[Pharmwaste] Thanks Walgreens! updated spreadsheet from JV

Volkman, Jennifer (MPCA) jennifer.volkman at state.mn.us
Thu Nov 1 17:32:00 EDT 2018

Yesterday's attachment had errors (thanks for the comments) and I added disposal info from another home disposal option, slight reformat. Please delete yesterday's version.



From: Pharmwaste <pharmwaste-bounces at lists.dep.state.fl.us> On Behalf Of Volkman, Jennifer (MPCA)
Sent: Wednesday, October 31, 2018 2:52 PM
To: 'Ed Gottlieb' <EGottlieb at cityofithaca.org>; philip.caruso at walgreens.com
Cc: emily.hartwig at walgreens.com; lev.facher at statnews.com; Cynthia Finley <CFinley at nacwa.org>; pharmwaste at lists.dep.state.fl.us; Silverman, Ed <ed.silverman at statnews.com>
Subject: Re: [Pharmwaste] Thanks (+ a ? & suggestion) to Walgreens for commiting to a no cost, safe drug disposal option in all of its pharmacies!

In the interest of being helpful, attached are my calculations for MN costs using different management methods, they are very similar to the estimates Ed included below. Incineration is our preferred method of disposal for medications, as it is in most states.

States that have passed product stewardship legislation, where the manufacturers pay the cost of implementing collection, do not allow the distribution of the shake and toss pouches as a qualifying disposal option. They only allow options that comply with DEA regulations, which are the collection bin system to incinerators and mail back envelopes. The use of pouches cost an order of magnitude more than bin collection and do not bind 100% of the API with normal use. (if anyone has test results showing they do, please forward them to me).

The mail-back envelopes are much easier for customers to use and hold far more pill weight (one envelope will hold at least 8-16 times the volume as a pouch), so the per pound cost is also much more reasonable than pouches. Almost no one has only 45 or less pills to manage, so providing one pouch per person won't generally be enough for them to use it properly (not overfill). Envelopes may be the low cost option per pound for some law enforcement entities in some states if transport to a HW incinerator is the only option for materials collected from bins. I don't have the full cost for the use of bin collection systems by pharmacies because I don't know their labor costs, but they should be less than for law enforcement here in MN who does all of the management vs. hiring a service to manage bins.

We have also seen that shake and toss pouches are disposed in collection bins here in MN, which obviously results in an increased cost to those with bins. We have spent years educating people to take their unused pharms to a collection bin, knowing it was the low cost option to reduce the amount of medications available for misuse.

Kudos to Walgreens for being the first national chain to invest in collection bins! You've done great work here in Minnesota and we are thankful! Please contact me if you have any questions on implementation here in Minnesota.

Jennifer Volkman
Statewide HHW Program Coordinator
Minnesota Pollution Control Agency
Jennifer.volkman at state.mn.us<mailto:Jennifer.volkman at state.mn.us>

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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: Wednesday, October 31, 2018 10:51 AM
To: philip.caruso at walgreens.com<mailto:philip.caruso at walgreens.com>
Cc: Cynthia Finley <CFinley at nacwa.org<mailto:CFinley at nacwa.org>>; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>; emily.hartwig at walgreens.com<mailto:emily.hartwig at walgreens.com>; Silverman, Ed <ed.silverman at statnews.com<mailto:ed.silverman at statnews.com>>; lev.facher at statnews.com<mailto:lev.facher at statnews.com>
Subject: [Pharmwaste] Thanks (+ a ? & suggestion) to Walgreens for commiting to a no cost, safe drug disposal option in all of its pharmacies!

Dear Mr. Caruso,

Kudos to Walgreens for being the first chain pharmacy in the U.S. to actively promote take-back for the safe disposal of unwanted household medications!  Walgreens instillation of kiosks in your 24 hour pharmacy locations was a significant commitment that made safe disposal far more convenient for members of those communities.

Walgreens new commitment (press release below) to provide a year-round, safe drug disposal option in all its pharmacies, at no cost to individuals, is a great service to our country!  Thank you so much!

Can you please explain Walgreens choice of a disposal option under this new initiative?  Why home disposal pouches rather than installing more kiosks or providing mail-back envelopes?  You may recall that I emailed you about this on January 3, 2018.

My research shows that kiosks have the lowest disposal cost per pound of unwanted medications ($2-5/lb or about $0.01/prescription), mail-back envelopes cost significantly more than that, and home disposal pouches have, by far, the highest per pound disposal cost ($50-100/lb)*.

Along with the very high per pound disposal cost of home disposal products, there are other concerns with the use of these technologies.**  When explaining Walgreens choice of home disposal pouches, can you please include a response to these concerns?  Thank you.

Your press release notes, "Both programs make the disposal of medications - including opioids and other controlled substances - easier and more convenient while helping to reduce the misuse of medications and the rise in overdose deaths."  In future, you may want to consider adding a third benefit.  Take-back programs also help reduce the rate of accidental poisonings.

Walgreens, thanks again for your leadership in promoting safe disposal of unwanted household medications!  Your consideration of my questions is very appreciated.  Please let me know if you have any questions.


Ed Gottlieb
Chair, Tompkins County Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY  14850
(607) 273-8381

* Calculation of the estimated per pound cost for two major brands of home disposal pouches:

Rx Destroyer uses Advil (200 mg IBU) pills to determine capacity.  A 200 mg IBU pill weighs 0.315 gm.
This will be used as the average weight for a "pill" in this calculation.

Deterra retail price (multiple vendors) for a disposal pouch that holds 45 pills = $6.50
[Manufacturer's list price reported as $5.99.]
45 x 0.315 gm = 14.175 gm = 0.0313 pounds @ $6.50 = $207.67/pound (retail)
Assuming a wholesale price of $3.33 (the PA AG paid almost $1 mil for 300,000 pouches), the disposal cost is $106.49/pound

Rx Destroyer, wholesale price of 4 oz size  $100/24 bottles + shipping.
If shipping is $8, 108/24 = $4.50/bottle; A 4 oz bottle holds 50 Advil
50 x 0.315 gm = 15.75 gm = 0.0347 pounds @ $4.50 = $129.68/pound

Estimated wholesale cost, to treat a pound of medication, is $106 & $130, for Deterra & Rx Destroyer, respectively.  Assuming a large bulk order from Walgreens gets a much larger discount, I imagine the cost is still above $50/pound, still the most expensive disposal technology.

**Concerns with home disposal technologies:  https://cdn.ymaws.com/www.productstewardship.us/resource/resmgr/GoToGuide/In-Home_Drug_Disposal_Risks_.pdf


Walgreens to Provide Free Safe Medication Disposal Option in All Drugstores in 2019
24 October 2018
Company Has Collected More than 400 Tons of Unwanted Medications to Date
DEERFIELD, Ill., October 24, 2018 - Walgreens today announced it is expanding its effort to combat the opioid epidemic as it encourages Americans to clean out their medicine cabinets in advance of Drug Enforcement Administration sponsored National Prescription Take Back Day on Saturday October 27. To complement its existing safe medication disposal kiosk program, Walgreens has committed to providing a year-round safe drug disposal option in all its pharmacies at no cost to individuals. Beginning in spring 2019, all Walgreens pharmacies that do not offer a safe medication disposal kiosk will stock a take home safe medication disposal kit in the pharmacy that will be available at no cost upon patient request.
"We are excited to build upon our efforts to make safe medication disposal easier and more accessible to more Americans," said Rick Gates, Walgreens senior vice president of pharmacy and healthcare. "Both of these programs offer the best way to ensure medications are not accidentally or intentionally misused as we continue our efforts to combat the opioid epidemic."
Walgreens continues to work with AmerisourceBergen, Pfizer and Prime Therapeutics to expand its safe medication disposal kiosk program to 1,500 drugstores across the country. Since the program began, more than 400 tons of medications, which is more than the weight of a 777 jet, has been collected and safely disposed of.
Both programs make the disposal of medications - including opioids and other controlled substances - easier and more convenient while helping to reduce the misuse of medications and the rise in overdose deaths.
Beginning next month, Walgreens will install 14 safe medication disposal kiosks throughout Missouri after working to update rules that will allow for the program's implementation in the state. When installation is complete, safe medication disposal kiosks will be available in select Walgreens across 46 states and Washington D.C.
As part of its continuing effort to combat drug abuse, Walgreens will again participate in the National Prescription Drug Take Back Day held on October 27 where select Walgreens stores throughout the country will serve as a collection point for law enforcement to collect unwanted, unused or expired medications for safe disposal.
Walgreens continues to increase access to naloxone, a lifesaving medication that if administered in time can reverse the effects of an opioid overdose. The medication is now available without a physician's prescription in 48 states including the recent addition of all of its Delaware pharmacies.
To learn more of Walgreens efforts visit Walgreens.com/combatdrugabuse.
About Walgreens
Walgreens (walgreens.com), one of the nation's largest drugstore chains, is included in the Retail Pharmacy USA Division of Walgreens Boots Alliance, Inc. (NASDAQ: WBA), the first global pharmacy-led, health and wellbeing enterprise. Approximately 8 million customers interact with Walgreens in stores and online each day, using the most convenient, multichannel access to consumer goods and services and trusted, cost-effective pharmacy, health and wellness services and advice. As of August 31, 2018, Walgreens operates 9,560 drugstores with a presence in all 50 states, the District of Columbia, Puerto Rico and the U.S. Virgin Islands, along with its omnichannel business, Walgreens.com. Approximately 400 Walgreens stores offer Healthcare Clinic or other provider retail clinic services.
View source version on businesswire.com https://www.businesswire.com/news/home/20181024005781/en/
Phil Caruso
philip.caruso at walgreens.com<mailto:philip.caruso at walgreens.com>
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