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California State Auditor Report Number : 2016-127

Home‑Generated Sharps and Pharmaceutical Waste
By Designating a Lead Agency, the State Could Increase Proper Disposal

Figure 1
Collection Sites Offer Options for Legal Disposal of Home‑Generated Sharps

Figure 1 is a flow chart showing what happens to home-generated sharps when they become waste. The figure shows two basic pathways for the waste, one path showing what happens when a consumer illegally disposes of sharps, and the other path showing what happens when a resident legally disposes of sharps waste. In the illegal disposal path, the consumer throws a syringe in the trash, which is then sent to the landfill. In the legal disposal path, the consumer places the syringe into an approved sharps container. The consumer then takes the containerized sharps to a collection site, which can include pharmacies (overseen by the Pharmacy Board), hospitals and clinics (overseen by Public Health), Syringe Exchange Programs (overseen by Public Health), and Household Hazardous Waste Sites (overseen by Toxic Substances Control). These sharps are then picked up by a hauler approved by Toxic Substances Control or Public Health and taken to ultimate disposal facilities either in state or out of state. When the sharps waste remains in state, they go to medical waste treatment sites. These sharps are treated by autoclave or microwave sanitation, at which point they become solid waste. Sharps taken out of state are taken to incinerators, where they are combusted.

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Figure 2
California’s Consumers Unknowingly Choose How Home‑Generated Pharmaceutical Waste Is Processed

Figure 2 is a flow chart that shows that consumers’ choice of where they dispose of their pharmaceutical waste impacts how that waste is disposed and what agencies regulate that deposal. The figure shows a person, who represents the consumer, disposing of his/her pharmaceutical waste at different locations, including: the toilet, the garbage, mail-back containers, law enforcement, and hospitals or pharmacies. In the case of the toilet, the pharmaceuticals are flushed and enter the sewer system and ultimately the environment. In the case of the garbage, when a consumer throws pharmaceutical waste in the garbage, it may be treated as solid waste and end up in landfills, which are regulated by CalRecycle. In the case of mail-back containers, these are shipped pursuant to U.S. Postal Service regulations to incinerators. They may be treated as controlled substances and regulated by the DEA. In the case of law enforcement, pharmaceuticals may either be treated as controlled substances, which are regulated by the DEA, or medical waste, which is regulated by Public Health. These pharmaceuticals may then be sent to an incinerator. In the case of pharmacies or hospitals, pharmaceuticals may either be treated as controlled substances, which are regulated by the DEA, or medical waste, which is regulated by Public Health. These pharmaceuticals may then be sent to a reverse distributor which act as agents for pharmacies and other entities by receiving, inventorying, managing, and disposing of outdated or unsalable dangerous drugs. Reverse distributors will send this waste to an incinerator. A note at the bottom of the Figure states that DEA regulations require reverse distributors to either render controlled substances irretrievable or return them to the manufacturer.

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Figure 3
State and Federal Agencies Suggest Ways to Dispose of Home‑Generated Sharps and Pharmaceutical Waste

Figure 3 is a graphic that demonstrates the different ways state and federal agencies tell consumers to dispose of home-generated sharps and pharmaceutical waste. The top part of the graphic shows a puzzled consumer wondering how to dispose of his home-generated sharps and pharmaceutical waste. The graphic then illustrates five different ways state and federal agencies suggest that consumers dispose of this waste. The first recommended method is to drop off sharps waste at a syringe exchange program. The second method is to take pharmaceutical waste to a “drug take-back” event. The third method is to throw pharmaceutical waste in trash after mixing it with an undesirable substance. The fourth method is to use a mail-back program for sharps or pharmaceutical waste. The fifth method is to take sharps or pharmaceutical waste to a collection site.

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Figure 4
State and Federal Agencies Offer Conflicting Guidance About Proper Disposal Methods for Home‑Generated Pharmaceutical Waste

Figure 4 is a graphic that shows how state and federal agencies offer conflicting guidance concerning proper disposal methods for home-generated pharmaceutical waste. The graphic shows a concerned consumer in the middle, wondering what to do with his home-generated pharmaceutical waste. On the top part of the chart are three messages that say what the consumer should do with pharmaceutical waste in regards to flushing. The graphic notes that two agencies, CalRecycle and the FDA recommend flushing certain dangerous medications. However, the graphic also notes that that three agencies, the FDA, U.S. Fish and Wildlife, and the U.S. Environmental Protection Agency, tell the consumer not to flush waste unless medication instructions direct the consumer to do so. The graphic also shows that six agencies tell consumers not to flush drugs, including: Public Health, CalRecycle, the Pharmacy Board, the University of California, San Francisco, the Centers for Disease Control and Prevention, the U.S. Fish and Wildlife Service, U.S. Environmental Protection Agency, and the FDA. On the bottom half of the graphic, the consumer is presented with two different messages regarding trashing pharmaceutical waste. Three agencies, Public Health, the Centers for Disease Control and Prevention, and the University of California, San Francisco, tell the consumer not to throw pharmaceutical waste in the trash. However, four agencies, the Pharmacy Board, U.S. Fish and Wildlife Services, the U.S. Environmental Protection Agency, and the FDA, tell consumers to mix pharmaceuticals with cat litter and place the waste in the trash.

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Figure 5
Most Californians Live Within a 20‑Minute Drive of Collection Sites for Home‑Generated Sharps Waste

Figure 5 is a map that shows that about 93 percent of Californians live within a 20-minute drive of collection sites for home-generated sharps waste and that the remaining 7 percent lives outside of that range. The map itself is the entire State of California, with county outlines shown on the map for orientation purposes. The map displays the population of California, represented by dots, each one of which equals 1,000 residents. These population dots are clustered mainly in the coastal metropolitan areas of Los Angeles and the San Francisco, with other significant concentrations of population in San Diego, the Sacramento area, and parts of the Central Valley. On the map is shading to represent the area of the State that is within a 20-minute drive of a home-generated sharps waste collection site. The State’s largest population centers are within this shaded area, but large swaths of the State that are rural areas, along with some population clusters in the Central Valley, are not. These unshaded areas represent areas of the State without reasonable access to a sharps waste collection site.

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Figure 6
Access to Home‑Generated Sharps Waste Collection Sites Varies Among Different Regions

Figure 6 shows how access to home-generated sharps waste collection sites varies among different region by showing access to collection sites in three different areas of California: the San Francisco Bay Area, the Los Angeles Metropolitan area, and Kern County. The figure is broken up into three separate maps. The top left map is that of the San Francisco Bay area, including parts or all of Marin, Sonoma, Napa, Solano, Contra Costa, Alameda, Santa Clara, San Mateo, and San Francisco Counties. The top right map shows the Greater Los Angeles Area, including much of Los Angeles and Orange Counties. The bottom map shows Kern County. Each map shows the population of the area using dots, with each dot representing 50 residents. On the map is shading to represent the area that is within a 20-minute drive of a sharps waste collection site. As a whole, the figure demonstrates that nearly the entire population of the San Francisco Bay Area is within a 20-minute drive of a sharps waste collection sites. In the Los Angeles Metropolitan area, nearly all of the populated areas are within a 20-minute drive of a sharps collection site. However, the map containing Kern County shows a stark contrast. While most of Kern County’s largest metropolitan area, Bakersfield, is with a 20-minute drive of a collection site, many smaller urban areas lie outside of a 20-minute drive of such sites. These areas include the cities of Delano, McFarland, Wasco, Shafter, Taft, Arvin, and Tehachapi-Golden Hills.

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Figure 7
Most Californians Live Within a 20‑Minute Drive of Collection Sites for Home‑Generated Pharmaceutical Waste

Figure 7 is a map that shows that about 91 percent of Californians live within a 20-minute drive of collection sites for home-generated pharmaceutical waste and the remaining 9 percent lives outside of that range. The map itself is the entire State of California, with county outlines shown on the map for orientation purposes. The map displays the population of California, represented by dots, each one of which equals 1,000 residents. These population dots are clustered mainly in the coastal metropolitan areas of Los Angeles and the San Francisco, with other significant concentrations of population in San Diego, the Sacramento area, and parts of the Central Valley. On the map is shading to represent the area of the State that is within a 20-minute drive of a home-generated pharmaceutical waste collection site. The State’s largest population centers are within this shaded area, but large swaths of the State that are rural areas, along with some population clusters in the Central Valley and southeastern part of the State, are not. These unshaded areas represent areas of the State without reasonable access to a pharmaceutical waste collection site.

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Figure 8
Access to Home‑Generated Pharmaceutical Waste Collection Sites Varies Among Different Regions

Figure 8 shows how access to home-generated pharmaceutical waste collection sites varies among different region by showing access to collection sites in three different areas of California: the San Francisco Bay Area, the Los Angeles Metropolitan area, and Imperial County. The figure is broken up into three separate maps. The top left map is that of the San Francisco Bay area, including parts or all of Marin, Sonoma, Napa, Solano, Contra Costa, Alameda, Santa Clara, San Mateo, and San Francisco Counties. The top right map shows the Greater Los Angeles Area, including much of Los Angeles and Orange Counties. The bottom map shows Imperial County. Each map shows the population of the area using dots, with each dot representing 50 residents. On the map is shading to represent the area of the State that is within a 20-minute drive of a pharmaceutical waste collection site. As a whole, the figure demonstrates that nearly the entire population of the San Francisco Bay Area is within a twenty minute drive of a pharmaceutical waste collection site. In the Los Angeles Metropolitan area, nearly all of the populated areas are within a20-minute drive of a pharmaceutical collection site. However, the map containing Imperial County shows a stark contrast. Specifically, Imperial County has virtually no area with reasonable access to a collection site, including the county’s urban areas of Calipatria, Brawley, El Centro-Calexico, and Holtville.

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