My latest dive into assessing whether medicine disposal products provide a safe, effective, and environmentally sound way to dispose of pharmaceuticals is now out in report form. Medicine Disposal Products: an overview of products & performance questions examines whether product testing supports performance claims and profiles each of ten products currently on the market. View the full report (PDF).
State and local agencies, policy-makers, and healthcare facility managers have many questions about medicine disposal products. This report summarizes available product testing information, examines key performance questions, and identifies relevant regulatory and policy considerations. The report reviews eight products marketed for use by consumers, healthcare facilities, law enforcement and others: Deterra, DisposeRx, Drug Buster, Element MDS, NarcX, Pill Catcher, Pill Terminator, and Rx Destroyer (also sold as Narc Gone HD). Also reviewed are two products marketed solely to healthcare facilities: Cactus Smart Sink and CsRx System.
The FDA, DEA, and EPA have not reviewed or approved any medicine disposal products and do not have any performance standards specifically for such products. Manufacturers of 6 of the 10 products have disclosed complete or partial results of their product testing. The other 4 manufacturers do not disclose any product testing, and did not provide more information in response to queries. Based on this review of available test results, none of the products thoroughly demonstrate irreversible physical or chemical inactivation of the medicines. Also, none of the eight products designed for solid waste disposal provide sufficient waste determination analysis to demonstrate that the product-pharmaceuticals mixture is non-hazardous and appropriate for solid waste disposal. The report provides summaries of product testing and analyzes how well performance questions are addressed. I also recommend further research needs to thoroughly examine product performance and actions by both manufacturers and governmental entities, including:
- Establish regulatory oversight for medicine disposal products. None of the medicine disposal products are approved by any federal agency despite some marketing language that suggests a product has undergone review or meets federal standards. Use of medicine disposal products is expanding, including through distribution of products for consumer use by major retail pharmacies. Federal review and regulation of medicine disposal products is needed, while maintaining existing state and local authority for more stringent solid waste management regulation and policies.
- Conduct additional independent lab testing to verify product performance claims. The medicine disposal products do appear likely to act as deterrents to diversion of leftover medicines and/or pharmaceutical wastage. The available product testing data, however, is not sufficient to verify claims that medicines are made non-retrievable through chemical or physical action of any product. For the eight products marketed for solid waste disposal, additional testing is also needed to verify claims that the used product-drug mixture is non-hazardous and appropriate for solid waste disposal. The regulatory context for disposal of pharmaceuticals must also be considered, and depends on the type of generator of the waste as well as the jurisdiction in which the waste is disposed.
- Test “real world” mixtures of medicines and dosage forms. Overall, product testing disclosed by the product manufacturers examines treatment of only a small number of pharmaceuticals. Most analysis was conducted on a single medicine at a time, rather than a combination of different types of pharmaceuticals in the way these products would likely be used.
- Improve instructions for consumers on spill clean-up and other safety risks. Most of the products are in liquid form, or water is added with medicines, so splashing and spills that create exposure to dissolved pharmaceuticals are a risk. Warning labels should be expanded to caution about any exposure to the product-drug mixture, including through dermal exposure to dissolved drugs. Instructions should also be provided for safe clean-up if the product container spills or leaks.
- Align consumer use directions with federal disposal guidelines for household medicines. The FDA, DEA, and EPA’s medicine disposal guidelines recommend secure medicine take-back programs as the best disposal option. Trash disposal of medicines is recommended only in situations where a secure medicine take-back program is not available. Marketing materials for these medicine disposal products skip over that portion of the federal agency guidelines and only describe how to dispose of medicines in the household trash, as if that is the only federal recommendation.
- Provide solidifying agents for products in liquid form for solid waste disposal. Many of the products designed for solid waste disposal are in liquid form after use. Product containers are likely to burst and release a liquid pharmaceutical waste mixture in the household trash can, garbage truck, or waste transfer station. Manufacturers should provide solidifying agents, or redesign the product form.
- Use in healthcare settings for diversion prevention, rather than final disposal. Regulated generators of pharmaceutical waste should take care to review applicable regulations to determine appropriate final disposal methods based on the pharmaceuticals to be disposed and the facility’s jurisdiction. In the healthcare setting, use of these products may be most appropriate for management of pharmaceutical wastage of controlled substances.
I am grateful to the San Francisco Department of the Environment for funding the research and development of this report. This March 2019 report updates an earlier report I wrote in April 2017. The new report reviews two additional products and summarizes additional product testing information that was provided by six of ten product manufacturers in response to a direct query to each of the manufacturers. A PDF of this March 2019 report is linked from the In-Home Medicine Disposal Products Review section on the S.F. Department of Environment’s webpage: https://sfenvironment.org/safe-medicine-disposal-policy-resources.
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