December 2010 report to the California Legislature: Recommendations for Home-Generated Pharmaceutical Collection Programs in California


Program Evaluation

In 2010, the Department of Resources Recycling and Recovery (CalRecycle) surveyed existing home-generated pharmaceutical waste collection programs including continuous collection sites (primarily law enforcement, pharmacy, and household hazardous waste facilities), periodic collection "events," and mail-back programs. Each has advantages and each faces barriers in being able to meet the voluntary model program guidelines. Local governments funded approximately 83 percent of all California collection programs.

Drug Diversion Incidences

Out of 256 collection sites or programs representing 86 percent of all known programs operating in California anytime since 1995, no survey respondents reported any signs of illegal drug diversion. Washington state's "PH:ARM Pilot" program (using a less costly two-key collection process in pharmacies than California's Model Guidelines) also reported no diversion incidences in the 3 and 1/2 years that 39 pharmacies in their original program had been operating collection programs.

However, outside of these programs, one Northern California pharmacy stopped its collection program after a young woman's drug overdose death was suspected to be linked to drug diversion from the pharmacy's collection program. Also, a Lynwood, Wash., "pharmacist of the year" collected expired and unexpired drugs from doctors, hospices, clinics, and pharmacy customers to allegedly distribute to less developed countries. Instead, he filled his pharmacy's regular supply pill bottles. However, they may not be considered a true "collection program" since the drug store employing the pharmacist may not have known he was collecting home-generated pharmaceutical waste from customers. No other home-generated pharmaceutical waste collection program in the world is known to have illegally diverted its collected pharmaceutical waste.


CalRecycle recommends that the Legislature adopt a combination of two options related to pharmaceutical waste collection programs.

  1. Statutory changes to establish clear state roles and responsibilities, provide direction to resolve several implementation challenges, and direct that the Criteria and Procedures for Model Home-Generated Pharmaceutical Waste Collection and Disposal Programs (Model Guidelines) be refined and converted in regulations.
  2. Statutory direction to address funding barriers by providing financing through a private sector approach with government oversight, commonly referred to as product stewardship.

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