May 15, 2014
Response Paper Workshop Three
As
a nation we are progressively facing an ethical issue, the proper disposal of
prescription drugs that have not been used or have expired. This has become an
urgent public health issue in the U.S. as the rate of prescription drug abuse
rises, along with accidental poisoning, and the prevalence of chemicals found
in the drinking water has gained nationwide attention. Most recent example of fluoride
in the water to prevent childhood tooth decay was voted down in Portland,
Oregon to keep chemicals out of the water. Consumers want to know how to keep
their water pure but at the same time they want to know how to keep their loved
ones and community at large safe from medication diversion. “Disposal of unused
prescription drugs, and controlled substances in particular, is a complicated
issue. Unused drug take-back programs are emerging across the country as one
strategy for reducing drug abuse, accidental poisoning, and flushing drugs
into the water supply. Current laws and regulations regarding controlled
substances, however, limit these programs from accepting all drugs without
strict oversight from law enforcement” (Avalere 2008).
The Drug Enforcement
Agency (DEA) has regulations that state who can handle controlled substances,
and more challenging how to dispose of unused or expired drugs. The law and
regulations specifically does not allow pharmacies, providers, and hospitals
from collecting controlled substances from patients. Meaning if a patient had
been already dispensed a controlled substance and on the rare occasion, a
provider may want to change treatment, the provider is unable to take
possession of the unused medications prior to the patient picking up a new
prescription. In these situations,
general rule of thumb is that the patient may be asked to dispose of the
medication in the provider’s presence. In compliance with U.S. Food and Drug
Administration (FDA) guidelines and the Controlled
Substances Act (CSA) opiate disposal down the drain sewer (flushing) is
an acceptable destruction option. That same destruction method would also apply
to fentanyl patches. Unused patches are to be removed from their pouches, folded
so that the adhesive side of the patch adheres to itself, and flushed down the
toilet.
Under
the Resource Conservation and Recovery Act (RCRA), the EPA regulates the production,
storage, transport, treatment, and disposal of pharmaceutical wastes that are
defined as hazardous. Some common examples of prescription medications that are
hazardous when disposing of them include nitroglycerin, warfarin, and some
chemotherapy agents. It is estimated that approximately that five percent of
pharmaceuticals are listed as hazardous. Local, state, and federal protocols
vary and control disposal practices. Law enforcement officers, under
supervision of the DEA, are able to accept controlled substances at take-back
events. Due to budgets these take-back events are held inconsistently across
the nation less than twice per year. The DEA has outlined proper disposal
methods on their website but, many patients hold onto unused/expired
prescriptions “just in case” or due to lack of education on how to dispose of
them properly.
As
can be imagined this ownership can pose several risks related to diversion,
accidental overdose, and ingesting of expired substances. The existence of
these unused or expired prescriptions are directly tied to the growing rates of
prescription drug abuse among Americans and teenagers in general. Teenagers
often succumb to Superman complex; invincibility, and/or mistakenly believe
that it is safer to use prescription drugs than street drugs. “Nearly 60
percent of people ages 12 and older obtain prescription painkillers for free
through friends or family” (Avalere 2008). The growing rate of prescription drug
abuse is propelling demand for a much needed thorough and functional drug
disposal program. Thanks in part to the White House Office of National Drug
Control Policy (ONDCP) National Anti-Drug Media Campaign more parents are aware
of this issue.
“To
date, scientists have identified numerous pharmaceutical compounds at
discernable concentrations in our nation’s rivers, lakes, and streams” (EPA, Aug. 2008). The
EPA has been researching how the drugs are entering waterways and what dynamics
contribute to the situation since 2007. The research on unused or expired
prescription medications does not include what has been excreted through human
waste or void. The EPA has also been
working diligently with local, state, and federal agencies to better understand
the consequences of surfacing chemicals or contaminants detected in our water
(drinking, waste, surface, and ground). As well as continues to actively
evaluate routes and levels of exposure, and potential effects on public health
and aquatic life. At this point in time, there is little data suggesting the
public and aquatic health is at risk due to these pharmaceutical chemicals. The
data does suggest there is more risk in diversion, abuse, and poisoning. Local,
state, and federal government really need to take on the responsibility for
achieving the goal of a controlled substances disposal system.
References
Avalere (2008). Safe disposal of
unused controlled substances: current challenges and opportunities for reform. Retrieved
from: http://www.ncdoi.com/osfm/safekids/Documents/OMD/SafeDisposalOfUnusedControlledSubstancesReport.pdf
American society of consultant pharmacists (2014). Pharmaceutical
waste practice resource center. Retrieved
from: https://www.ascp.com/articles/pharmaceutical-waste-practice-resource-center
Environmental protection agency (2007-2009). Health care industry
unused pharmaceuticals detailed 2007-2009 data collection and outreach.
Retrieved from: http://water.epa.gov/scitech/wastetech/guide/unusedpharms_index.cfm
Environmental protection agency (Aug 2008). Unused pharmaceuticals
in the health care industry: interim report. Retrieved from: http://water.epa.gov/scitech/wastetech/guide/unusedpharms_index.cfm
U.S. Department of justice drug enforcement administration office of
diversion control (Dec. 21, 2012). Rules – 2012. Retrieved from: http://www.deadiversion.usdoj.gov/fed_regs/rules/2012/fr1221_8.htm
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