[Pharmwaste] FW: Request Support for Cook County's proposed extended producer responsibility ordinance

Jim Mullowney jmullowney at pharma-cycle.com
Sat Mar 19 17:56:15 EDT 2016


Margaret, 

 

Good points!

 

I would add the following

1. Not all drugs are equal as pollutants as Aspirin and cyclophosphamide
should not be lumped in the same category.

2. A study done at the request of the European Commission by a division of
Deloitte in 2014 references a study ranking the relative dangers of
Medicines in the environment. The outcome of the study has  birth control
pills on one end of the spectrum and cyclophosphamide on the other with nine
orders of magnitude or saying that Cyclophosphamide is a Billion times more
dangerous than Birth control pills. I have attached the graph to this study.

3. Cyclophosphamide has no safe level of exposure for anyone including
children and is classified as a Band 5 chemical by the manufacturer. Lead
has a safe level for adults.

4. USGS has another study stating that the fish in Cape Cod have cancer from
Cyclophosphamide, really.
http://cytotoxicsafety.org/wp-content/uploads/2014/03/USGS-Fish-Tumors-Cape-
Cod.pdf 

 

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Margaret Shield
Sent: Saturday, March 19, 2016 12:46 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] FW: Request Support for Cook County's proposed
extended producer responsibility ordinance

 

There's an often forgotten contributor to pharmaceutical pollution -
manufacturing releases. Perhaps we in the U.S. often neglect this as so much
pharmaceutical manufacturing occurs outside our borders.

I found this USGS study on manufacturing facility releases in NY state
fascinating.  Levels far higher than in regular wastewater from excretion
and flushing of excess medicines.  I wonder what else is being done on this
industrial source that needs reducing:
http://toxics.usgs.gov/highlights/PMFs.html

 

The available evidence does not allow us to accurately define the relative
contributions of all the sources of pharmaceutical pollution in our
waterways.  Working towards proper disposal of the 30% or more of
unused/expired medicines sold to consumers also serves to reduce access to
medicines that could be diverted or misused.  Saving lives from the acute
threat of addiction, poisonings, and overdoses.  Pharmaceutical pollution is
the chronic threat.  That is the rationale behind the emphasis on medicine
take-back. Of course, one approach does not negate the need for
comprehensive approaches, including source reduction efforts on all fronts.

 

Margaret Shield, PhD

Community Environmental Health Strategies, LLC

Smart Science & Policy for Our Health and Environment

Seattle, WA 

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

mobile:  206-499-5452

 <http://www.linkedin.com/in/margaretshield>
www.linkedin.com/in/margaretshield

 

P.S. There is no safe level of exposure to lead for a child.
http://www.toxipedia.org/display/toxipedia/Health+Effects+of+Lead

 

 

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Jim Mullowney
Sent: Friday, March 18, 2016 6:04 PM
To: 'Gilliam, Allen' <GILLIAM at adeq.state.ar.us>; 'Catherine Zimmer'
<zenllc at usfamily.net>; 'Seery, Scott, Env. Health' <scott.seery at acgov.org>;
'Tenace, Laurie' <Laurie.Tenace at dep.state.fl.us>;
pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] FW: Request Support for Cook County's proposed
extended producer responsibility ordinance

 

Allen. 

 

Great post.

A couple of points to add

 

1. Drugs get into the environment mainly from excretion

2. Lowering the dose is a way to minimize the effect drugs have on the
environment.

3. This approach will not work with certain highly toxic drugs such as
cytotoxic chemotherapy drugs 

4. The best approach to deal with such dangerous drugs may to simply prevent
the urine and feces from entering our sewer systems

 

This is all spelled out nicely by Dr. Christian Daughton of the EPA in 2014
and the study can be found at
http://www.cytotoxicsafety.org/wp-content/uploads/2014/09/Eco-directed-susta
inable-prescribing-by-Christian-Daughton.pdf 

 

This same study found Cyclophosphamide (poster child for Chemo) in water at
13.1 ppb. 

In Flint Michigan the levels of lead were found from 5ppb to 25ppb and look
at the panic that happened there with ordinary lead.

 

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Gilliam, Allen
Sent: Friday, March 18, 2016 1:35 PM
To: 'Catherine Zimmer'; 'Seery, Scott, Env. Health'; 'Tenace, Laurie';
pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] FW: Request Support for Cook County's proposed
extended producer responsibility ordinance

 

Catherine,

 

I'm all the way in with you on Pollution Prevention.  Keep beating that
drum!

 

It seems EPA forgot its Pollution Prevention Act of 1990
(http://www.epw.senate.gov/PPA90.pdf ); especially ALL of its functions in
Sec. 6604(b).  

 

Wonder if Scott Cassell and his group can get Gina McCarthy's attention on
this one?

 

It's great some counties and States are having luck forcing Big Pharma pay
for take-back programs, but those costs are only going to be piled back on
you and I in the form of higher prescription costs.  Where's the break-even
point? 

 

I've recently seen/heard of only some cancer meds are now being tailored to
the age/weight of the patient.  

 

Keep flying the P2 banner Catherine, but I don't believe Big Pharma is going
to move in the source reduction direction in our work life times (at least
not mine).

 

Sincerely,

 

Allen Gilliam

ADEQ State Pretreatment Coordinator

501.682.0625

 

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Catherine Zimmer
Sent: Friday, March 18, 2016 11:18 AM
To: 'Seery, Scott, Env. Health'; 'Tenace, Laurie';
pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] FW: Request Support for Cook County's proposed
extended producer responsibility ordinance

 

Hi all,

Just a comment, while EPR helps eliminate sewering as a disposal method for
un-used drugs, it likely does nothing in the realm of true source reduction
and pollution prevention.  To do that we need to minimize consumption and
excretion of pharmaceuticals, and other personal care product chemicals that
are sent to the sanitary sewer and ultimately our aquatic systems.    

 

Very truly yours,

 

Catherine Zimmer, MS, BSMT

Executive director, HEARRT Midwest

Principal, Zimmer Environmental Improvement, LLC

Reducing and managing healthcare related waste and costs for fifteen years.


St. Paul, MN 

Ph:  651.645.7509

 <mailto:zenllc at usfamily.net> zenllc at usfamily.net

 

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Seery, Scott, Env. Health
Sent: Thursday, March 17, 2016 12:20 PM
To: 'Tenace, Laurie'; 'pharmwaste at lists.dep.state.fl.us'
Subject: Re: [Pharmwaste] FW: Request Support for Cook County's proposed
extended producer responsibility ordinance

 

The last sentence on the first page needs to be rewritten to make any sense.

 

--S

 

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf
Of Tenace, Laurie
Sent: Thursday, March 17, 2016 10:00 AM
To: 'pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] FW: Request Support for Cook County's proposed
extended producer responsibility ordinance

 

Please note this email did not originate with me - Laurie

 

From: Ingram, Tiffany [mailto:tingram at nrdc.org] 
Sent: Thursday, March 17, 2016 12:03 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: Request Support for Cook County's proposed extended producer
responsibility ordinance 

 

On Wednesday, March 22, 2016, the Cook County Board will be considering an
extended producer responsibility ordinance for pharmaceuticals.   Cook
County is one of the largest counties in the country.  Passage of an EPR
ordinance in Cook County will influence other jurisdictions to pass similar
measures. Please sign-on to the attached letter in support of the proposed
ordinance.  Thank you.  

 

TIFFANY C INGRAM, JD 

Midwest Advocacy Director for Great Lakes Policy 

 

NATURAL RESOURCES 

DEFENSE COUNCIL 

20 North Wacker Drive, Suite 1600

Chicago, IL 60606

T 312-651-7919

M 312-479-6133

tingram at NRDC.ORG

NRDC.ORG

 

 

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