The TCEQ's Pharmaceutical Disposal Study (S.B. 1757)

1. The TCEQ's Pharmaceutical Disposal Study (S.B. 1757)

2. Overview • Review of Pharmaceutical Study Report • Sources of Pharmaceuticals • Current Disposal Methods • Alternative Disposal Methods • Analysis and Recommendations for Disposal Methods

3. Senate Bill 1757 Project • Passed in 81st Legislative Session, 2009 • TCEQ shall study and make recommendations regarding the methods to be used by consumers, health care providers, and others for disposing of unused pharmaceuticals so that they do not enter a wastewater system. • Report turned into legislature November 2010

4. Objectives • Specifically, TCEQ shall consider: • the methods currently used in Texas (by consumers, health care providers, and others); (2) alternative methods used, including methods used in other states; and • the effects on public health and the environment of the various methods used for that purpose. • The report must also provide an analysis of the feasibility of implementing the recommended disposal methods on a statewide basis.

5. Intent of Advisory Group • To provide a forum for TCEQ to gather appropriate and sufficient information to understand the: • methods currently used in Texas to dispose of unused pharmaceuticals; • amount and type of unused pharmaceuticals currently disposed; • factors driving disposal practices; • regional differences in disposal practices; and • desires of consumers, the health-care industry and others for alternative disposal methods. http://www.tceq.state.tx.us/permitting/water_supply/ pdw/pdagroup

6. Consumers • 1-day collection events • Mail-back • HHW collection • Drop boxes/kiosks • Trash disposal after • rendering undesirable • Providers • Best management practices • Reverse distribution • Educational strategies • Optimizing compliance • w/ current rules • Treat all as hazardous • Segregate waste • Rule/regs • Ban on drain disposal • Limited dispensing supplies • Universal Waste rule changes • Changes existing TCEQ rules • Require take-back events • Enhance enforcement • on current rules Alternative Methods Considered by Study Team

7. Study Report Review • Pharmaceuticals in the • Environment

8. Medicines consumed & not completely metabolized (or metabolized into other forms) Major: Excretion Minor: Sweat & vomit Intentional disposal of unused drugs (flushed down toilet or sink) FEWER Pharmaceuticals enter wastewater stream General Intent of SB-1757 is to consider:

10. Sources of Pharmaceuticals in the Environment • Agricultural Sources • Manufacturing • Landfills

11. Occurrence Data • South-central Texas WWTP influent /effluent study: • Most pharmaceuticals were completely removed (except carbamazepine) as a result of WW treatment. • None detected in treated drinking water supply. • North Texas DWTP raw/treated study: • Pharmaceuticals were detected in raw water. • However, none (except an anti-anxiety drug) were found above detection limits in the treated drinking water. • Parts per trillion levels.

12. Occurrence Data • Landfills in Maine • Maine Department of Environmental Protection • Tested lechate from three operating lined landfills • 47 out of 135 compounds were detected in the lechate at least one of the landfills • Carbamazepine and Ibuprofen along with 18 other compounds were detected in the lechate of all three landfills

13. Occurrence Data • Biosolids • USGS tested commercial biosolid products • Detected 55 of the 87 organic compounds in at least one of the products tested • 25 compounds were present in every sample three were pharmaceuticals

14. Occurrence Data • Soils • USGS tested soils irrigated with wastewater effluent • Analyzed the soil core samples during irrigation season samples for 19 pharmaceuticals • Pharmaceuticals were detected

15. Human Health Impacts • EPA reports no adverse human health effects from consuming water with ppb levels of pharmaceuticals. • For most pharmaceuticals, drinking 2 L/day of the water (containing pharmaceuticals at the low levels seen in drinking water) over a lifetime would not deliver the equivalent of a single prescribed dose.

16. Disposal Surveys • To collect a baseline set of information documenting: • how health-care providers, consumers and others currently dispose of unused pharmaceuticals in Texas; • how much of what is being disposed of; • why certain disposal practices are chosen; and • what the preferred disposal practices are. • Distributed through Advisory Group stakeholders.

17. Disposal Surveys • (1) In-patient Health-Care Providers (hospitals, clinics) (2) Veterinary Care Providers (3) Pharmacies (4) Waste Disposal Operations (5) Pharmaceutical Manufacturers (6) Ranchers/Farmers (7) Consumers (8) Drinking Water & Wastewater Utilities (9) Local Governments (Solid Waste) (10) In-home care providers (11) Law Enforcement (12) Research Institutions (13) Long-Term Care Facilities

18. Findings - Utilities • DW/WW utility survey questions related to: • If the utility has sampled their WW or DW for pharmaceuticals. • If the utility has been involved in consumer drug return programs & if so, why. • How the State can provide information on this topic to utilities. • 85 DW/WW utilities responded to survey • Utilities well represented in Advisory Group • AWBD, AWWA, WEAT, many municipalities.

19. Utilities represented in Advisory Group appreciated that intentional flushing is the minor source of pharmaceuticals in water (compared to excretion). • However, utilities generally support avoiding drain disposal. E.g. consumer drug take back programs. • Obvious need for accurate information to be provided: • (1) Significance of the data (consumer relations) • (2) Guidance if systems want to participate in programs

20. Findings - Utilities • Most (75%) of utilities surveyed said they’ll wait for EPA/Texas to regulate pharmaceuticals in water before they consider changing treatment decisions. • 4% of utilities have collected/analyzed drinking water samples for pharmaceuticals. • ~ 20% of utilities have developed or supported some sort of consumer drug take-back program for pharmaceuticals.

21. Current Disposal Methods Review • Numerous Disposal Management Practices • Health care providers (including hospitals)use a combination of methods to management unused pharmaceuticals • Reverse Distributors primarily incinerate • Consumers tend to use trash disposal

22. Current Disposal Methods Review • Nursing Homes, assisted living, and some hospices manage all unused pharmaceuticals as medical waste • Ranchers, and farmers typically rely on veterinarians or a combination of disposal methods

23. Current Disposal Methods Review • Current Disposal Methods were driven primarily by a couple of factors: • Current Regulatory Structure • Industry Practices • Type of pharmaceutical

24. Alternative Disposal Methods Review • TCEQ obtained information on alternative disposal methods by: • Conducting a literature review to determine what alternative methods were be utilized • Discussions with stakeholders during the advisory group meeting.

25. Alternative Disposal Methods Review • Single Day Collection Events: • Typically a drive through or drive up to event • Type of drugs excepted can vary based on staff training and availability of law enforcement

26. Alternative Disposal Methods Review • Single Day Collection Events: • Means to remove unused drugs from the home • Opportunity to do public outreach • Provides opportunities for partnership • Depended on having all available resources • Arrangements for disposal is necessary • Need for Law Enforcement presence

27. Alternative Disposal Methods Review Permanent Collection Facilities: (Drop Boxes or Kiosks) • Located either in a law enforcement facility or a pharmacy • Limit on accepting controlled substances unless in law enforcement facility

28. Alternative Disposal Methods Review Permanent Collection Facilities: (Drop Boxes or Kiosks) • Means to remove unused drugs from the home • Raises Awareness on amount of unused • Pharmaceuticals • Disposal and transportation already established

29. Alternative Disposal Methods Review Mail-Back Programs: Prepaid enveloped offered in pharmacies, clinics, and other health care facilities. Consumers place unused pharmaceuticals in the envelope for mail back to disposal location.

30. Alternative Disposal Methods Review • Mail-Back Programs: • Removes drugs from the household to prevent • Poisonings • Higher level of access for consumers • Provides confidentiality

31. Alternative Disposal Methods Review Summary • Render Undesirable and Dispose of in • Municipal/Household Trash: • Practice of rendering drugs undesirable prior to • disposal into municipal trash is not a common • practice

32. Alternative Disposal Methods Review • Render Undesirable and Dispose of in • Municipal/Household Trash: • Simple disposal method • Available to all consumers • Consistent with current regulatory requirements • Requires continued public outreach

33. Recommendations for Disposal Methods • Promote Municipal Trash disposal • Develop a Strong Education Program • Encourage he voluntary use of take-back • programs

34. Conclusions • Additional research needed to develop analytical • methods to distinguish sources of unused • pharmaceuticals • Further research needed on the impact of unused pharmaceuticals on human health and the Environment • Education programs will provide an opportunity to impact the amount of pharmaceuticals • intentionally disposed of into the wastewater stream

35. Questions? • TCEQ Contacts: • Elston Johnson (project lead) • <eljohnso@tceq.state.tx.us> • 512-239-0990 • Daniel Ingersoll • <dingerso@tceq.state.tx.us> • 512-239-3668