The controlled substances not only have to be stored, handled and dispensed carefully, but the stipulations extend to their disposal as well. The DEA has established collection sites and events for the same.
What does a pharmacy, hospital or medical practitioner do with controlled substances that are unused, out-of-date, damaged or otherwise unusable or unwanted for some reason? Disposing the Schedule I to V drugs is not as easy as flushing them down the toilet. In fact, the Drug Enforcement Administration (DEA) does not permit the registered entities to even pour such medications down the drain or dispose them in a landfill by mixing with coffee grounds or kitty litter.
By law, DEA veterinary and regular registrants can only dispose of controlled substances by destruction, return, recall, sale or through the manufacturing process. The destruction has to be in a non-retrievable manner – permanently and irretrievably alter the physical or chemical condition of the drug so that it becomes completely unusable. Incineration is currently the only acceptable method of destruction for pharmaceutical wastage prescribed by the DEA.
By law, DEA veterinary and regular registrants can only dispose of controlled substances by destruction, return, recall, sale or through the manufacturing process. The destruction has to be in a non-retrievable manner – permanently and irretrievably alter the physical or chemical condition of the drug so that it becomes completely unusable. Incineration is currently the only acceptable method of destruction for pharmaceutical wastage prescribed by the DEA.
In addition to this, there are drug take back options as well. The DEA has registered specific facilities and businesses as Authorized Reverse Distributors and drug take back sites where unused or expired medications can be dropped off after completing the accompanying paperwork. They safely and securely gather and dispose of the drugs. Registrants should note that they will have to record the transfer of the drugs using an invoice or form (as specified) and maintain copies of the records documenting the transfer and disposal for a period of two years.
Then there are the periodic take back events. In fact, since 2010, the DEA is holding a National Drug Take Back Initiative (NTBI) as a safe and easy means of disposing of unused or expired medications, while also educating the public about prescription drug abuse.
While the authorities are doing their best to remove expired and unused medications from circulation as a means of pre-empting drug diversions and abuse, the registrants are bound to comply with the regulations and follow the spirit of the law.
So, how can the DEA registrants ensure that they are in compliance with the state and federal laws? Can they afford to run afoul of the regulations even if it happens inadvertently? And how should they stay abreast of the changes and updates in the stipulations, let alone keep track of the take back days and other such events?
While there are varied resources to help DEA license veterinary and other registrants, it is advisable to employ a professional service provider like the Titan Group. Being former DEA special agents, diversion and state investigators themselves, they possess ample knowledge and experience of the management, oversight and disposal of controlled substances. They can check the policies and procedures of the DEA registrant entities while suggesting and instituting best practices to ensure that they stay within the law at all times.
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