The role of Municipalities and Producer programs in extended producer responsibility by Brad Wright
One Year Mark for Extended Producer Responsibility of Pharmaceuticals and Sharps in Ontario
Health Products Stewardship Association (HPSA) is pleased to announce the performance results from the first year of the (OSCP) and the (OMRP), the first two extended producer responsibility (EPR) programs legislated under Regulation 298/12 of the Ontario Environmental Protection Act. In year one of these new programs, 201,971 kgs of used sharps and 328,404 kgs of medications were returned by consumers to participating retail pharmacies. Over 84% of eligible pharmacies in Ontario are now registered and voluntarily participating in these programs.
In total, more than 530 tonnes of materials were removed from homes in Ontario through the two programs between October 1, 2012 and September 30, 2013. Producers of these products have made significant gains toward preventing illicit diversion and abuse of medications in households and have helped reduce drug and needle related accidents in the home by providing consumers with easy access to retail pharmacy locations where materials can be returned for proper disposal. Keeping used needles and other consumer medical sharps and unused/expired medications out of household garbage and sewage treatment systems is also a priority of the HPSA programs.
Under the new EPR regulation in Ontario, HPSA has established effective plans for managing post-consumer sharps and medications that include an ongoing promotion and education strategy for consumers and retail pharmacies that began in March 2013. HPSA has also undertaken the first ever review of the voluntary retail pharmacy collection network to promote awareness of program requirements, to encourage more pharmacies to register and to ensure material from industrial, commercial and institutional generators is not entering the post-consumer collection network. These efforts have produced a 10% increase in volumes of materials collected compared to the prior programs that were administered by Stewardship Ontario under the Waste Diversion Act and funded by Ontario taxpayers
The Health Products Stewardship Association, formally known as the Post-Consumer Pharmaceutical Stewardship Association, has changed its look but kept its mandate of serving its members in complying with provincial environmental stewardship programs. In 2012, the Ontario government passed a regulation for the collection of pharmaceuticals and sharps. As we have expanded our product categories and membership to include the sharps producers and as well as the animal health sector, a change of name was in order.
2013 Sector Shares
Last October, HPSA conducted a baseline audit of pharmaceutical waste through a statistically significant sample of returns (113) and the logging of their content. The results showed that Brand Prescriptions (39.7%) and Generic Prescriptions (33.8%) contributed the most to the overall pharmaceutical waste stream from consumers. Over-the-counter and Natural Health Products (26.3%) were the next greatest contributor, while Veterinary Prescriptions (0.2%) contributed little to the waste stream. These new rates of 73.7% and 26.3% will be used in 2013 when preparing invoices/budgets to cover costs associated for each provincial program.
HPSA basic rate
With the addition of the Ontario program and a subsequent increase in the number of stewards and products recovered (Rx, OTCs NHPs, Sharps and Animal health), HPSA will be adding a fixed rate for all members to support the administrative functions associated with the regulatory compliance process required for each provincial program. This contribution will be indicated on a separate line rather than be included with the collection and disposal costs, as done in the past, and minimum charges have been eliminated.
HPSA meets provincial standards, gains government approval on performance and is addressing challenging take-back issues. The costs for maintaining a national office has been set at $900.00 per member per program. Services at a glance:
· Not-for-profit standard, records are current, provincial and federal reports are filed annually, audited financial statement as well as 3rd party verification for non-financial standards is performed as required.
· Provides patients, consumers, retailers, and local governments with information and materials about the safe and responsible way to use, store, and dispose of products in a safe and responsible manner.
· Maintains a website and a list collection sites for returns of products in regulated provinces (3).
· Manages stewardship programs in a number of Canadian provinces.
· Supports an office with staff.
· Submits annual provincial reports, on behalf of all stewards, to meet producers’ obligations under three separate provincial regulations.
British Columbia Members with packaged goods
If your company sells packaged goods or provides marketing and printed materials to BC residential consumers, this is a reminder that Multi-Material British Columbia (MMBC), has submitted a stewardship plan for printed paper and packaging on behalf of companies that do business in BC.
By joining MMBC's Stewardship Plan, your company will fulfill its legal obligation under the regulation and your ability to sell or distribute in BC will be protected.
To appoint MMBC as the stewardship agency to meet the requirements of the BC Recycling Regulation on your behalf, send email to firstname.lastname@example.org for more information.
Ontario Medications Program Update
The Ontario government passed a regulation (Ontario Regulation 298/12) under the Environmental Protection Act entitled “Collection of Pharmaceuticals and Sharps - Responsibilities of Producers” on September 28, 2012. The regulation came into force on October 1, 2012, with a transition period of three months for producers to meet most requirements. As anticipated, HPSA received the financial support from members and new stewards with Rx (human/animal health), OTC’s and NHP’s products.
HPSA will administer a Medications Return Program in Ontario under the same policies as the BC and Manitoba Programs.
Sharps Return Program Update
Sharps transition committee (Bayer, GSK, Lifescan, Beckton Dickenson Medical and Novo Nordisk) identified approximately 36 producers clearly obligated under the EPA 298/12 regulation; of which approximately 29 are producers funding the medications program leaving only a hand full to join the association or to appoint HPSA as their agent. We are still trying to secure the commitment of two major producers. In January, the board will re-assess HPSA’s ability to continue to represent producers for the return of sharps in Ontario. Alternatives are:
o The producer’s community currently engaged with HPSA will agree to cover the full costs of the program in 2013 and beyond.
o Lifescan and BD Medical will join HPSA and producers will provide funding for the full costs of the sharps program.
o HPSA will cease to represent the sharps community past March 31st 2013.
Forthcoming from the OFFICE
o Thank you for the prompt payment from the majority of members that received the invoice for the Ontario Medications Return Program.
o Please note that invoices for the Ontario Medications Program went to members with sales of 1 million+. In 2013, if your company was not invoiced for that program, some charges for 2012 will be included with your 2013 charges ($100.00~)