By Sandy Jensen, Riverkeeper Intern
Medications that are non-hazardous can lawfully be disposed of through a municipal solid waste system. But because the intent of a pharmaceutical take-back program is to keep meds out of the traditional waste stream, the better method is to dispose of medications as hazardous waste. Hazardous waste regulation is incredibly complex, but from a strictly legal standpoint, take-back program coordinators can simply leave the details of handling to a hazardous waste contractor. There is an array of disposal options, so consulting with potential contractors about their practices for disposal of pharmaceutical waste is recommended. Usually, hazardous waste is treated then landfilled or incinerated.
In this model, consumers can bring their medications to a continuous drop-off location such as a bin or other secure container. Pharmacies can act as a convenient drop-off site and residents can bring their unwanted meds to the pharmacy at their convenience. A major drawback to this model is that the Drug Enforcement Agency (DEA) usually will not allow controlled substances to be collected in this manner. The DEA has been relatively uncooperative in this regard and in at least three cases, they have refused to grant a waiver to this type of program. In Kendall County, Ill., the drop-off location is the county police department office where they accept unwanted medications including both controlled substances and legend drugs. The police package legend and OTC medications in containers supplied by the Illinois EPA, who will then coordinate pick-up with their HHW contractor. The police department destroys controlled substances the same way they do drugs confiscated in the course of regular law enforcement.
The process of moving manufactured drugs backward through an established supply chain. Reverse distributors take outdated or unwanted pharmaceuticals from DEA retailers such as pharmacies, institutions and wholesalers, and return them to the manufacturer for credit and proper disposal. British Columbia’s Medications Return Program is an example of a product stewardship approach. That program is implemented and funded by pharmaceutical brand-owners in cooperation with more than 800 pharmacies. Producer responsibility has taken hold in some countries, but has yet to become a serious movement in the U.S. and is likely to be an uphill battle.
One alternative that has potential to keep a large amount of drugs out of the waste stream is drug recycling. A recycling program is a system whereby unused, unopened pharmaceuticals are collected and redistributed to low-income community members or other designated populations. Such a system, however, is fraught with concerns about safety, liability and compensation. For these reasons, most programs that have been implemented have done so only after legislative action established safety standards and addressed liability concerns. California, Wisconsin, Nebraska and Oklahoma have drug-recycling programs. Recycling programs present an opportunity to save millions of Medicaid dollars. One study found that the value of unused drugs in American long-term care facilities amounted to $378 million a year.
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