The Environmental Protection Agency (EPA) public comments on the draft guidance entitled, Best Management Practices for Unused Pharmaceuticals at Health Care Facilities (attached). This guidance is targeted at hospitals, medical clinics, doctors' offices, long-term care facilities, and veterinary facilities to help decrease the amount of pharmaceuticals that are discharged to water bodies.

The EPA has drafted the guidance document for health care facilities which describes:

• Techniques for reducing or avoiding pharmaceutical waste
• Practices for identifying and managing types of unused pharmaceuticals
• Applicable disposal regulations

The AVMA applauds the EPA for its efforts in creating the "Guidance Document: Best Management Practices for Unused Pharmaceuticals at Health Care Facilities." The Guidance, which is organized, comprehensive, and user friendly, is expected by the AVMA to be a useful resource for the veterinary profession. Environmental responsibility is important to the AVMA. As part of this, the AVMA supports education of and understanding by veterinarians and the public regarding control and prevention of environmental impacts of pharmaceuticals as well as other substances. In addition, the AVMA encourages promotion of scientifically-based, environmentally sensitive practices of veterinary medicine to ensure a viable ecosystem for future generations.

The veterinary profession is a minimal contributor of pharmaceutical waste in the water systems. Nonetheless, the AVMA worked closely with the EPA to establish in 2009 the AVMA's "Best Management Practices for Pharmaceutical Disposal," which provides an additional resource and model for veterinary practices to further reduce the small amount of pharmaceutical waste being generated.

Although most private veterinary practices are conditionally exempt small quantity generators under the Resource Conservation and Recovery Act, the expanded detail and clarification offered by the EPA Guidance on pharmaceuticals which are classified and regulated as hazardous substances and wastes are extremely beneficial.

• September 8, 2010; Federal Register Notice (PDF)
• November 4, 2010; Full AVMA Response (PDF)
• EPA Draft Guidance – "Best Management Practices for Unused Pharmaceuticals at Health Care Facilities" (PDF)
• AVMA – "Best Management Practices for Pharmaceutical Disposal "
• EPA – Health Care Industry Unused Pharmaceuticals Detailed Study; 2007-2009 Data Collection and Outreach (PDF)
• EPA Interim Report – Unused Pharmaceuticals in the Health Care Industry (PDF)