[Pharmwaste] Resource guide on drug deactivation bags

Tue Jul 7 11:39:28 EDT 2026

EXTERNAL MESSAGE
This email originated outside of DEP. Please use caution when opening attachments, clicking links, or responding to this email.

Hey Ed,

I thought I might chime in here.  I concur; the home disposal companies should not be downplaying the national collection events at all!  Here in California, they took it a step further and tried to pass a bill a couple of times to require pharmacies to provide their products with opioid prescriptions.  Their first attempt was in 2024 with Assembly Bill 2445 (AB 2445) (https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB2445).  That first attempt didn't even get out of the first committee in the house of origin!  The bill was reintroduced again in 2025 under AB 1394 (https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB1394), this time placing the cost burden on the State.   Again, this bill also didn't get past the first committee.

California already has a robust statewide collection network pursuant to Senate Bill 212 (Jackson, 2018) that CPSC sponsored (https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB212).  This program is funded and operated by the pharmaceutical industry.  Information on this program can be found on CalRecycle's website at:  https://calrecycle.ca.gov/epr/pharmasharps/pharma/ or on Med-Project's website at: https://med-project.org/locations/california/meds/?utm_source=medtakebackcalifornia&utm_medium=domain_redirect&utm_campaign=legacy_domain.

In addition to the statewide program (see map from the Med-Project website below), nine counties have their own EPR ordinances that are structured similar to the statewide program.  According to Med-Project's 2025 annual report (https://www2.calrecycle.ca.gov/PublicNotices/Documents/18139) there were 1,104 collection locations under their part of the statewide program.  Until recently, there were an additional 521 locations run by the Drug Takeback Foundation (Inmar) according to their 2025 annual report (https://www2.calrecycle.ca.gov/PublicNotices/Documents/18135), however, they have ceased to run a program here in California as of June 30, 2026.  It is uncertain if those 521 locations will join Med-Project's network.

According to the annual reports, the statewide program costs in 2025 for Med-Project were about $8.6M and for Inmar, about $2.2M, or a total statewide cost of $10.8M for 2025.  With a population of 39M people in California, that is $0.28/person/year!

[cid:image002.png at 01DD0DE7.87FE7670]

Back in 2024, my research showed the costs that would be borne by either the pharmacies or the State if these products were mandated:

We've included some cost analysis below based on four popular disposal options found online for drug disposal systems (Cheapest to Most Costly)*:

·       Element MDS:  $4.66/pouch; would create a likely cost burden of approximately $63.6M/year.

·       Deterra:  $6.25/pouch; would create a likely cost burden of approximately $85.3M/year.

·       RX Pill Disposal:  $13.97/bottle; would create a likely cost burden of approximately $190.6M/year.

·       Pill Terminator:  $14.99/bottle; would create a likely cost burden of approximately $204.5M/year.

*Based on CDPH 2023 Opioid Dashboard for Q1-Q4 of 13,640,794 prescriptions annually.

Furthermore, I'm not certain that these at home disposal products are actually legally landfillable here in California.  I have been having an ongoing email discussion with one of the product manufacturers starting back in 2019 over their products that require adding water as part of the deactivation process.  Below is the California specific regulations regarding Moisture-Holding Capacity and Free Liquids:

Landfills must comply with Title 27 of the California Code of Regulations.  Title 27 covers the requirements of both CalRecycle and the State Water Resources Control Board.

https://govt.westlaw.com/calregs/Browse/Home/California/CaliforniaCodeofRegulations?guid=I9C47A720D44F11DEA95CA4428EC25FA0&transitionType=Default&contextData=%28sc.Default%29<https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fgovt.westlaw.com%2fcalregs%2fBrowse%2fHome%2fCalifornia%2fCaliforniaCodeofRegulations%3fguid%3dI9C47A720D44F11DEA95CA4428EC25FA0%26transitionType%3dDefault%26contextData%3d%2528sc.Default%2529&c=E,1,fduSiz2iq8klKvyWWtgsB19hlnGsAUXN0nhFJbsMlvJCQHBJAPtTxJlQ5NIRlL7GknC3WUBgZJ3clmz4SgsCsPnG03svrXk_PkC8S_V7kec,&typo=1>

Title 14 covers Transfer Stations and Material Recovery Facilities, among other operations.  The same requirement may also be included there for Transfer Stations since most of the material ends up at a landfill.

Here is some of the code around liquids in landfills:

>From Title 27:

https://govt.westlaw.com/calregs/Document/IE6390BE05F6811DFBF66AC2936A1B85A?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Default)<https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fgovt.westlaw.com%2fcalregs%2fDocument%2fIE6390BE05F6811DFBF66AC2936A1B85A%3fviewType%3dFullText%26originationContext%3ddocumenttoc%26transitionType%3dCategoryPageItem%26contextData%3d%28sc.Default%29&c=E,1,xguwf2XwCp-DH6Ka0P_ez0Kn5d7FxxquXsX_UY7nE4y9EIiC0EOHdXWv3LukdNXais3odCJRJ8Q6rxK1a8Sn7KxfH7b7f_MoWQXvXZUp_J4Sh1Psj_VC&typo=1>

Title 27. Environmental Protection

Division 2. Solid Waste

Subdivision 1. Consolidated Regulations for Treatment, Storage, Processing or Disposal of Solid Waste

Chapter 2. Definitions

Article 2. Specific Definitions (Refs & Annos)

27 CCR § 20164

§ 20164. Combined CalRecycle & SWRCB Technical Definitions.

"Moisture-holding capacity" (SWRCB) means the amount of liquid which can be held against gravity by waste materials without generating free liquid

"Free liquid" (SWRCB) means liquid which readily separates from the solid portions of waste under ambient temperature and pressure. Free liquids are not present when a 100 milliliter representative sample of the waste can be completely retained in a standard 400 micron conical paint filter for 5 minutes without loss of any portion of the waste from the bottom of the filter (or an equivalent test approved by the Department of Toxic Substances Control).

https://govt.westlaw.com/calregs/Document/IBE7EA7D0D44F11DEA95CA4428EC25FA0?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Default)<https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fgovt.westlaw.com%2fcalregs%2fDocument%2fIBE7EA7D0D44F11DEA95CA4428EC25FA0%3fviewType%3dFullText%26originationContext%3ddocumenttoc%26transitionType%3dCategoryPageItem%26contextData%3d%28sc.Default%29&c=E,1,1FPEzyl0srVdjDMgjYE6eb5galwedNql8I4q521FhEFbv11oECGQ9YSEbmOX5UnfC9V5vbncVqvrkubicelKeRh8I6m5wPmMyXJXApxXerY,&typo=1>

Title 27. Environmental Protection

Division 2. Solid Waste

Subdivision 1. Consolidated Regulations for Treatment, Storage, Processing or Disposal of Solid Waste

Chapter 3. Criteria for All Waste Management Units, Facilities, and Disposal Sites

Subchapter 2. Siting and Design

Article 2. SWRCB - Waste Classification and Management (Refs & Annos)

27 CCR § 20200

§ 20200. SWRCB - Applicability and Classification Criteria. (C15: s2520)

(d) Management of Liquids at Landfills and Waste Piles -The following requirements apply to discharges of liquids at Class II waste piles and at Class II and Class III landfills, except as otherwise required for MSW landfills by more-stringent state and federal requirements under SWRCB Resolution No. 93-62 section 2908 of Title 23 of this Code (see 40CFR258.28) [Note: see also definitions of "leachate" and "landfill gas condensate" in s20164 ]:

(1) [Reserved.];

(2) wastes containing free liquids shall not be discharged to a Class II waste pile. Any waste that contains liquid in excess of the moisture-holding capacity of the waste in the Class II landfill, or which contains liquid in excess of the moisture-holding capacity as a result of waste management operations, compaction, or settlement shall only be discharged to a surface impoundment or to another Unit with containment features equivalent to a surface impoundment; and

(3) liquids or semi-solid waste (i.e., waste containing less than 50 percent solids, by weight), other than dewatered sewage or water treatment sludge as described in s20220(c), shall not be discharged to Class III landfills. Exceptions may be granted by the RWQCB if the discharger can demonstrate that such discharge will not exceed the moisture-holding capacity of the landfill, either initially or as a result of waste management operations, compaction, or settlement, so long as such discharge is not otherwise prohibited by applicable state or federal requirements.

Note: Authority cited: Section 1058, Water Code. Reference: Section 13172, Water Code; and Section 43103, Public Resources Code.

I hope those reading this response find it helpful.  Please let me know if you have any questions.

Respectfully,

Doug Kobold | Executive Director
[cid:image001.png at 01DD0DE5.81BE57F0]<https://linktr.ee/CalPSC>
921 11th Street, Suite 700
Sacramento, CA  95814
C: (916) 205-2017<tel:(916)%20413-5262>
Doug at calpsc.org<mailto:Doug at calpsc.org>

From: Pharmwaste <pharmwaste-bounces at lists.dep.state.fl.us> On Behalf Of Ed Gottlieb
Sent: Tuesday, July 7, 2026 6:52 AM
To: Knieser, Brian <knieser.brian at epa.gov>
Cc: Fitzgerald.Kristin at epa.gov; U.S. Drug Enforcement Administration <dea at public.govdelivery.com>; Cynthia Finley <CFinley at nacwa.org>; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Resource guide on drug deactivation bags

EXTERNAL MESSAGE
This email originated outside of DEP. Please use caution when opening attachments, clicking links, or responding to this email.
Hi Brian,

Yes, I wanted to copy you since products for home disposal of medications are on EPA's radar.

By my thinking, it is unethical for companies making or selling drug home disposal products to purposefully create the false impression that safe disposal options are very limited (by not providing a link to the DEA's Year-Round Drop-Off Locations - Search Utility) in order to sell more product.

I would be happy to speak with anyone at the EPA (or the DEA) about this and why I think home disposal is significantly inferior to take-back & mail-back programs.

Best regards,
Ed

Ed Gottlieb

Industrial Pretreatment Coordinator / 4A Senior Operator

Ithaca Area Wastewater Treatment Facility

Chair, Tompkins County Coalition for Safe Medication Disposal

Member, NACWA Pretreatment Committee

Member, NYWEA Pretreatment/Industrial Wastewater Committee

525 3rd Street

Ithaca, NY 14850

(W) 607-273-8381 x4416
(C) 607-229-3722
________________________________
From: Knieser, Brian <knieser.brian at epa.gov<mailto:knieser.brian at epa.gov>>
Sent: Monday, July 6, 2026 5:24 PM
To: Ed Gottlieb <EGottlieb at cityofithaca.org<mailto:EGottlieb at cityofithaca.org>>
Subject: RE: Resource guide on drug deactivation bags

Hi Ed,

Did you mean to copy me on this email? For what it's worth, Kristin and I agree with you. Did you want to discuss this with us? Up to you.

Thanks,

Brian

From: Pharmwaste <pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us>> On Behalf Of Ed Gottlieb
Sent: Thursday, July 2, 2026 11:20 AM
To: Andrew Olsen <aolsen at growresolve.com<mailto:aolsen at growresolve.com>>; info at ncaddwestchester.org<mailto:info at ncaddwestchester.org>; jdwyer at deterrasystem.com<mailto:jdwyer at deterrasystem.com>
Cc: dea at public.govdelivery.com<mailto:dea at public.govdelivery.com>; cfinley at nacwa.org<mailto:cfinley at nacwa.org>; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] Resource guide on drug deactivation bags

Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links.

EXTERNAL MESSAGE
This email originated outside of DEP. Please use caution when opening attachments, clicking links, or responding to this email.

Andrew,

Following the link you provided to Drug Rehab USA, there seem to be connections between GrowResolve, Drug Rehab USA, Deterrasystem, and NCADD. will you please clarify what the connections are?

Everyone agrees that convenient, free, safe, and effective options for disposal of unwanted medications are an important first step in preventing opioid addiction. Towards this end, I would urge all of these organizations to provide links to the DEA's Year-Round Drop-Off Locations - Search Utility (https://apps.deadiversion.usdoj.gov/pubdispsearch/spring/main?execution=e1s1). When a website uses a proprietary medication disposal location finder or links to Google Maps, the chances are that most dropoff locations are missed. This inaccurately makes it seem like local disposal options are very limited, leaving home disposal pouches as the primary remaining option.

Sincerely,

Ed Gottlieb

Industrial Pretreatment Coordinator / 4A Senior Operator

Ithaca Area Wastewater Treatment Facility

Chair, Tompkins County Coalition for Safe Medication Disposal

Member, NACWA Pretreatment Committee

Member, NYWEA Pretreatment/Industrial Wastewater Committee

525 3rd Street

Ithaca, NY 14850

(W) 607-273-8381 x4416

________________________________

From: Andrew Olsen <aolsen at growresolve.com<mailto:aolsen at growresolve.com>>
Sent: Wednesday, July 1, 2026 9:42 PM
To: Ed Gottlieb <EGottlieb at cityofithaca.org<mailto:EGottlieb at cityofithaca.org>>
Subject: Re: Resource guide on drug deactivation bags

Thank you for getting back to me.

I'm afraid, I'm only available through email.

Please let me know if that's possible.

-----Original Message-----

Andrew,

I have a few questions. Please call me when you have a chance.

Ed

Ed Gottlieb

Industrial Pretreatment Coordinator / 4A Senior Operator

Ithaca Area Wastewater Treatment Facility

525 3rd Street

Ithaca, NY 14850

(W) 607-273-8381 x 4416

________________________________

From: Andrew Olsen <aolsen at growresolve.com<mailto:aolsen at growresolve.com>>
Sent: Tuesday, June 30, 2026 9:43 AM
To: Ed Gottlieb <EGottlieb at cityofithaca.org<mailto:EGottlieb at cityofithaca.org>>
Subject: Re: Resource guide on drug deactivation bags

Hi Ed

I hope all is well.

This will be my last nudge regarding the resource page suggestion on how the community can prevent medication abuse and subsequent addiction with proper use of drug deactivation bags. No worries if it's not the right fit for now, but if you have feedback or anything, feel free to email us.

I wish you continued success.

Best regards,
Andrew

-----Original Message-----

Hi Ed

I hope this message finds you well. A short while ago, I sent you an email regarding our resource guide on drug deactivation bags. This resource could be immensely beneficial for veterans.

I understand inboxes can get overwhelming, so I'm bringing this back to your attention. I would love to hear your thoughts on it!

Cheers,
Andrew

-----Original Message-----

Hi Ed

I hope you're doing well!

Our team really appreciates your efforts in supporting your readers and community members with facts and figures regarding drug use, rehabilitation, and overall wellness, particularly on how you disseminate valuable information through this resource page:

http://cityofithacany.gov/677/Safe-Medication-Disposal

According to statistics, 50% of individuals who misused prescription painkillers got them from their friends and families. Prescription drugs are used as recreational drugs, which may lead to accidental overdose. One of the most recent and effective resources in the battle against medication abuse and subsequent addiction is drug deactivation bags. This allows users to safely and responsibly dispose of their leftover prescription supplies.

Our team came up with a comprehensive guide on the use of drug deactivation bags to help reduce the health risks posed by expired and unused drugs.

Here's the link for your convenience:
https://drugrehabus.org/drug-deactivation/

This resource covers the following:
- How drug deactivation bags work?
- Why you shouldn't just flush unused and expired medications down the toilet?
- How effective are drug disposal bags?
- Where to get drug disposal bags?
- How to find drug disposal locations near you.

This content will guide families and community members on how to dispose of unused and expired medications properly. Please do not hesitate to reach out if you require more details or wish to discuss how this guide can benefit your community.
We look forward to the opportunity to contribute to your incredible work. Thank you so much.

Warm regards,
Andrew Olsen
Content Advocate @ Grow Resolve
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20260707/22d4af5f/attachment-0001.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image001.png
Type: image/png
Size: 63269 bytes
Desc: image001.png
URL: <http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20260707/22d4af5f/attachment-0002.png>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image002.png
Type: image/png
Size: 263807 bytes
Desc: image002.png
URL: <http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20260707/22d4af5f/attachment-0003.png>