Do you know your Drugs?
By Kate Carpenter, TRS, Triumvirate Environmental Somerville
Do you know if you have Drug Enforcement Agency regulated materials onsite? Although only registered persons or entities are legally able to purchase DEA materials it is too easy to purchase a chemical without knowing it is regulated as long as you have a credit card. This may lead to huge implications as DEA materials require particular disposal in addition to storage requirements.
To legally purchase a DEA regulated chemical, you must register for every class of drug you intend to use through the DEA, thanks to the Controlled Substances Act of 1970. Additionally, you may need to register with the state, depending on what state you live in. If you do purchase a DEA material without realizing it, you will most likely store it on the shelf with other commonly used chemicals. However if you read 21 CFR 1301.72 for fun, you will see that you need to keep all DEA drugs in a locked safe or other secured location. An inventory must be maintained of all compounds, and these records must be kept onsite for at least two years. If you find that you do have contraband onsite, disposal may be the best option.
Proper disposal of DEA regulated material is key because you do not want it to fall into the wrong hands. The best option is to contact your hazardous waste vendor and they can run through the options with you. Having an onsite chemist is particularly helpful in ensuring that no DEA material is improperly disposed. If you have properly managed material that is linked to a registrant then you have a few options, such as reverse distribution, or a watched burn or flush (the flush of course can contradict with local wastewater regulations so it is best to check beforehand). Assuming that you did purchase the DEA material without registering it, then your best option is to have a licensed hazardous waste vendor come to denature and dispose. This option requires written notification into the DEA and a waiting period prior to the denaturing and shipment.
Some of the most common drugs used in research are Chloral Hydrate, Ketamine, and barbiturates. If you have a question whether something is regulated, a quick call to an environmental advisor can tell you for certain. He or she can also give you options on how to proceed so you will not have the Feds chasing you down.