The TCEQ's
Pharmaceutical Disposal
Study
(S.B. 1757)
Overview
Review of Pharmaceutical Study Report
• Sources of Pharmaceuticals
• Current Disposal Methods
• Alternative Disposal Methods
• Analysis and Recommendations for
Disposal Methods
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
Objectives
•
Specifically, TCEQ shall consider:
(1) the methods currently used in Texas (by
consumers, health care providers, and others);
(2) alternative methods used, including methods used
in other states; and
(3) the effects on public health and the environment of
the various methods used for that purpose.
(4) The report must also provide an analysis of the
feasibility of implementing the recommended
disposal methods on a statewide basis.
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
Consumers
Providers
•1-day collection events
•Mail-back
•HHW collection
•Drop boxes/kiosks
•Trash disposal after
rendering undesirable
•Best management practices
•Reverse distribution
•Educational strategies
•Optimizing compliance
w/ current rules
•Treat all as hazardous
•Segregate waste
Rule/regs
Alternative
Methods
Considered by
Study Team
•Ban on drain disposal
•Limited dispensing supplies
•Universal Waste rule changes
•Changes existing TCEQ rules
•Require take-back events
•Enhance enforcement
on current rules
Study Report Review
Pharmaceuticals in the
Environment
General Intent of SB-1757 is to
consider:
Medicines consumed &
not completely
metabolized
(or metabolized into
other forms)
Intentional disposal of
unused drugs
(flushed down toilet
or sink)
Major: Excretion
Minor: Sweat & vomit
FEWER Pharmaceuticals enter wastewater stream
Sources of Pharmaceuticals in
the Environment
• Agricultural Sources
• Manufacturing
• Landfills
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.
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
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
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
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.
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.
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
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.
• 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
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.
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
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
Current Disposal Methods
Review
• Current Disposal Methods were driven
primarily by a couple of factors:
• Current Regulatory Structure
• Industry Practices
• Type of pharmaceutical
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.
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
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
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
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
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.
Alternative Disposal Methods
Review
Mail-Back Programs:
•
•
•
•
Removes drugs from the household to prevent
Poisonings
Higher level of access for consumers
Provides confidentiality
AlternativeSummary
Disposal Methods
Review
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
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
Recommendations for Disposal
Methods
•
•
•
•
Promote Municipal Trash disposal
Develop a Strong Education Program
Encourage he voluntary use of take-back
programs
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
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