THE ORCBS > Chemical Safety > Programs & Guidelines > Controlled Substances >

DISPOSAL

When a registrant has controlled substances that are expired or unwanted the one of the following protocols must be followed.

A. Use to completion/manufacturer return

The preferred method of disposal of Controlled Substances is complete use of the substance such that there is none left to dispose. If there is excess material at the completion of research, contact the manufacturer to return the remainder.

B. Disposal through ORCBS

Destruction through ORCBS may take place only one time per calendar year per registrant.

Required Information

To dispose of Controlled Substances, the registrant must contact the Office of Radiation, Chemical and Biological Safety (ORCBS) and provide the following information.

1. Name of contact person and phone number where they can be reached 
2. Name of person under whom substances are registered with the DEA
3. DEA registration number
4. Location of Controlled Substances
5. Inventory of drugs to be destroyed including:
   1. Name of drug with strength
   2. Quantity of drug
   3. Technical name of controlled substance

DEA Notification

Upon receipt of information, the ORCBS will draft a letter notifying the DEA. The letter will be sent to the DEA by the ORCBS no less than two weeks prior to the scheduled destruction event. Information included in the letter will be:

1. Name, address of the facility wishing to dispose of the controlled substance
2. Name, address and DEA registration number
3. Exact place, time, and date destruction is to take place
4. Name and positions of persons who will witness the destruction
5. Method of destruction
6. DEA Form 41, listing:
   1. Inventory of drugs to be destroyed
   2. Name of drug with strength
   3. Quantity of drug
   4. Technical name of controlled substance
   5. Signature of DEA notification

The registrant or registrant's designee will sign the letter of notification. In the event that the registrant is unavailable to sign or designate someone to sign, a faculty member from the registrant's department will authorize the destruction. This may be necessary due to the registrant's death, retirement, extended absence, or because they have left the University for any other reason and will not return. In addition, a department faculty member may sign the letter if the controlled substances pre-date the existence of the DEA or if the substances were purchased before being added to the list of controlled substances.

Witnessing the destruction

Destruction will only take place after receiving written authorization from the DEA.

One person must represent the registrant and be a permanent employee of Michigan State University or its satellite facilities. This person must be from the department under whom the registrant employed. One person must be a permanent employee from the ORCBS. At a minimum, two persons will be present to witness the destruction and sign a statement of witness.

Method of destruction

The method of destruction will be to rinse the controlled substances down a drain connected to the sanitary sewer. The bottles or vials in which the controlled substances were stored will be triple rinsed with the remaining container discarded as normal refuse. For Phenobarbital and chloral hydrate only (listed Michigan hazardous wastes), the materials will be commingled with other hazardous wastes. This is an effective method of destruction since material added to hazardous waste cannot be reclaimed.

Certificate of destruction (DEA Form 41)

A record of destruction will be made documenting the event. The certification of destruction will list the substances rendered unreclaimable and will be signed by the persons who witnessed the destruction.

Controlled Substance Program