Consumer Guidance on Proper Drug Disposal Critical, Yet Lacking Consistency

Clear and consistent information is needed to encourage prompt disposal of both prescription and over-the-counter medicines when they are no longer wanted or needed in our homes. While inconsistent messages on consumer drug disposal reflect a lack of consensus nationally, there is general agreement that leftover drugs should not be allowed to linger in medicine cabinets where they may be accessible to accidental poisoning or intentional abuse.

The White House Office of National Drug Control Policy (ONDCP) recently released a revision to its drug disposal guidelines for consumers. The guidelines, available online, now state up front that drugs should not be flushed unless recommended by the U.S. Food and Drug Administration (FDA). When first published in 2007, the ONDCP guidelines included a list of drugs for which flushing was the recommended method of disposal. This list has been removed, and the guidelines now direct consumers to the FDA website for more information on disposal instructions.

The ONDCP guidelines provide best practices for consumers, although key federal agencies concerned about the disposal and handling of medications are still wrestling with statutes, regulations, and programs that were developed before the drug disposal issue had emerged as an issue of national concern. These challenges are complicated by the fact that the science is still emerging and much remains to be understood about environmental and human health impacts. The following federal agencies have taken slightly different positions on the drug disposal issue:

• The U.S. Fish and Wildlife Service, a sponsor of the SMARxT Disposal campaign (along with the American Pharmacists Association and the Pharmaceutical Research and Manufacturers of America) cautions against flushing or pouring drugs down the drain.
• The U.S. Food and Drug Administration recommends flushing certain narcotic pain relievers and other controlled substances for safety reasons.
• The U.S. Environmental Protection Agency stated at a Senate hearing that “it is important that the public understand that the toilet is not a trash can for unused medications.”
• The U.S. Drug Enforcement Administration currently requires that narcotics covered by the Controlled Substances Act are either flushed or delivered to law enforcement.

State and local agencies are developing and distributing their own recommendations as well. State guidelines vary, with many recommending drug take-back programs (if available), or trash disposal in a manner that renders the substance undesirable. The Product Stewardship Institute, Inc. compiled a list of disposal recommendations in March 2009 that is available online.

Most guidelines do not take into account the small number of drugs that are subject to FDA-mandated restricted distribution programs, such as thalidomide. These special programs provide their own return and disposal program specific to a product because it has been deemed necessary to protect consumers from safety risks.

Last year, the Associated Press (AP) examined the information that accompanies the 50 most commonly prescribed medications, ranging from the information patients receive when they pick up a prescription to detailed technical literature for healthcare providers. According to the AP, none of the information referenced the federal guidelines, nor did it offer instructions for disposal. Some pharmacists, when asked why this information was not included, responded that, “space is very limited on drug instructions and people often don't read them carefully, so side effects and other risks are more important to detail than disposal.” However, a few drugs do come with disposal recommendations, and a growing number of pharmacists and other healthcare providers are providing drug take-back opportunities and educating patients. Many more will be able to help deliver a clear and consistent message when there is wider consensus on exactly what that message should be.