page-1/#comment-3001309

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Ed Gottlieb
Sent: Friday, February 5, 2016 5:18 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Story on FDA don't flush letter & EPR

https://www.environmentalleader.com/2016/02/04/pharmaceutical-waste-management-flush-take-back-laws-or-something-else/

One reader comment so far, with a pro-trash disposal, anti take back stance.  Anyone want to rebut this comment?
Thanks!
Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY  14850
(607) 273-8381
fax: (607) 273-8433
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