Presentation Abstract

Washington State and King County’s Perspective on Pharmaceutical Stewardship
Dave Galvin
King County Department of Natural Resources and Parks, Seattle, WA

Local governments across the country are faced with having to address the nascent and complex issue of proper management of waste pharmaceuticals — the latest “waste du jour” — as part of their continued but unhappy role at the end of the consumer product life cycle. We are just now learning about pharmaceutical chemicals turning up in our waters, potentially affecting our fish…and us, too? We are aware that they are showing up in wastewater treatment systems, effluent discharges, and biosolids. Also, we are discovering that there is a hard-to-quantify but potentially huge amount of medications that go unused, and thus become a significant waste management issue, one we want to keep out of wastewater and the environment while we separately figure out how to deal with the substances that get there through regular use. Many pharmaceuticals designate as hazardous waste under the Resource Conservation and Recovery Act (RCRA); others designate under more stringent state regulations, such as those in Washington. Even those pharmaceuticals that do not designate as official hazardous wastes represent problematic chemicals in wastewater systems and the environment.

The vast majority of people in the Seattle area, as well as in Washington State and throughout the country, want a safe, environmentally acceptable way to dispose of old/unwanted/unused pharmaceutical products. Neither flushing nor solid waste disposal are acceptable long-term solutions. Dependence on local household hazardous waste collection services is not the answer. Now is the time to develop a forward-looking, national system via a product stewardship model.

At the moment, only one local government program in Washington State is actively collecting waste pharmaceuticals. The Clark County ( Vancouver, WA, area) household hazardous waste program accepts waste pharmaceuticals and has arranged with local retail pharmacies for in-store take-back. Controlled substances are handled via the local sheriff. Because budgets and staffing are low, publicity is restrained and participation to date has been very low. (http://www.co.clark.wa.us/recycle/documents/Medical%20Waste/Medications.pdf)

Two large pilot projects are in development at this time in the Seattle area. Both will test a pharmacy take-back model: one in a private, regional retail chain (Bartell Drugs) and the other at internal pharmacies of a large regional HMO (Group Health Cooperative). In both cases, we are working with representatives to develop collection containers and protocols. As is true across the country, one of the challenges we face is to address Drug Enforcement Administration (DEA) requirements for handling controlled substances. Other concerns include: who can and should take possession of waste medications from consumers (pharmacists? sheriffs? reverse distributors? wholesale service providers that collect from a secure bin? mail-back to a secure entity?) How would these entities sort the wastes for designation (RCRA hazardous, state-only hazardous, non-hazardous, controlled) and transport the material to final disposal?

A national listserv has been set up by state and local waste management personnel to answer questions and share information; it is hosted by the State of Florida (http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste) . Also, work with the Product Stewardship Institute is underway to develop a national dialogue of all major stakeholders (http://www.productstewardship.us) .

The United States needs to address this issue in a comprehensive and systematic way. It should not be left to local governments to figure out how to handle these complex wastes. A product stewardship approach is essential. Retail take-back, with handling by the retail entities, reverse distributors, manufacturers, or others, is the preferred model, so that it is convenient to the consumer, comprehensive, safe, professionally managed, and legal. It should be paid for by those marketing the products, not by local ratepayers. Look at the example across the border to the north: British Columbia has a simple, comprehensive medications take-back program via pharmacies that has been operating for almost 10 years and is privately managed with little governmental involvement save oversight (http://wlapwww.gov.bc.ca/epd/epdpa/ips/meds/meds2003.html) . The U.S. Environmental Protection Agency must support a comprehensive approach to pharmaceutical waste management. DEA must provide flexibility regarding its controlled substance regulations to allow for simple, safe solutions to this significant national problem.

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