Vol. 14 Issue 2, Spring/Summer 2009
By Carmi Orenstein, MPH, Editor
A year ago in our Spring 2008 issue we wrote about “Following the News on Pharmaceuticals in Drinking Water.” Here we offer an update on some of the efforts in New York State (NYS) to keep pharmaceuticals out of the water that have taken place since then.
NYS bill passed, public information campaign initiated
A bill that requires the New York State Department of Environmental Conservation (DEC) in cooperation with the Department of Health (DOH) to conduct an extensive public information campaign on the proper storage and disposal of prescription and over-the-counter (OTC) drugs was passed in late Fall 2008. The bill also requires the DEC to develop a notice containing proper disposal information to be displayed in every pharmacy and retail business with more than 3,000 square feet of retail space that is authorized to sell drugs. The new law authorizes DEC to establish or enter into contracts for the establishment of demonstration programs to determine the most effective methods of drug disposal. Assemblyman Steven Englebright states on his website that his original proposal (introduced on the Senate side by Senator James Alesi) “was more far-reaching and would have established a drug collection system statewide to be conducted and paid for by the pharmaceutical companies. However, this new law is a good first step toward a comprehensive drug collection program, and I am hopeful we can build on our progress during the next few years.”
The “Don’t Flush Your Drugs” campaign (www.dontflushyourdrugs.net) consists of guidance for pharmacies and a poster for display. The poster is required to be “conspicuously displayed” as of March 24, 2009. The website has additional information including background on why we are now being instructed not to flush pharmaceuticals (when previous guidance often suggested otherwise, since flushing was considered the best way to keep drugs out of the hands of children). It also addresses why most community household hazardous waste (HHW) collection days do not accept medications. This latter issue is the reason that policy emphasis is now also being placed on community “take-back” programs. Explains the DEC, “to ensure that controlled substances (narcotics) are properly disposed of, the collection must ... occur separately from the other HHW and a law enforcement official must be present to take possession of those drugs.”
Local and regional pharmaceutical take-back programs growing in numbers
Westchester County is providing an excellent example of utility, convenience, and success for a community take-back program for pharmaceuticals. In the past year and a half, Westchester County, partnering with the Westchester/Rockland Society of Pharmacists, has collected 4,250 pounds of unused medications from 1,600 households at drive-through events at multiple locations around the county. These events are linked with the county’s roving Household Recycling Days. Deputy Commissioner Louis Vetrone states that the program is “really taking off” and even further expanding this year. Vetrone and Environmental Project Coordinator Peter Costa describe a very comprehensive outreach program involving automated recorded calls, print ads and brochures, and email news blasts. These events have had increasing participation, but they also plan to add events at senior centers, in order to reach that crucial group for whom the drive-through events may not be as appropriate. See http://www.westchestergov.com/environment_householdrecyclingschedule.htm for the schedule of their events countywide.
On Long Island, Suffolk County Legislator Lynne C. Nowick is spearheading action on pharmaceutical take-backs. Her actions, together with Stony Brook University, Stony Brook University Medical Center, and other partners, supported the New York Sea Grant (NYSG) program in the planning of a community event this past April in Setauket, where almost 500 pounds of unwanted medicines were collected from 140 participants. Legislator Nowick has also worked with hospitals to sponsor take-back programs, including a yearly event to take place at St. Catherine of Siena Medical Center in Smithtown. Larissa Graham, the Long Island Sound Study Coordinator for the NYSG, collected evaluation data from their April event and found that 34 towns were represented, with some participants traveling over 45 miles to attend the event. All participants that filled out the evaluation survey said that they would attend another event, and the majority wanted to see this type of event held once a year. Participants also expressed that they would like to see legislation at the town or village level to collect unwanted medicines. Ms. Graham is currently developing a report designed to help other entities establish such collection programs in response to calls she has received requesting such guidance. “We are more than happy to lend advice to other agencies that are interested in organizing a similar event,” she says. To obtain their report about how to hold a successful pharmaceutical take-back program, please visit www.nyseagrant.org. In Nassau County, a town-run collection by the North Hempstead Solid Waste Management Authority in Port Washington was held in late June. (Contact Frances Reid at 516-526-2572 or firstname.lastname@example.org for information on future events.)
Ray Krupski, Director of Pharmacy at Eastern Long Island Hospital, describes a unique program in which anyone can drop off unused pharmaceuticals at their pharmacy, seven days a week, from 10:00am to 3:00pm. Situated on the far eastern end of Long Island (with community members often arriving by boat to the facility), the leadership at the hospital felt it important to make this contribution to protecting their ecosystem and they conceptualized this program over a year ago. Because this is an ongoing collection and having law enforcement at the collection is not feasible, the program does not accept controlled substances. (It also does not accept chemotherapy drugs.) There are plans, however, for a community collection in October that would include law enforcement and therefore be able to include controlled substances. Mr. Krupski also does outreach to seniors in the community to build awareness of the program and to teach about the importance of proper disposal of expired medications. He regularly receives calls from other pharmacies interested in setting up such a program.
Pharmaceuticals collected at all of the above events are destroyed by incineration. In many cases they are dealt with in the same manner as drugs confiscated by law enforcement. In the case of Eastern Long Island Hospital, the take-back program links with the hospital’s existing setup for the facility’s expired medications with Guaranteed Returns (a pharmaceutical reverse distribution vendor).
DEC engaging in cooperative activities
In May of 2008, DEC and DOH hosted a roundtable with stakeholders to discuss management options for unwanted drugs. The proceedings for this meeting can be downloaded at http://www.dec.ny.gov/chemical/45118.html (on the right sidebar of the web page, “Related Links”). This meeting not only addressed management of household/individual disposal of medications (such as the programs described above address), but also the vast issues associated with institutional pharmaceuticals management. One presentation focused on the state of practice in long-term care facilities where “common practice ... is to flush,” (as is still approved by the DOH for these facilities). “While alternative management systems exist ... they are costly and lacking a mandate or a strong education program, and unlikely to gain administrative support,” explained the presenter, Holly Vaughn of the Fort Hudson Nursing Home. The following presenter, Nancy Leveille of the NYS Health Facilities Association, said that, “there is potentially less waste of pharmaceuticals in a hospital setting than a nursing home/long-term care facility since hospitals have in-house pharmacies and tend to dispense medication by the individual dose.” Apart from approved destruction methods for controlled substances however, flushing is still common for other medications. Important steps outlined at the meeting for hospitals and institutional pharmaceutical waste management included more regulatory clarity and education and the need to revise Medicare Part B to allow for crediting and reuse of unused medication. The DEC also pointed out that even the most advanced wastewater treatment used in NYS does not effectively remove pharmaceutical contaminants and that the state should “continue to monitor and support research to develop technologies to address this and other emerging contaminants.”
Concerns with the use of triclosan addressed in new fact sheet
In 2007 we interviewed Dr. Anthony Hay on his work addressing contaminants in sewage sludges. He discussed triclosan, a compound that shows up increasingly in sludges, ecologic samples, and human blood, urine and breastmilk. Triclosan is a widely used biocide that is present in almost all antibacterial soaps, as well as many other products. According to Dr. Hay, as well as a 2005 FDA advisory panel and a 2000 report from the American Medical Association, there is no sound scientific support for its use, and it may pose hazards (such as antibiotic resistance and ecologic and health concerns). A new fact sheet outlining “The Trouble with Triclosan” is available at http://www.foodandwaterwatch
what-is-lurking-in-your-soap. It was produced by two organizations: Food & Water Watch and Beyond Pesticides.
In a letter to the US Environmental Protection Agency dated May 27, 2008, the DEC Commissioner Alexander Grannis stated, “The problem of pharmaceuticals and personal care products in water systems is multifaceted with no single solution, “ and that the Pharmaceuticals Working Group established by the DEC “has initially focused on reducing the disposal of unused pharmaceuticals into the waters of New York State.” Looking beyond state lines for partnerships, the DEC is also participating in the New England Interstate Water Pollution Control Commission’s work group on pharmaceuticals, and continuing its work with the US Geological Survey, which has reported for over a decade on the presence of human and veterinary drugs in waterways. Also on a national level, DEC is participating in the Product Stewardship Institute’s pharmaceuticals initiative. Commissioner Grannis’ letter to the EPA makes an appeal for “a more proactive and precautionary approach toward limiting the levels of contaminants that enter in sources of drinking water...” and outlines the deficiencies of federal regulations currently in place.
With over 225 million prescriptions filled annually in NYS, no access to take-back programs for most of the State’s residents, barriers to carrying out best practices in institutions, and regulatory deficiencies, clearly this is just the beginning of the action needed for the management of pharmaceutical waste.