Concerns About Opioid Mail-Back Envelope Proposal

Share

 

Pharmaceutical Research and Manufacturers of America (PhRMA) says it believes an FDA proposal to require manufacturers to provide mail-back envelopes and education on the safe disposal of opioid analgesics dispensed in an outpatient setting is well-intentioned but could inadvertently lead to increased opioid theft and diversion. PhRMA’s letter says the association believes current drug disposal options are sufficient. PhRMA also makes these points: 

  •          a wide range of options in addition to in-home disposal already exist, providing a range of options for consumers;
  •          in-home disposal has the least harmful impact on the environment compared to other disposal approaches;
  •          the potential increased risk for diversion created by a potential mail-back program far outweighs the potential benefit to consumers;
  •          there is limited evidence to suggest that takeback programs meaningfully affect non-medical use or diversion in the home or that a mail-back program would yield different results;
  •          PhRMA is concerned over the proliferation of various drug deactivation packets or pouches despite inadequate scientific or technical evidence of their effectiveness and insufficient research on ease of use from end-users compared to other approaches; and
  •          the association supports efforts to increase education around the appropriate use of medicines as well as around the appropriate disposal of unused medicines.

In its letter, the National Association of Chain Drug Stores calls on FDA to “leverage its opioid analgesic risk evaluation and mitigation strategy to require opioid manufacturers to fund and provide for a variety of disposal solutions that healthcare providers (including but not limited to pharmacies) and other stakeholders could voluntarily make available to patients.” The association also provides additional ideas for modifying the REMS.

Read more