Abstract
Pharmaceuticals produce considerable environmental harm. The industry's resource-intensive nature, coupled with high energy costs for manufacturing and transportation, contribute to the "upstream" harms from greenhouse gas emissions and ecosystem pollution, while factors such as overprescription, overuse, and pharmaceutical waste contribute to the "downstream" harms. Effectively addressing pharmaceutical pollution requires an understanding of the key roles and responsibilities along the product lifecycle. In this commentary, we argue that three actors-producers, regulators, and prescribers-have unique and interdependent responsibilities to address these issues. Producers and market access regulators are upstream actors who can manage and mitigate harms by both shifting manufacturing, business practices, and regulatory requirements and producing transparent, robust data on environmental harms. By contrast, prescribers are downstream actors whose capacity to reduce environmental harms arises principally as a "co-benefit" of reducing inappropriate prescribing and overuse. Potentially complicating the prescriber's role are the calls for prescribers to recommend "environmentally preferable medicines". These calls continue to increase, even with the sparsity of transparent and robust data on the impact of pharmaceuticals on the environment. Recognizing the interdependencies among actors, we argue that, rather than being ineffectual, these calls draw needed attention to the critical responsibility for upstream actors to prioritize data production, reporting standards and public transparency to facilitate future downstream efforts to tackle pharmaceutical pollution.