[Pharmwaste] RE: Med Take Back and Pharmacies

Barry Fernandez barry at clean-fuels.net
Thu Feb 12 18:34:29 EST 2015

I agree with Jennifer.  We consolidate between 90 to 100 tons of pharmaceuticals a year.  Chemical incompatibility hasn't created any plumes of toxic clouds at our facility.  I do agree that security and lack of funding is a deterrent for a pharmacy to put their business and personnel at risk, even for the greater good of the community.  Holding pharmaceutical companies financially responsible sounds like a good idea on its face, as proposed by groups like Product Stewardship, however that's tantamount to corporate shakedown.  Once you shake the money out of the tree, who do you get to administer the programs and regulate funding?  Besides, not all pharmaceutical companies are gargantuan money trees, quite a few (the majority) are struggling small businesses.

I believe that the responsibility ultimately falls to local governments.  After all, the drugs left behind by my granddad upon his demise are a hazard to the local community, not the whole country.  Therefore, I don't see it federally funded by DEA or other Fed agency.  The best place for this waste stream to originate is through hospital pharmacies.  They are more secure than brick-and-mortar retail pharmacies, they already have a fairly robust program for patient meds, and there's a hospital near you (well, most of you).  To integrate the relatively small volume from a community take back would be seamless.  To pay for it the city or county could grant a tax credit or some other concession for example.

Of course, before any of it could even be contemplated, the DEA would have to come together with EPA and remove the barriers to compliance.  Their respective Washington DC offices are literally less than one mile from each other.  They could meet at the Starbucks half way and strike a deal before noon.


From: Volkman, Jennifer (MPCA) [mailto:jennifer.volkman at state.mn.us]
Sent: Thursday, February 12, 2015 2:30 PM
To: Pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: Med Take Back and Pharmacies

I just gave you a standing ovation!
I have only a slightly different view point...

I don't agree that there is a significant chemical hazard or that it is likely that a cloud will emerge from a collection bin.

I understand that many states have hoped pharmacies could collect because surveys say people need this convenience to make collection successful. I am fortunate to live in a state that has a lot of participation by law enforcement and we're still adding collection boxes across the state at their facilities, but that isn't the case everywhere. Now some states are losing those due to discontinuation of funding. We are also fortunate to have low cost WTE incineration available throughout our state.

Pharmacies and manufacturers both make profits by selling drugs, I'd like to see them both involved in funding collection. The DEA is chasing the drug abuse issue and it costs them time and money to do so. They could certainly contribute more than updated regulations. We'll all be paying...the goal is the safest, most convenient, most economical collection system that keeps drugs off the streets and out of our water.

From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jaramillo, Jeanie
Sent: Thursday, February 12, 2015 1:08 PM
To: Pharmwaste at lists.dep.state.fl.us<mailto:Pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] Med Take Back and Pharmacies

I see lots of discussion on med take back and pharmacies with some focus on laws needing to be changed for those states that currently prohibit pharmacies from taking back meds, or just controls. There are still some big issues that were not addressed by the DEA regs that most of you are aware of, but perhaps some are not.

Drop boxes in pharmacies are a hazard.

Pharmacies are being robbed every day across the country for medications; and at an increasing rate. Pharmacists have even lost their lives. This is occurring when people know that controlled substances are stored in locked vaults and that they are closely inventoried, and when there are security cameras rolling. Placing a drop box in a publicly accessible area is an added target, regardless of being bolted to the floor, one way accessible, etc. Not to mention that customers bringing meds for "deposit" make easy targets.

Aside from being a target for theft and creating human targets for assault, these boxes are a chemical hazard. Ever wonder what will happen if a gas cloud begins emerging from one of these boxes? Evacuation will be necessary with a disruption to the entire pharmacy. Many meds are reactive and while one would hope people will leave items in their containers, many people do not trust to leave their information on the bottles. As a result, they will mix all their items together and then deposit them. I could tell stories about what we've seen brought to our take back events. Yes, clearly this is not going to be an everyday occurrence, but how often would this have to occur for it to be "significant"?

And then there's the funding issue. The DEA was simply providing a stop gap measure from the time the Secure & Responsible Drug Disposal Act of 2010 was enacted until the time the new regs went into place that would "expand" disposal options. Unfortunately, it was not made clear to law enforcement agencies or really to anyone  that was continually encouraged to participate and create drop boxes.. that the DEA was going to stop the program entirely. I think this info was there for those who wanted to dig for it, but DEA did not say to participating agencies, "we are only doing this until our regs come out and are enacted." So, now the response regarding why such a hugely successful program is being stopped cold turkey... there was never a budget to provide for the program to begin with. As with most all governmental agencies, funding is limited, sometimes bare bones - presumably, funding for med destruction for the DEA program had to be carved out of their operational budget.

So, what's my point? The DEA is not in the drug disposal business. You know what? Neither are pharmacies. They are businesses. They exist to make money. Everything depends on the bottom line. They are "for profit". These are not charitable organizations. They are not a "community service." Why would the DEA or anyone else ever have expected them to voluntarily pay for med disposal boxes that take up floor space that could be used for profitable sales? Attach something that is required to be permanently affixed, or otherwise, non-movable - i.e. destructive to the structure to which its being attached? Then utilize a very specific, highly regulated system for collecting, storing, and disposing of items in the box? This requires money, people (more $), and time (more $). But yet, no funding is being provided. And who thought this would work? The rationale - it will bring customers to the pharmacy....? This is the same pharmacy where I wait in line for 30 minutes to pick up my meds. I don't think they are hurting for customers.

But wait, law enforcement can still have boxes, right? Yep. And they all have money to spare! Let me see if their mission/vision includes drug disposal.

So, who should fund med disposal? You'll hear at least two answers. 1) the consumer. Next time you go to the pharmacy, ask them if their med disposal mailers are selling like hotcakes. 2) the people who are making the most profit from selling the medications - yes, that would be the drug companies! If we look at other countries across the world, the drug companies DO pay for med disposal; and they don't make a big deal about it. But here in the US, the companies spend their money fighting this. In fact, I'd venture to guess that in the jurisdictions they've been battling with this, they've spent more on the battle than they would have if they'd just agreed to participate in stewardship of their own products. Where do you suppose they get the money to fight against these city ordinances, etc.? From sales of their meds. Take a look at their quarterly profit reports.

Unfortunately, while this is all figured out, people will continue to be poisoned. Teens will continue to access med cabinets and abuse meds they find. And some people will get frustrated and flush or trash their unused meds, contributing to the demise of the environment whether it be miniscule or not.

In my opinion, the DEA has simply passed the buck on down the line; the buck not really having been theirs in the first place. I say that, not in their defense, because I don't agree with all that they've done; but, being familiar with the government funding process, I think their options were limited.

Jeanie Jaramillo, PharmD
Managing Director, Texas Panhandle Poison Center
Asst. Professor, Texas Tech UHSC School of Pharmacy
Director, Medication Cleanout
1300 S. Coulter St., Suite 105
Amarillo, TX 79106
(office): (806)414-9299
(mobile): (806)376-0039

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