[Pharmwaste] Est cost of take back per site?

Lucy, Burke at CalRecycle Burke.Lucy at CalRecycle.ca.gov
Tue Feb 3 20:52:39 EST 2015


Ed/all,

This info is old and in some cases shows early findings based on some newer programs at the time like mailback, but may still be worth a look, keeping in mind our notes/disclaimer(s) below.

From our 2010, Report to the Legislature: Recommendations for Home-Generated Pharmaceutical Collection Programs in California<http://www.calrecycle.ca.gov/Publications/Documents/1370/20110080.pdf>:



Costs



Program type

Average

Range (low)

Range (high)

# Reporting

Pharmacy

$5.60/lb

$1.00/lb

$16.67/lb

75

Law Enforcement

$4.56/lb

$0.38/lb

$13.89/lb

63

Household Hazardous Waste Facility

$2.86/lb*

$0.13/lb

$6.38/lb

15

Collection Events

$6.06/lb

$0.87/lb

$16.67/lb

36

Mailback

$6.54/lb*

$4.59/lb

$8.10/lb

3

* This average is considerably lower than the average costs of other programs; however, the weights of pharmaceuticals at HHW programs are more likely to be estimated rather than measured, which could impact the cost-effectiveness results (e.g., if the estimated amounts are twice the actual weight, the cost per pound will be half what it should be).
** Because all mail-back programs started in 2009 and are relatively new in California, CalRecycle only includes the costs and pounds collected for returned mailers. Program managers pay for mailers up-front regardless of whether they are subsequently used or not. If generators (residents) do not return some mailers, then overall cost per pound will increase (e.g., if residents returned only half of the mailers, the cost per pound would double). A mailer’s $3.65 flat rate cost per envelope may encompass more upfront costs than the reported costs from pharmacy programs (e.g., staff time, kiosk cost and maintenance, and lost retail space, etc.). Finally, if residents put more pharmaceuticals in each envelope, the cost effectiveness increases (i.e., a lower cost per pound) because the current mail-back programs use flat rate shipping arrangements. However, encouraging residents to hold onto materials longer and send fewer, fuller envelopes may increase illegal diversion opportunities. In addition, Walgreens has made postage paid mailers available in its stores nationwide for $2.99 each,56 and at least 200 Kaiser Permanente Hospitals in California are offering the same mailers for $4.95 each. Anecdotally, Kaiser has had considerable customer demand.

Notes:
CalRecycle also cautions readers about trying to compare the different program types. First, the data varied significantly within each program type as well as between program types; when this type of variability exists, one must use caution when comparing averages. Second, the program types vary tremendously in whom they serve and how they provide their services. By way of example, grocery stores, fast food chains and high-end restaurants all provide food but do so very differently and each type excels in different situations. Similarly, the fundamental differences in service delivery models in different pharmaceutical collection program types make comparisons fruitless.
…
Responses that did not include both costs and pounds of pharmaceutical waste collected were not included in the cost-effectiveness analysis. Errors or misreporting in overall cost or amount collected will impact the reliability of the cost-per-pound calculation.

Program costs may include: 1) advertising costs; 2) a medical or hazardous waste hauler’s collection, transportation, disposal, and processing fees (hauler fees); and 3) administrative/staff time. Survey respondents could choose to provide costs for any or all of these categories. This analysis uses the cost data that program managers provided. For instance, many programs did not provide advertising costs because their program was mature enough that advertising was not needed, or funds were so limited that it was not an option. In addition, in many cases, staff time was not tracked and was not provided. Out of all survey responses, 51 percent of the programs and sites representing a cross section of all program types did not have associated staff costs. Because all costs were not included, the results presented here may be a low estimate. The cost data varied significantly within program type as well as between program types; when this type of variability exists, readers need to use caution when comparing averages.

CalRecycle did not adjust the reported amount of pharmaceutical waste collected to compensate for packaging discarded with the pharmaceuticals. While some programs encourage participants to remove packaging more than other programs, CalRecycle could not quantify the effect of this encouragement due to lack of accurate data. As a result, the cost effectiveness and efficacy relate to the combined weight of pharmaceuticals and associated packaging. Most HHW programs do not track pharmaceutical weights separately from other household wastes they collect; most reported estimated weights. CalRecycle excluded one HHW program from the analysis because it reported a combined weight of household wastes and pharmaceuticals.

…also note that roughly one-third of all programs met our voluntary model guidelines<http://www.calrecycle.ca.gov/HomeHazWaste/Medications/ModelProgram/Criteria.pdf> (see breakdown in graph below), which include some standards that may be more onerous than the new DEA regulations.  For instance, from the guidelines: “Bins located at pharmacies shall have a two key security system--one in the possession of the collection site’s designated responsible person and the other in the possession of the licensed hauler who will pick up the contents for appropriate destruction.”

[cid:image009.jpg at 01D03FDA.33CC1EA0]


Mr. Burke Lucy
Environmental Scientist
Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street, PO Box 4025
Sacramento, CA 95812
Burke.Lucy at CalRecycle.ca.gov<mailto:Burke.Lucy at CalRecycle.ca.gov>
916.341.6592
[California Department of Resources Recycling and Recovery (CalRecycle)]<http://www.calrecycle.ca.gov/>
Connect with us!
[Visit CalRecycle on FaceBook]<http://www.facebook.com/pages/Sacramento-CA/CalRecycle/232843879097> [Follow CalRecycle on Twitter] <http://twitter.com/calrecycle/>  [Subscribe to CalRecycle Feeds] <http://feeds.calrecycle.ca.gov/default.aspx>  [Find CalRecycle videos on YouTube] <http://www.youtube.com/user/CalRecycle?feature=creators_cornier-http%3A//s.ytimg.com/yt/img/creators_corner/YouTube/youtube_32x32.png>  [CalRecycle Mobile App] <http://m.calrecycle.ca.gov/Mobile/>

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Chris Angel, President
Sent: Monday, February 02, 2015 10:45 AM
To: Ed Gottlieb
Cc: pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Est cost of take back per site?


Ed and ListServe Info below as of October 2014



  *   We have demonstrated that the maximum cost per location is $300 per year. This includes all materials to collect unused/unwanted drugs, posters, hand-outs and the transport of collected Rx waste for ultimate disposal/destruction at a high temperature incinerator. Currently the program has 352 pharmacies participating in MI,IL, WI and IN. OH to be added in October 2015. PA NY to be added in 2015 and we will soon be offering the program to other states. Because of the economy of scale, as the number of pharmacies increase it is feasible that the cost per location could be less than $300.

FR: Chris Angel President Great Lakes Clean Water

Conclusions based on six years of operating Yellow Jug Old Drugs Rx-Waste Collection/Disposal Program at pharmacies in the Great Lakes region.

Rationale for considering funding options other than Full Producer Responsibility Funding

Benchmark Cost Per Pharmacy



  *   Large Scale-state wide and regional drug collection programs provide the most cost effective method of collection and disposal of unused/unwanted drugs. Having many locations under one umbrella program with a low administrative overhead is preferable to local programs providing service to a smaller number of locations yet incurring similar administrative costs.



  *   Pharmacies are the most logical, convenient, safe and most effective locations for  proper collection and disposal of unused/unwanted drugs



  *   The Secure and Responsible Drug Disposal Act will now allow pharmacies to collect controlled substances in much the same manner they have been doing with Yellow Jug Old Drugs. This will provide even better access for citizens wanting to dispose of unused/unwanted drugs. Law enforcement will soon be deferring collection of controlled substances to pharmacies and more pharmacies will be providing collection/disposal of Rx-Waste for their customers



  *   Independent pharmacies are willing to provide financial support to provide program to their communities. Chain pharmacies which make up a majority of pharmacies in the country should be strongly encouraged to participate to provide even greater access to citizens wanting to properly dispose of unused/unwanted drugs.



  *   There are several reasons that citizens should be educated and encouraged to properly dispose of unused/unwanted drugs. These include; Environmental, Water Quality, Public Health and Safety and Substance Abuse Prevention. Individuals deciding to take action are motivated by sometimes more than one concern. We feel that a primary focus on Great Lakes Water Quality is one of the major factors in the success of the Yellow Jug Old Drugs Program. The issue of water quality, whether it’s drinking water or lakes, rivers or streams for recreation, has been a unifying message while also addressing the other concerns cited.





Sustainable Funding





  *   Long –term sustainable funding is critical to long term success of Rx waste collection and disposal programs. The Yellow Jug Old Drugs program is currently funded primarily by support from participating pharmacies with a small percentage funded by grants. It is the goal of GLCW to have funding sustained by 1/3 pharmacies, 1/3 individuals and grant funding and 1/3 pharmaceutical companies.



  *   Some groups have supported the idea that the Pharmaceutical Industry should fund the entire cost of Pharmaceutical Collection/Disposal Programs. We have been encouraging them to consider funding that would include the Pharmaceutical Industry in the overall solution but not as the only source of funding. It is our opinion that all of us; pharmacies, consumers and pharmaceutical companies contribute to creating drug waste and we all benefit by proper disposal so we should all be part of the solution to fund collection and disposal.



  *   Asking the Pharmaceutical Industry to be responsible for all the costs is a bit like asking the Automobile Industry to fund the operation of all junk yards recycling all unused automobiles.



  *   Some support the idea that the Pharmaceutical Industry should support all the cost of Rx-Waste collection/disposal much the same as the producers of electronics, paints, metals, plastics etc. help fund programs to recycle those items. The major difference being that these recyclable items have some value in the marketplace so it is advantageous for producers to help fund collection of these materials. Rx-Waste is never recycled and has no value. It is collected and taken to a High temp incinerator for complete destruction.



  *   We have seen some estimates for funding collection programs at pharmacies in the range of $2000-$2500 per location. It has been our goal to operate the Yellow Jug Old Drugs Program at the lowest possible cost to reach the maximum number of people. We feel that this is critical to educate the greatest number of people about the importance of proper disposal for Rx-Waste.



Benchmark Cost Per Pharmacy $300 per year



  *   We have demonstrated that the maximum cost per location is $300 per year. This includes all materials to collect unused/unwanted drugs, posters, hand-outs and the transport of collected Rx waste for ultimate disposal/destruction at a high temperature incinerator. Currently the program has 352 pharmacies participating in MI,IL, WI and IN. OH to be added in October 2015. PA NY to be added in 2015 and we will soon be offering the program to other states. Because of the economy of scale, as the number of pharmacies increase it is feasible that the cost per location could be less than $300.



  *   Having effectively demonstrated that a collection/disposal program can operate very successfully within a budget of $300 per location will be beneficial especially for local and state governments to compare costs that they incur to operate Rx-Waste collection/disposal programs. It will also provide a benchmark for actual costs of a collection/disposal program to aid in planning any legislative efforts.





I hope the thoughts that I have shared will be the start of a deeper conversation amongst all interested parties about long-term, sustainable funding for Rx Waste collection/disposal programs.

Chris Angel, GLCW President










---------------------------- Original Message ----------------------------
Subject: [Pharmwaste] Est cost of take back per site?
From: "Ed Gottlieb" <EGottlieb at cityofithaca.org<mailto:EGottlieb at cityofithaca.org>>
Date: Sat, January 31, 2015 10:29 am
To: "pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>" <pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>>
--------------------------------------------------------------------------

> The pharmaceutical lobby claims that the cost of take back programs is too high.
>
> I'd like to estimate what it would cost and see how that compares, percentage wise, to other industries with product stewardship programs.
>
> I don't know what percent of gross sales are used to pay for outreach, waste collection and disposal by industries with lifecycle programs. Maybe the folks at PSI have some numbers? Does the percent vary widely or are they in the same ballpark? Could a pharmaceutical program be done for a similar or lower percentage?
>
> A quick check shows there are approximately 67,000 pharmacies (Wiki) and 16,000 nursing homes (CDC) in the U.S. Couldn't find a number for narcotic treatment centers. It is not likely that every pharmacy, long term care facility, and narcotic treatment center will become a collection site, even if the cost of the program is covered. I'm going to optimistically assume high participation rate of 85,000 collection sites.
>
> In 2009, gross sales of pharmaceuticals in the US totalled 300 billion dollars [http://www.bls.gov/ppi/pharmpricescomparison.pdf]. With the growth of health care costs, it is safe to assume that this is now a low number.
>
> Not yet knowing what percent of gross sales other industries put into collection and disposal, I'm going to make a big assumption. I'd guess that most people would agree that 1/10 of 1% of gross sales is not a lot to cover the costs of a take back program. Using my assumptions, 300 million dollars is roughly $3500 per collection site per year.
>
> Obviously, the start-up cost for a pharmaceutical program is significantly higher than the ongoing costs since drop boxes need to be purchased, staff needs to be trained, and outreach materials developed. We should also assume there will be ongoing government oversight costs that need to be covered.
>
> There is an economy of scale that applies here. For example, if the manufactures chose to work together, one outreach program could be used nationwide, tweaking it for maximum effectiveness in different regions. Also, the cost of a collection box (roughly 7-9 hundred) will come down some with large volume purchases.
>
> Are my assumptions and quoted numbers reasonable? How does the $3500/site figure compare to the start up and maintenance costs of your take back program?
>
> Your thoughts are appreciated!
>
> Ed Gottlieb
> Chair, Coalition for Safe Medication Disposal
> 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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Chris Angel, President







www.GreatLakesCleanWater.org<http://www.GreatLakesCleanWater.org>                     989.736.8179

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