Letter to the Editor by Diane Ellmers to “Think Before You Flush! A Sustainable Aquatic Eco-System’s Relation to Human Health”

Environmental Health: Important Choices for a Greener World

January 9, 2014

Response by Diane Ellmers to the article “Think Before You Flush! A Sustainable Aquatic Eco-System’s Relation to Human Health” by Elaine McKeown, MSN, RN, and Judith Pawloski, MSN, RN (December 18, 2012)

Dear Editor:

After personally viewing the barges scooping water and PCB-containing silt from the bottom of the Hudson River to perform one of the most expensive environmental clean-ups performed in U.S. history, I have to ask, isn’t it best to eliminate the hazard and the expense to humans and the environment by keeping chemical waste from the water supply in the first place (“Hudson River”, 2012)?

As a registered nurse who administers intravenous narcotics and benzodiazepines regularly to hospitalized patients, I am required to place any controlled substances down the sink if there is more of the medication than what is ordered by the physician to be administered to the patient. Fentanyl patches are required to be flushed down the toilet when removed from a patient. These medications are not allowed to be placed in a sharps container or in the garbage, as was done as recently as 2012.

The purpose of disposing narcotics down the sink or the toilet is to keep them out of the hands (and bloodstream) of those for whom the drug isn’t intended. The Food and Drug Administration (FDA) and the Environmental Protection Agency (EPA) have specific information on the handling of unwanted pharmaceuticals for the consumer on their websites. For instance, the EPA (2010) indicates that consumers not dispose of their medications and supplements in the drain or to flush them down the toilet but instead mix them with substances like kitty litter, coffee grounds, spoiled food, or cayenne pepper, and then place this into a sealed bag or lidded container into the trash. Like the EPA, the FDA (2013) indicates that trash disposal is the best method except for certain medications (e.g., narcotics) in which they recommend flushing them down the sink or toilet to avoid accidental ingestion. Although the FDA acknowledges recent reports that trace amounts of medicines are in the water system the majority is from drug elimination in feces or urine and that the risk outweighs the potential for accidental ingestion which may result in a life-threatening situation (2013).

It is understandable that consumers would be in a quandary about the disposal of unused and expired meds but hospitals and long-term health facilities? One would expect cutting-edge technology to be in place and that federal guidelines be aggressively protective of our environment and the community in which we live. Gebhart (2009) indicated that the Drug Enforcement Agency (DEA) was rethinking disposal methods along with the EPA and others due to environmental concerns. Apparently they have (the basis being the Secure and Responsible Drug Disposal Act of 2010) and, according to the DEA, expanded options for private individuals include take back events, mail-back programs and authorized collection receptacles (2012). Focusing on the DEA’s disposal procedures such as at a hospital (Sec. 1317.95), two authorized employees (e.g., RNs) witness the removal and the disposing of controlled substances until they are rendered non-retrievable (2012). This procedure isn’t new and how the substance is rendered non-retrievable isn’t detailed. That leaves a questionable interpretation of the rules, in my opinion.

Although progress is being made for private individuals, it appears to be lacking for facilities such as hospitals. Why haven’t inexpensive and secured disposal systems been put in place at these facilities?

Instead, I am required to essentially place various medications into the ecosystem, and eventually our drinking water, because it is more cost-effective (until you compare the same misguided thinking to the polluting of the Hudson River). Somehow it seems contradictory to my line of work. After all, it is a nurse’s job to care and advocate for the patient and this is an example in which our water, and eventually our health, needs our advocacy as well.

Diane Ellmers, RN
E-mail: ellmers@verizon.net


Gebhart, F. (2009, March 1). Controlled-substance disposal: DEA wants to make it easier. Drug Topics. Retrieved from http://drugtopics.modernmedicine.com/news/controlled-substance-disposal-dea-wants-make-it-easier

United States Environmental Protection Agency. (2012). Hudson river cleanup. Retrieved from www.epa.gov/hudson/cleanup.html

How do I dispose of unwanted or expired prescriptions and over-the-counter medicines, vitamins and other supplements properly? Retrieved from http://safewater.supportportal.com/link/portal/23002/23015/Article/15086/How-do-I-dispose-of-unwanted-or-expired-prescription-and-over-the-counter-medicines-vitamins-and-other-supplements-properly

United States Food and Drug Administration. U. S. Department of Health and Human Services. (2013). Disposal of unused medicines: What you should know. Retrieved from www.fda.gov/Drugs/ResourcesForYou/Consumers/BuyingUsingMedicineSafely/EnsuringSafeUseofMedicine/SafeDisposalofMedicines/ucm186187.htm

U.S. Department of Justice. Drug Enforcement Administration. Office of Diversion Control. (2012) Rules – 2012. Federal Register Volume 77, Number 246. Retrieved from www.deadiversion.usdoj.gov/fed_regs/rules/2012/fr1221_8.htm