The creation of an accessible, statewide program ensuring the proper management and disposal of unused, expired and unwanted pharmaceuticals was the major focus of New York’s Department of Environmental Conservation and Department of Health 2018 Pharmaceutical Stewardship Report, released earlier this month.

This idea complements DEC’s current $2 million pilot pharmaceutical take-back program, launched in December 2017. In the pilot, 87 collection boxes were distributed to retail pharmacies, hospitals and long-term care facilities willing to participate.

An additional bill was proposed in 2017 to Gov. Andrew Cuomo that would have required chain pharmacies with at least 10 locations to offer mail-back envelopes to consumers for unused pharmceuticals. Cuomo vetoed this bill, however, due to concerns of financial burdens and unfair distribution.

The new program introduced in the report was discussed in meetings held in February of this year with DOH and DEC representatives, as well as local government officials and various members of the medical field. The program will cover prescription and nonprescription drugs, combination products, drugs in medical devices and veterinary drugs. However, it will not cover sharps collections, vitamins and supplements, homeopathic drugs, herbal remedies or cosmetic or personal-care products.

The major concern for members of the NY Pharmacist Society after reviewing the report, according to Executive Director Kathy Febraio, is how universal the program is for pharmacies. This is mostly in regard to the guidelines of the receptacle itself, such as the size and spacing.

“We need flexibility in solutions so that each local pharmacy can work with their own community,” Febraio said. “We are concerned that there might be specific pharmacy requirements that would be identical and won’t work for each pharmacy.”

DEC Chief of Staff Julia Tighe said that if the legislation for this program goes forward, there should be a waiver of some kind that would allow pharmacies to make the program best for their space and community.

Febraio added she is worried there will be challenges with the current language of the program. Aside from the size of the receptacle, another concern is supervision of the receptacle. Without proper supervision, the receptacle could easily be broken into, making it counter-productive. Febraio said having proper supervision will require procedural or staffing changes, which may only be possible for certain pharmacies.

In response, Tighe said as part of the DEA requirements, the receptacles are intended to be tamper-resistant and should not require any type of supervision.

Both Febraio and Tighe stressed the importance of a take-back program in NY in regard to the opioid epidemic, as well as being environmentally conscious.