NONCONTROLLED SUBSTANCE DISPOSAL
Contact UW-Madison Environment, Health & Safety (EH&S):
- Non-DEA regulated pharmacy items for disposal need to be listed on the Surplus Chemical Form and submitted to EH&S with the Chemical Waste/Surplus Pickup Request Form
For help, contact EH&S at 265-5000 or email@example.com
Please Note: UW-Madison Chemical Safety officers are not authorized to pick up controlled substances.
CONTROLLED SUBSTANCE DISPOSAL
The Drug Enforcement Administration (DEA) has implemented new regulations for controlled substance disposal. Previously approved disposal methods, such as flushing substances down a drain or mixing with kitty litter or coffee grounds and disposing as solid waste, are no longer permitted.
Controlled substances must be disposed of in a manner that permanently and irreversibly alters the substance's physical or chemical state, rendering the drug unavailable and unusable (nonretrievable). Visit the DEA Office of Diversion Control website for regulatory information and resources.
MAINTENANCE OF SUBSTANCES AWAITING DISPOSAL
DEA Registrants in possession of expired or waste controlled substances that need to be stored for a period of time should keep these substances in their drug lockbox. Any expired substances must be clearly labeled* and physically segregated from in-date and in-use drugs by placing them in a small container or plastic bag. For users with large stocks of expired or waste controlled substances, a second lockbox may be necessary to provide segregation from in-use supplies. Note: Controlled substances awaiting disposal must be included in your inventory as long as they remain in your possession.
*Expired or waste materials must be clearly labeled "Expired – Awaiting Disposal. Do Not Use in Animals." Stickers with this labeling are available from the RARC Pharmacy at no charge: e-mail for assistance. Alternatively, you may print your own stickers; a template can be found below.
EXPIRED MATERIALS AND TERMINAL STUDIES
Some expired medical materials may be used for acute terminal studies in which the health and well-being of the vertebrate animal are not affected and the scientific integrity of the experiment is not jeopardized. These materials must be labeled appropriately (see example below) and stored in a physically separate area from nonexpired materials. Under no circumstance can expired anesthesia, analgesia, euthanasia, or emergency drugs be used in any vertebrate animal.
EXPIRED MATERIALS -- IDENTIFICATION SYSTEM
The use of expired medical materials is prohibited in any survival procedure performed on live vertebrate animals used for research or teaching. In order to abide by legal regulations, these materials must be regularly segregated and/or disposed of to ensure they are not erroneously used in research animals. RARC veterinary staff requires that labs conduct a monthly self-assessment to ensure this is done in a timely manner and developed a colored dot system to help principal investigators with the task.
Labs should apply a colored dot sticker to any item with an expiration date. Each color corresponds with a different year and the month of expiration is written in the center.
To ensure outdated materials are never used in your lab, look through all medical materials on a regular basis and dispose of any items due to expire. You may also want to document your monthly self-assessments.
Contact your veterinary staff to obtain colored stickers and key codes to post in your lab. You can also contact your veterinary staff for special stickers:
1. Expired materials to be used in terminal procedures:
2. Expired materials being stored until proper disposal:
You may also print your own color key code and/or special expired material labels using the following templates:2016 Color Key Code
Expired – Awaiting Disposal Stickers (to be printed on Avery® White 5 ¼” Diskette Labels, 12 per Sheet, #5197)
Expired – Terminal Procedure Stickers (to be printed on Avery® White 5 ¼” Diskette Labels, 12 per Sheet, #5197)Frequently asked questions about the identification system
Q: Where is the best place to put the sticker on the expiring medical material?
A: Place the sticker on the container in a manner that covers as little of the original label as possible. Do not place sticker over: name, contents, uses, directions, warnings, storage instructions, expiration date etc.
Q: If the label states an expiration of JAN 2011 for example, does the item expire at the beginning of January or the end?
A: The item expires at the end of January and should be disposed of on or before the last day of that month.
Q: If the label states an expiration of 12 JUN 2011 for example, what should I write on the sticker?
A: In this case, we suggest that the item be treated as though it is expiring in May 2011. Place a blue sticker on the vial and write the number 5 in the center. At the end of May 2011 assess your situation:
- If you think you will use the item before it expires, make a note (i.e. on your calendar, on the drug vial, on the storage cabinet) to ensure the item is disposed of on or before the expiration date.
- If you don’t think you will use the item before it expires, dispose of it.
Q: What if my stickers are falling off?
A: Before placing stickers, be sure the item is clean and dry. After placing the sticker, press it on firmly with your finger. This problem has occurred mostly on refrigerated or very small items. Try placing a piece of scotch tape over the sticker or use a piece of colored laboratory tape in place of the sticker.
Q: I’m having a hard time reading what is written on the purple stickers. What should I
A: Contact your RARC Veterinary Technician for a special pen for writing on dark surfaces.
A: Place the appropriate sticker on the outside of the storage, indicating the next time an item is due to expire.
Q: What if my materials are in a box containing multiple items?
A: Place the appropriate sticker on the outside of the box, then on the individual container as it’s removed from the box.