I wanted to share the endorsed comments I provided for the Product Stewardship Institute at the DEA’s public hearing yesterday. Thank you to the 119 endorsers for helping me to deliver the message that these considerations for the DEA’s rulemaking process are widely supported by groups concerned about the future and improvement of drug take-back programs around the country. The DEA, EPA, FDA, ONDCP, CMS, and USPS were all present. Congressman Jay Inslee from Washington opened the second day.
In two days of comments by both federal agencies and members of the public (including local government, state government, waste companies, reverse distributors, data companies, environmental organizations, law enforcement, pharmacies and pharmacists, drug abuse prevention groups, poison control, academic institutions, the pharmaceutical industry, and on incredibly moving grieving father), a number of themes were repeated by multiple presenters:
- Communities need a range of options for secure disposal of controlled substances and other pharmaceutical drugs. Those mentioned included collection at pharmacy and other community locations, mail-back from the home, and HHW.
- Take-back programs (including all methods described above) should be able to include both controlled and non-controlled substances without sorting them.
- Take-back programs must be convenient and accessible to the public.
- Security to prevent diversion is critical, including tracking of containers, tamper evident seals, locked containers, and other such measures.
- Regulations should not require that individual pills/vials/etc. be counted and logged.
In addition, the question of who should pay for take-back programs was brought up many times in spite of the fact that this important question lies outside of the DEA’s responsibility under this rulemaking. There were many references to needing “public-private partnerships,” support/sponsorship from companies, and/or calling on the pharmaceutical industry to fund take-back programs. The importance of reducing drug waste was also mentioned. We look forward to seeing and commenting on the DEA’s proposed rule-making in the near future.