Medication Disposal in Alameda County and the Safe Medication Disposal Ordinance

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2 Medication Disposal in Alameda County and the Safe Medication Disposal Ordinance BILL POLLOCK - PROGRAM MANAGER ALAMEDA COUNTY HHW PROGRAM BILL.POLLOCK@ACGOV.ORG

3 About the HHW program In operation since facilities 57,000 HHW facility users per year currently 4 million pounds of waste/yr currently 550k visits and 36 million pounds since 1993 Accepting medications since 1993 Non controlled substances only Misc waste stream consolidated with Toxic Pesticides ~100k lbs/year Medicines <5000 lbs/yr ~5000 people/year bringing medicines

4 Medication Procurement infrastructure Pharmacies only ~ 20 independents 40+ Hospitals comprising 100+ locations 30+ Veterinary clinics Medication Disposal infrastructure Sherriff's dept Legal Controlled site 2 Police Department non controlled 4 HHW facilities non controlled only 11 Hospital/Clinic sites 1 Xfer Station 2 fire stations 2 office buildings 1 Wastewater Treatment Plant 9 Independent pharmacies

5 Pre OCT 2014 Disposal infrastructure Poorly distributed some sites not compliant with DEA Map here

6 Legal Controlled substances site established at Alameda County Sherriff s dept 2010

7 Supervisor Miley s Senior AOD group AOD = Alcohol and other Drugs of concern to seniors Sponsored 14+ one day events Concluded one day events poor substitute for permanent sites. 5K local Stopwaste grant for 5 permanent sites. Followed SF s ordinance efforts Committed to establishing ordinance in Alameda County

8 Alameda County Safe Drug Disposal Ordinance

9 Ordinance Basics July 2012 ( before new DEA rules) Create/Join a Product Stewardship organization File Product Stewardship Plan describing how: Establish collection sites Collect all unwanted products Educate the public, Promote the program. Support Law Enforcement for controlled substances File Annual Report describing activities Pay all the costs of collection and reasonable costs of regulation/oversight Enforcement process, civil penalties/fines for non-compliance

10 Ordinance basics 2 No point of sale fee. Not covered: Non prescription drugs ( later amended to cover) Medical devices not containing drugs when sold Clinical use only drugs by Exemption process Hauling by Med or Haz waste hauler Disposal by Incineration - Med or Haz Waste New disposal methods by petition must be equal or better than incineration Department has broad authority to exempt

11 Convenience Standard No Numerical standard Provide collection services that are reasonably convenient to the public. Scope and extent of the stewardship program are consistent with the scope and extent of the sales of covered products within the County. Industry proposed 100 sites in their plan about 1-15k population

12 Timeline - Ordinance Deadline for plan filing MAY 1 st 2014 May petition for extension Spring 2014 Contact with potential Product stewardship organizations Phone and in person meetings Pharmaceutical industry creates product stewardship organization PPSWG ( formed late 2013) Pharmaceutical Product Stewardship Working Group ~ 360 members =~ 90% +of market currently 457 companies identified selling in Alameda County

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14 Their plan 3 year implementation 1 st year 12 one day events and 20 Law enforcement kiosks 1 st event within 30 days 2 nd & 3 rd year... pharmacies Website, 800 number & Robust outreach planned T&D vendor Stericycle Goal of 100 Kiosks at the end of year 3

15 Their performance 1 st year March event 0 kiosks Ordinance OTC issues 2 nd year events( 9 HHW events) Poor outreach for non HHW events 16 signed contracts for kiosks 0 kiosks in service so far Holdup is plan and model for service Pickup, store, and transport vs common carrier model

16 One day events

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19 Kiosks Spring 2016 Stewardship organization recruiting pharmacies Difficult landscape in Alameda County <20 independent pharmacies 200+ Chain & HMO Major Chains are not participating 37 Walgreens in Alameda County 3 participating independent of med project Kaiser not participating so far Some interest from smaller chains 9 Signed contracts with Independent Pharmacies 7 LEA s sign contracts

20 Kiosk Holdup 2015 issues with Ordinance not covering OTC s delay implementation Feb 2016 Ordinance amended to include OTC s Med Project starts recruiting pharmacies and LEA s Med Project requests plan modification many changes including signage change. Add sharps to the not accepted list Add DEA required text re Schedule 1 Signage This is the only thing holding up kiosk installation

21 Kiosk Holdups -2 May Sept 2016 Med project submitted 4 revised, updated or amended stewardship plans and a supplement Shifted from Vendor pickup to Common carrier model Tried to reduce pharmacy goals and restart clock on plan More restrictions on waste acceptable on kiosks No aerosols or inhalers requiring new signage Oct 26 County approves common carrier model for retail pharmacies Denies common carrier model for One Day events Hospitals and LEA To Date still no kiosks

22 Obstacles Inexperienced Product stewardship group Did not understand contracting with LEA Few Players in the vendor arena Intersection between DEA and DOT unclear DEA regs barriers to new entrants Reverse distributors must have DEA registered location meet stringent security requirements to do pickup/store/ship California Board of Pharmacy adds more barriers in pending rulemaking Additional registration requirements Pharmacist in Charge escape clause from mandatory ordinance

23 Successes Product stewardship group formed 350+ members - represents 90+% of industry Jointly with AC Sherriff s dept. developed robust one day event protocols. Customer Unloads vendor limits direct handling of drugs Vendor takes on Shipper status Vendor transports directly from event site to incinerator on SP - 66lb per container limit DOT Issues SP & Additional SP with greater weights possible

24 Current Status April Kiosks installed and operating in Oakland, Hayward Piedmont,Castro Valley, & Fremont More kiosk installation scheduled in Livermore, Castro Valley Pleasanton & Newark this month Kaiser is moving( slowly) towards participating at up to 13 sites in the county.

25 BERKELEY IS NOT COVERED BY THE ORDINANCE Jurisdictional issues Berkeley has it s own Health Code and is not subject to county health related ordinances Current sites (2) in Berkeley are operating outside DEA regulations Berkeley can either Do nothing Pass and administer it s own ordinance Pass a version of the county ordinance and delegate enforcement to the county The ball is in Berkeley s court