Preliminary 2010 Effluent Guidelines Program Plan

November 10, 2008 Water Docket Environmental Protection Agency Mailcode: 4203M, 1200 Pennsylvania Ave., NW., Washington, DC 20460 Re: Study of Unused Pharmaceuticals from Medical and Veterinary Facilities Docket ID No. EPA–HQ–OW–2008–0517; OMB Control No. 2040–NEW Dear Sir or Madam: I am writing on behalf of the American Veterinary Medical Association (AVMA), established in 1863 and the largest veterinary medical association in the world. As a not-for-profit association established to advance the science and art of veterinary medicine, the AVMA is the recognized national voice for the veterinary profession. The association's more than 76,000 members comprise approximately 86% of U.S. veterinarians, all of whom are involved in a myriad of areas of veterinary medical practice including private, corporate, academic, industrial, governmental, military, and public health services. The AVMA appreciates the opportunity to offer comments and input to the EPA's "Unused Pharmaceuticals Disposal at Veterinary Hospitals in the Health Services Industry" Survey which is part of a new Study of Unused Pharmaceuticals from Medical and Veterinary Facilities. As the voice of the veterinary profession we affirm our profession's commitment to protect the public health and our environment. We work diligently with our members to create management practices that protect the health of our environment. In this correspondence, our intent is to describe 1) the veterinary profession's de minimis contribution to pharmaceutical waste, including the AVMA's answers to the Federal Register investigative questions, 2) the AVMA's demonstrated commitment to continue working with our members to ensure proper pharmaceutical disposal, and 3) the AVMA's analysis of the Draft Questionnaire and significant concerns. The EPA is to be commended for its continued efforts to protect our nation's waters. However, the AVMA's volunteer leaders, serving on our councils and committees and representing environmental issues, biologic and therapeutic agents, veterinary services, and clinical practice, believe the current draft survey will be excessively time consuming, economically burdensome, and will likely not provide the information EPA desires based on current veterinary medical business practices. Therefore, we assert that inclusion of veterinary medicine in the questionnaire is not necessary for the proper performance of functions of the EPA, and we recommend the removal of veterinary facilities from the survey. Veterinary Medical Business Practices The AVMA asserts that its members, 66% of whom practice in small business (private) clinical settings, contribute very little to pharmaceuticals found in water effluent. Veterinary facilities in the United States, their ownership and operations, and the practices they utilize to handle and to dispose of pharmaceuticals, are very different from those found in human medical settings. Unlike the human model of extended stay and residence at long-term care facilities, veterinary facilities do not house animals for these purposes. Consequently, veterinary facilities do not have the occupant drug disposal issue that long-term care facilities experience. Appendix A, "Comparison of Health Facility Risk Factors: Disposal of Unused Pharmaceuticals in Water (drain, toilet)," further contrasts human long term care settings with veterinary facilities, illustrating that veterinary facilities do not generate many unused pharmaceuticals. Veterinary facility operations also contrast those of human hospitals. In particular, the majority of animal patients examined by veterinarians in small business veterinary facilities are handled on an outpatient basis. It is customary for veterinary facilities to maintain an on-site inventory of medications for dispensing to patients seen during out-patient appointments or to the hospitalized patient as they are undergoing…