Journal of Human Security | 2017 | Volume 13 | Issue 1 | Pages 5–15
DOI: 10.12924/johs2017.13010005
ISSN: 1835–3800
Journal of
Human Security
Research Article
Emerging Security Challenges to Africa: The Case of
Haphazard Disposal of Pharmaceuticals in Ghana
Ken Emmanuel Ahorsu
1,
* and Yvonne Esseku
2
1
Legon Centre for International Affairs and Diplomacy (LECIAD), University of Ghana, Legon, Ghana
2
African Collaborating Centre for Pharmacovigilance, Accra, Ghana. E-Mail: esseku@yahoo.com
* Corresponding author: E-Mail: t28aug@hotmail.com; keahorsu@ug.edu.gh, Tel.: +233 208142882
Submitted: 13 July 2016 | In revised form: 28 November 2016 | Accepted: 3 January 2017 |
Published: 27 March 2017
Abstract:
The study of the Disposal of Unused/Unwanted Medicines Project examines ways in which
medicines are disposed of in Ghana and assesses how disposal methods can impact water resources.
The study showed a number of challenges: gaps in the legislative framework for the disposal of medicines;
environmentally-unfriendly methods of disposal of medicines; and large quantities of medicines potentially
disposed of indiscriminately with major impact on the environment. It recommends a review of the legal
framework to ensure the proper disposal of all unused medicines; policies to mop up excess medicines with
members of the public; review of prescribing and dispensing practices to reduce excess medicines; and
further research into the types of pharmaceuticals that are present and persist in the environment, their
effects and how they affect quality of life.
Keywords:
disposal of unused medicines Project (DUMP); environmental security; eco-pharmacovigilance;
Ghana; human security
1. Introduction
The concept of security, today, has become more inclusive,
holistic, and often conceptualised in global terms rather than
the hitherto realpolitik notion of national security. Issues
bordering on economics, socio-culture, migration, public
health, and the environment, among others, have become
integral parts of the security calculus with the view to safe-
guarding the welfare of citizens within nation-states and the
environment [
1
]. The 1992 Rio de Janeiro United Nations
Conference on Environment and Development (UNCED),
in particular, raised concerns about unsustainable develop-
ment and its inimical impact on the environment, people,
and society [
2
]. The expanded notion of security under the
banner of human security has increasingly been conceived
as a universal, interdependent, and people-centred norm
that focuses jointly on protecting people from fear and want
[
3
]. Direct and indirect causal links have been established
between human activities, environmental degradation and
climate change; and the transnational dangers therein to a
sustainable world [4–6].
Human beings and other living organisms interact ac-
tively with, and depend on the environment for their suste-
nance and survival. While the environment ecologically
recycles waste products, the disequilibrium caused by
human exploitation and dependence on the environment
undermines sustainable ecosystems. This, in turn, in-
creasingly inhibits the environments continued ability to
optimally support human life [
7
]. Human enterprises of-
ten introduce pollutants into the environment, either pur-
c
2017 by the authors; licensee Librello, Switzerland. This open access article was published
under a Creative Commons Attribution License (http://creativecommons.org/licenses/by/4.0/).
librello
posely or by accident, that affect the quality and quantity
of available natural resources such as water, arable land,
pasture, food, and air for breathing. Even seemingly pos-
itive practices such as the use of pharmaceuticals and
other chemicals for the treatment and improvement of the
quality of human life can result in pollution and seriously
threaten the environment and the quality of human life in
unforeseen ways [3].
This article is concerned with the disposal of pharmaceu-
ticals, the probable environmental degradation they cause,
and the real dangers they pose to the well-being of indi-
viduals, communities, and societies. Pharmaceuticals are
useful in the effective delivery of health care both for hu-
mans and for veterinary use. However, pharmaceuticals
enter the environment through consumption, metabolism,
and elimination through faeces and urine or through direct
disposal of excess or expired supplies [
8
,
9
]. While usage
of pharmaceuticals always comes with certain outcomes
in mind, there are often latent effects other than those en-
visaged by the consumer, dispenser, and prescriber. The
science and activities related to the detection, assessment,
and understanding of these unintended effects is known
as pharmacovigilance. In view of the frequency with which
these effects occur in the environment after elimination of
the product by the consumer, eco-pharmacovigilance has
emerged as a branch of pharmacovigilance in the study of
the unintended consequences of pharmaceuticals on the
environment.
The study of the impact of the presence and persis-
tence of pharmaceuticals on environmental security is
an emerging one. This article argues that while eco-
pharmacovigilance manifestations are ubiquitous, popu-
lations and environmental interdependence specifics cul-
turally bound in the maelstrom of social change, in turn
influence the former’s dynamics and adaptive responses.
People-environment interdependence differs from culture to
culture; so too does the nature of degradation and pollution
differ from one culture to the other. Africa and, for that
matter, Ghana, traditionally has a rich environment and bio-
diversity; however, with heightened social change, Africa’s
conservation movement does not incorporate the pressures
posed by the use and disposal of orthodox medicine. The
article, therefore, makes the case that the study of the
presence and persistence of pharmaceuticals in the envi-
ronment, as well as the potential human security threats
they pose to Africa is topical, and urgent.
The study investigates how unused pharmaceuticals
are disposed of, the state in which they enter the environ-
ment, and the potential effects they might have on water
resources and ecosystems, and subsequently on environ-
mental and human security. The article is organised into
the following sections: introduction, methodological consid-
erations, literature review, legal framework for disposal of
pharmaceuticals in Ghana, overview of the practice and
culture of pharmaceutical disposal in Ghana, hazards and
challenges of pharmaceutical disposal, case study of the
Disposal of Unused Medicines Project (DUMP), findings,
and the conclusion. The article looks at the ways in which
these pharmaceuticals are introduced into the Ghanaian
environment by conducting a case study of the Disposal of
Unused Medicines Project (DUMP) of the Cocoa Clinic in
Accra-Ghana that is run under the supervision of the Food
and Drugs Authority (FDA). Based on this case study, it
assesses the impact of both regulated and unregulated dis-
posal on the environment, examining how the presence and
persistence of pharmaceuticals in the environment affects
ecosystems and water resources. The article investigates
the various ways in which these effects impact environmen-
tal security.
2. Methodological Considerations
There is a dearth of studies on the subject in the Ghanaian
context. As such, the study reviews research conducted in
other parts of the world to project potential and probable
effects of pharmaceuticals on water resources and ecosys-
tems in Ghana. The paper adopts a qualitative case study
approach. We consider the case study method the most
appropriate, because, as stated earlier, while the manifesta-
tions of eco-pharmacovigilance are ubiquitous, populations
and environmental interdependence bordering specifics dif-
fer largely from culture to culture. The phenomenon of
regulated pharmaceutical disposal in Ghana is new and
quite technical, making the knowledge of its practice and
concepts not widespread. Given these conditions and limita-
tions, this study uses a small technical specific sample that
affords deep investigations in order to achieve an in-depth
understanding of the legal framework, concepts, practices,
benefits, limitations, and challenges associated with the
disposal of unused medicines in Ghana. The Cocoa Clinic
in Accra, the Food and Drugs Authority (FDA), and the En-
vironmental Protection Agency (EPA), all of Ghana, are the
institutions engaged in the DUMP project. Semi-structured
interviews held in January 2014 with the clinical pharmacist
in charge of DUMP at the Cocoa Clinic, two officials of the
FDA directly involved in DUMP, and an official of the EPA
responsible for the disposal of medical and industrial waste
provided primary data for the study.
The interview with the Cocoa Clinic official seeks to
discover the aim, concepts, processes, practices, and chal-
lenges of the DUMP project. It enquires about how, what,
which, when, and how much medicines were received, han-
dled, and disposed off from both the public and the Cocoa
Clinic. It ascertains if the unused, unwanted or expired
medicines collected were categorised before disposal; and
if the disposal facility is open to all segments of the pub-
lic or only to clients of the Cocoa Clinic. It also seeks to
know if banned narcotics and native drugs were sought
and collected in addition to the orthodox medicines, and if
they were, how they were handled. The interview further
seeks information on how unexpired medicines are handled
upon collection, how long the medicines collected are kept
before disposal, and whether or not the clinic was directly
involved in the actual disposal of the drugs. It also enquires
6
if officials of the Cocoa Clinic visit the disposal sites and
attempts to discern any other challenges encountered by
the clinic in the running of the DUMP project.
The FDA is responsible for the regulation and practice of
the disposal of medicines and other chemicals in Ghana; it
administers the activities of DUMP in collaboration with the
Cocoa Clinic. The interview with the FDA seeks to ascer-
tain the efficiency of national guidelines on the disposal of
expired and unused medicines in Ghana; to know the differ-
ent sources from which unused and expired medicines are
received for disposal; and to assess the challenges the FDA
faces with respect to the effective disposal of medicines and
the environment’s safety. The interview also enquires as to
whether current disposal methods were at par with interna-
tional best practices. Questions were also asked pertaining
to costs associated with DUMP, collaboration with other
national agencies with respect to the disposal of medicines,
the general effects of indiscriminate and unregulated dis-
posal of medicines on the environment and society, and the
measures put in place to tackle these adverse effects.
The study also seeks to know the regulations relating to
the disposal of unused and expired medicines; the EPA’s
perspectives with respect to the disposal of medicines; and,
its roles in the DUMP Project. Questions in the interview
also focus on whether or not the medicines disposed of by
the EPA are categorised in any way before disposal. This
is important since different types of medicines often have
varied effects on the environment; and if the EPA has any
contingency plans for the mitigation of negative fallouts that
may arise as a result of the methods used for the disposal
of medicines. The EPA is also quizzed on the main dangers
that indiscriminate and unregulated disposal of medicines
poses generally to Ghana, and if there are any strategic
measures in place to counter such effects alone or in col-
laboration with other public agencies.
3. Literature Review
Earlier studies on the environment and security after the
two World Wars and the inception of the nuclear arms race
have focused on the promotion of positive peace through
sustainable development and living in harmony with nature.
As the Cold War realpolitik tapered away from the 1970s
into the mid-to-late 1980s, the field emerged as ‘environ-
mental’ security, while acknowledging that environmental
factors play roles in violent conflicts[
5
,
6
]. Barnett defines
environmental degradation as “the process by which the
life-sustaining functions of the biosphere are disturbed. [
10
]
The 1994 UNDP Report called for sustainable development
strategies to curb pollution, and to preserve and regenerate
the environment for future generations. Harmful chemicals
and other toxins are increasingly being introduced into water
systems by human activities [
7
,
11
,
12
]. Increased scarcity
and pollution of water sources, cost of water provision,
water-borne diseases, worm infestations, and dwindling
fish stocks have all been attributed to man-made pollution
[
13
]. Of late, pharmaceuticals have been increasingly found
in, and perceived as, major pollutants of the environment,
especially in water bodies making ‘pharmaceuticals in the
environment’ (PIEs) an integral part of environmental and
human security [8,14,15].
Holm, et al define eco-pharmacovigilance as the sci-
ence and actions related to the detection, assessment,
comprehension, and avoidance of adverse effects of phar-
maceuticals in the environment [
16
]. Pharmaceuticals enter
the environment through human, institutional and animal
consumption, excreta or disposal; they are disposed of as
unaffected compounds or active metabolites into sewer-
age systems or straight into the drainage system without
purification. The mode of disposal notwithstanding, phar-
maceuticals have a probability of entering the human food
cycle and into surface and underground water bodies often
escaping purification [17].
Once in the environmental media, pharmaceuticals
go through varied diminishing processes such as photo-
degradation, dilution, uptake by soil, and physiological and
anaerobic breakdown [
18
]. Nilsen et al, however, find
the presence of pharmaceuticals in residue tests on the
Columbia, Willamette, and Tualatin rivers, numerous small
urban coves and the sewage of waste water treatment
plants (WWTPs) [
19
]. Presence of veterinary pharmaceu-
ticals were found in lagoons, underground water, soil, and
the run-off from farms and lands treated with mixtures of
pharmaceuticals [
20
,
21
]; showing that pharmaceuticals reg-
ularly endure in their original form or as metabolites in the
environment [
19
,
22
]. Kinney et al, find the presence of phar-
maceuticals in both upstream and downstream WWTPs
with discharge samples studied showing that WWTPs are
not able to completely remove pharmaceuticals from waste
water [
23
]. Glassmeyer et al find WWTPs as an important
origin of pharmaceuticals in the environmental media. In
circumstances where there are no WWTPs to treat chemi-
cals and pharmaceuticals, pharmaceuticals in their active
forms or as metabolites are openly discharged into the en-
vironmental media; and may affect all organisms they come
into contact with [24].
Watanabe et al find veterinary pharmaceutical antimi-
crobial Monesin, introduced to the environment by lactating
cows from flush lanes to lagoons and nearby underground
water sources [
20
]. This shows that Monesin persists in
water bodies and nearby soils. The impact of antibiotics
used in dairy production and their introduction in water
bodies, Boxall finds, may be responsible for producing
resistance in some microorganisms [
8
]. Monesin was, how-
ever, absent from dairy farm fields treated with manure,
suggesting absorption of monesin by soil particles and at-
tenuation under anaerobic circumstances. Davis et al in a
worst case scenario study, collected runoff water from soil
treated with pharmaceuticals before any attenuation could
take place and found all the pharmaceuticals present [21].
It demonstrates that soils treated with pharmaceuticals can
become a source of pollution of nearby surface water. It is
not clear what the long-term exposure and effects of such
non-therapeutic doses found in drinking water are.
7
Wu et al study the uptake of pharmaceuticals by agricul-
turally relevant plants that were grown in pharmaceutical-
treated hydroponic and soil systems and find the presence
of pharmaceuticals in different concentrations in the plants
that were harvested [
25
]. Different components of plants,
and even entire plants, were examined. They find that the
absorption of pharmaceuticals in the cases of some plants
or certain pharmaceuticals is extremely quick, attaining
equilibrium within four hours while some pharmaceuticals
took as many as 51 days. The traces and concentration of
the pharmaceuticals in the different parts of the plants were
significantly different. It was less in scale along the contin-
uum of the roots, stems, leaves and seeds. The absorption
of pharmaceuticals from soil systems was not as decisive as
was the case in hydroponic systems; and that the presence
and concentration of pharmaceuticals in plants depend on
the frequency with which soils are spiked. Younger plants
exhibit higher chemical presence than the older ones when
the soil is spiked only once, but the presence and concen-
tration of chemicals are similar in both younger and older
plants when the soil is spiked repeatedly and the scale of
presence and concentration of chemicals in the different
parts are similar in both hydroponic and soil systems.
Guillette Jr. et al study the effects of endocrine disrupt-
ing contaminants (EDCs) such as pesticides on various
physiological characteristics and other features of alligators
in Lake Apopka (that witnessed a huge pesticide leak 40
years prior) and Lake Woodruff (unexposed to pesticides),
both fresh water bodies located in Florida, USA [
26
]. The
studies show alligators in Lake Apopka laying fewer eggs
and showing lower survival rates for both hatchlings and
juvenile alligators over the years, relative to those of Lake
Woodruff. The results also demonstrate that some EDCs
are capable of changing both endocrine and physiological
characteristics of alligators; affecting certain organs and pro-
ducing stunted hormones essential for survival and repro-
duction; thus reducing male alligator genital sizes [
26
,
27
]. A
chemical such as trans-Nonachlor, by itself may reverse sex
whereby male alligators becomes female [
28
]. When alliga-
tors are exposed to a combination of chemicals such as p,p-
DDE and trans-Nonachlor, there is no sex change despite
the high presence of the latter. The effects of chemicals on
reptiles depend on the level of the chemical’s concentration
and other environmental conditions such as changes in
temperature. As such, the presence, concentration, and
effects of pharmaceuticals can only be accurately predicted
when their entry into the environment is scrutinized and
regulated. Other studies have found that exposure of fish
to female human hormones in bodies of water, often results
in feminisation of male fish [
29
,
30
]. The near annihilation
of Southeast Asian vultures has been traced to their con-
sumption of dead cattle that had earlier been treated with
the pain killer, Diclofenac [31,32].
UNEP identifies the oil industry in the Niger Delta Region
of Nigeria as the main source of extensive contamination
of the region with severe ramifications for the people of
Ogoni [
33
]. Aworawo observes that “drill cuttings, drilling
mud, the fluids used to stimulate production, the chemicals
injected into the earth to control corrosion or to separate oil
from water and the production of general waste” gas flares
and hazardous effluents are responsible for the constant
pollution of land and water bodies in the Niger Delta region
[
34
]. Uneasily degradable chemicals, construction of flow
lines and trunk networks, oil terminals, creation of waste
pits and barrow pits, oil spillage as a result of old corrosive
pipes, human error and sabotage, equipment failure, and
unceasing flaring of natural gas have resulted in surface
and underground water pollution, other ecological damage
and violence [
35
37
]. The net effect of oil production and
petroleum wastes has resulted in the presence and con-
centration of organic chemicals such as phenol, cyanide,
sulphide-suspended solids, chromium, and biological oxy-
gen that degrade water bodies, soil and air, thereby posing
countless health challenges to the people of the region [
38
].
In Ghana, the mining of gold and other precious minerals
takes place across the country but is mainly concentrated
in the greenstone and alluvial regions of Birim, Tarkwa and
the Offin, Pra, Ankobra, and Tano rivers and their tribu-
taries: the main locales for food and cash crop farming. The
culture of mining is inherently, intensively, and irreversibly
destructive to the environment, poisoning the environment
with enormous quantities of hazardous chemicals such as
mercury and cyanide, degrading arable land through inap-
propriate and wasteful working practices, depleting forest
and eroding soil cover, poisoning underground and surface
water bodies, and undermining livelihoods and the health
and safety of communities [
39
]. The use of Mercury and
cyanide and their presence in the mining environs are ad-
versely affecting biodiversity, fishing, and farming [
39
42
].
Farming and fishing communities in mining areas are ex-
posed to neurological disorders as a result of consuming
food and fish produced from soils and water bodies polluted
by mercury use in mining [42].
On the occurrence and persistence of pharmaceuticals
in the environmental media and the quality of water bodies
in Ghana, Abruquah, et al, carried out a pioneering study on
how the residents of Konongo-Odumasi in the Ashanti Re-
gion dispose of their unwanted medications and the probable
effects these medications and their disposal practices have
on the environment [
9
]. They employed judgement sampling
and interviewed 500 residents and found that 38% of those
interviewed disposed of their discarded medication by bury-
ing; 29% put them in their domestic garbage and disposed of
them; 7% burnt them; 4% flushed them down the toilet; and,
only 1% returned their unwanted medications to the pharma-
cies [
9
]. The findings of the study imply that a high 71% of
the respondents disposed of their redundant medicines by
dumping them straight into the environmental media.
As stated earlier, environmental security has risen to
the fore as the concept of security has shifted to a more
human-centred approach. The exigencies of ecological
degradation may be felt locally and globally, and often in-
tersects with other components of human security such
as public health and food security. Pharmaceuticals in the
8
environment, over sometime, pose potential risk to human
and other consumers higher up the food chain [
14
]. These
effects impact on the health of ecosystems, and pollution
of this nature often leads to environmental insecurity and
unsustainable development [3,17].
4. Legal Framework for the Disposal of Medicines in
Ghana
The disposal of medicines in Ghana is regulated by the
Public Health Act, 2012 (Act 851) [
43
]. Under Act 851,
the disposal of pharmaceuticals falls within the remit of the
Food and Drugs Authority as provided for under Section
132, Closure of Premises and Safe Disposal of Unwhole-
some Regulated Products:
1.
The Authority shall, order the closure of any premises
where articles regulated by this Part are manufac-
tured, stored, prepared or sold, if the Authority has
reason to believe that the articles are exposed to the
risk of contamination or deterioration, and the Au-
thority may make a further order appropriate in the
circumstances.
2.
The Authority shall supervise the safe disposal of an
unwholesome regulated product at a fee determined
by the Authority.
3.
A person shall not dispose of an unwholesome regu-
lated product without the supervision of the Authority.
4.
A person who contravenes subsection 3 shall pay a
fine of not more than five thousand penalty units to
the Authority.
Section 148 of the Act empowers the FDA to provide guide-
lines “for the destruction of an adulterated food or drug”
and “for the seizure and disposal of products regulated
under this Part. The Act does not, however, insist on ad-
herence to disposal methods and procedures that protect
the quality of the environment in general or that of water
resources. The choice of appropriate methods and proce-
dures for the preservation of the environment and water
bodies are therefore left to the environmental conscious-
ness and judgement of the officials of the FDA. Prior to the
passage of the 2012 Public Health Act, the EPA was, by de-
fault, responsible for the eco-friendly disposal of medicines,
chemicals and industrial waste. The establishment, func-
tions, and responsibilities of the EPA are enumerated under
the 1994 Environmental Protection Agency Act, (Act 490).
Under Section 2, the EPA is:
“to secure by itself or in collaboration w ith any other
person or body the control and prevention of discharge
of waste into the e nvironment and the protection and im-
provement of the q uality of the environment” and “to pre-
scribe standards and guidelines relating to the pollution
of air, water, land and any other forms of environmental
pollution including the discharge of waste and the control
of toxic substances”.
By virtue of these provisions and in the absence of
clearer provisions, the EPA became responsible for advis-
ing other institutions including the FDA on the judicious
disposal of medicines to better protect the environment.
The provisions of Act 851 specifically provide for the dis-
posal of unused, expired or unwanted medicines held by
commercial facilities and supply points but not for those held
by members of the public. This lacuna poses a number of
dilemmas to individuals as to what to do with their unwanted
medications. Moreover, since the eco-friendly disposal of
such unwanted drugs comes at a cost, the cost may most
probably serve as a disincentive for eco-friendly disposal.
5. The Practice and Culture of the Disposal of
Pharmaceuticals in Ghana
The process for regulated disposal of medicines is triggered
by the receipt of an official letter by the FDA from an or-
ganisation that has some medicines to be disposed of. It
can also be initiated by an order of a court of competent
jurisdiction which requires that a particular quantity or batch
of medicines be disposed of. Before the institution of Act
851, such entities would have had to notify the EPA by letter
with pictures of such intents. Beyond expired or unwanted
medicines, these products might also include active phar-
maceutical ingredients that are no longer required by the
manufacturing concerns that own them. Next, the FDA car-
ries out an onsite inspection and audit of the medicines
marked for disposal in order to confirm the types and quan-
tity as well as determine the necessary fees to be paid
by the holding organisation. This fee is not charged if the
holding organisation is run by the state. The products to be
disposed of are held in storage by the holding organisation
till the date set for disposal, since the FDA does not own
storage facilities. Again, there are no specific guidelines
on the storage conditions of medicines marked for disposal.
The FDA supervises the packing of the medicines, leads
the vehicle to the chosen disposal site, and carries out the
disposal of the medicines using a predetermined method
of disposal in the presence of an official of the organisation
that initiated the entire process. Prior to Act 851, an EPA
official would be present during the period of disposal.
The FDA undertakes disposal of these medicines in four
ways; these are crushing and burying, burning, incinera-
tion, and emptying liquid formulations into municipal drains.
Crushing and burying involves placing the products into
an identified excavated spot, crushing them in the pit and
covering it over with earth afterwards. With burning, the
medicines are doused with fuel and set on fire at the dis-
posal site. Incineration is mostly used for the disposal of vac-
cines, oncogenic medicines and steroids, and involves the
use of incinerators owned by other organisations as the FDA
does not own any incinerators. All solid medicines besides
those that fall into the category for incineration are disposed
of either by crushing and burying or by burning, while liq-
uid products are poured down municipal drainage systems.
Medicines are not sorted out according to their pharmaco-
9
logical action during the process of disposal, which means
medicines with augmenting effects might end up together
and possibly produce enhanced effects beyond that which
they might individually produce.
Disposal sites are not owned by the FDA, and as a result,
the organisation initiating the disposal, whether public or pri-
vate, pays a site fee for the use of the site. The FDA’s lack
of control over the management of disposal sites means
it is unable to ensure that any other activities at the sites
are carried out in a manner that does not prove detrimental
to the surrounding environments and the people. Current
dump sites used by the FDA for disposal of medicines are
located in Kpong, Abokobi, and Nsawam. All three sites
are used for disposal processes that require crushing and
burying while the latter site at Nsawam, which is signifi-
cantly removed from the human population, is also used for
disposal that involves burning. The distance of the Nsawam
site from the closest human settlement (the Nsawam Town-
ship), is meant to prevent residents from being exposed to
the possibly toxic fumes that the burning process generates.
The crushing and burying sites are chosen based on the
level of the water table in order to reduce the possibility of
contaminating the ground water with the pharmaceuticals
that have been buried on the site.
Prior to the passage of Act 851, the EPA was largely
responsible for all the processes referred to above. It is still,
however, responsible for the management of the disposal
of industrial and medical waste. Its Chemicals Control and
Management Centre (CCMC) collaborates with the FDA
and District Assemblies on the disposal of medical waste.
The CCMC’s objectives are to protect human health and the
environment from the indiscriminate, inappropriate use and
improper management of chemicals while ensuring safe
use of chemicals for people and the environment, among
others (Information on the CCMC is on its page at the EPA
Ghana website. http://www.epa.gov.gh/epa/-).
6. The Disposal of Unwanted/Unused Medicines
Project (DUMP)
The DUMP project pioneered by the Cocoa Clinic’s phar-
macy in 2009, was in response to a need identified during
dispensing of medicines. A counselling session with a hy-
pertensive diabetic revealed the patient had large quantities
of prescribed medications from previous visits that had not
been used. This led to the realization that there was a
need to provide support services to clients to handle un-
used medicines in their possession. The project initially
focused on the clientele of the Cocoa Clinic, providing edu-
cational programmes to encourage patients to return their
unwanted, unused, and expired medications to avoid the
attendant risks of accidental poisoning of children or the
abuse of medication by other parties with access to these
medications. Disposal of drugs by flushing them down the
toilet or throwing them in the trash which have been iden-
tified by another study as among the major methods of
disposal by individuals in Ghana is also discouraged. [9]
The clinic also encouraged its clientele to stick to and
complete dosage regimens to avoid having left over quanti-
ties of medicines at their disposal. They were also warned
about the potential dangers of sharing medications with
other parties who have neither been diagnosed nor advised
by qualified personnel to take such medication. Any un-
used drugs are to be placed by clients of the clinic into bins
placed at vantage points around the facility. Posters are
strategically placed to serve as a helpful reminder, fliers
and stickers are periodically distributed, while a magazine
published with the project in mind, Safe Medicines, is also
made available to clients and members of the public. The
DUMP project has not been limited to the clients of the Co-
coa Clinic. Through periodic public outreach programmes,
some identifiable groups have participated in the project and
also deliver their unused and unwanted medicines to the
Cocoa Clinic for onward disposal by the FDA. Currently, the
Calvary Baptist Church and different groups in the Kaneshie
Central Market collect unused medicines for regulated dis-
posal under the DUMP project. The project also involves
the Cocoa Clinic’s mother organisation, Ghana Cocobod,
and provides collection bins on all floors of the Cocobod
Head Office for the convenience of staff members who want
to dispose of medicines. All the bins (at the Cocoa Clinic
facility and Cocobod Offices) are regularly emptied and
the contents sorted out into their various pharmacological
classes.
The bins provided for disposal are labelled as follows:
A) Tablets and Capsules
B) Suspensions and Syrups
C) Injections and Injectables
D)
Eye preparations, skin preparations and other topical
preparations
Clients are free to dispose any quantity or type of
medicines without any questioning or interference by clinic
officials, and the bins are available throughout the week
to clients who wish to dispose of medicines. Medicines
collected under the DUMP project after being grouped into
their pharmacological classes are then weighed to assess
the quantities and percentages of the medicines collected.
Table 1 shows a typical distribution, in percentages, of the
medicines received for disposal according to their pharma-
cological activity.
The quality of medicines that are neither expired nor
damaged cannot be guaranteed because verification of
the conditions under which they were stored is next to im-
possible. As a result of this, all medicines received under
the project are disposed of even if they are not expired or
undamaged. Since 2009, no banned narcotic drugs have
been collected. The clinical pharmacist at the Cocoa Clinic,
however, judged that there may be some individuals who
may wish to dispose of these kind of drug (Interviewed by
Y.Y. Esseku, 22
nd
January 2012). He suggested there was
a need to either extend the DUMP project or create a new
project to encourage the disposal of banned narcotics with-
10
out risk of being prosecuted. The project has also collected
both complementary and unorthodox medicines which are
all handled in the same manner. The Cocoa Clinic in line
with FDA procedure for the disposal of pharmaceuticals
stores the collected medicines on its premises until they are
finally disposed of once every year under the auspices of
the FDA. The procedure for the disposal of medicines col-
lected under the DUMP project follows the exact procedure
laid down by the FDA described in an earlier paragraph of
this paper. The Cocoa Clinic is classified as a government
facility and so does not pay the disposal fee but does pay
the site fee as required. Figure 1 shows the scheme of
movement of unused and unwanted medicines from collec-
tion to disposal.
Table 1.
Categories and Quantities of Medicines Received for
Disposal under DUMP (Culled from Safe Medicines, 2011).
Class Total collected (%)
Antihypertensive agents 21
Antibiotics 18
NSAIDs and Analgesics 18
Steroids 8
Anti-Malarial agents 6
Haematinics 6
Anti-diabetic agents 5
Antiulcer agents 3
Antacids 3
Cough preparations 3
Spasmolytic agents 3
Antihistamines 2
Anti-asthmatic agents 2
Anti-gout agents 1
Muscle Relaxants 1
Figure 1.
Movement of Unused Medicines DUMP (dis-
tilled from interviews by authors).
7. DUMP and Environmental Security
The DUMP project, despite its obvious limitations and nar-
row coverage, provides an outlet for the regulated disposal
of pharmaceuticals. It helps to reduce incidences of acci-
dental poisoning or abuse of unused, unwanted or expired
medicines and ensures that the potential effects of these
drugs on the environment can be controlled through their
regulated disposal. Thus, in its own limited manner, it con-
tributes to the environmental security of the population and
by extension the sustainable development of the country.
Interviews with Mr. Amedzro of the FDA and Dr Coomson
of the EPA showed both men agreed that unregulated and
improper disposal of pharmaceuticals poses negative con-
sequences for the environment and its inhabitants. This is
perhaps the main motivation behind the FDA siting disposal
sites at locations significantly removed from human settle-
ments. To avoid the possible contamination of ground water,
sites chosen for crushing and burying are located in areas
that have very low water tables. The study finds that there
is no policy in place to evaluate or deal with potential long-
term effects that might result from the current regulated
methods of disposal. The methods, for instance, ignore the
possibility of the noxious fumes from disposal sites where
the pharmaceuticals are burned travelling great distances
by wind to neighbouring communities. While the concentra-
tion of chemicals in these fumes might be low by the time
they reach such settlements, long-term exposure to even
the small quantities of chemicals in the air might be harmful
to the health of inhabitants and the natural environment.
It is interesting to note that Mr Amedzro and Mr
Abubakari, both officials of the FDA, considered the meth-
ods currently in use as inadequate in protecting the environ-
ment from long-term exposure that is potentially detrimental
to the environment and public health. They were of the
belief that more sophisticated methods and facilities such
as incinerators might be better options and may significantly
lower the risks to the environment posed by the disposal
of these medicines. Mr Amporful, an official of the Cocoa
Clinic who had visited the disposal sites used for the DUMP
project, believes that the current methods in use were not
adequate to protect the environment. He felt that the lack of
facilities which would ameliorate the environmental effects,
was a result of challenges faced by government agencies
in securing funds for facilities whose immediate use will not
be appreciated.
The possibility of polluting surface water sources be-
cause of burning of medicines is a concern. Chemicals
present in the fumes from the burning of several pharma-
ceuticals have the potential to dissolve into nearby water
bodies that might serve local communities. They may be
dissolved in rain or fog and enter these water sources. Tak-
ing into consideration the fact that medicines of various
chemical compositions are often burnt together, there is
the significant risk of chemical reactions that produce com-
pounds with unknown effects. Davis et al also indicate that
surface water is exposed to pharmaceuticals found in the
11
runoff from soil that washes into them [
21
]. Despite these
chemical residues being small in quantity, their long-term
exposure to aquatic life and animals that are dependent on
these water sources might be detrimental.
The current disposal method of choice for liquid
medicines, according to Mr Amedzro of the FDA, involves
their discharge into municipal drains. This makes the receiv-
ing waters that these drains flow into the ultimate recipients
of these waste products which are often introduced in active
forms into the drains. These drains empty into streams and
rivers, reducing the quality of the water supply and directly
exposing the aquatic habitat to these pharmaceuticals. Again
while the concentrations of these liquid medicines in these wa-
ter bodies might be low, aquatic organisms such as fish have
been known to accumulate some of these medicines in vari-
ous body tissues with other studies noting male fish experi-
encing feminisation on exposure to human female hormones
[
44
]. Alligators have also been found to suffer lower survival
rates, reduced phalanges, shrinking genitalia (males), and
sex reversal on exposure to certain chemicals [
28
]. There is
of course the yet to be investigated potential risk to human
health as a result of long-term exposure to these doses of
medicines present in water sources being consumed. Such
contamination could, over time, lead to the non-availability
of that water body as a source of water for domestic con-
sumption. It could also result in the removal of a source of
livelihood and survival particularly in communities that rely
on such water bodies. The current methods of disposal also
do not address the likelihood of plants absorbing these chem-
icals, particularly plants that grow in swamps. According to
Wu et al, these plants pose the danger of reintroducing these
pharmaceuticals into the terrestrial environment. Some hu-
man pharmaceuticals are also known to be toxic to plants
and when absorbed in this manner might lead to the destruc-
tion of the plant itself or be stored in parts of the plant which
might be consumed by other organisms higher up the food
chain including humans [26].
As earlier stated, the sites for crushing and burying are
selected with the water table in mind to avoid contaminating
ground water sources. Thus, the sites chosen are usually
areas that have a very low water table. This was confirmed
by Mr Abubakari and Dr Coomson of the FDA and EPA
respectively. Despite the presumption that carrying out
this disposal method high above the water table will pre-
vent contamination of groundwater by pharmaceuticals so
dumped, Shield reports the presence of pharmaceuticals in
groundwater samples 300 metres away from a landfill site
which had been abandoned for over 20 years [
44
]. Phar-
maceuticals are thus shown to persist for long periods in
soil and are, in time, able to reach the water table. Dump-
ing in un-engineered landfills, no matter how high above
the water table only postpones the inevitable pollution of
groundwater resources nearby. Dr Coomson of the EPA
points out though that sites marked for burying hazardous
waste are noted to prevent burying chemicals that have
the potential of reacting with the waste previously buried
at the site. This measure is to prevent the creation of toxic
compounds that might be damaging to the environment and
nearby populations.
Anti-microbial resistance (AMR) has over the years been
a major cause of concern for the health care delivery indus-
try with the WHO identifying it as one of the causes of the
escalating costs of treatment. AMR develops as a result of
infection causing microorganisms developing resistance to
existing medication, creating the need for stronger medica-
tion to be developed and often resulting in the unchecked
spread of difficult to treat conditions [
45
]. Although this
research has not uncovered any findings on the subject
confirming resistance as a result of exposure of microorgan-
isms to medications in the environment, there is a realistic
possibility for instance that exposure to antibiotics will de-
velop resistant capabilities in microorganisms so exposed
[
16
,
46
,
47
]. This possibility is enhanced by the fact that
the doses that might be released through various disposal
methods are smaller and thus unlikely to result in the de-
struction of such organisms as is the case with therapeutic
doses. Messrs Amedzro and Abubakari of the FDA and
Dr Coomson of the EPA all share the opinion that unregu-
lated and indiscriminate disposal of medicines holds dire
implications for the environment and the population. They
point to possible contamination of ground water sources
when such drugs are buried without regard for the depth
of the water table, the inhalation of toxic fumes from open
burning of such medicines, and finally the risk of polluting
water bodies and harming aquatic life through unchecked
dumping of medicines into drains.
The Cocoa Clinic serves a very tiny segment of the
Ghanaian population. In its home region, the Greater Ac-
cra Region, there are 384 health institutions with several of
them being much larger than the Cocoa Clinic and therefore
serving larger segments of the population [
48
]. No other
health facility in the region or in any other part of the country
is on record for collecting unused medicines from clients or
the general public besides the Cocoa Clinic. Two hundred
and fifty-two of these health institutions are classified as
clinics. For the purposes of this paper, attendances at the
Cocoa Clinic will be used to represent average attendance
figures at clinics in the Greater Accra Region.
The research thus assumes that the average quantities
of drugs collected by the Cocoa Clinic would be represen-
tative of the average that could be collected by clinics in
the Greater Accra Region if they all ran a program simi-
lar to DUMP. The Table 2 shows an extrapolation of the
potential quantities of drugs that are unused, unwanted or
expired and are possibly being disposed of with unregulated
and unsafe methods. The estimated figures here are only
based on possible clients of clinics in the region and do
not include those of other larger health facilities like district,
regional, and referral hospitals or much smaller facilities like
community health posts or low level health centres.
These figures indicate quantities of medicines that are
potentially available from clients of these clinics but are not
being collected for regulated disposal under the auspices of
the FDA. These medicines are likely being indiscriminately
12
disposed of into the environment with little or no documenta-
tion as to what possible effects they might be having on the
environment. There is the possibility that sources polluted by
this potential unregulated disposal are consumed by unsus-
pecting humans and other organisms, negatively impacting
their life and engendering environmental insecurity.
Table 2.
Projected Quantities of Medicines Disposed of
in an Unregulated Manner by Attendants to Clinics (Cal-
culated by authors using figures Cocoa Clinic and Ghana
Health Service).
Class Quantities (kg)
Antihypertensive agents 3916
Antibiotics 3357
NSAIDs and Analgesics 3357
Steroids 1492
Anti-Malarial agents 1119
Haematinics 1119
Anti-diabetic agents 932
Antiulcer agents 559
Antacids 559
Cough preparations 559
Spasmolytic agents 559
Antihistamines 373
Anti-asthmatic agents 373
Anti-gout agents 186
Muscle Relaxants 186
8. Effects of the Presence and Persistence of
Pharmaceuticals on Water Resources and
Ecosystems
As indicated above, even the most cautious disposal meth-
ods are not fool proof at preventing pharmaceuticals in the
environment from entering either surface or ground water
sources. They contaminate these sources, often becoming
toxic to the aquatic life forms and other living organisms
higher up the food chain that either consume these animals
or depend on these sources of water for drinking. Some
human hormones and certain pesticides affect the reproduc-
tive health of fish, alligators, and other aquatic organisms
that might be sensitive to them. Plants may also be affected
through drawing on water that contains pharmaceuticals.
This might be toxic to the plants, or may be absorbed and
concentrated into certain parts of the plant, to be later rein-
troduced into the terrestrial environment after consumption
by animals. Such contaminated water sources are unwhole-
some for human and animal consumption. The exposure of
essential body organs such as the liver to non-therapeutic
doses over long periods of time is likely to induce severe
health complications.
Pharmaceuticals can also produce major unintended
effects that affect ecosystems. Evidence for this comes
from drawing on the example of the near collapse of the
Southeast Asian vulture population where large numbers
of vultures died after consuming the flesh of cattle that
had earlier been treated with Diclofenac. These doses of
Diclofenac, though not harmful to the cattle, had become
stored in their tissues and proved poisonous to the vul-
tures who consumed their flesh after the cattle had died
[
32
]. This proves that the consumption of body tissues that
have significant concentrations of pharmaceuticals might be
detrimental to the health of organisms further up the food
chain. Animals such as fish and other aquatic organisms
that serve as food for humans and other animals, when
exposed to pharmaceuticals in their habitat, might store
them in their tissues in similar fashion and prove toxic to the
humans and other organisms that feed on them.
Another effect on the ecosystem as a result of dis-
posal of pharmaceuticals has to do with the feminisation
of male fish after exposure to female human hormones
[
30
,
31
]. This holds dire repercussions for the maintenance
of a healthy fish stock in the affected water body. This
might have knock-on effects for human populations that
are dependent on these fish stocks for their survival and
even other organisms living within that ecological system
which feed on the fish. The exposure of producers (plants)
and primary consumers to these pharmaceuticals has the
potential to put all other consumers in that particular eco-
logical food chain at risk.
9. Conclusion
In conclusion, the study finds that while quite a few leg-
islative provisions exist for the disposal of pharmaceutical
waste and general preservation of the environment, they do
not specifically cover unwanted, unused or expired pharma-
ceuticals that are held by members of the general public.
The DUMP project instituted by the Cocoa Clinic in Accra
has managed, with the help of the FDA and EPA, to provide
an outlet for the regulated disposal of unwanted pharma-
ceuticals held by the public. The study finds that these
regulated disposal methods, despite taking health and envi-
ronmental precautions in their execution, are not sufficient
to protect the environment from the possibilities of damage
and long-term health effects.
The quantities of medicines collected annually under the
DUMP project points to the possibility of very large quan-
tities of unused, unwanted or expired medicines held by
members of the general public and disposed of in ways that
are unregulated and essentially indiscriminate in nature.
The study finds that such unregulated and indiscriminate
disposal has the potential of leading to pharmaceuticals
finding their way into environmental media and generating
all sorts of ill-effects for both plants and animals.
The study finds that water resources are at extreme
risk from both regulated and unregulated forms of dis-
posal of pharmaceuticals. These reduce the quality of
water resources and may prove toxic to the aquatic habi-
tat therein and other organisms that inhabit the same
ecological food chain.
13
The study recommends, among other things, that to en-
sure sustainable development, there is the need to improve
the current legal framework to adequately address the effects
of pharmaceuticals on the environment as a result of their
disposal by members of the public. This study further shows
that there are large quantities of pharmaceuticals held by
members of the general population, that can be described
as unwanted, unused or expired. In order to prevent their
indiscriminate disposal into the environment, it would be
important to introduce new policies or amend existing ones.
10. Recommendations
Given the findings of the study, there is the need to increase
public education through the Food and Drugs Authority
on the potential dangers of improper disposal of unused
and unwanted pharmaceuticals. One of the main factors
enabling improper disposal appears to be the complete
absence or lack of any comprehensive program/avenue to
receive unused/expired pharmaceuticals. An increased pub-
lic education on safe disposal of unwanted pharmaceuticals
will only be meaningful when unwanted pharmaceuticals
Collection Centers are established at health facilities nation-
wide to receive unused/expired pharmaceuticals from the
public for proper disposal by the authority.
FDA regulation of pharmaceuticals in terms of safety
and marketing should be extended to include a database
for all drugs to enable the authority to track these drugs
even while they are in circulation. This should aid in locating
expired drugs still in stock or on the market so they can
be immediately and safely disposed of. To make this even
more feasible, Ghana’s relatively high ‘mobile phone’ pen-
etration rate can prove useful as has been the case in the
implementation of other policies that have needed to reach
both urban and rural areas. The FDA already has a system
in place for the public to verify the authenticity of drugs via
a ‘mobile phone’ platform. This paper recommends an ex-
tension of the current FDA ‘mobile phone’ platform to allow
registered pharmaceutical points of sale, and other health
institutions around the country, to be included in a database
that would track and collect unused and expired medicines
while serving as collection points for such medicines held
by members of the public.
These recommendations would require extra financing
to be feasible. As stated above, the FDA and the EPA
in Ghana are both severely underfunded and have to bill
private holders of unused/expired drugs for disposal while
not being able to reach out to members of the general
public in this respect. This paper recommends that govern-
ment should consider increasing budgetary support to these
agencies through allocating a bit of the National Health In-
surance Levy charged as part of Value Added Tax (VAT) on
goods and services to support effective disposal of pharma-
ceuticals. In addition, they could levy importers and local
manufacturers of medicines to raise funds to support proper
disposal of their merchandise. Government can also seek
to encourage donor organisations and corporate entities,
particularly those in the health sector, to emulate the Cocoa
Clinic by supporting similar initiatives across the country as
part of their aid activities or corporate social responsibilities
respectively. Increased funds should enable the FDA to
remove cost barriers that are presently a significant contrib-
utory factor to unapproved disposal of drugs outside FDA
involvement or supervision.
As research in this area continues to grow, it would
be helpful if state agencies such as the FDA and the EPA
increased collaboration with both local and international
scholars in the field through workshops and conferences
towards developing new and improved strategies to dispose
of pharmaceuticals without harming the environment any
further than is already the case. Seeing as this poses a
key environmental security concern, it would be necessary
for the National Human Security Office to play a key role in
this proposed development by securitizing the problem thus
emphasizing its seriousness and drawing significant public
and state attention to addressing it.
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