Pharmaceutical disposal guide intended to reduce water contamination

The AVMA is providing veterinarians with drug disposal guidelines to reduce water contamination and the potential for federal regulation.

The Executive Board approved July 8 the policy "Best Management Practices for Pharmaceutical Disposal," which was drafted in response to an August 2008 proposal by the Environmental Protection Agency to survey human and veterinary health care facilities on disposal of unused pharmaceuticals. Officials from the agency indicated at that time that such a survey could be a prelude to increased oversight.

Janet Goodwin, chief of the Technology and Statistics branch of the EPA Engineering and Analysis Division, said her agency has not made a final decision on whether to survey any of the medical professions but is currently recommending to senior managers not to survey veterinarians. She praised the AVMA for its "very positive" work on the BMPs for pharmaceutical disposal, and she would like to see that effort continue as veterinarians adopt the recommended practices.

In fact, Goodwin said it is not clear whether the EPA will proceed with a survey on pharmaceutical waste disposal. The agency had planned to use such a survey to determine which industries contribute to pharmaceutical water pollution and what risks that contamination poses.

Goodwin said she thinks her agency, through the Office of Water and the Office of Solid Waste and Emergency Response, will continue examining the best practices for pharmaceutical waste disposal and work with departments and agencies such as the Department of Agriculture, Drug Enforcement Administration, and Centers for Medicare and Medicaid Services to establish disposal opportunities that help prevent the flushing of pharmaceuticals at human and veterinary health care facilities.

The AVMA has stated the veterinary profession is a minimal contributor to pharmaceutical waste in water and has encouraged the EPA to exempt veterinary facilities from any such survey. AVMA staff members have also worked with the EPA on development and adoption of the best management practices.

After the veterinary profession was identified as a possible contributor to pharmaceutical pollution, three AVMA councils and committees, on advisement from the AVMA Clinical Practitioners Advisory Committee, determined the Association should develop a set of best management practices to further decrease the profession's contribution to water pollution. The AVMA entities are the Council on Biologic and Therapeutic Agents, the Council on Veterinary Service, and the Committee on Environmental Issues.

The BMPs are intended to create a self-regulating structure for drugs and biologics used in the profession. The document also provides guidelines for minimizing unused pharmaceuticals, disposing of pharmaceutical waste, and educating clients.

In a Federal Register notice Aug. 12, 2008, the EPA said the proposed study was part of a strategy for "improving science, communicating risks, identifying partnership and stewardship opportunities, and taking regulatory action as appropriate." In that notice, agency officials expressed concern that health service providers were disposing of "excess, expired, and unwanted medications" down drains and toilets, which could pass the contaminants through publicly owned treatment works and into surface waters.

The AVMA guidelines on pharmaceutical disposal are available at here.