The Environmental Protection Agency recently invited comments on an upcoming survey the agency plans to conduct on disposal methods of unused pharmaceuticals (JAVMA, Oct. 1, 2008, page 1029). The draft study included a questionnaire pertaining to veterinary hospitals. This prompted Dr. Lyle P. Vogel, AVMA assistant executive vice president, to comment on behalf of the Association.
The 16-page document the AVMA sent to the EPA on Nov. 10 stated that, by and large, inclusion of veterinary medicine in the questionnaire wasn't necessary. The Association ultimately recommended the removal of veterinary facilities from the survey.
The AVMA consulted with four of its councils and committees before coming to the conclusion that "the current draft survey is poorly customized for veterinary medicine, that it will be excessively time consuming, economically burdensome, and that it will likely not provide the information EPA desires," because "the expense and effort put into surveying veterinary facilities is not commensurate with the veterinary profession's contribution of unused pharmaceuticals into the water."
Overall, the AVMA's position asserts that veterinary practices do not generate many unused pharmaceuticals and, thus, have a negligible impact on the water supply through disposals. In addition, veterinary facilities have a number of incentives that provide alternatives to disposing of them in the drain or toilet.
The minimal environmental impact of the veterinary profession's disposal practices is based largely on the business practices of serving mostly outpatients and dispensing drugs for in-home use, practices that are different from those used by some human hospitals and by long-term care facilities.
Full comments can be found on the AVMA's regulatory advocacy page by going to the "Environmental issues" section and clicking on the "Unused pharmaceuticals study" link.
The AVMA already has established, relevant policies on environmental responsibility and guidelines on companion animal care, veterinary prescription drugs, and veterinary wastes. They are accessible in the Issues section of its Web site, www.avma.org.
The AVMA also is currently cooperating with an EPA contractor to develop a Web-based Veterinary Environmental Compliance and Assistance clearinghouse providing federal and state regulatory information on veterinary waste, including pharmaceutical disposal.The project is intended to ensure compliance with environmental, public health, and worker safety regulations.
In addition, the Association has initiated a procedure to develop best management practices on proper disposal of veterinary medical waste. Anticipated to be completed in the spring/summer of 2009, the practices will address environmental responsibility and include specific guidance on items such as employee training, record keeping and inventory control, transfer of unused pharmaceuticals back to pharmaceutical distributors, and best management of de minimis unused pharmaceuticals.
The EPA's draft study indicated that information compiled from the completed surveys would be used in a detailed study on how veterinary hospitals, human hospitals, long-term care facilities, and hospices dispose of their unused pharmaceuticals.
The purpose of the study would be to inform future regulatory actions and identify the best management and proper disposal practices. The study would be one of several actions the agency was planning to strengthen its understanding of disposal practices and potential risks from pharmaceuticals in water. It is part of the EPA's overall strategy to address the risks associated with emerging contaminants, which can be viewed at www.epa.gov/ost/ppcp.