Prescription for Safe Water
Scientists are becoming increasingly concerned about the potential public health impact of pharmaceuticals in water. It has been determined that traces of certain health care products have been found in potable water supplies and that they have an adverse affect on aquatic life. While the risk assessments of pharmaceuticals in potable water supplies are not conclusive, potential long-term concerns have started to drive new legislative measures that prohibit the disposal of pharmaceuticals in drinking water systems.
Illinois, for example, has passed a Safe Pharmaceutical Disposal Act. Effective Jan. 1, 2010, public and private health care institutions operating in the state are not allowed to flush unused medications into public wastewater collection systems or septic systems. The act requires that health care providers immediately develop policies and procedures to ensure their compliance.
To gain a better understanding of the benefit of proper disposal programs, WWD invited Charles F. Helsten, a partner with Hinshaw & Culbertson, LLP, whose practice focuses on environmental law, and Richard Lanyon, executive director of the Metropolitan Water Reclamation Water District (MWRD) of Greater Chicago, to comment on this issue.
Neda Simeonova: What is the risk assessment of pharmaceuticals in water?
Charles F. Helsten: Risk assessments are obviously only as good as the quality of the data being studied. Moreover, the results of risk assessments may vary based upon input parameters and/or assumptions employed in conducting the assessment/study. That being the case, the results of risk assessments of pharmaceuticals in potable water supplies have, to date, yielded inconclusive results; however, suffice it to say that the potential concern was great enough to prompt passage of legislation prohibiting the disposal of spent or unused pharmaceutical substances in drinking water systems. I believe the general regulatory sentiment is to head off a potential problem before it ever arises.
Richard Lanyon: We [the MWRD] have not performed a “risk assessment,” but the risk of pharmaceuticals in water is to have adverse impacts on aquatic life and presence in ground or surface waters serving as a supply for potable use. To date, monitoring has shown that the concentrations of pharmaceuticals have not risen to threatening levels.
Simeonova: Do you anticipate that the problem with pharmaceutical contamination will continue to increase, and if so, why?
Helsten: Given the fact that our general populace is growing older, and thus relying more and more on medications of certain types, kinds and sorts, one could expect that the potential for pharmaceutical contamination would theoretically increase. However, I suspect that, as is the case with most industries, safeguards are being developed and will continue to be developed to address the potential problem.
In this particular case, I suspect we will see a greater emphasis on testing for pharmaceuticals in potable water supply sources and, in turn, commensurate treatment of those contaminants.
Lanyon: Thus far we do not consider it contamination because there are no standards for comparison. The concentration of pharmaceuticals is likely to continue to rise due to the widespread use of these products and lack of accepted practices for safe disposal of unused medications.
Simeonova: Please discuss how the Illinois Safe Pharmaceutical Disposal Act would affect health care institutions?
Helsten: The act targets a wide range of health care providers, including hospitals, nursing homes, residential health care facilities, home health care facilities, hospice programs, mental health facilities and agencies providing services to persons with developmental disabilities.
The act reflects an intent to exercise strict control over the disposal of unused or expired pharmaceuticals, and accordingly, its application is extremely broad.
Simeonova: Research has recently focused on the ability of current drinking water treatment technologies to remove pharmaceutical contaminants. How would proper disposal practices of pharmaceuticals affect water processing facilities?
Helsten: New treatment technologies designed to remove pharmaceutical contaminants are, of course, driven by the potential presence of pharmaceuticals in public drinking water sources. That being said, to the extent that proper disposal practices effectively minimize the amount of pharmaceutical substances entering potable water sources, the easier it is to treat these potential contaminants.
Lanyon: We should see modest decreases in the concentration of pharmaceuticals at our treatment plants. We say modest because most pharmaceuticals are those taken by individuals and passed through the digestive system. This portion is likely not to decrease.
Simeonova: Would this be enough to reduce the detrimental effects caused by introducing such materials into water systems?
Helsten: I think it is safe to say that the potential nature and impact of the presence of pharmaceutical contaminants in drinking water sources is presently largely unknown. In addition, treatment technologies for these substances—in the potable water supply context—are in their early stages of development, so it is probably too early to know how effective these treatment methods are or will be.
Many states have developed take-back/return programs, where consumers can return unused or spent quantities of prescription drugs for safe and proper disposal. In my opinion, these type of stewardship programs will be the most effective in methods of addressing this concern, as the greater the degree of control exercised over the potential problem at the base level, the better.
Lanyon: No. We still need the federal agencies—DEA, EPA and FDA—to come up with effective control strategies to reduce the excessive use of these products. For instance, a prohibition on advertising would help to curb the popular demand for drugs where there is no medical necessity.
Simeonova: What other steps should states take to educate the public about safe pharmaceutical disposal practices?
Helsten: As with any potential health concern, both online and hard copy fact sheets, “frequently asked questions” sheets, etc., are beneficial. However, again, I believe the most beneficial form of education is advising the public of the existence of take-back programs whereby unused or spent quantities of prescription drugs can be returned and properly disposed of before they ever present a potential concern.
Lanyon: Step one would be to have proactive educational programs. We don’t see or hear public service announcements. Also, the various regulatory agencies and medical organizations should cooperate in developing and supplying educational programs and materials. Thus far, we have seen little cooperation and coordination.
Typical for the American experience, this issue will remain largely unattended until it reaches crisis level and then there will be an all-out effort to do something. We hope that this does not happen because it may be too late. Once these pharmaceuticals become embedded in the ecosystem, it will take generations for removal and for them to be diminished.