The Association of Metropolitan Water Agencies (AMWA) strongly supports a coordinated, multi-pronged approach to the challenges posed by pharmaceutical compounds found at trace levels in many surface and groundwater sources used for drinking water supply. A clear focus on source control, which targets the approval, use and disposal of pharmaceuticals, is imperative, while recognizing the balance of public health benefits of pharmaceuticals versus the impacts to drinking water.
AMWA believes continued research to gather information on pharmaceuticals in water is critical to informing future actions such as the development of water quality criteria and possible mitigation. Therefore, AMWA recommends that:
- Congress increase the U.S. Environmental Protection Agency’s (EPA) research budget for pharmaceuticals in water.
- EPA and the United States Geological Survey (USGS) establish a target compound list and prioritize the standardization of analytical methods.
- EPA and other federal agencies focus pharmaceutical research efforts on relative source contribution, human health effects, and effects on aquatic life.
- Water and wastewater research organizations coordinate their activities and focus research on treatment technologies, risk assessment, fate and transport, and effective communication.
Minimizing pharmaceutical loading by pharmaceutical take back programs is one step that will help reduce pharmaceutical concentrations in wastewater streams. However, human and animal excretion resulting from the metabolism of pharmaceuticals and unmetabolized pharmaceuticals are by far the largest contributor and cannot be stopped or easily controlled.1 When necessary, more must be done to reduce pharmaceutical concentrations in wastewater streams before discharging into the environment. In this regard, AMWA recommends that:
- The Food and Drug Administration (FDA) require environmental assessments (e.g., fate, transport,residuals, by-products, etc.) as part of the drug approval and registration process. These assessments would predict possible resultant concentrations of the pharmaceutical in drinking water supplies and the environment. This would provide valuable information to EPA in the development of national impact and mitigation estimates and, if necessary, response plans.
- U.S. Department of Agriculture develop guidance for animal feeding and production operations to reduce antibiotics and steroids in runoff, and that EPA monitor the effectiveness of its present National Pollution Discharge Elimination System (NPDES) programs for preventing such pollution and adjust them appropriately.
- The federal government develop a national program to provide consumers with an easy and secure method to dispose of unused prescriptions. Specifically, federal entities such as EPA, FDA, and the Justice Department should identify barriers and pursue changes in federal and state regulations that currently impede the success of drug return, disposal, and reuse programs. AMWA believes that the key to any effort on pharmaceuticals must engage the public in the process. AMWA therefore supports development of public education tools and programs to garner public support and participation in source reduction programs, which includes pharmaceutical take back disposal programs.
AMWA is concerned that FDA’s “flush list” continues to promote the disposal of certain medications by flushing into the toilet.2 While AMWA recognizes the importance of encouraging the immediate disposal of leftover pharmaceuticals that could be abused, such a policy conflicts with campaigns that ask consumers to “only flush the 3 Ps” into the toilet.3 AMWA therefore believes that the federal government should refrain from endorsing or encouraging the disposal of any medication or controlled substance by flushing it into the wastewater system.
AMWA further believes that enhanced public engagement and streamlined communication is key to any effort to provide education about pharmaceuticals in water supplies. AMWA supports development of public education tools and programs to garner public support and participation in source reduction programs, which includes pharmaceutical take back disposal programs.
Rationale:
- Pharmaceutical residues found in the water environment are a concern that drinking water utilities take seriously. Health effects research must continue to better understand whether exposure to low concentrations has any human impact. Such information needs to be coupled with relative source contributions so it can be integrated into a risk management framework.
- Preventing the entry of contaminants into waste streams will reduce their concentration in drinking water sources, which will also serve to reduce contamination from today’s pharmaceuticals and those developed in the future. It is challenging and expensive to address pharmaceuticals after they are in drinking water sources and have been diluted to trace levels.
- More research in the arena of water is needed so public policy makers can make decisions and risk trade-offs based on sound science. The unintended consequences of pharmaceuticals and current water treatment processes (like ozonation) are unknown; we know ozone reduces the concentrations of some pharmaceuticals, but oxidation is not complete, leaving unknown by-products. Research in this area is needed so we can weigh the public health benefits against the economics of more stringent source control measures.
- In addition to information on the occurrence of pharmaceuticals, the public also needs information related to health relevance in order to draw informed conclusions. This information must be developed by federal agencies and by experts in the field. Water utilities can assist by making the information available to their customers. The public is beginning to recognize that improper use and disposal of pharmaceuticals contributes to the problem, as does human metabolism of drugs taken as properly prescribed. As a result, the public wants to be part of a solution for reducing pharmaceuticals in the water environment. Products and tools need to be developed to tap this reservoir of help and support.
1 "271M Lbs Of Pharmaceuticals In Our Water,” CBS News, April 20, 2009.