Department of Environmental Conservation

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NYS Comptroller

THOMAS P. DiNAPOLI

Taxpayers' Guide to State and Local Audits

Department of Environmental Conservation
Drug Management and Disposal


Issued: April 27, 2018
Link to full audit report 2016-S-82
Link to 90-day response

Purpose
To determine whether the Department of Environmental Conservation (Department) developed and implemented a public information program on the proper storage and disposal of medications (drugs), and publicly disseminated a notice to pharmacies, retailers, and consumers on the proper storage and disposal of drugs. We also sought to determine whether registered pharmacies and retailers of drugs properly display this notice. Additionally, we sought to gather and assess information on the extent of availability and usage of drug collection and disposal options across the State in order to examine ways to improve the efficacy of the Department’s voluntary initiatives. This audit covers the period January 1, 2015 through May 19, 2017.

Background
Unused pharmaceuticals present a range of harmful environmental and societal consequences. In the past, pharmaceuticals were typically disposed of by throwing them in the trash or flushing them down drains, where they ultimately flow into wastewater treatment plants, which are not equipped to remove them. The resultant pharmaceuticals in the environment and water resources have had biological consequences (e.g., mutations of fish). On the other hand, unused drugs that are not disposed of have been linked to drug abuse and addiction. Both conditions factor into the need for safe drug disposal practices. Drug disposal options for the public include permanent collection boxes, where unwanted drugs can be dropped off in a secure box; takeback events, which are generally held at locations across the State twice a year; and mail-back programs, which provide envelopes to consumers to securely mail unwanted drugs to a drug disposal site for destruction.

Key Findings

  • We found that the Department developed and implemented a public information program on the proper storage and disposal of drugs, and created a notice regarding the proper storage and disposal of drugs for display in pharmacies and other drug retailers. Our visits to 106 pharmacies found that 82 (77 percent) displayed the notice, albeit generally inconspicuously. However, there is no way to know how effective its public information program has been because the Department has not measured public awareness, nor is it mandated to do so.
  • The Department has engaged in other initiatives, beyond those mandated, to promote proper drug collection and disposal. For instance, the Department frequently partners with other government agencies and advocacy groups to advance research on pharmaceuticals in the environment and to develop drug collection programs.
  • U.S. Drug Enforcement Administration-sponsored take-back events have collected large sums of drugs in New York since 2010, peaking at over 96,000 pounds in 2013.
  • As of March 2017, there were at least 346 collection box locations in the State, of which over 65 percent were operated by law enforcement agencies. The availability of the boxes varies widely, with some areas of the State having a relatively significant number and other areas having very few or none, as shown in Map 2 on page 12 of the report. The quantity of drugs collected in the boxes statewide is not known. Likewise, information on mail-back program availability and usage is limited. For example, there is no information on participation in the mail-back program or amounts of drugs collected.
  • Additionally, the Department has initiated its Pilot Pharmaceutical Take-Back Program, which it expects 400 pharmacies to participate in. Department officials state that the boxes cost $1,250 each, including delivery.
  • There are significant disincentives that likely discourage some entities from voluntarily operating a drug collection box and some citizens from properly disposing of drugs. Common reasons why entities do not operate collection boxes include the cost of the box (approximately $800), drug disposal charges, and personnel and the need to provide space and security for it. The main disincentive to mail-back envelopes is the cost to customers to buy them.

Key Recommendations

  • Assess additional strategies to continue raising public awareness of proper drug disposal, such as the use of various media, and implement those deemed to be optimal.
  • To improve the efficacy of its voluntary initiatives for the proper collection and disposal of drugs in the State, the Department should work with stakeholders to identify and attempt to reduce barriers or disincentives to collectors and consumers.

Other Related Audits/Reports of Interest
None


State Government Accountability Contact Information:
Audit Director: Stephen Goss
Phone: (518) 474-3271; Email: StateGovernmentAccountability@osc.state.ny.us
Address: Office of the State Comptroller; Division of State Government Accountability; 110 State Street, 11th Floor; Albany, NY 12236