[Pharmwaste] Disposal of Dispensed Controlled Substances in Hospitals

[Volkman, Jennifer (MPCA)]

I think they use the standard raccoon trap.

For CS, there is specific regulatory protocol and forms for matching what comes in with what is dispensed and then what is returned or disposed through another registrant. And a form for discrepancies. There is no requirement that CS have to be made non-retrievable before disposed or sent through reverse distribution. The registrant that accepts them for disposal or reverse distribution has to demonstrate that they were redistributed (which I don't really think happens) or that they were disposed of in a manner that meets the non-retrievable definition. (Generally met by incineration of the pharms.) DEA says in their comments to the rule that they will not issue approvals or certify that any particular technology meets their definition.

If a hospital wants to render CS non-retrievable to prevent employee diversion, they might want to try to establish a system they believe meets DEA's definition, or just something that tracks them to a secure receptacle that can be handed off for disposal with a registrant. If they dispose of CS on-site, the Plan needs to address non-retrievable. I think this is the niche that the drug buster type systems are trying to fill. They can claim they meet DEA's definition (and they do claim this), but they can't say that DEA approved or certified that their system meets the definition.

Take a look at pages 53547-53550 of the Federal Register...it is somewhat helpful on this issue.


From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Kernen, Brandon
Sent: Friday, October 17, 2014 7:29 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Disposal of Dispensed Controlled Substances in Hospitals

I am looking for examples of detailed standard operating procedures for disposing of  "dispensed" controlled substances in a hospital setting - both residual and bulk volumes.

I have seen a lot of hospital plans for medicine disposal, but just about all lack specific instructions for rendering drugs "non-recoverable."   The plans just say the drugs need to be "non-recoverable" and are absent of explicit guidance on how to achieve this.

Thank you.

Brandon Kernen, PG| NHDES | 603 271 0660

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