                 EPA/HQ Summary  -  Communications with Genco

Attendees

Genco Participant:
Ashley Swanson
EPA/HQ Participant:
Drew Lausch

Dates:  December 16, 2016; January 5, 2017; January 6, 2017

Location:  E-mail Exchanges

Summary

EPA HQ posed a question to a representative from Genco, a third party logistics provider and reverse distributor of pharmaceuticals, regarding prescription drugs (Rx) and the "aging" process that occurs when otherwise potentially creditable pharmaceuticals are held based on the manufacturer's current return policy. As an example, EPA noted its experience that a manufacturer does not take back indated (non-expired) items even though the drug meets all the creditable criteria  -  except that it has not yet expired  -  adding that pharmaceuticals may sometimes be held for many months or even longer during the "aging" process.

EPA stated its understanding that "aging" would only occur in the case of Rx drugs and not with other items such as over-the-counter medications (OTCs) and dietary supplements but requested clarification.  EPA also asked about the rationale for "aging" pharmaceuticals; in other words, why certain pharmaceuticals that would otherwise be creditable cannot be returned for credit until the expiration date is met.

Genco indicated that EPA's understanding is mostly correct but added that its understanding is that indates, while largely Rx, can also include OTCs and dietary supplements  -  adding that this is dependent upon the requirements of the owner of the product.  Genco stated that the rationale for indating is that the owner of the product does not believe the product can be dispensed but it is still not eligible for manufacturer credit.  Genco further stated that product eligibility for credit is dictated by agreements between the manufacturer and owner of the product and that one of the terms of eligibility is frequently that the product must be expired or within a certain window of the expiration date.

