Pilot Pharmaceutical Take-Back Program
DEC is working with retail chain and independent pharmacies across New York State to establish a pilot pharmaceutical take-back program. The program will cover the costs of consumer drug collection boxes and disposal for two years. All pharmacies in New York State are encouraged to apply to participate in the program, and at least 200 pharmacies will be funded.
Why is the New York State Department of Environmental Conservation implementing this pilot program?
Some of our lakes, rivers and streams contain low levels of pharmaceuticals, which may be attributed, in part, to years of consumers flushing unwanted drugs down the drain. Furthermore, prescription drug abuse has become epidemic across New York State and the nation. Providing a safe, convenient and effective way to collect unused drugs via a pharmacy-based take-back program can improve water quality, reduce potential adverse impacts to aquatic organisms, and dramatically reduce these public health and safety risks. See our page Drugs in New York's Waters for more information.
DEC will select pharmacies to participate in the pilot program based on the following criteria:
- The applying pharmacy's willingness to continue medication collection, at their expense, when the pilot program ends;
- A shortage of existing drop box locations in proximity to the applying pharmacy;
- Proximity of the applying pharmacy to drinking water sources;
- Proximity of the applying pharmacy to potential environmental justice areas;
- Pharmacies located in counties with a high-rate of opioid deaths.
How does a pharmacy apply to the pilot program?
Pharmacies interested in applying to the pilot program must complete an online application. A separate application must be completed for each pharmacy location; retail chains may submit up to 20 applications (locations). Only pharmacies located within New York State are eligible for participation in this pilot program.
Given the potential interest in this pilot program and limited funding available, there is no guarantee that all interested pharmacies will be able to participate. Every effort will be made to maximize program participation.
It will be helpful to gather the following information before completing the online application:
- Who will be the pharmacy's Point of Contact? The Point of Contact is the person we will communicate and work with, if your pharmacy is chosen for the pilot program.
- In which County is the pharmacy located?
- What is the distance between existing drop box locations and the applying pharmacy location?
- Use our Google Earth map to find existing NYS Medication Drop Box Locations.
- Copy the address of the drop box location closest to the applying pharmacy.
- Go to Google Maps (link leaves DEC website). Enter the applying pharmacy's address and hit enter or click the search button. To determine mileage, click on "Directions" and enter the address of the nearest drop box location.
On the application, you will be asked to choose a distance range. Choose the range that best fits; you may round to the nearest mile. If the chosen range is incorrect, it may result in the elimination of your pharmacy from consideration in the pilot program.
- Is the applying pharmacy's location in a potential environmental justice area? Reference our County maps showing potential Environmental Justice areas; these areas are shaded in purple. Please note, there are no potential environmental justice areas in these counties: Hamilton, Orleans, Putnam, Schuyler, Seneca, and Yates.
To apply, use our online application through Survey Monkey (link leaves DEC website). Applications are due by May 1, 2017.
How will the pilot program work?
For selected pharmacies, the pilot take-back program will cover the full cost of purchasing a U.S. Drug Enforcement Administration (DEA) compliant medication drop box, replacement inner liners, and the cost of pick up, transport and destruction of all collected waste pharmaceuticals by a DEA-registered reverse distributor for a period of two years. DEC will purchase the DEA-compliant medication drop box and will have it shipped directly to the participating pharmacy. The participating pharmacy will be required to install, operate and maintain the collection box pursuant to DEA regulations (link leaves DEC website) for the two year pilot. DEC will hire a third party contractor who will either pick up, transport and destroy these waste drugs directly or will use a common carrier to undertake these activities.
How long will the pilot program be implemented?
The pilot program will cover the cost of drug disposal for a period of two years. At that point participating pharmacies will have the option to continue with the program and cover the disposal costs at their own expense. If a pharmacy is not interested in continuing, DEC has the right to require that the medication drop box be removed from the pharmacy and placed in one that is interested in providing this service to its customers.
If selected, what will be the participating pharmacy's responsibilities?
The general responsibilities of the pharmacy for participating in the pilot program include the following:
- Once selected, the pharmacy must modify its DEA registration (link leaves DEC website) to become an authorized collector to collect controlled substances through an on-site take-back program. This is a free and simple online process that just takes minutes to complete.
- The pharmacy will need to install the medication collection box according to the third-party contractor's instructions and per federal DEA requirements (link leaves DEC website).
- The pharmacy will be responsible for managing the collection receptacle to ensure its proper operation. This includes periodic monitoring to determine when it is full, unlocking and removing the inner liner, and contacting the collection third-party contractor or common carrier to arrange for liner pickup. Please note that the pharmacy will need to follow all DEA regulations related to unlocking the collection receptacle and removing the inner liner. This means the installation, removal, transfer and storage of full inner liners shall be performed by or under the direct supervision of two employees of the participating pharmacy.
- The pharmacy will replace inner liners when they are full. Inner liners will be sealed in accordance with the included instructions for use, and provided to the selected third-party contractor or common carrier for prepaid return transportation to the treatment facility. Upon removal, sealed inner liners must be securely stored at the participating pharmacy's registered location in a securely locked, substantially constructed cabinet or a securely locked room with controlled access until transfer to the common carrier.
- The pharmacy will need to maintain all records as required by DEA regulations by filling out the Step Log provided by the drug disposal third-party contractor. This is a fairly easy and straight-forward process.
- The pharmacy will need to make sure signage is properly displayed on or in close proximity to the collection receptacle. Signage and display information will be provided by the medication collection box third-party contractor.
The third-party contractor will be responsible for providing the pharmacies with training and support throughout the program.
Where should the medication collection box be installed within the pharmacy?
The collection receptacle must be installed in an area that can be easily and continuously monitored by the pharmacist or pharmacy staff and is accessible to the public.
How big are the DEA-compliant medication collection boxes?
To accommodate the needs of participating pharmacies and potential space limitations, DEC intends to offer at least two medication collection box sizes for installation at participating pharmacies. This includes 18-gallon and 38-gallon collection boxes. An 18-gallon medication drop box dimensions are generally 38.25" tall by 17" wide by 16.25" deep, while a 38-gallon medication drop box receptacle is generally 43.75" tall by 22.5" wide by 21.25" deep. If space is not an issue, DEC recommends going with the larger sized unit to minimize liner replacements and disposal costs. Depending on the ultimate third-party contractor selected, collection boxes larger than 38-gallons may be offered if space is not a limiting factor in the pharmacy.
Where can pharmacies find additional resources related to pharmacy-based collection efforts in New York State?
The Product Stewardship Institute (PSI) has a number of valuable resources related to pharmacy-based collections programs implemented in New York and across the United States, including the "How-to Guide for Drug Take-Back: Managing a Pharmacy-Based Collection Program for Leftover Household Pharmaceuticals" (PDF, 2.92 MB). This guide was created as an outcome of a recently completed and successful pilot pharmacy-based medication collection program in Oneida and Lewis Counties. PSI also held a webinar on this pilot program and included the participating pharmacies as speakers. A recording of the webinar can also be downloaded at PSI's website, Best Practices for Running Pharmacy-Based Drug Take-Back-Webinar Recording (link leaves DEC website).