[Pharmwaste] HI take-back bill

Ed Gottlieb EGottlieb at cityofithaca.org
Thu Feb 15 15:01:56 EST 2018

The State of Hawaii is consider a take-back bill, SB2339 which has an Assembly equivalent.
“Every pharmacy shall accept for disposal from any person the return of any unused, remaining, or expired prescription drug that the pharmacy previously dispensed. “

Following are comments I submitted to one of the committees consider this legislation.

I regret not making the effort to be more positive, starting with thanking them for taking action.

Once submitted, there is no way to change testimony.

Dear CPH Committee,
Thank you for the opportunity to submit testimony regarding SB2339.
U.S. Drug Enforcement Administration (DEA) rules forbid pharmacy staff from touching previously dispensed medications when assisting a person who has come to drop-off unwanted medications. Staff can look at what a person has, and let them know what can and can’t be deposited in a take-back kiosk. In existing pharmacy take-back programs, a pharmacist rarely interacts with a person doing drop-off. It typically happens only if that person has a question regarding if particular item can be deposited.
With SB2339:
1. Every person doing drop-off would need to wait for pharmacy staff to be free to review their items. They would have to dump what they have on a counter, or otherwise display, their unwanted medications for staff to identify, without touching any of it, which came from that pharmacy. Sometimes shopping bags full of unwanted medications are brought in. It would take an inordinate amount of time, for both the customer and staff, to review the medications that arrive.
2. To ensure that review happens, the kiosk would have to be put behind the counter, where space is at a premium.
3. There is no way to know if what is in a bottle is actually the unwanted portion of what was dispensed in that bottle.
4. What should done when a person says a zip-lock bag full of pills came from that pharmacy?
Please consider introducing take-back legislation that provides free, convenient take-back opportunities for both prescription and over-the-counter medications (both human and veterinary) for all residents and, which is paid for by the manufacturers of these drugs.  For a take-back program to be a success, a robust outreach program is necessary.  For a model, refer to the most recent pharmaceutical take-back, extended producer responsibility laws past or pending in this country.  The Washington State bill, that recently passed their Assembly, is a particularly good model for your consideration.
As a first step, HI needs to change its rules to allow the DEA rule, permitting authorized collection, to proceed.  Almost every other state now permits pharmacies to register with the DEA and do take-back.
Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY 14850
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