NCHR Comments on the Food and Drug Administration In-Home Disposal Systems for Opioid Analgesics

August 28, 2023

We are pleased to have the opportunity to share our views with the Food and Drug Administration (FDA) regarding In-Home Disposal Systems for Opioid Analgesics.

The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which prevention strategies and treatments are most effective for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.

National Center for Health Research agrees that proper disposal of controlled substances, especially opioids, is important in helping to prevent nonmedical opioid use and opioid overdose. While opioid awareness has grown and prescriptions are decreasing nationally, opioid use disorder and overdose remain a major public health burden. We also support the FDA’s efforts to move away from flushing unused medications, as this directly leeches medications into water systems where they cannot be removed. We also recognize that organized drug disposal events have a minimal impact on reducing the availability of unused opioid medications within the community.¹ Thus, we commend the FDA on considering in-home disposal systems for opioids and believe that ideal in-home disposal systems are those that are practical, user-friendly, and accessible while also being cost-efficient and environmentally sustainable.

Specifically, most of the commercially available in-home disposal products use a deactivation technique which renders the medication inert, and we favor this mechanism over in-home disposal systems using incineration. Deactivation methods for in-home disposal have been shown to be advantageous in terms of improved accessibility and safety compared to incineration methods.² However, we still recommend that the sequestration, adsorption, and absorption of deactivation disposal systems be tested to thoroughly by the FDA to ensure the systems are effective and work as described. The NCHR also favors smaller products that are readily portable and come with easy-to-follow instructions as these products have been shown to have higher use among patients using controlled substances.²

Further, while it is important to consider ideal in-home disposal methods, it is equally important to emphasize improving patient education on proper medication disposal. Currently, it is estimated that only 22% of patients actually receive pharmacist-led counseling on proper medication disposal.² Pharmacists and pharmacies are widely available resources that should be leveraged in order to improve patient education regarding the importance and need for proper opioid disposal. We suggest these education materials be as practical, user-friendly, and environmentally sustainable as the in-home opioid disposal systems being considered and offer the benefit of increasing awareness and compliance with unused opioid disposal.

In summary, in-home opioid disposal systems have the potential to reduce medication misuse, addiction, and overdose while preventing unintended pollution from medication waste. We commend the FDA on considering in-home disposal solutions for unused opioid medications and favor systems that use deactivation techniques, are small, easily portable and are widely accessible. We also urge the FDA to consider methods aimed at improving patient education on the significance and need for proper opioid disposal in order to optimize awareness and compliance with in-home medication disposal.

References:

1. Egan et al. “From dispensed to disposed: evaluating the effectiveness of disposal programs through a comparison with prescription drug monitoring program data. The American Journal of Drug and Alcohol Abuse. 2017.
2. Imarhia et al. “Prescription drug disposal: Products available for home use.” Journal of the American Pharmacists Association. 2020.

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