DEA Prescription Takeback Day: Time to Think About Safe Controlled Substance Disposal

October 28 is National Prescription Drug Takeback Day.

This twice-annual event, sponsored by the Drug Enforcement Administration (DEA), assists organizations of all sizes, as well as individuals, to safely eliminate controlled substances. And for the past 10 years, it has underscored the dangers of pharmaceuticals that come loose in the reverse distribution chain.

Eliminating unwanted, expired, mistakenly delivered, or unneeded controlled substances is a challenge for organizations of all types. As a manager or administrator in an affected organization, it’s key to understand how controlled substance disposal rules affect you. So, the event provides managers a great opportunity to think about the best, safest, and most compliant ways of drug removal.

Perhaps you are participating this year. Or, you may be interested in launching a complete controlled substance disposal program. Either way, it’s key to observe the DEA reverse distribution rules—these are very strict and can require complex protocols. To help you maintain compliance for the occasion, the DEA lists approved diversion destinations on a searchable website.

DEA Rules for Controlled Substances

Controlled substances are necessary to many organizations, including:

• Treatment centers
• Hospitals
• Correctional facilities
• Pharmaceutical compounders
• Medical offices
• Higher education research labs
• Municipal drug collection sites

The volumes of unwanted controlled substance volumes are enormous. Last year, the April National Prescription Drug Takeback Day resulted in the diversion of 700,000 pounds of substances (360 tons). This past April's event saw the removal of 664,000 pounds of pharmaceuticals (332 tons). Overall, the program has taken in 17.3 million pounds of drugs (8,650 tons).

Dangers of Loose Controlled Substances

Bad things can happen when drugs fall out of the chain of accountability. They can find their way into the wrong hands—and ultimately, feed addiction and result in overdose, or even death. As such, shrinkage in any part of the reverse distribution chain means potential:

• Noncompliance with state and federal laws
• Fines and other penalties
• Legal consequences—including criminal prosecution
• Negative brand damage

Fortunately, organizations don’t have to operate blindly. The DEA and Environmental Protection Agency (EPA) provide a broad framework for legal disposal. The agencies offer guidelines that cover the disposal of:

• Vaping and cannabis concentrates
• Medicines
• Medical sharps and needles
• Pharmaceutical waste in healthcare facilities

Seeking a DEA-Approved Disposal Partner

Clearly, there are lot of controlled substances in the United States. There is a serious need for accountable, safe management of drugs, from point of origin to destruction (or return to the manufacturer). Reverse pharmaceutical distribution is complex, however, and requires organizations to invest significant focus and effort to avoid noncompliance.

Fortunately, there are partners available to assist. The DEA has an approved list of vendors that meet its requirements for drug management and disposal. (However, the agency never makes recommendations for specific reverse distributors.) A full DEA-EPA compliant partner will offer the gamut of drug management and disposal services.

To determine if a vendor will suffice, you should analyze if its services include the handling of:

• Controlled substances, per schedules I-V (CI-CV)
• Mixed DEA and Resource Conservation and Recovery Act (RCRA) regulated waste
• Drum quantity DEA controlled substances
• Out-of-date, off-spec, and returned products
• Illicit drugs from law enforcement

The partner should also offer:

• Consultation on what services you need
• Controlled substances verification, collection, and secure packaging, by licensed professionals
• Removal and safe transportation to destination
• Final witnessed disposal or destruction

If you prefer to just ship controlled substance waste, the partner should also provide appropriate containers and other materials. This can be sent to the client facility so that internal team members can then pack and ship the waste securely to a designated disposal location.

Consider Triumvirate Environmental

At Triumvirate Environmental, we offer 30 years-plus of expertise managing pharmaceutical waste disposal. We are a proven and trusted partner: You can read about our success supporting reverse pharmaceutical services provider Rx Return Services.

Talk to us today to discuss your controlled substances management needs.