CMA 2016 #262 · Agenda item attachment · Sep 19 2016

TO: Richard C. Rossi, City Manager FROM: Claude-Alix Jacob, Chief Public Health Officer DATE: September 14, 2016 SUBJECT: Response to Policy Order #3, adopted 4/11/16 Excerpt of Order: That the City Manager be and hereby is requested to confer with the Cambridge Department of Public Health, the Police Department and any other appropriate City departments to discuss the feasibility of hosting additional drop-off locations to provide for the safe disposal of unused prescription medications, and to report back to the City Council in a timely manner. (For full text: https://cambridgema.iqm2.com/Citizens/Detail_LegiFile.aspx?ID=2339) The City of Cambridge is committed to making it easier for residents to dispose of unwanted medications. Proper disposal of unwanted medications helps protect the environment, prevent accidental poisonings, and reduce the likelihood that the drugs could be illegally sold or used by someone for whom they were not prescribed. The city currently offers residents several methods and venues for disposing of prescription drugs and other medications at no cost in a safe and environmentally-friendly manner. In addition, staff from the Cambridge Public Health Department (CPHD) and Department from Human Service Programs (DHSP) have been exploring strategies for expanding disposal opportunities, especially for seniors (see following section). Until recently, options available to consumers for disposing of pharmaceutical controlled substances in the United States were limited because of strict security standards set forth by the U.S. Drug Enforcement Administration (DEA). Pharmaceutical controlled substances are Schedule II-V medications, which include prescription pain medications (e.g., oxycodone, codeine), stimulants (e.g., Ritalin), and sleep medication (e.g., Xanax, Valium). Note: Schedule I controlled substances, which include drugs such as marijuana, heroin, or LSD, are not categorized as pharmaceutical controlled substances. Prior to 2014, the only options available to Americans for disposing of Schedule II-V medications was self-disposal or bringing unwanted medications to prescription drug take- back events hosted by local police departments or to police stations that maintained medication collection kiosks. These options were fully explained in past CPHD policy order responses about medication disposal that were submitted in 2011 and 2013. In 2014, the DEA promulgated regulations that expanded options for safely and responsibly disposing of unused and unwanted, lawfully-possessed pharmaceutical controlled substances through collection receptacles, mail-back programs, and take-back events. Of note, individuals may not dispose of illicit drugs (Schedule I controlled substances) through any of the three disposal methods.

2 As a result of the 2014 regulatory change, it is now possible for:  Authorized mail-back programs to accept lawfully obtained and possessed pharmaceutical controlled substances. Consumers can use mail-back packages, including ones obtained from other states and/or delivered to other states for destruction.  Authorized retail pharmacies, hospitals with an on-site pharmacy, and narcotic treatment programs to collect lawfully obtained and possessed pharmaceutical controlled substances by maintaining collection receptacles and/or by voluntarily administering mail-back programs.  Authorized hospitals and retail pharmacies to voluntarily maintain collection receptacles at long-term care facilities.  Any person or community group, DEA registrant or non-registrant, to partner with law enforcement to conduct take-back events. The DEA encourages communities to partner with law enforcement to continue to conduct take-back events. To become an authorized collector, a hospital, pharmacy, or other qualified entity must be a current DEA registrant for controlled substances. In addition, hospitals or clinics that wish to become authorized collectors must also have an on-site pharmacy, which could either be an inpatient pharmacy (not accessible to the public) or an outpatient pharmacy. At a hospital or clinic site, a collection receptacle must be located in an area regularly monitored by employees (e.g., an outpatient pharmacy or hospital lobby), as long as that area is not in close proximity to where emergency or urgent care is provided. As of August 2016, nine Massachusetts hospitals and clinics were registered as collection sites with the U.S. Drug Enforcement Agency. Of these sites, the Cambridge Public Health Department has confirmed that eight hospitals and clinics currently operate a medication collection program:  Beth Israel Deaconess Hospital – Plymouth  Beverly Hospital  Boston Medical Center  Brigham and Women’s Hospital – Boston  Brigham and Women’s Hospital – Chestnut Hill  Martha’s Vineyard Hospital  Massachusetts General Hospital  Revere HealthCare Center (affiliated with MGH) The Cambridge Public Health Department has spoken with staff from the New England Division of the U.S. Drug Enforcement Agency and several hospital pharmacists who oversee collection programs at the above-mentioned Massachusetts hospitals. The purpose of these conversations was to better understand the 2014 DEA regulatory changes, as well as the benefits and costs associated with operating collection receptacles in hospital settings. On September 7, 2016, Governor Charlie Baker announced that Walgreens had become the first pharmacy in Massachusetts to launch a new safe and convenient medication disposal program to reduce prescription drug misuse.

3 The company has installed drug take-back kiosks in 13 Massachusetts Walgreens stores in the communities of East Boston, Fall River, Framingham, Gloucester, Lowell, Malden, Quincy, Randolph, Roxbury, Stoneham, Stoughton, Springfield and Worcester. Individuals can dispose of all prescriptions including controlled substances and over-the-counter medications. The kiosks at Walgreens pharmacies are available for use during regular pharmacy hours. To date, Walgreens has installed take-back kiosks in more than 500 of its stores in 35 states. CPHD staff have contacted the Walgreens corporate office in Chicago several times over the past few months to learn about the company’s criteria for selecting store locations for the take- back kiosks, but to date have not received a response. Current Disposal Opportunities Permanent Drop-Box  A permanent medication drop-box in the lobby of the Cambridge Police Department (CPD), 125 Sixth Street, is available to residents 24 hours a day, seven days a week. The unused medications are collected, removed, stored, and taken to an incinerator for destruction by CPD personnel under the direction of a police officer. Free Postage-Paid Mailers  Residents can request a free, postage-paid mailer from the Cambridge Public Health Department to send unwanted prescription medicines, including Schedule II-V medications, to a company (Sharps Compliance, Inc.) that will dispose of them properly under U.S. Environmental Protection Agency license. Residents can obtain mailers by contacting the Cambridge Public Health Department at [phone removed] or emailing [email removed].  As of mid-September 2016, seniors are now able to pick up free, postage-paid mailers for unwanted medications, including Schedule II-V medications, at the front desk of the Citywide Senior Center (806 Massachusetts Ave.) and the North Cambridge Senior Center (2050 Massachusetts Ave). Note: These are the same Sharps Compliance, Inc. mailers provided by the Cambridge Public Health Department. Community Events  Medication Take Back Event for Seniors: The Council on Aging hosted a medication take-back event on Sept. 13 at the Citywide Senior Center in Central Square. Middlesex District Attorney Marian Ryan spoke at the event and Cambridge police personnel were on-site to collect medication.  Medication Take-Back Events at Cambridge Police Department: The Cambridge Police Department, in partnership with OPEN* (Overdose Prevention and Education Network), hosts medication take-back days twice a year, in April and September. * OPEN (the Overdose Prevention and Education Network), is a four-city opioid coalition based at the Cambridge Public Health Department. The coalition is comprised of Cambridge, Everett, Somerville, and Watertown. To learn more, visit odprevention.org.

4  Household Hazardous Waste Days: Collection of unused or unwanted prescription drugs by the Cambridge Police Department at the Department of Public Works’ Household Hazardous Waste (HHW) Collection Days began in 2010 with grant support and has continued during each of the four collection events per year. All medications collected by CPD are tracked until destruction, conforming with laws governing controlled substances and in compliance with all conditions set forth by the Massachusetts Department of Environmental Protection. Promotion of Safe Medication Disposal The Cambridge Police Department, Cambridge Public Health Department, Cambridge Department of Public Works, and OPEN promote safe medication disposal options in Cambridge on their respective websites and through other communication channels. In addition, OPEN and CPHD routinely promotes safe medication disposal on their respective Twitter pages (@OPENCambridge and @CambHealth) and through a public service announcement that is currently airing on CCTV and posted on YouTube (https://youtu.be/cr7n8tYDyao). Next Steps The Cambridge Public Health Department will continue to continue to speak with representatives from hospital collection programs in Massachusetts to gain a more complete understanding of how these programs operate. CPHD will then share findings with Cambridge pharmacies, hospitals, and ambulatory sites that are DEA registrants and meet other DEA criteria to become authorized medication collection sites. In addition, CPHD will organize an informational meeting in fall 2016 with interested hospitals, clinics, and pharmacies. This meeting will be an opportunity for:  CPHD staff to share information about the benefits and estimated costs associated with operating a medication disposal kiosk, based on conversations with Massachusetts hospitals that are currently operating programs.  One or more representatives from the aforementioned Massachusetts hospitals to give an overview of their program(s), including compliance with the DEA regulations, costs, and legal and security issues.  Participants to ask questions and gather the information they need to make an informed decision about whether their organizations should become medication collection sites. CPHD staff will also reach out to appropriate city departments to determine what technical assistance the city can offer health care sites and pharmacies that are interested in hosting medication collection kiosks.