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Dispose of Controlled Substances

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.

  1. Clearly label the substances for disposal (e.g., “to be disposed”, “do not use”, or “expired”). 
  2. Segregate the substances labeled for disposal from remainder of inventory within the secure storage location (i.e., safe, lock box).
  3. Contact U-M EHS – Hazardous Materials to schedule a controlled substance pickup.
  4. 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.
  5. 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.
  6. Record the disposal on the applicable inventory and usage log, and zero out the remaining balance.

Laboratory Self-Disposal

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.

  1. Record the waste amount on corresponding use log (e.g., Multiple Dose Log) and on DEA Form 41.
  2. Waste the contents into the Rx Destroyer™ bottle, then shake the bottle several times to activate the ingredients.
  3. When the content in the bottle has reached the fill line, use the hardener pellet to solidify the contents.
  4. 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)

  1. Place cleanup refuse (e.g., paper towels) from a spilled container into a secure hazardous (chemicals) materials or biohazard sharps container.
  2. Record spillage amount on the usage log and DEA Form 41

References and Resources

  • Reverse Distributor Inventory List

    Inventory template to use when disposing of controlled substances through EHS - Hazardous Materials using U-M's contracted reverse distributor (Drug, & Laboratory, Inc. or DLD.)  Also known as the DLD Controlled Substance Inventory List.

  • Reverse Distributor Inventory Instructions

    Instructions to complete the Reverse Distributor Inventory List, also known as the DLD Controlled Substance Inventory List.  

  • Controlled Substance Diluted Solution Log

    Log (Word) used to document the usage details for a controlled substance that has been withdrawn from its original container and mixed with a solution to dilute the concentration.

  • Controlled Substance Multiple Dose Log

    Log (Word) to document the details for each use of any controlled substance amount removed from its original container.

Controlled Substance Procedures


U-M EHS - Hazardous Materials

(734) 763-4568

For more information about RX Destroyer™ bottles, see