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California State Auditor Report Number : 2016-127

Home‑Generated Sharps and Pharmaceutical Waste
By Designating a Lead Agency, the State Could Increase Proper Disposal

May 9, 2017

The Governor of California
President pro Tempore of the Senate
Speaker of the Assembly
State Capitol
Sacramento, California 95814

Dear Governor and Legislative Leaders:

As requested by the Joint Legislative Audit Committee, the California State Auditor presents this audit report concerning home‑generated sharps and pharmaceutical waste. This report concludes that the lack of a lead state agency to oversee home‑generated sharps and pharmaceuticals waste disposal has left California consumers with conflicting guidance and a lack of adequate information about collection sites. Because it already has oversight of state‑managed solid waste handling programs, the California Department of Resources Recycling and Recovery (CalRecycle) may be best positioned to manage this oversight. In fact, one of the four options for statewide pharmaceutical waste collection that CalRecycle provided in a 2010 report generally aligns with our recommendation to assign oversight responsibility to a single state agency.

Improper disposal of sharps and pharmaceutical waste can pose risks to the public and to the environment. While our analysis suggests that more than 89 percent of Californians have access to free collection sites, the State does not maintain an accurate and accessible list of these collection sites. Further, about four million Californians may not live within 20 minutes of a collection site. By designating a lead state agency to coordinate messages, educate consumers, maintain an accurate collection site list, and implement disposal options for consumers who do not live near a collection site, the State could increase the proper disposal of this waste. California has sufficient capacity to process increased amounts of home‑generated sharps and pharmaceutical waste, but pharmaceutical waste is mostly disposed of out of state because government recommendations and legal requirements discourage in‑state incinerators from accepting it.

California could improve its collection and disposal of home‑generated sharps and pharmaceutical waste by adopting parts of programs and practices that other states and countries use. However, some programs, including those that assign the cost for disposal to manufacturers—known as extended producer responsibility (EPR) programs—are likely to pass on costs to consumers. Several California counties have begun implementing EPR programs, but some manufacturers have resisted, in part, because counties may adopt different requirements that manufacturers believe create inefficiencies and add to costs. To ensure consistency throughout the State and to minimize the cost to consumers, the Legislature should adopt standard requirements for counties to follow when implementing EPR programs.

Respectfully submitted,

Chief Deputy State Auditor

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