Regulatory Brief

 Study of Unused Pharmaceuticals from Medical and Veterinary Facilities


Formal title: Docket Number [EPA-HQ-OW-2008-0517, FRL-8703-1] Agency Information Collection Activities: Proposed Collection; Comment Request; Study of Unused Pharmaceuticals from Medical and Veterinary Facilities (NEW), EPA ICR Number 2316.01, OMB Control No. 2040-New

The Environmental Protection Agency (EPA) announced its proposed collection and comment request of the Study of Unused Pharmaceuticals from Medical and Veterinary Facilities.

Brief Description and AVMA Response:

The EPA announced it is planning to seek government clearance to survey veterinary hospitals on disposal of unused pharmaceuticals. The EPA is particularly interested in characterizing pharmaceutical disposal in water, via drain or toilet. The EPA is also requesting information on alternative management options for unused pharmaceuticals and associated costs.

The AVMA commends the EPA for its continued efforts to protect our nation's waters. However, the AVMA believes veterinary facilities are de minimus contributors of pharmaceuticals in water. Consequently, the AVMA believes the current draft survey will be excessively time consuming, economically burdensome, and will likely not provide the information the EPA desires based on current veterinary medical business practices. The AVMA asserts that inclusion of the veterinary medicine in the questionnaire is not necessary for the proper performance of functions of the EPA and the AVMA recommends the removal of veterinary facilities from the survey.

Background Documents:

Status Line

AVMA responded on November 10, 2008.