Controlled Substance Disposal Options on the IUPUI Campus

The Indianapolis U.S. Drug Enforcement Agency Office (DEA) recently approved the following disposal options for expired controlled substances on the IUPUI campus: 

1. In-Lab Disposal Option:

Campus Registrants are allowed to blend waste controlled substances into an appropriate volume of a suitable flammable solvent within the confines of the lab under the following conditions: 

• The controlled substance is soluble or miscible in the solvent selected (e.g. water-soluble materials are blended into acetone, ethanol, methanol, or other similar solvent depending on solubility). Contact IUPUI Environmental Health and Safety (EHS) for additional guidance on selecting an appropriate solvent for the controlled substance involved.  
• The disposal is recorded and witnessed by laboratory staff on a DEA Form 41.
• The waste solvent is referred to EHS by means of a one-line request form available at: https://apps.ehs.iupui.edu/waste-manifest.asp within three (3) working days of blending.
• The signed Form 41 is retained on-site by the registrant for inspection by request by regulatory authorities.
• EHS is responsible for ensuring that the blended controlled substance/solvent is collected in a timely manner, consolidated with other waste solvents and incinerated at a fully-permitted hazardous waste treatment/disposal facility and maintaining all associated paperwork.

2. Stryker Cactus Smart Sink System:

Campus Registrants may schedule a time with EHS to dispose of waste controlled substances by means of a Cactus Smart Sink System under the following conditions:

• (Additional on the Cactus Smart Sink System can be found at: https://www.stryker.com/content/dam/stryker/surgical/products/cactus/resources/Cactus%20SmartSink%20FAQ.pdf).
• The disposal is scheduled in advance with EHS by calling 4-6795, 4-4351 or e-mailing EHS@iupui.edu.
• The Registrant is responsible for transporting the material to the 4^th floor of the Lockefield Village Building at an agreed-upon date and time. (EHS will not take possession, transport or store material intended for disposal).
• The disposal is recorded on a DEA Form 41 and the disposal witnessed by the laboratory representative transporting the material and an EHS representative.
• The signed Form 41 is retained on-site by the registrant for inspection by request by regulatory authorities.
• EHS is responsible for ensuring that the disposal cartridges in the Cactus Smart Sink unit are changed on a frequency recommended by the manufacturer and incinerated at a fully-permitted hazardous waste treatment/disposal facility and maintaining all associated paperwork.

3. On-Campus Incineration

Registrants may schedule a time through EHS to have controlled substances (with the exception of chloral hydrate) incinerated at an incinerator owned and operated by the University under the following conditions: 

• The incinerator is typically operated once per month from mid to late April into late October or mid-November.
• Registrants complete a Form 41 for the inventory of controlled substances to be
• The completed Form 41 is submitted electronically to: https://www.iu.edu/~ehs/sites/dashboard/?module=9.
• Upon review of the Form 41, the material will be scheduled for incineration at the Campus Services 4 Building, 1830 W. 16^th, Indianapolis, IN.
• The Registrant is responsible for transporting the material to the Campus Services 4 Building at an agreed-upon date and time. (EHS and/or Radiation Safety will not take possession, transport or store material intended for disposal).  
• Following incineration, the Registrant and an EHS/Radiation Safety representative and/or appropriate law enforcement officer (an Indiana University Police Officer or Officer of another recognized police jurisdiction) will sign the Form 41 as a witness to the destruction.
• The signed Form 41 is retained on-site by the registrant for inspection by request by regulatory authorities.

4. Reverse Distributor:

Campus Registrants may, for a fee, utilize the services of an appropriate reverse distributor under contract with the University to provide disposal services directly to the registrant in accordance with DEA rules and regulations.  Contact EHS at 4-4351, 4-6795 for additional information.  

The disposal of controlled substances at IUPUI is strictly the responsibility of the Registrant.  EHS cannot legally take possession of controlled substances.   Our office can only assist in their disposal.

Disposal options #1 and #2 are unquestionably the most convenient options and require the least amount of staff time.   Additionally, the campus incinerator only operates from mid to late spring into the fall (typically mid to late April to early to mid-November). 

For disposal option 1 and 2: per DEA guidance, the container is legally “empty” when the last full dose has been extracted or poured from the vial.  Once empty, DEA requires the label be removed or defaced with a permanent marker.  The empty vial is to then be discarded in a sharps container or glass waste box. 

The Indiana Professional Licensing Agency and the United Stated Drug Enforcement Administration (DEA) have determined that expired controlled substances must be discarded within 30-days following the date of expiration.  Failure to dispose of expired medications within this time limit may result in the issuance of a warning or citation during an on-site inspection.

Contact EHS at 4-4351 or 4-6795 if uncertain which disposal option is appropriate for the controlled substance involved.