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Wasting - Best Practices
Two authorized personnel (one being the registrant or an authorized agent) must perform the waste procedure, including witnessing that waste on the applicable logs and forms.
Unacceptable disposal methods for non-significant recoverable amounts include wasting into animals or into a sharps container, as well as the use of:
- blue pads
- the laboratory sink
- cat litter
If you prefer not to self-waste recoverable controlled substances, contact EHS - Hazardous Materials for assistance.
Reverse Distributor Disposal
Proper disposal of controlled substances is important to reduce the risk of diversion and ensure safety and security within the laboratory or registered storage location.
For expired/unwanted controlled substances
Controlled substances that are expired, unwanted, or damaged (i.e., unused vials, expired dilutions, or broken/damaged containers with recoverable contents) must be transferred to a reverse distributor for destruction. U-M Environment, Health & Safety (EHS) Hazardous Materials Management (HMM) program contracts with Drug and Laboratory Disposal, Inc. (DLD) for reverse distribution.
- Clearly label the substances for disposal (e.g., “to be disposed”, “do not use”, or “expired”).
- Segregate the substances labeled for disposal from remainder of inventory within the secure storage location (i.e., safe, lock box).
- Contact U-M EHS – Hazardous Materials to schedule a controlled substance pickup.
- Complete, scan, and email the DLD Controlled Substance Inventory List to EHS (address shown below), or submit the EHS online Waste and Supply Request form.
- Note: Submission of the Inventory List acts as a request to schedule a controlled substance pickup.
- Sign DLD Chain of Custody Form provide by EHS/DLD upon substance pickup, make a copy of the signed form, and file it with the controlled substance records.
- Note: If disposing of Schedule I or Schedule II substances, you need to complete the DEA Form 222 provided by DLD upon substance pickup. For instructions and document retention information, see the Dispose of Controlled Substances procedure in Reference and Resources.
- Record the disposal on the applicable inventory and usage log, and zero out the remaining balance.
For Waste of "Non-recoverable" contents
Residual amounts of non-recoverable waste may remain in the used (empty) syringes or vials after the administration or use of a controlled substance. If this waste amount cannot be drawn out with a syringe (i.e., is non-recoverable), you may discard the empty controlled substance container in a biohazard sharps container. There is no need to record the disposal of the non-recoverable waste separately on the usage log if the container balance is zeroed out on the usage log upon disposal of that container.
For Waste of "recoverable" contents
Using controlled substances in a laboratory procedure may result in recoverable waste amounts from unused doses in a syringe (e.g., 5 ml was drawn out of a vial or dilution, but only 4 ml was administered) or from container spillage. The use of Rx Destroyer™ is the only U-M approved method of laboratory self-wasting.
If recoverable waste remains from unused volume in a syringe:
A witness must be present to observe the waste and to document the waste (via initials) on the applicable use log.
- Record the waste amount on corresponding use log (e.g., Multiple Dose Log) and on DEA Form 41.
- Waste the contents into the Rx Destroyer™ bottle, then shake the bottle several times to activate the ingredients.
- When the content in the bottle has reached the fill line, use the hardener pellet to solidify the contents.
- Once the contents have solidified, discard the bottle in hazardous waste.
If recoverable waste remains from container spillage (e.g., puddle on the bench top)
- Place cleanup refuse (e.g., paper towels) from a spilled container into a secure hazardous (chemicals) materials or biohazard sharps container.
- Record spillage amount on the usage log and DEA Form 41.