Medication Disposal in
Alameda County
the Safe Medication
And Sharps Disposal
Ordinances
BILL POLLOCK - PROGRAM MANAGER
ALAMEDA COUNTY HHW PROGRAM
[email protected]
Medication Procurement & Disposal
infrastructure
Pre Product Stewardship ordinance
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200 + Pharmacies only ~ 20 independents
40+ Hospitals comprising 100+ locations
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30+ Veterinary clinics
Medication Disposal infrastructure - 31
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1 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
Legal Controlled substances site established
at Alameda County Sherriff’s dept 2010
Pre OCT 2014 Disposal infrastructure
Poorly distributed some sites not compliant with DEA
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Map here
All funded
With public money
EBMUD
San Leandro
Hayward
CVSAN
UCSD
O L
SD
Supervisor Miley’s
Senior AOD group
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AOD = Alcohol and other Drugs of concern to seniors
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De-facto coordinating group for public agencies sponsoring kiosks
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Sponsored 14+ one day events 2008-11
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Concluded one day events poor substitute for permanent sites.
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5K local Stopwaste grant for 5 permanent sites.
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Followed SF’s ordinance efforts
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Committed to establishing ordinance in Alameda County
Alameda County Safe Drug
Disposal Ordinance
Ordinance Basics
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July 2012 ( before new DEA rules)
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Create/Join a Product Stewardship organization or go it alone
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File Product Stewardship Plan describing how the organization will:
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Establish collection sites
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Collect all unwanted products
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Educate the public, Promote the program.
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Support Law Enforcement for controlled substances
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File Annual Report describing activities
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Pay all the costs of collection and reasonable costs of regulation/oversight
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Enforcement process, civil penalties/fines for non-compliance
Ordinance basics 2
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No point of sale fee.
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Not covered:
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Non prescription drugs ( later amended to cover)
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Medical devices not containing drugs when sold
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Clinical use only drugs by Exemption process
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Hauling by Med or Haz waste hauler
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Disposal by Incineration - Med or Haz Waste
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New disposal methods by petition
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must be equal or better than incineration
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Department has broad authority to exempt
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Does not include Berkeley due to Jurisdictional issues
December 2012
December 2012
Industry Responds – With Lawsuit
PhRMA,
Generic Pharmaceutical Association &
Lawsuits – County Prevails
Ordinance timelines delayed by mutual
agreement.
August 29th 2013 Alameda County wins
in 9th circuit
Appeal Filed 9th Circuit Court of Appeals
July 11 2014 Hearing
Alameda County wins again
Ordinance moves forward
Timeline - Ordinance
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Deadline for plan filing July 2014 1st
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Spring 2014
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Contact with potential Product Stewardship Organizations
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Phone and in person meetings
Pharmaceutical industry creates product stewardship
organization
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PPSWG ( formed late 2013)
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Pharmaceutical Product Stewardship Working Group
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~ 360+ members =~ 90% +of market currently
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457 companies identified selling in Alameda County
Their plan
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3 year implementation
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1st year 12 one day events and 20 Law enforcement
kiosks – 1st event within 90 days
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2nd & 3rd year... pharmacies
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Website, 800 number & Robust outreach planned
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T&D vendor Stericycle
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Goal of 100 Kiosks at the end of year 3
Their performance
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1st year March 2014-2015 1 event 0 kiosks
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Contracting and Ordinance OTC issues
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2nd year 16-23 events( 9 HHW events)
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Poor outreach for non HHW events
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16 signed contracts for kiosks
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0 kiosks in service so far
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6 kiosks installed Tuesday & Wednesday – 11 by Friday at
independent pharmacies & law enforcement sites
One day events
Kiosks
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Spring 2016 Stewardship organization recruiting
pharmacies
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Difficult landscape in Alameda County ~20
independent pharmacies 200+ Chain & HMO
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Major Chains are not participating
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37 Walgreens in Alameda County
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3 participating independent of med project
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Kaiser – Announced pilot program with 6 sites in
Alameda county early 2017
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Some interest from smaller chains
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9 Signed contracts with Independent Pharmacies
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6 LEA’s sign contracts
1st Batch of Kiosks installed
this week Dec 6-9 2016
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Law Enforcement sites
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Alameda, Piedmont, Pleasanton, Oakland (x2) + Sherriff’s
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Albany & Hayward declined
Pharmacy sites
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New Oakland Pharmacy (x2) Downtown
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Total of 5 scheduled
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Tennyson pharmacy Hayward
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Teds Drugs Hayward
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Clayworth Castro Valley
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Hallers – Fremont/Union City X 2
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Midtown Pharmacy Bay Farm Island
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Wellspring Pharmacy Oakland
Obstacles
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DEA Rules Restrict Sites to Pharmacies, Hospitals, Nursing Homes, &
Law Enforcement only
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Relies on Voluntary Participation by the above
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Inexperienced Product stewardship group
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Did not understand contracting with LEA
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Few Players in the vendor arena
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Intersection between DEA and DOT unclear
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DEA regs barriers to new entrants
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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
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Additional registration requirements
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Pharmacist in Charge escape clause from mandatory ordinance
Law Enforcement agencies not
participating as of yet
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Albany - lobby space issue
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Hayward - space issues
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Fremont - contracting issue
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Union City - contracting issues
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Newark
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Livermore
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Dublin
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San Leandro – contracting
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Berkeley – Jurisdictional issue
Sharps Ordinance
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Estimated 15-45,000 medical sharps users in Alameda County
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New drug therapies for self injection continue to come out!
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Supervisor Carson – Decade long concern about lack of convenient
disposal for sharps
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Supported SB 1305 Figueroa – Allows sharps collection at HHW
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Few disposal sites, 4 HHW facilities, some Kaiser and pharmacy sites
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Proposed Sharps Ordinance modeled after Drug ordinance in 2015
after court challenges to Med ordinance resolved
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Passed BOS 11-2015 – Plans due next week
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Drug Stewardship organization will also handle sharps
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Collection activities could happen by July 2017
Future candidates for
Product Stewardship ordinance
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Batteries
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Fluorescent lamps
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Propane Cylinders
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Marine Flares
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SF Marin San Mateo Santa Clara joint ordinance
model – 4 counties collaborate on coordinated
ordinances