The Necessity For Medication Waste Disposal The Necessity For Medication Waste Disposal Management In The Hospice Homecare SettingManagement In The Hospice Homecare Setting

Catherine J. Woods, JD

cwoods@excellerx.com

Saturday, December 1, 2007

The Pill ProblemThe Pill ProblemThe Pill Problem

Trash!Trash!

The Rules The Rules

• The Medicare Conditions of Participation require hospices to have a written Policy and Procedure for the disposal of unused controlled drugs maintained in the patient’s home when the drugs are no longer needed by the patient.

The PlayersThe Players

• DEA• EPA• State Governments• Local Governments• Pharmacies• Pharmacists

• Nurses • Doctors• Patients/Consumers • Pharmaceutical

Companies

The ConcernsThe Concerns

• Diversion of controlled substances• Contaminated water supply• Negative impact on aquatic life• Possible increased resistance to antibiotics• Hormone disruption• Unintentional exposure to possibly toxic

medications

The Longstanding Practice - FlushingThe Longstanding Practice - Flushing

X

The Longstanding Practice – Flushing The Longstanding Practice – Flushing

STRENGTHS

• Fast

• Easy

• Effective

• Traditional

• Controlled (immediately minimizes diversion risk)

CONCERNS

• Contaminated water supply

• Negative impact on aquatic life

• Possible increased resistance to antibiotics

• Hormone disruption

• Unintentional exposure to possibly toxic medications

Statistics and Information Statistics and Information

• In 2005, approximately 3.6 billion prescriptions were purchased¹.

• Over 80% of elderly individuals take more than one drug daily.50% of the elderly take three or more drugs daily2.

• In 2007, an estimated 1 billion dollars worth of unused medications will be wasted3.

• Illicit use of legitimately prescribed medications continues to increase. The practice of “Pharming” among teens and young adults continues to grow4.

More Statistics and InformationMore Statistics and Information

• Medicare Part D requires 30-day supply billing, regardless of need.

• A 2002 US Geological Survey study indicates that greater than 80% of US waterways tested contained trace contamination of medications.

Two New Options Two New Options

OPTIONS STRENGTHS WEAKNESSESCommunity Take-Back Programs

•Disposal of drugs occurs in a regulated/controlled environment

•Reduces diversion risk

•Reduces potential for accidental poisoning

•Limited availability/accessibility (but is growing)

Controlled Substances not accepted

•Time commitment

•Cost

Household Solid Waste Disposal

(with dilution and masking of drugs prior to disposal)

•Limits diversion risk

•Reduces environmental pollution exposure (landfill v. water contamination)

•Diversion risk still exists

•Release into environment still occurs

•Time commitment

•Labor-intensive

The Federal GuidelinesThe Federal Guidelines

• Created in February 2007 as a resource for best practices in the disposal of household medication waste.

• Suggestions include mixing unused medications with coffee grounds or kitty litter and other forms of dilution prior to disposal.

• Includes exceptions for disposal of controlled substances.http://www.whitehousedrugpolicy.gov/drugfactsht/proper_disposal.html.

The ProgressThe Progress

Suggestions To Manage Proper Disposal of Suggestions To Manage Proper Disposal of MedicationsMedications

• Create or update your hospice’s Policy and Procedure on medication disposal.

• Educate your staff on the importance of following your policy.

• Carefully weigh the risk of diversion of certain drugs against any potential environmental impact. Err on the side of caution.

• Check to see if your state or local municipality has its own laws or regulations regarding disposal of household medications.

Additional ResourcesAdditional Resources

General References

– DEA Website• http://www.usdoj.gov/dea/index.htm

– EPA Guidelines• http://www.epa.gov/epaoswer/osw/home.htm#medical

(“Around Your Home: Waste Reduction and Recycling”)

Questions/Comments?Questions/Comments?

Please contact

Catherine J. Woods, JD

Senior Director, Regulatory Affairs

cwoods@excelleRx.com

215.282.1735