This document discusses the necessity for proper medication waste disposal management in hospice homecare settings. It outlines federal and state regulations requiring hospices to have policies for disposing unused controlled drugs in patients' homes. While flushing medications down the drain was a traditional practice, it can contaminate water supplies and increase antibiotic resistance. New options like take-back programs and solid waste disposal with dilution are preferable but have limitations. The document provides suggestions for hospices to create disposal policies and educate staff on safely managing medication waste.

1. The Necessity For Medication Waste Disposal
Management In The Hospice Homecare Setting
Catherine J. Woods, JD
cwoods@excellerx.com
Saturday, December 1, 2007

2. The Pill Problem
The Pill Problem

3. Trash
!

4. The Rules
• The Medicare Conditions of Participation require
hospices to have a written Policy and Procedure
for the disposal of unused controlled drugs
maintained in the patient’s home when the drugs
are no longer needed by the patient.

5. The Players
• DEA • Nurses
• EPA • Doctors
• State Governments • Patients/Consumers
• Local Governments • Pharmaceutical
• Pharmacies Companies
• Pharmacists

6. The Concerns
• Diversion of controlled substances
• Contaminated water supply
• Negative impact on aquatic life
• Possible increased resistance to antibiotics
• Hormone disruption
• Unintentional exposure to possibly toxic
medications

7. The Longstanding Practice - Flushing
X

8. The Longstanding Practice – Flushing
STRENGTHS CONCERNS
• Fast • Contaminated water
• Easy supply
• Effective • Negative impact on
• Traditional aquatic life
• Possible increased
• Controlled (immediately
resistance to antibiotics
minimizes diversion risk)
• Hormone disruption
• Unintentional exposure to
possibly toxic medications

9. Statistics and Information
• In 2005, approximately 3.6 billion prescriptions
were purchased¹.
• Over 80% of elderly individuals take more than
one drug daily.50% of the elderly take three or
more drugs daily2.
• In 2007, an estimated 1 billion dollars worth of
unused medications will be wasted3.
• Illicit use of legitimately prescribed medications
continues to increase. The practice of
“Pharming” among teens and young adults
continues to grow4.

10. More Statistics and Information
• Medicare Part D requires 30-day supply billing,
regardless of need.
• A 2002 US Geological Survey study indicates that
greater than 80% of US waterways tested
contained trace contamination of medications.

11. Two New Options
OPTIONS STRENGTHS WEAKNESSES
Community Take-Back •Disposal of drugs occurs •Limited
Programs in a regulated/controlled availability/accessibility
environment (but is growing)
•Reduces diversion risk Controlled Substances not
•Reduces potential for accepted
accidental poisoning •Time commitment
•Cost
Household Solid Waste •Limits diversion risk •Diversion risk still exists
Disposal •Reduces environmental •Release into
(with dilution and pollution exposure environment still occurs
masking of drugs prior to (landfill v. water •Time commitment
disposal) contamination) •Labor-intensive

12. The Federal Guidelines
• Created in February 2007 as a resource for best
practices in the disposal of household medication
waste.
• Suggestions include mixing unused medications
with coffee grounds or kitty litter and other forms
of dilution prior to disposal.
• Includes exceptions for disposal of controlled
substances.
http://www.whitehousedrugpolicy.gov/drugfactsht/proper_disposal.html.

13. The Progress

14. Suggestions To Manage Proper Disposal of
Medications
• Create or update your hospice’s Policy and
Procedure on medication disposal.
• Educate your staff on the importance of following
your policy.
• Carefully weigh the risk of diversion of certain
drugs against any potential environmental impact.
Err on the side of caution.
• Check to see if your state or local municipality has
its own laws or regulations regarding disposal of
household medications.

15. Additional Resources
General References
– DEA Website
• http://www.usdoj.gov/dea/index.htm
– EPA Guidelines
• http://www.epa.gov/epaoswer/osw/home.htm#medical
(“Around Your Home: Waste Reduction and Recycling”)

16. Questions/Comments?
Please contact
Catherine J. Woods, JD
Senior Director, Regulatory Affairs
cwoods@excelleRx.com
215.282.1735