GUIDANCE FOR COLLECTING UNWANTED HOUSEHOLD PHARMACEUTICALS

 

Introduction

Unwanted household pharmaceuticals represent an increasingly problematic waste stream both health wise and environmentally.  Household pharmaceuticals, which include both prescription and over the count drugs, come in many shapes, sizes and forms, including pills, liquids, sprays, ointments, etc.  Conventional disposal methods for household pharmaceuticals have included flushing them down the drain into the conventional sewer or disposing of them in the regular solid waste stream.  Increasing evidence has suggested that this is not only environmentally unsound but it is potentially creating antibiotic resistant strains of bacteria and viruses.  As a result, many states, municipalities and health care organizations are looking at alternative methods for managing this common waste stream.

Regulatory requirements

Due to the various regulatory structures of pharmaceuticals, initial collection efforts have confronted many barriers to proper management. Some of these barriers have included Controlled Substances and Solid and Hazardous Wastes management rules and regulations.

Controlled Substances

Some household pharmaceuticals are regulated by the US Drug enforcement Administration (DEA).  These pharmaceuticals, which include many of the narcotic prescription drugs, are strictly regulated as to their prescription, dispensing, use and ultimate disposal.  As a result, these pharmaceuticals may be collected by a solid waste entity but once collected these pharmaceuticals must be immediately surrendered to law enforcement.  The law enforcement officer must then inventory and manage these controlled substances according to applicable DEA guidelines.

Solid and Hazardous Wastes 

When collection entities begin to take waste pharmaceuticals from businesses (i.e., nursing homes, doctors offices, pharmacies, etc), the household exemption from hazardous waste regulations does not apply.  What this means is that businesses must manage their waste pharmaceuticals according to all applicable laws and regulations.  These include the Drug Enforcement Agency (DEA) for regulated narcotics, Solid Waste Management Rules for Regulated Medical Wastes (http://www.anr.state.vt.us/dec/wastediv/solid/pubs/MedWaste.pdf) and Hazardous Waste Management regulations for any listed or characteristic waste pharmaceuticals (http://www.anr.state.vt.us/dec/wastediv/rcra/hazregs/VHWMRFull_wCover.pdf), to name a few.

If Waste Household pharmaceuticals are collected only from households, they are exempt from Hazardous waste regulations.  It is important to note, that any waste pharmaceuticals collected from businesses are subject to all applicable VT Hazardous Waste Regulations, Drug Enforcement Agency (DEA) Laws and Solid Waste Rules for Regulated Medical Wastes

For collection events accepting only unwanted household pharmaceuticals, the collecting entity must submit an Insignificant Waste Management Event Approval Application (IWMEA).  This application, which “may only be issued if the Secretary finds that the collection event will not result in a threat to the public health and safety or to the environment, and will not create a nuisance.”, is available at   http://www.anr.state.vt.us/dec/wastediv/solid/permit.htm.

 

Collection program requirements

Due to the increasing demand for collection programs for unwanted household pharmaceuticals, the Vermont Agency of Natural Resources (ANR) suggests that entities implementing collection programs include the following in developing their unwanted household pharmaceutical collection events:

 

1. Complete and submit an IWMEA application including the date and length of the proposed collection program, the location, proposed site security, site map, site specific safety, accident and contingency plan and the ultimate disposal of any unwanted household pharmaceuticals collected.
2. Obtain the services of a licensed pharmacist, to indentify, count and segregate unwanted household pharmaceuticals.
3. Obtain the services of certified law enforcement personnel for site security and management of DEA regulated substances.
4. Obtain the services of a licensed Hazardous waste contractor for proper hazardous waste disposal (preferably hazardous waste incineration).
5. Partner with a local solid waste planning entity and/or a local healthcare institution.
6. Address the potential for any sharps and/or any other regulated medical waste being delivered to the collection event. 
7. Submittal of a report on the amount and type of waste pharmaceuticals collected and the number of participants.