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MARCH 2009

Medications Return Program: Setting a precedent
for environmental responsibility

Issue:

Consumers are growing concerned about small amounts of potentially dangerous substances being released into the environment through various routes and have called on governments to put in place risk management strategies to address these concerns. The concerns include the presence of medications in waterways.

NDMAC stepped up to the plate in the mid-1990s by working with other stakeholders to develop programs designed to divert unused and expired consumer health products away from landfills and waterways. Since 1997, NDMAC members have been funding British Columbia's Medications Return Program and contributing to Alberta's EnviRx Program. Both of these programs collect and dispose of unused and expired medications that have been returned to pharmacies by consumers. Between 1997 and 2008, the B.C. Medications Return Program, in collaboration with other brand-owners of medications, has collected and disposed of over 189,000 tonnes of expired and unused medications.

A number of other provinces are considering implementing programs to deal with "household special waste." To avoid having a mishmash of different programs operating in different provinces, NDMAC will universally be advocating the implementation of the Medications Return Program.

Ontario will be the next province to set up a program. At the moment, medications are being lumped in with other waste products. NDMAC is adamant that a program for medication/pharmaceutical waste should be separate from other waste disposal programs, be modeled on the successful Medications Return Program, and be managed by the Post Consumer Pharmaceutical Stewardship Association (PCPSA).

Other provinces are watching Ontario's initiative closely and can be expected to follow suit in the future so it is important to ensure that Ontario implements the Medications Return Program.

What's New:

Under the Waste Diversion Act, Ontario is developing a Municipal and Household Special Waste (MHSW) recycling initiative, which is being implemented in phases. Phase I of the initiative began in July 2008 and includes paints, solvents, oil filters, antifreeze, pesticides, and fertilizers. Phase II will begin in 2010 and will add more categories of waste including medications, which have been categorized as "pharmaceuticals" by government.

The MHSW Program requires that brand owners and first importers of the designated materials become fully responsible by addressing all associated costs. Associated operational costs include: collection; storage; handling; transporting; processing; marketing; disposal; R&D/capital costs; promotion, education and public awareness of the program.

The government has placed high emphasis on consumer accessibility and convenience regarding collection options, including residential collection and retail take-back. By July 31, 2009, the responsible agency - Waste Diversion Ontario - must submit a program plan to the Minister of the Environment that addresses the requirements. The Minister has identified Stewardship Ontario as the industry funding organization responsible for managing program plans for each of the MHSW materials.

NDMAC in Action:

NDMAC is advocating that any program for medication/pharmaceutical waste should be separate from other waste disposal programs. NDMAC would also like the program to be modeled on the Medications Return Program, and be managed by the Post Consumer Pharmaceutical Stewardship Association (PCPSA).

NDMAC and PCPSA advocate using pharmacies as collection points and have received support from the Canadian Association of Chain Drug Stores and the Ontario Pharmacists Association. The consensus view is that expired and unused medications should not be sent to municipal hazardous waste depots, but should be returned to community pharmacies for collection and disposal in an environmentally responsible manner.

Over the past few months, NDMAC's Robert White and Ginette Vanasse, Executive Director of the PCPSA, have been meeting on a regular basis with officials from the Ministry of the Environment, the Minister's Office, Waste Diversion Ontario, Stewardship Ontario, and other stewardship organizations regarding definitions and program plan elements. They have emphasized that PCPSA could quite rapidly roll out an effective system for collecting and disposing of expired and unused medications.

This effort will also require further meetings with supporters, Stewardship Ontario's newly established plan development team, and the ministry.

In addition, the federal government has developed a set of best practices for pharmaceutical disposal programs. NDMAC submitted detailed comments that have resulted in a document that notes the challenges of changing consumer behaviour to increase the amount of unused and expired medications returned for disposal.

What You Can Do:

NDMAC is seeking your support in ensuring the Medications Return Program is permitted to operate in Ontario with PCPSA acting as the industry funding organization.

PCPSA has a draft program plan that addresses the requirements of the Ministry for municipal special waste, and has as its members the brand-owners that will fund the program as well as support from pharmacy organizations to act as the collection points for expired and unused medications.

We ask you to write to Ontario's Minister of the Environment and recommend that he recognize PCPSA as the industry funding organization for the "pharmaceutical" category and approve the program plan. In doing so, Ontarians will be able to dispose of their unused and expired medications and have them managed in an environmentally responsible manner.

Write to:
The Honourable John Gerretsen
Minister of the Environment
12th Floor, 135 St. Clair Avenue West
Toronto, Ontario
M4V 1P5

Background: How does the Medications Return Program work?

The Medications Return Program, which has been operating in British Columbia since 1997, allows consumers to return their unwanted medications to any participating pharmacy throughout the province. Prescription drugs (brand name and generic) and consumer health products including nonprescription medicines and natural health products are accepted. There are no user fees directed to the consumer at time of purchase or at the point of collection. Medicines returned from each pharmacy are tracked by weight, pickup date, and location, and are stored in a secure location until a shipment is accumulated for safe destruction through a licensed incineration facility. Program costs, such as management, communications, collection, transportation, storage, disposal and promotional activities, are covered by NDMAC members and other brand-owners.

Background: What is PCPSA?

The Post Consumer Pharmaceutical Stewardship Association (PCPSA) is a Canadian not-for-profit organization that administers medications return programs and serves as an interface with federal and provincial stakeholders to develop an efficient process for disposing of medications.

Background: What is Waste Diversion Ontario?

The Waste Diversion Act, 2002, created Waste Diversion Ontario (WDO), a permanent, non-government corporation, which is run by a Board of Directors comprised of industry, municipal and non-governmental representatives.

The Act empowers the Minister to designate a material for which a waste diversion program is to be established. Once the Minister has designated a material through a regulation under the Waste Diversion Act, the Minister asks Waste Diversion Ontario, working co-operatively with stewards, to develop a diversion program. The Minister of the Environment has designated Blue Box Waste, Used Tires, Waste Electrical and Electronic Equipment and Municipal Hazardous or Special Waste under the WDA.

The Blue Box Program Plan was approved by the Minister on December 22, 2003 and commenced on February 1, 2004. The first phase of the Municipal Hazardous or Special Waste Program Plan was approved by the Minister on February 19, 2008 and commenced on July 1, 2008. The first phase of the Waste Electrical and Electronic Equipment Program Plan was approved by the Minister on July 10, 2008 and will commence on April 1, 2009.

Background: What is Stewardship Ontario?

Stewardship Ontario is Ontario's first Industry Funding Organization (IFO). It was created in 2002, in response to Sections 23 and 24 of the Waste Diversion Act, 2002 under which the Minister of the Environment is authorized to require Waste Diversion Ontario to develop a waste diversion program for a "designated waste" in conjunction with an Industry Funding Organization (IFO).

Further Resources:

NDMAC Contact:
Robert White
Director, Scientific & Regulatory Affairs


Copyright 2009 by NDMAC. Action Report is published four times a year. It is designed to increase awareness of specific issues that have a direct impact on the self-care health products industry.

 

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