Is It Wasting or Disposal?

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When handling controlled substances, it is essential that everything is done within the bounds set by the many regulations. However, one area that can become confusing in practice is what to do with drug that is no longer needed/usable.

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Definitions

For controlled substances, answering this question requires differentiating between Wasting and Disposal because these have different requirements for documentation and what to do with the drug.

• Wasting occurs when a drug has been logged out for a specific patient but is not needed. This may occur when a patient dies before the full volume can be administered, or when a drug is titrated to effect, and the full volume isn't needed to reach the desired effect.
• Disposal is when a drug is no longer going to be used, but wasn't logged out of the inventory for a specific patient. A common example of this is expired drug, but this also occurs when a vial breaks or other non-recoverable drug spillage.

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Recordkeeping

For drug waste, this is documented on a waste log, and disposed of internally. The waste log is created internally and must include the following information.

• Name strength and dosage form of the drug
• Quantity being wasted
• Patient ID for which the drug was originally removed
• Signature of both the person wasting the drug and a witness

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For drug disposal, this is documented on a DEA Form 41.

Both forms of documentation must be kept for a minimum of 2 years according to Federal law. However, this retention period may be longer based on state law.

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Destruction

For actually disposing of these drugs, there may be differences depending on if it's wasting or disposal.

• When wasting drug, the drug is always destroyed in-house. The disposal method used must render the drug non-retrievable. Chemical digestion systems such as RxDestroyer, Cactus and others can meet this requirement. However, kitty litter, sawdust, putting into a sharps container, and squirting down the drain do NOT meet this requirement.
• For disposal, state laws come into play. Federal law allows disposing of drug in-house in the same way wasted drug is disposed. However, state laws may differ with some requiring use of a reverse distributor unless specific approval has been granted.

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Accepting Drugs from Clients

For clients that have controlled drugs that are no longer needed, they should be directed to find a DEA drug disposal location. Veterinarians must not accept controlled drugs from clients for disposal unless they are registered as collectors (which most are not).

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Conclusion

It's important to ensure that controlled substances are maintained securely and all recordkeeping requirements followed throughout the drug's lifecycle. Therefore, practices should ensure the staff handling controlled substances are clear on what is wasting versus disposal and the specific steps that must be taken in each situation.

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👉 Need help strengthening your controlled-substance protocols? click here to get started.

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