Pharmaceutical waste management

Whether the waste from pharmaceutical R&D, manufacturing, stocking and over-stocking in pharmacies, over-prescribing or patient non-compliance, there is a great need to minimise pharmaceutical waste. The combined aims must be the avoidance of waste and unnecessary expense, and environmental protection.

Pharmacies are now more than ever aware of their central role in waste minimisation. Badgering prescribers toward lean prescribing, ensuring patients know how and when to take their medicines and to ensure that the full prescribed dose is completed as instructed (let’s, for now, draw a veil over the inevitability that what goes in at the top comes out down below and finds its way into the sewage system!).

Though the amount of unused medicine can be reduced by these simple steps a comprehensive scheme for drug waste disposal must be developed, approved and applied. There are some useful guides, and a recent review of the US situation is available at pharmacypracticenews.com. This is a nicely written and very practical review, but one important anomaly catches my eye. In Figure 4 of page 43, it is stated that simple IV fluids comprising saline, water and the like can be flushed to the public sewer system. No problem with that, but surprisingly this route is also permitted, and seemingly the preferred route, for controlled drug disposal!

The problem lies with the Drug Enforcement Administration which ‘requires’ controlled drug waste to be flushed to sewer to render it immediately unrecoverable. As the review states, though healthcare services are not obliged to follow this ‘recommendation’ which has not legal status there is a constant threat that widespread non-compliance will prompt the DEA to seek formal legislation in this area. In this case at least, it seems that drug law trumps environmental law.

Immediate disposal of controlled drugs is particularly importance, and this disposal must ensure that CDs are immediately put beyond use. Packaging for supervised incineration might be reasonable but is not entirely convenient for the multiplicity of arisings and for field use – the packaging and security implications would be too onerous. Alternately we have kits for the disposal of unwanted medicines including, in particular, Controlled Drug disposal.

Most of these DooM kits are nothing more than wallpaper paste mixed with a dry powder poster paint in corporate colours. That is possibly enough since it provides some dilution and dissolution/disruption of tablets and most capsules. However, when these were first developed a detailed technical assessment by Blenkharn Environmental required the addition of Bitrex™ to prevent accidental of intentional ingestion. That was not, and still has not been done by most suppliers – it was too expensive and customers had not requested it,m and was too fiddly and unpleasant to handle but after all that’s the whole point of Bitrex™! –  and the safety and compliance standard of DooM kits may be far less than expected.

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