on the radar screens of the US

Food and Drug Administration

(FDA) and the US Drug Enforcement

Agency (DEA) is the lack of a systematic,

consistent, and controlled approach to the

proper disposal and treatment of unwanted

medications. Many wind up down our

drains, a disposal method that is among

the solutions posted on the FDA’s Web site

In contrast, the US Environmental

Protection Agency (EPA) is well aware of

the ramifications of such substances entering

waterways and potable water supplies. EPA

recently looked at the impacts of unused

pharmaceuticals from medical and veterinary

facilities as part of an information collection

request to support the Clean Water Act (CWA)

Section 304(b) effluent guidelines annual

addition, the EPA maintains a blog that solicits

comments related to unused medications (see

Given the lack of consistent and effective

direction at the federal level, some US

pharmacies are spearheading their own

proactive activities to keep medications out

of traditional waste treatment streams, which

could affect surface or ground water (see

pharmacy trade magazines have been keen

to highlight pharmacies that have introduced

such programs with relative success. In this

article, we compare the experiences of three

such forward-looking pharmacies. The three

pharmacies highlighted — Leesburg Pharmacy,

in Leesburg, Virginia; Good Day Pharmacy,

a chain in Colorado; and Eaton Apothecary, a

small chain in Massachusetts — each share a

genuine conviction to “do the right thing,” both

for their customers and the environment.

Cheri Garvin, Chief Executive Officer

of Leesburg Pharmacy, says she became

interested in drug takebacks after hearing

about the waste issue through the media. She

was also concerned about the large amount

of drug waste the pharmacy was generating,

which needed to be disposed. She began

to wonder where the waste was going and

what harm it might be causing. When she

questioned the pharmacy’s waste hauler, she

was told that all of the pharmacy’s waste goes

to a landfill. About the same time, more and

more customers were asking what they should

do with their expired drugs. Her “Aha!”

moment was a realization that the pharmacy

could do something about both issues.

The key for the pharmacy is to use “reverse

distributors,” who agree to take the unwanted

medications, with the exception of controlled

substances, to a waste-to-energy facility

for incineration. When asked about the

controlled substances issue, Garvin explained

that the Controlled Substances Act was meant

to create a closed loop, with exceptions for

accepting controlled medications only under

specific conditions: (1) a pharmacy must hold

a specific event, such as a special takeback

event; and (2) local law enforcement must be

present.

In the Leesburg program, customers come

in with their expired or unused medications,

including sharps, and go to the counseling

counter. After the substance is identified and

technicians ensure that the patient’s name is

blocked on the container (protecting patient

privacy rights), the medications are put into a

50-gallon “fishbowl.” This set-up received no

formal approval from either the Virginia Board

of Pharmacy or the DEA; instead, all that was

required was for the local Board inspector to

examine the drop-off site and “OK” it. (By

contrast, the Massachusetts Board of Health

requires a letter approval for such events.)

Garvin stated that the greatest cost of the

program is staff time; waste incineration

has cost about US $500 to date. She further

estimates that, since Leesburg started their

program, the pharmacy has shipped out about

1,000 pounds of drugs. When asked about

the controlled substances, Garvin replied, “We

would entertain it, but it’s too cumbersome

to manage. It becomes a logistical and cost

issue. On top of that, we don’t know how

successful that event would be.”

For more information on the problems of

Leesburg Pharmacy, Inc. Tel: +1 703 777