Editor’s Note: The following report details recent moves by Alameda County, Calif., to institute an extended producer responsibility-based drug take-back program to ensure the proper handling of pharmaceutical waste without placing an undue financial burden on traditional waste handlers.

“What should I do with my unused medications?”

People ask this question every day and are rarely satisfied with the answer: “Don’t flush them. Put them in the trash with kitty litter.”

Elected officials are at a loss. Their stopgap disposal solution is disappointing to the public and highlights the fact that they do not have the resources for a different approach. So, what should local governments do? What can they afford to do? What should the water districts, pharmacies, hospitals, waste handlers and law enforcement do?

These are questions that are being asked all over California. Since the pharmaceutical industry and federal and state governments have failed to provide adequate disposal solutions, California municipalities have been forced to take matters into their own hands.

Although the Drug Enforcement Agency’s (DEA) twice-yearly collection events are appreciated, they aren’t the solution. The events aren’t fully funded and still leave local governments with a sizable tab. Most importantly, they aren’t convenient to the public.

Frustration around this issue in California came to a head in the city and county of San Francisco in 2010. The city had operated a series of one-day collection events but there was not enough funding to continue, let alone to expand the program to permanent collection sites. Temporary solutions involved providing the public with mail-back envelopes and tasking city staff with running occasional weekend take-back events. Again, these did not prove to be the solution.

This led San Francisco County Supervisor Ross Mirkarimi’s office to develop the country’s first local ordinance mandating that producers of pharmaceuticals design, fund and operate the collection program. However, the Safe Drug Disposal Ordinance was put on hold while the city worked with Pharmaceutical Research and Manufacturers of America (PhRMA), a group representing all pharmaceutical companies, on a voluntary pilot take-back project. The pilot has been funded at $110,000 and is the first drug collection program voluntarily funded by pharmaceutical companies. The pilot was structured as follows:

• The pilot will follow an 18-month time frame
• There will be 20 or more collection sites, facilitating acceptance of non-controlled substances at a number of participating pharmacy locations, and acceptance of both controlled and non-controlled substances at several designated police stations. (An up-to-date list of collection points can be found at http://sfenvironment.org.)
• The pilot will strictly follow the CA Model Guidelines (Model Guidelines -- see “criteria and procedures”), which includes two-key collection bins, use of a licensed medical waste hauler, etc.
• The pilot includes $35,000 budgeted for public outreach.

While implementing this program, the city found that many large (chain) pharmacies and retailers of drugs were not eager to serve as voluntary collection locations. In response, on May 24, 2011, San Francisco passed the Safe Drug Disposal Information Ordinance. This ordinance was meant to supplement the pilot program and requires all local pharmacies to conduct outreach on safe medicine disposal options for the public. Practically speaking, pharmacies that refuse to participate in the take-back program must direct customers to stores that have agreed to serve as collection points, even if they are direct competitors. Thus, the city chose to use competition to drive additional collection locations by forcing retailers who refused to collect the medications to advertise those who did.

After less than six months of the pilot’s operation, San Francisco residents have safely disposed of more than 6,000 pounds (3 tons) of medicine. While San Francisco was rolling out their pilot pharmaceutical collection program, across the Bay Bridge, Alameda County was also receiving a lot of public pressure to have a convenient medication collection program.