[Pharmwaste] Pharmacies in 3 States Can't Take Back Controlled

Ed Gottlieb EGottlieb at cityofithaca.org
Thu Feb 5 11:08:11 EST 2015

I didn't remember that during the Office of National Drug Control Policy (ONDCP) webinar<http://www.whitehouse.gov/blog/2014/11/17/watch-webinar-dea-s-final-rule-disposal-control-substances> we were told that state board of pharmacy rules did not allow controlled substances to be taken back in Georgia, Oklahoma and Hawaii.

I wrote to the National Association of Boards of Pharmacy to get this and related information.  My email and their reply are below.


Dear Mr. Gottlieb,

Thank you for contacting the National Association of Boards of Pharmacy® (NABP®). NABP is the independent, international, and impartial association that assists its member boards and jurisdictions for the purpose of protecting the public health. NABP does not have any regulatory or interpretive authority over its member boards.

Since the DEA Final Rule on Disposal of Controlled Substances  is a new federal regulation, unfortunately; the majority of the states that have not previously prohibited community pharmacies from taking back controlled substances are still silent on the issue and are in the process of reviewing their existing statutes and regulations. Until new laws/regulations are enacted or it is addressed through policy interpretation, we do not have new information to share.

NABP is following this issue and we are staying vigilant on the matter. We will inform our member boards and the public through our website as more information becomes available. In the meantime, according to the Office of National Drug Control Policy (ONDCP) webinar<http://www.whitehouse.gov/blog/2014/11/17/watch-webinar-dea-s-final-rule-disposal-control-substances>, the following states may not permit pharmacies to take back controlled substances: Georgia, Oklahoma and Hawaii.

Professional Affairs


It is my understanding that the existing rules (and recommendations?) of many state boards of pharmacy are in conflict with the new DEA rule allowing pharmacies to take back controlled substances.

If my understanding is correct, do you know which states need to make changes to be in-line with this DEA rule? Can you please provide me with details?

Has, or will, your organization be encouraging members to make the changes necessary to allow pharmacies to participate in controlled take back?  If you have, may I please see a copy of what you did?

If you haven't, please consider doing so.  Though it is possible that not many pharmacies will participate in this voluntary, unfunded opportunity, it would be unfortunate if those that wanted to provide this important public service were unable to do so because some state boards of pharmacy's failed to act.

Thanks for your assistance and consideration.


Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY  14850
(607) 273-8381
fax: (607) 273-8433

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