EPA scales back waste disposal survey

Agency seeks information on veterinarians' waste disposal practices

March 5, 2009 (published)
By Edie Lau

A proposed survey on pharmaceutical disposal practices at veterinary offices and other medical facilities will be vastly shortened to lighten the burden on respondents, an official at the U.S. Environmental Protection Agency (EPA) said this week.

Meghan Hessenauer of the EPA's Engineering and Analysis Division in its Office of Science and Technology told The VIN News Service that the survey may be scaled back to as few as one or two pages. The original draft was 28 pages, including a table of contents, instructions, definitions and appendices.

The purpose of the survey is to determine to what extent the health services industry is disposing of unused pharmaceuticals by pouring them down drains or flushing them down toilets. Doing so is not illegal, and drug residues are showing up in streams, rivers and lakes possibly as a result. The risk is unclear, but scientists are concerned that drug compounds could harm aquatic ecosystems and/or end up in drinking water.

In shortening the survey, Hessenauer said, the EPA is acknowledging concerns that answering the questionnaire would require of participants too much time and money. The EPA had calculated that the survey would take the average participant 41 hours and cost $1,463.

Of 3,544 parties it has proposed to survey, 296 are veterinary offices.

In comments to the EPA, the American Veterinary Medical Association (AVMA) objected to including veterinarians at all, arguing that most of its members work in small clinics that contribute negligibly to pharmaceutical water pollution.

Hessenauer said representatives for dentists made the same case.

But since the survey's aim is to determine to what extent various sectors of the medical industry contribute, Hessenauer said the EPA can't exempt any group without some objective evidence or information about their drug disposal practices.

"Hopefully, we'll get honest answers (to the survey)," she said.

Hessenauer said a Federal Register notice of the retooled proposed survey will be posted this summer, probably July. The earliest the survey would be distributed is November, she said.

In a separate but related proposal, the EPA is considering allowing generators of pharmaceutical wastes to come under the auspices of the federal Universal Waste Rule rather than the Resource Conservation and Recovery Act (RCRA).

The change would enable facilities to accumulate more wastes for a longer time period on their premises. Disposal would still be at a hazardous-waste facility, according to EPA spokeswoman Latisha Petteway.

The AVMA told the EPA that while its members generate little in the way of hazardous pharmaceutical waste, it appreciated the greater flexibility allowed under the plan.

The comment period for the proposal ended Wednesday. An EPA official said the rule will be finalized in late 2010.

VIN News Service commentaries are opinion pieces presenting insights, personal experiences and/or perspectives on topical issues by members of the veterinary community. To submit a commentary for consideration, email

Information and opinions expressed in letters to the editor are those of the author and are independent of the VIN News Service. Letters may be edited for style. We do not verify their content for accuracy.