The TCEQ's Pharmaceutical Disposal Study (S.B. 1757)

Overview Review of Pharmaceutical Study Report Sources of Pharmaceuticals Current Disposal Methods Alternative Disposal Methods Analysis and Recommendations for Disposal Methods

Senate Bill 1757 Project Passed in 81 st Legislative Session, 2009 TCEQ shall study and make recommendations regarding the methods to be used by consumers, health care providers, and others for disposing of unused pharmaceuticals so that they do not enter a wastewater system. Report turned into legislature November 2010

Objectives Specifically, TCEQ shall consider: (1)the methods currently used in Texas (by consumers, health care providers, and others); (2) alternative methods used, including methods used in other states; and (3)the effects on public health and the environment of the various methods used for that purpose. (4)The report must also provide an analysis of the feasibility of implementing the recommended disposal methods on a statewide basis.

Intent of Advisory Group To provide a forum for TCEQ to gather appropriate and sufficient information to understand the: –methods currently used in Texas to dispose of unused pharmaceuticals; –amount and type of unused pharmaceuticals currently disposed; –factors driving disposal practices; –regional differences in disposal practices; and –desires of consumers, the health-care industry and others for alternative disposal methods. pdw/pdagroup

Consumers 1-day collection events Mail-back HHW collection Drop boxes/kiosks Trash disposal after rendering undesirable Providers Best management practices Reverse distribution Educational strategies Optimizing compliance w/ current rules Treat all as hazardous Segregate waste Rule/regs Ban on drain disposal Limited dispensing supplies Universal Waste rule changes Changes existing TCEQ rules Require take-back events Enhance enforcement on current rules Alternative Methods Considered by Study Team

Study Report Review Pharmaceuticals in the Environment

General Intent of SB-1757 is to consider: Intentional disposal of unused drugs (flushed down toilet or sink) FEWER Pharmaceuticals enter wastewater stream Medicines consumed & not completely metabolized (or metabolized into other forms) Major: Excretion Minor: Sweat & vomit

Sources of Pharmaceuticals in the Environment Agricultural Sources Manufacturing Landfills

Occurrence Data South-central Texas WWTP influent /effluent study: Most pharmaceuticals were completely removed (except carbamazepine) as a result of WW treatment. None detected in treated drinking water supply. North Texas DWTP raw/treated study: Pharmaceuticals were detected in raw water. However, none (except an anti-anxiety drug) were found above detection limits in the treated drinking water. Parts per trillion levels.

Occurrence Data Landfills in Maine  Maine Department of Environmental Protection  Tested lechate from three operating lined landfills  47 out of 135 compounds were detected in the lechate at least one of the landfills  Carbamazepine and Ibuprofen along with 18 other compounds were detected in the lechate of all three landfills

Occurrence Data  Biosolids  USGS tested commercial biosolid products  Detected 55 of the 87 organic compounds in at least one of the products tested  25 compounds were present in every sample three were pharmaceuticals

Occurrence Data Soils USGS tested soils irrigated with wastewater effluent Analyzed the soil core samples during irrigation season samples for 19 pharmaceuticals Pharmaceuticals were detected

Human Health Impacts EPA reports no adverse human health effects from consuming water with ppb levels of pharmaceuticals. For most pharmaceuticals, drinking 2 L/day of the water (containing pharmaceuticals at the low levels seen in drinking water) over a lifetime would not deliver the equivalent of a single prescribed dose.

Disposal Surveys To collect a baseline set of information documenting: –how health-care providers, consumers and others currently dispose of unused pharmaceuticals in Texas; –how much of what is being disposed of; –why certain disposal practices are chosen; and –what the preferred disposal practices are. Distributed through Advisory Group stakeholders.

Disposal Surveys (1) In-patient Health-Care Providers (hospitals, clinics) (2) Veterinary Care Providers (3) Pharmacies (4) Waste Disposal Operations (5) Pharmaceutical Manufacturers (6) Ranchers/Farmers (7) Consumers (8) Drinking Water & Wastewater Utilities (9) Local Governments (Solid Waste) (10) In-home care providers (11) Law Enforcement (12) Research Institutions (13) Long-Term Care Facilities

Findings - Utilities DW/WW utility survey questions related to: If the utility has sampled their WW or DW for pharmaceuticals. If the utility has been involved in consumer drug return programs & if so, why. How the State can provide information on this topic to utilities. 85 DW/WW utilities responded to survey Utilities well represented in Advisory Group AWBD, AWWA, WEAT, many municipalities.

Utilities represented in Advisory Group appreciated that intentional flushing is the minor source of pharmaceuticals in water (compared to excretion). However, utilities generally support avoiding drain disposal. E.g. consumer drug take back programs. Obvious need for accurate information to be provided: (1) Significance of the data (consumer relations) (2) Guidance if systems want to participate in programs

Findings - Utilities Most (75%) of utilities surveyed said they’ll wait for EPA/Texas to regulate pharmaceuticals in water before they consider changing treatment decisions. 4% of utilities have collected/analyzed drinking water samples for pharmaceuticals. ~ 20% of utilities have developed or supported some sort of consumer drug take-back program for pharmaceuticals.

Current Disposal Methods Review Numerous Disposal Management Practices Health care providers (including hospitals)use a combination of methods to management unused pharmaceuticals Reverse Distributors primarily incinerate Consumers tend to use trash disposal

Current Disposal Methods Review Nursing Homes, assisted living, and some hospices manage all unused pharmaceuticals as medical waste Ranchers, and farmers typically rely on veterinarians or a combination of disposal methods

Current Disposal Methods Review Current Disposal Methods were driven primarily by a couple of factors: Current Regulatory Structure Industry Practices Type of pharmaceutical

Alternative Disposal Methods Review TCEQ obtained information on alternative disposal methods by: Conducting a literature review to determine what alternative methods were be utilized Discussions with stakeholders during the advisory group meeting.

Alternative Disposal Methods Review Single Day Collection Events: Typically a drive through or drive up to event Type of drugs excepted can vary based on staff training and availability of law enforcement

Alternative Disposal Methods Review Single Day Collection Events: Means to remove unused drugs from the home Opportunity to do public outreach Provides opportunities for partnership Depended on having all available resources Arrangements for disposal is necessary Need for Law Enforcement presence

Alternative Disposal Methods Review Permanent Collection Facilities: (Drop Boxes or Kiosks) Located either in a law enforcement facility or a pharmacy Limit on accepting controlled substances unless in law enforcement facility

Alternative Disposal Methods Review Permanent Collection Facilities: (Drop Boxes or Kiosks) Means to remove unused drugs from the home Raises Awareness on amount of unused Pharmaceuticals Disposal and transportation already established

Alternative Disposal Methods Review Mail-Back Programs: Prepaid enveloped offered in pharmacies, clinics, and other health care facilities. Consumers place unused pharmaceuticals in the envelope for mail back to disposal location.

Alternative Disposal Methods Review Mail-Back Programs: Removes drugs from the household to prevent Poisonings Higher level of access for consumers Provides confidentiality

Summary Render Undesirable and Dispose of in Municipal/Household Trash: Practice of rendering drugs undesirable prior to disposal into municipal trash is not a common practice Alternative Disposal Methods Review

Render Undesirable and Dispose of in Municipal/Household Trash: Simple disposal method Available to all consumers Consistent with current regulatory requirements Requires continued public outreach

Recommendations for Disposal Methods Promote Municipal Trash disposal Develop a Strong Education Program Encourage he voluntary use of take-back programs

Conclusions Additional research needed to develop analytical methods to distinguish sources of unused pharmaceuticals Further research needed on the impact of unused pharmaceuticals on human health and the Environment Education programs will provide an opportunity to impact the amount of pharmaceuticals intentionally disposed of into the wastewater stream

Questions? TCEQ Contacts: – Elston Johnson (project lead) –Daniel Ingersoll