Action Please By:
October 3, 2008

The U.S. Environmental Protection Agency (EPA or Agency) is seeking comments on a proposed information collection request (ICR) on pharmaceutical handling practices at the nation’s health care facilities.  EPA intends to conduct a “detailed study of unused pharmaceutical disposal methods by hospitals, long-term care facilities, hospices and veterinary hospitals” to support its ongoing effluent guidelines work and broader efforts on pharmaceutical issues.

This Regulatory Alert provides a brief summary of the types of information EPA is seeking and provides links to the draft surveys for health care facilities and veterinary hospitals.  EPA’s data collection effort will inform the Agency’s ongoing evaluation of the Health Services Industry under the effluent limitation guidelines (ELG) program (see Regulatory Alert 07-05), which NACWA is closely tracking.  NACWA’s Emerging Contaminants Workgroup will discuss the ICR during its August 13 teleconference and will continue to review the ICR to determine whether the Association should submit comments.  Comments on the ICR are due to EPA by November 10, and NACWA is requesting that members send any comments on the ICR to Chris Hornback at This e-mail address is being protected from spambots. You need JavaScript enabled to view it by Friday, October 3, 2008.

Surveys Seek Information on Disposal Practices

EPA’s notice (PDF) announcing the proposed ICR (August 12, 2008; 73 Fed. Reg. 46903) said the Agency wants more information on the practices of the health care industry to inform future potential regulatory actions and to identify best management and proper disposal practices.  The proposed study comes after Benjamin Grumbles, EPA assistant administrator for water, faced a tough line of questioning during a Senate hearing this past April on the agency’s efforts to address pharmaceuticals in water, but the data collection effort would likely have been conducted anyway under the Agency’s ongoing work on the Health Services effluent guideline.

EPA is interested in whether it is asking the right questions, has included the appropriate scope and type of facilities, and has accurately estimated the burden on the health care facilities that will be required to complete the surveys.  EPA is planning to include health services establishments including hospitals, hospices, long-term care facilities, and veterinary facilities.  EPA is seeking comment on whether to include veterinary clinics, medical and dental offices, as well as university and prison health clinics.

EPA indicates that it believes the health services industry accounts for the majority of the institutional (non residential) discharges of unused pharmaceuticals to wastewater and identifies the following areas for investigation in the surveys:

• What are the current industry practices for disposing of unused pharmaceuticals?
• Which pharmaceuticals are being disposed of and at what quantities?
• What are the alternatives to disposing unused pharmaceuticals down the drain or toilet?
• What factors influence disposal decisions?
• Do disposal practices differ within industry sectors?
• What best management practices (BMPs) could facilities implement to reduce the generation of unused pharmaceuticals?
• What reductions in the quantities of pharmaceuticals discharged to wastewater treatment plants would be achieved by implementing BMPs or alternative disposal methods?
• What are the costs of current disposal practices compared to the costs of implementing BMPs or alternative disposal methods?

NACWA has posted both the health services establishment survey and the veterinary hospital survey on its website.

Again, NACWA is requesting that members send any comments on the ICR and the draft surveys to Chris Hornback at This e-mail address is being protected from spambots. You need JavaScript enabled to view it by Friday, October 3, 2008.

EPA to Convene NAS Panel on Pharmaceuticals

In addition to the planned information collection effort from the Health Services Industry, EPA recently announced it is commissioning the National Academy of Sciences (NAS) to provide scientific advice on the potential risk to human health from low levels of pharmaceutical residues in drinking water.  NAS will convene a workshop of scientific experts Dec. 11-12 to advise the agency on methods for screening and prioritizing pharmaceuticals to determine potential risk.