Controlled Substances Disposal
March 4, 2024

Organizations, healthcare clinics, and hospitals that use controlled substances are required by law to have procedures and policies in place for the proper disposal of these materials. These procedures and policies are to avoid environmental pollution and potential drug diversion. The procedures can become challenging, especially if your facility has a high volume of controlled substances requiring disposal. Talk to the experts at Environmental Marketing Services to learn how this process can be handled safely, affordably, and professionally.

DEA Controlled Substances Management

The DEA now enforces new regulations for controlled substances disposal in accordance with the Disposal Act of 2010. The Act amends the authorization of users to deliver controlled substances to another person for disposal purposes. It has expanded the entities to which users can transfer expired, unwanted, or unused controlled substances for disposal.

Under the new DEA controlled substances management, a review of DEA regulations and policies was conducted regarding each element of the disposal process. The elements reviewed consist of the transfer, delivery, destruction, return, collection, and recall of all controlled substances.

One of the goals of the Disposal Act of 2010 is to set parameters for controlled substances disposal. The Act encourages private and public entities to implement methods to collect and destroy controlled substances conveniently and securely. The Act’s goal is also to decrease the amount of controlled substances being introduced into the environment, especially into the water systems.

One final rule being implemented under DEA controlled substances management is a standard of destruction. While there is no procedure for destruction laid out, the DEA does ask that a desired result be achieved. The standard intended will allow public and private entities to create a destruction method that is convenient, secure, and responsible, and prevents diversion of the controlled substances.

Controlled substance disposal methods must also meet all state, federal, and local law regulations. Environmental Marketing Services can help ensure your facility is meeting all requirements and create a process for all your controlled substances disposal needs.

Regulations for Controlled Substances Disposal

The regulations governing controlled substances disposal often overlap within state, federal, and local authorities. Some states have more stringent rules than the federal government, and rules vary among states. Disposal of controlled substances can become challenging when authorities overlap.

Regulations for controlled substances disposal are also updated and revised often, making it difficult to meet all relevant requirements. An example of the overlaps happens when federal regulations state controlled substances must be destroyed so they are non-retrievable and any diversion is prevented for illicit purposes. Under this regulation, incineration would be acceptable if it does not cause occupational or environmental issues.

Other overlaps occur when sewering is recommended as the DEA does not consider this method as meeting the standards. Sewering is also discouraged by the EPA for environmental safety reasons. The FDA, on the other hand, accepts sewering and uses this method as common practice in many facilities. Any questions or concerns your facility has for disposing of controlled substances can be answered by Environmental Marketing Services.

On-Site Disposal of Controlled Substances

Environmental Marketing Services can offer on-site services for the disposal of your facility’s controlled substance waste. Controlled substance waste can be transferred to a facility which is authorized to destroy them. Witnesses must oversee the transfer, transport, and destruction of these materials. Documentation will be required that the disposal of these substances was rendered in a manner that makes them non-retrievable.

Typically controlled substances in a facility such as hospitals, healthcare clinics, and others are placed in special waste receptacles consisting of an outer container with a removable liner. These receptacles should be placed in an area that can be regularly monitored so that diversion does not occur. If continuous monitoring is not possible, a closed-circuit video should be installed.

Facilities such as healthcare clinics, hospitals, and others that dispense controlled substances have to maintain a record-keeping system. This system is to include records regarding the use and disposal of controlled substances. This system should include the substance prescribed, how much was used, and the amount left to be disposed of.

When the controlled substances are transported for disposal or destruction, there will also be documentation of all steps taken. Recordkeeping can be vulnerable to diversion if someone were to exploit the witnessing or sign-off requirements. Using a trusted, experienced carrier, such as Environmental Marketing Service eliminates this risk to your company or facility. 

Environmental Concerns with Controlled Substances Disposal

Some healthcare organizations dispose of their unused controlled substance materials by flushing them down the drain. This disposal method causes the substances to enter municipal water systems. Healthcare facilities often face environmental challenges with this practice.

Healthcare organizations have an unpredictable volume of waste in a variety of forms. These forms can include syringes, nebulizers, liquids, patches, pills, and more. All of these products are considered hazardous waste, and if your facility does not have a professional trained in the handling of hazardous waste, you need to contact Environmental Marketing Service.

The professionals at Environmental Marketing Service are experienced and trained in how to handle hazardous waste materials. This service will provide your facility with experts who understand what can be safely disposed of in the sewage and what is considered environmental hazards.

Many believe water treatment plants adequately remove controlled substances from the water. The fact, however, is sewage treatment plants have not been designed to remove all controlled substances and waste from the water received. The result is that much of the controlled substances waste passes through the treatment process unchanged.

Environmental Protection Agency (EPA) Hazardous Waste Regulation

In 2019 the EPA issued a new hazardous waste regulation prohibiting the sewering or flushing of hazardous pharmacy waste. The definition of hazardous pharmacy waste by the EPA is any that is listed in the Resource Conservation and Recovery Act. Hazardous pharmacy waste is also any product containing hazardous characteristics. If you are unsure whether or not your waste materials are considered hazardous, talk to the experts at Environmental Marketing Service.

The EPA’s new hazardous waste regulation states hazardous pharmacy waste cannot be sewered and must be handled in compliance with DEA regulations. These materials must be destroyed in a manner that meets DEA’s non-retrievable standards of destruction.

Non-hazardous and hazardous pharmacy waste can be commingled in airtight, leak-proof, nonporous containers which are also structurally sound and non-reactive. The containers are required to be properly labeled as hazardous waste and need to include the date the container was started.

Arguments Concerning Controlled Substances Disposal

Controlled substances disposal regulations appear from multiple organizations. This fragmented approach can make the process challenging for many facilities trying to navigate the laws and rules to ensure compliance. There are no specific, definitive guidelines to follow to place appropriate procedures into your workflow.

Another argument to complicate controlled substances disposal is how some of the products are formed. One example of this controversy is the transdermal system of dispensing medication. Simply folding a patch to put the adhesive sides together does not make this item safe to flush. Many of the transdermal systems have been designed to only dispense approximately half of the medication. A substantial amount of the residue will remain on the patch and flushing it can put a significant portion into the water system.

Solutions For Controlled Substances Disposal

As noted above, the regulations for disposing of your controlled substance waste can be challenging. Environmental Marketing Service can help your facility to safely and properly dispose of these materials and other hazardous waste. We offer an efficient and safe transportation and disposal service for a variety of materials including universal, non-hazardous, and hazardous waste.

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