Can anyone point me in the right direction? I need to generate a SOP discribing how to dispose of waste contining controlled substances. DEA at least, right?

Can anyone point me in the right direction? I need to generate a SOP discribing how to dispose of waste contining controlled substances. DEA at least, right?

What type of controlled substances are you refering to?

You state the acronym "DEA" - does this refer to Drug Enforcement Agency, or another entity?

Most likely it's a hazardous waste to be managed under 40CFR. The DEA has to comply with 40CFR when disposing of materials. In California you'll follow CA Regs...go to this site for help http://www.calepa.ca.gov/

or maybe here... http://www.calepa.ca.gov/Search/default.aspx?q=drug+disposal&cx=016697183436188592925%3Aufud9xiklcq&cof=FORID%3A11#1202

(I've been trained by the DEA and have been involved of disposal in the past)

HI Carol,

Yes, let me clarify: the drug is fentanyl (narcotic derivative). DEA is the Drug Enforcement Agency. I know that we will have to satisfy their regulatory requirements. This would be with the solid, high percentage, waste.

I think I may have to address EPA (Environmental Protection Agency) regulations and California State (RCRA) regulations as well. This would be when the controlled substance is in solution. I need to find the threashhold quantity at which the regulations go into affect. Apparently small amount can just be tossed into the garbage.

Any suggestions?

You better be sure of the "presumtive" level or "diminimous" before "tossing"

I wouldn't dispose of even small amount in the trash. Fentanyl Citrate has a minimum lethal dosage of 250 micrograms, and Fentanyl isn't much better. VERY potent stuff.

There are reverse distributors out there that will manage the disposal for you (for a price, of course). They take care of all of the state and federal paperwork for you. In essence, they purchase the material from you, then take on the liability.

If it is a very small amount on a one time basis, your local DEA office may be able to handle it for you.

Thanks Dan! Yes we have a "returns company" that handles reconcilliation, packaging, and transport to the disposal facility. When I mentioned that small amounts can be tossed, I was quoting a guidance that I read. However, it did state that there strict regulations regarding the threshhold. I do want to verify, but I do not think we can toss any of our waste.

Wow! Your response is great. I love this forum!

Most likely it's a hazardous waste to be managed under 40CFR. The DEA has to comply with 40CFR when disposing of materials. In California you'll follow CA Regs...go to this site for help http://www.calepa.ca.gov/

or maybe here... http://www.calepa.ca.gov/Search/defa...ORID%3A11#1202

(I've been trained by the DEA and have been involved of disposal in the past)

Randy,

Thank you very much. I am happily perusing the 40CFR, Part 261. I did not knoww that the DEA also complies but it makes sense!

Roger

Trust me, everyone complies with 40CFR or they face prosecution....even Fed agencies.

You basically have a hazardous waste, you're in California....you need to meet California Regs.