The possibility of unacceptable pharmaceutical discharges from ATT treatment wastewaters has repeatedly been used as an unacceptable ‘tool’ by EA to maniplulate their regulatory position.
It works like this:
- We are concerened that there might be pharma residues in your wastewater outputs
- We will not permit processing of x, y and z waste fractions and, because of these concerns, we demand that these are sent to incineration
- However, if you provide a detailed assessment of any possible pharmaceutical residues in your wastewaster discharges, we will review the situation.
This last statement leaves the door open, or at least ajar, and avoids direct legal challenge. But what happens when an apraisal has been completed. “It’s not adequate, provide more detail“, or “you have considered the fate of only 10 common drugs, we want 20“…. and so it goes on, since when data has been collected on 20, then that too is deemed inadequate and 30 are required!
The cost and time input for such work is unacceptable and commercially non-viable so the restrictions renmain in place without fear of any legal challenge. After all, nobody has said no and the door remains ajar; the onus is on the applicant to provide proof but in circumstances where the goalposts are deliberately being moved.
In reality, this is little more than a regulatory scam. The question of pharmaceutiocal residues in wastewater is one of concern and of course something must be done about it. We cannot expect that Victorian wasterwater treatment processes can cope with, or were ever intended to cope with, pharmaceutical residues in wastewater.
As significant investiment in wastewater treatments seem a long way off, the problem 
will undoubtedly continue. Reducing input levels is a great idea. Improment in lean prescribing, providing effective options for collection and disposal of unwanted household POMs and OTC medicinal products, and ore general education of the population are likely to have a significant effect but are being largely ignored.
There is some work on the local treatment of hospital wastewater outputs that is showing promise, but this is fostering an idea among regulators that someone in the hospoital must spend their time tipping wuantities of unwanted medicines down the loo. That is not so.
Pharmaceutical resdidues in hospital wastewater result from the normal excretion of 90%+ of the administered dose, and of its metabolites. Put a lot of ill people together, give them the drugs they need to make them better, and of course as they urinate the hospital wastewater will be rich in drug residues. This happens too in the community, where patients receive a prescription from their GP, or self-medicate, and excrete those drugs into the domestic sewer.
The possibility of unacceptable concentrations of drug residue in ATT wastewater output seems so small that it should be trivial. Of course, source segregation should be robust, but not queite to the point of obsession, and regular audits should be done to make certain that waste segrgation standards are being maintained. That should be enough. A slippery approach to regulation does not allow this to happen and actually promotes segrgation failure by removing an effective driver for waste management training for producers.
A particular news item exemplifies the environmental impact of excretion of pharmaceuticals – not forgetting also the contribution of veterinary uses and the excretion directly to land of drugs given to the national herd. Radioactive iodine-131 has been found in the water Wissahickon Creek, just upstream from a Philadelphia drinking water intake.
Despite extensive sampling of other water sources in the region including wastewater outputs from the local hospitals, the Department of Environmental Protection found no apparent source. Concluding that as iodine-131 is used for the treatment of thyroid cancer it is concluded that such patients receive their medication in hospital, go home while continue to take that radioactive medication, and excrete, quite normally, the radioactive drug in their urine.
Despite warnings to hospital patients receiving radioactive drugs for diagnosis and treatment to stay away from yound children and pregnamnt women for the duration of treatment and for several days after the last dose, no constraint is placed on the need to releive a full bladder!
The same hapens with other more conventional pharamceuticals, including OTC products, but their widespread distrubution and use makes it perhaps less clear that excretion of the administered dose far exceeded, by many orders of magnitude, the contibution of a few stray tablets that slip into a sack of clinical waste processed by an ATT.
Ignoring the obvious uses bad science to support an unacceptable regulatory process. That should not happen. As long as it continues, it places a stain on the regulatory agencies and trade representative bodies – Water UK are now jumping on the bandwagon – and impedes teh introducton of more meaningful and effective strategies that could make a substatial, long-lasting and cost-effectcontribution