[Pharmwaste] updated report on Medicine Disposal Products

[Margaret Shield]

"Medicine Disposal Products: an overview of products & performance
questions", a report examining available information about medicine disposal
products, is now available online. A PDF of this March 2019 report is linked
from the In-Home Medicine Disposal Products Review section on this webpage:
https://sfenvironment.org/safe-medicine-disposal-policy-resources. 

 

The report reviews eight medicine disposal products that are marketed for
use by consumers, healthcare facilities, law enforcement and others. It also
reviews two products marketed solely to healthcare facilities. The products
are: Cactus Smart Sink, CsRx System, Deterra, DisposeRx, Drug Buster,
Element MDS, NarcX, Pill Catcher, Pill Terminator, and Rx Destroyer (also
sold as Narc Gone HD). The report was produced through funding from the San
Francisco Department of the Environment, and updates an earlier version
released in April 2017. The March 2019 report reviews two additional
products and summarizes additional product testing information that was
provided by six of ten product manufacturers in response to a direct query
to each of the manufacturers.

 

The report is designed to assist readers in making their own determinations
about appropriate use of the products by presenting available information,
examining key performance questions, and describing relevant regulatory and
policy considerations. Further research needs and recommended actions for
both manufacturers and governmental entities are also suggested. 

 

Recommendations in the report include:

*	Additional independent laboratory analysis is needed to verify
performance claims. The medicine disposal products do appear likely to act
as deterrents to diversion of leftover medicines and/or pharmaceutical
wastage. The available product testing data, however, is not sufficient to
verify claims that medicines are made non-retrievable through chemical or
physical action of the products. For the eight products marketed for solid
waste disposal, additional testing is also needed to verify claims that the
used product-drug mixture is non-hazardous and appropriate for solid waste
disposal. The regulatory context for disposal of pharmaceuticals must also
be considered, and depends on the type of generator of the waste as well as
the jurisdiction in which the waste is disposed.
*	"Real world" testing of mixtures of medicines and dosage forms is
needed. Overall, product testing disclosed by different manufacturers
examines treatment of only a small number of pharmaceuticals. Most analysis
was conducted on a single medicine at a time, rather than a combination of
different types of pharmaceuticals as these products would likely be used.
*	Instructions for consumers should be improved to address spills and
other safety risks. Warning labels should be expanded to caution about any
exposure to the product-drug mixture, including through dermal exposure to
dissolved pharmaceuticals.  Instructions should also be provided for safe
clean-up if the product container spills or leaks.
*	Product use directions for consumers should be aligned with federal
disposal guidelines for household medicines. The DEA, FDA, and EPA's
medicine disposal guidelines recommend secure medicine take-back programs as
the best disposal option. Trash disposal of medicines is recommended only in
situations where a secure medicine take-back program is not available. 
*	Products in liquid form need solidifying agents or absorbents for
solid waste disposal. Many of the products designed for solid waste disposal
are in liquid form after use. Product containers are likely to burst and
release a liquid pharmaceutical waste mixture in the household trash can,
garbage truck, or waste transfer station. 
*	Use in healthcare settings may be most appropriate for diversion
prevention, rather than final disposal. Regulated generators of
pharmaceutical waste should take care to review applicable regulations to
determine appropriate final disposal methods based on the pharmaceuticals to
be disposed and the facility's jurisdiction. In the healthcare setting, use
of these products may be most appropriate for management of pharmaceutical
wastage of controlled substances.
*	Appropriate regulatory oversight of medicine disposal products needs
to be defined. None of the medicine disposal products are approved by any
federal agency despite some marketing language that suggests a product has
undergone review or meets federal standards. Use of medicine disposal
products is expanding, including through distribution of products for
consumer use by major retail pharmacies. Federal review and regulation of
medicine disposal products is needed, while maintaining existing state and
local authority for more stringent solid waste management regulation and
policies.

 

Questions and comments on the report may be directed to me at
margaret.shield at CEHstrategies.com <mailto:margaret.shield at CEHstrategies.com>
or to Maggie Johnson, Senior Residential Toxics Reduction Coordinator, San
Francisco Department of the Environment at margaret.johnson at sfgov.org
<mailto:margaret.johnson at sfgov.org> . We hope the information and analysis
in this report is valuable to you.

Best regards,

 

Margaret Shield, PhD

(pronouns: she/her/hers)

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.cehstrategies.com/> www.CEHstrategies.com 

 

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