[Pharmwaste] How does Canada fund take back

Jaramillo, Jeanie Jeanie.Jaramillo at ttuhsc.edu
Sun Aug 27 17:30:46 EDT 2017

Wow! I wonder how the Alberta Pharmacists' Association funds this. Seems like the cost could be considerable.

Dr. Jeanie Jaramillo-Stametz
Managing Director, Texas Panhandle Poison Center
Asst. Professor, Pharmacy Practice
Director, Medication Cleanout
Texas Tech University Health Sciences Center
School of Pharmacy
jeanie.jaramillo at ttuhsc.edu<mailto:jeanie.jaramillo at ttuhsc.edu>
Office: (806) 414-9402
Voice mail: (806) 414-9299
Mobile: (806) 376-0039

From: Jeff Hollar [mailto:jhollar at pwaste.com]
Sent: Thursday, August 24, 2017 4:31 PM
To: 'Ed Gottlieb' <EGottlieb at cityofithaca.org>; pharmwaste at lists.dep.state.fl.us; Pretreatment_Coordinators at yahoogroups.com
Subject: Re: [Pharmwaste] A badly flawed pharmaceutical take-back bill may become state law

In Alberta, Canada the take back program is funded by the Alberta Pharmacists' Association.  In 2014, they collected over 71 metric tons.

Full story link: http://lethbridgeherald.com/commentary/letters-to-the-editor/2017/08/24/return-unused-meds-to-your-pharmacist/

Jeff Hollar
PharmWaste Technologies, Inc.
4164 NW Urbandale Dr., Ste A
Urbandale, IA 50322
515-276-5302 (general)
515-331-7310 (direct)
515-360-9785 (cell)

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Ed Gottlieb
Sent: Thursday, August 24, 2017 4:06 PM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>; Pretreatment_Coordinators at yahoogroups.com<mailto:Pretreatment_Coordinators at yahoogroups.com>
Subject: [Pharmwaste] A badly flawed pharmaceutical take-back bill may become state law

Any day now, a seriously flawed New York State chain pharmacy take-back bill could be signed into law.  https://www.nysenate.gov/legislation/bills/2017/a387/amendment/b
It would do a poor job of providing convenient take-back and who pays for it is wrong.

This could be the leading edge of a wave of state bills that shield manufactures from any responsibility for the collection and disposal of their unwanted products.  To prevent this, we need to take action!  (Suggestions highlighted below.)

The bill requires pharmacies with 10 or more stores in the state to offer take-back options (plural in the NY bill).  Pharmacies could choose among any legal method, including:  mail-back, home disposal products, collection events (no frequency specified), and kiosks.

It appears that the original Senate version of the bill required that all take-back be free to consumers.  It was amended to allow the pharmacies to pass on 100% of the cost of mail-back envelopes to consumers.  The final version, amended by the Assembly, allows them to pass on up to $2 of the cost of mail-back envelopes to consumers, with other take-back options remaining free.  Does your inner cynic wonder, as mine does, if the change from "free" to "pay 100% for mail-back" was a bait and switch to get the support of legislators?

My interpretation of the bill is that it would be easy for chain pharmacies to comply with the law.  They could sell small take-back envelopes for $2 and sponsor a once-a-year collection event.  When I spoke with representatives of a couple of chain pharmacies, they were supportive of the compromise version because it releases them from having to install kiosks, which take more effort and are seen as a liability risk (something EPR bills need to address!).

The bill does nothing to increase take-back in rural areas without a chain pharmacy.

The bill also preempts local law, so existing EPR laws will be struck down.  This totally relieves manufactures of any responsibility to organize or pay for take-back and puts the full burden on chain pharmacies and consumers.

If you don't live in NY and want to see an effective pharmaceutical EPR law in your community or state, or don't want to see your local EPR law disappear, please educate state legislators about EPR now.* If they don't get the facts, a state chain pharmacy bill will probably look like a good compromise solution.
If you are a New Yorker, please ask Governor Cuomo to veto A.387-B, the chain pharmacy take-back bill.  It could be sent to his desk for a signature any time, so contact him right away!  He will have to hear from many of us to consider a veto, the bill had strong, bipartisan support.
Talking points:

*        This bill is a give-away to the pharmaceutical manufactures, relieving them of any responsibility for the collection and disposal of their unwanted product.  Chain pharmacies and consumers will have to pay for take-back.

*         It fails to provide effective take-back of unwanted household medications.

o    Charging $2 for a small mail-back envelope is a strong disincentive to participate.

o    Many rural communities are not served by chain pharmacies.  This bill does nothing for them.

*         Without convenient take-back options, medicine cabinets will continue to fuel the opioid addiction crisis, accidental poisonings, and environmental contamination.

*         It preempts any local law related to take-back.  Rockland County's extended producer responsibility (EPR) law, will no longer be valid.  Similar bills, including those under consideration in Erie and Westchester Counties, will be moot.  The only reason for preemption is to ensure that manufactures won't have to pay.

*         MA & VT, along with many municipalities, have passed pharmaceutical EPR laws.  NY should improve upon those models and take the lead on this important public health issue!
Contact Governor Cuomo's office by phone:  1-518-474-8390<tel:15184748390>  Hours: 9:00am to 5:00pm
Web form: https://www.governor.ny.gov/content/governor-contact-form
The Honorable Andrew M. Cuomo
Governor of New York State
NYS State Capitol Building
Albany, NY 12224
* Here are a couple of links to information on EPR:

Thanks for speaking out!
Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Board Member, New York Product Stewardship Council
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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