Disposal of Expired Veterinary Drugs

Disposal of Expired Veterinary Drugs

With so much to keep track of in a veterinary practice, drug disposal can sometimes slip past the radar. After all, your top concern is keeping fur kids, horses, exotic pets, etc. healthy and strong, and that often comes hand in hand with pressing demands, hectic days, and unexpected events.

Yet as in any medical practice, there are important guidelines for the proper disposal of medications that are unused, leftover, or expired. Did you know, for example, that according to the Arizona Administrative Rules for Arizona Veterinarians, Prescription-Only Drugs (not including controlled substances) need to be returned to the wholesaler or destroyed within 30 days past expiration?

In other words, all veterinarians must destroy any “non-controlled drugs” within a rather limited timeframe. Plus, ensuring proper record-keeping, especially for any controlled substances, is crucial for DEA compliance. It’s also key to ensure patient safety by preventing old or unsafe products from getting to pet families.

To help ensure the safety of pets, we recommend starting by setting up a regular (weekly or biweekly) auditing process of pharmaceuticals. Check for products that have expired or will expire by the next check and remove them from current stock. Store in a secure location until you can return them to the manufacturer or properly destroy them. (Remember the 30-day time limit.) Then log the substance in your records for compliance.

Proper Drug Disposal

To help ensure your practice is in compliance with this regulation, fortunately, at 123 Compliant Logistics, both controlled (i.e., CIIs, CIII-V) and non-controlled substances can be placed in the same box and shipped together to be destroyed. 

Expired or unused medications not only need to be handled by veterinarians but by pet parents. Yet many of these types of drugs linger in the backs of drawers or pantries as people aren’t sure what to do with them. Flushing them down a toilet or sink can lead to contamination of streams, rivers, groundwater, and drinking supplies, so it’s important to understand how to properly dispose of these types of products once they leave the clinic as well.

When used correctly, prescription and over-the-counter medications can help animals recover and heal. But if misused, they can lead to problems, including:

  • Poisoning of pets—animals finding and eating leftover medications, animal or human, is the leading cause of pet poisonings. After all, many pets are notorious for getting into things they shouldn’t.

  • Water contamination—drugs flushed into waste systems—whether septic tank system or municipal sewage water treatment—can’t be entirely eliminated. As a result, pharmaceuticals of every kind have been found downstream in rivers, streams, and drinking water.

Consumers can take advantage of various prescription drug disposal programs, even for pet pharmaceuticals. These may be run by a local clinic or pharmacy, law-enforcement agency, or municipalities. Consumers can discuss options with their local veterinary office to find one that’s convenient.

Once received by a proper disposal company like 123 Compliant Logistics the medications are appropriately destroyed in an incinerator that’s been specifically approved for drug disposal.

How to Protect Pets and the Environment

  • Encourage customers to administer medications as directed for their pet’s particular issue.

  • Remind them to never flush medications down the drain and provide recommendations on where to take unused products, such as through authorized take-back events, mail-back programs, or collection receptacles. Only accept unused or expired medications from your customers if you are authorized to do so.



Medication Recycling

Pharmaceutical Waste and Disposal

Pharmaceuticals are used for a wide variety of purposes—to help patients recover from illness, treat a disease, manage a chronic condition, etc. Yet even after being prescribed, many drugs go unused. So, understanding how to properly dispose of pharmaceutical waste is vital to any community. It’s also governed by strict, complex, and sometimes confusing regulations.

When mistakes are made and pharmaceutical waste isn’t disposed of properly, there’s a risk of harmful chemicals being released into the environment, which could contaminate water sources (including groundwater) as well as endanger plant, animal, and human life. It can also lead to large fines and negatively impact the good name of an organization.

It’s often tempting to simply wash unused drugs down in a sink or toilet or toss it into the trash, but this can lead to health and environmental concerns in the community. This practice (known as “sewering”) is also federally prohibited, and most states also have stringent regulations banning this practice.

Definition of Pharmaceutical Waste

Any leftover, unused, or expired medication and vaccines that can no longer be used is pharmaceutical waste. As such, it needs to be disposed of properly. Pharmaceutical waste consists of both hazardous and non-hazardous products, depending on the chemical compounds and what risks those may play for humans or the environment.

Pharmaceutical waste also includes contaminated products, such as items needed for the proper handling of pharmaceuticals, including bottles, vials, boxes, tubbing, and PPE like gloves and masks.

Who Regulates Pharmaceutical Waste Disposal?

Pharmaceutical waste can be categorized as either non-hazardous or hazardous waste. If it’s hazardous, it must be disposed of properly through a Hazardous Waste company.

Through the Resource Conservation and Recovery Act (or RCRA, pronounced “rick-rah”), the Environmental Protection Agency (EPA) has been tasked with regulating the disposal of hazardous waste pharmaceuticals. This federal law informs how to classify and properly dispose of various pharmaceuticals. However, states often have additional protections, so it’s important to know state, federal, and local regulations for medical waste disposal.

In addition, the U.S. Department of Transportation (DOT) has other regulations on how to transport pharmaceutical waste. And the U.S. Drug Enforcement Administration is in charge of managing controlled substance waste management. Other government agencies involved in the regulation of the proper disposal of pharmaceutical waste can include the Fish and Wildlife Services (FWS), OSHA, and the Joint Commission.

Depending on the size of the healthcare facility and the volume of pharmaceutical waste it creates as well as the amount of non-acute vs. acute hazardous waste, the regulations also vary.

Categories of Hazardous Pharmaceutical Waste

Three categories of pharmaceutical waste have been defined by the RCRA:

P-list waste is considered acutely hazardous. Pharmaceuticals in this category include a wide range of drugs from warfarin to epinephrine to nicotine and phentermine. This also consists of the containers that have carried P-list medications.

U-list waste is from discarded commercial chemical products and includes sulfuric acid, dimethyl ester, streptozotocin, cyclophosphamide, and many chemotherapy drugs.

A complete list of P-listed and U-listed chemicals can be found here.

Characteristic hazardous waste has one or more of four characteristics that indicate hazardous waste, such as:

  • Ignitability, with the flashpoint of below 60˚ C indicating how ignitable the compound is. This can include, for example, some cough syrups and flammable propellants found in aerosols.
  • Corrosivity, including acid and bases with a pH less than or equal to 2 or greater than or equal to 12.5, which can corrode steel.
  • Reactivity for chemicals that may react with water or heat that then give off toxic gases or detonate.
  • Toxicity,for chemicals that are toxic when ingested or absorbed.

The best way to determine how pharmaceutical waste should be treated is to follow the regulations under RCRA. Yet it’s also important to follow state and local regulations and those of specific facilities as well, which may have even more stringent guidelines.

Another way pharmaceutical waste is classified is by regulated medical waste, solid waste, or hazardous waste. This, however, typically depends on the state or locality.

Regardless of how pharmaceutical waste is classified, it needs to be disposed of properly. Even medications that haven’t been classified as hazardous, such as antidepressants, statins, antibiotics, or hormone replacement therapy can be damaging to the health and environment in the community.

How to Manage Pharmaceutical Waste

Disposing of pharmaceutical waste is a priority for any healthcare company, including pharmacies, clinics, hospitals, and more. While the guidelines from federal, state, and local governments can be confusing and strict, there are simple steps to help streamline the process:

  1. Separate pharmaceutical waste from biohazard waste, placing the biohazard waste in specified red biohazard waste containers.
  2. Segregate any controlled substances, such as opiates and benzodiazepines, as these must be handled in accordance with DEA regulations.
  3. Remove chemotherapy waste, even if there are only trace amounts, including empty vials and bottles, IV tubing, and even gloves, and place them in FDA compliant yellow containers. Bulk waste, such as unused medications, are to be treated as hazardous chemical waste.
  4. Separate hazardous waste, which poses a greater risk to the public, and place them in black containers specified for this purpose.
  5. Gather what’s left in white containers with blue lids to ensure any remaining pharmaceutical waste is also disposed of according to regulations.
  6. Finally, contact your preferred licensed pharmaceutical waste disposal service. Ensure your partner is licensed and up to date on all the regulations for your specific area.

123 Compliant Logistics makes your compliance with pharmaceutical waste as easy as 1-2-3. We help healthcare companies consolidate materials from numerous sources, manage the complexities, and ensure compliant handling and destruction. Services include:

  • Hazardous pharmaceutical waste
  • Large volumes of materials
  • Simple rate box programs for those with smaller quantities
  • Route services for qualified Arizona customers.
  • Direct ship

Simply stated, we take our customers out of the waste management business.

New Mexico May 1 Controlled Substance Inventory

May 1 Annual Inventory

All New Mexico Controlled Substance Registrants are required to conduct an annual inventory of all controlled substances on May 1. This includes doctors, veterinarians and dentists. Now is the time to prepare so your May 1 inventory is a breeze!

Organize your Controlled Substances and Records

  • Keep controlled substances separate from other drugs
  • Group controlled substances by their NDC (National Drug Code)
  • Organize controlled substance logs, purchase invoices, and destruction records

Reduce Inventory Stockpiling

  • Remove expired and short-dated controlled substances
  • Remove controlled substances you know you will not use
  • Don’t order in bulk if you know you won’t use it all before expiration

Send Expired and Unused Controlled Substances for Destruction

  • Only send controlled substances to a DEA registered Reverse Distributor
  • Ensure you receive a DEA Form 222 for all CIIs BEFORE you ship
  • Ensure the destruction company receives the shipment prior to the inventory date **Controlled Substances remain on your inventory while in transit**

123 Compliant Logistics has a budget-friendly, simple rate box destruction.

No contracts required!

Contact us by chat, email or phone. We are here to help!

(602) 612-4140

[email protected]

or Chat on our Website!

Memorial Day

Established to honor the men and women who have lost their lives in service of our country,

Memorial Day is a time to reflect and say thank you for the sacrifices that have enabled the freedoms and opportunities this great nation provides. This year, the reflections of those sacrifices, and the freedoms and opportunities, have never been more important.

The team at 123 Compliance Logistics wishes everyone in this great land of the free and home of the brave a safe, happy and healthy Memorial Day Weekend.

DEA Form 222s may be Emailed or Faxed…Temporarily

DEA Exception for CI-II Order Forms

The Drug Enforcement Administration (DEA) has granted an exception to 21 CFR 1305.13 which requires the original paper DEA Form 222 to be sent your supplier. As you know, the DEA regulations require the supplier of schedule I-II controlled substances receive the physical DEA Form 222 before they are able to ship your order. Due to the public health emergency declared by the Secretary of Health and Human Services (Secretary of HHS), the DEA granted an exception of this requirement to ensure adequate supply of schedule I-II controlled substances during this public health emergency.

The Details

The exception allows all DEA Registrants who order schedule I-II controlled substances with paper order forms to fax or scan/email a DEA Form 222 to their supplier. When the supplier receives the faxed or emailed DEA Form 222, they shall treat it as the original and complete their respective fields as they would on the original. This exception will remain in place through the duration of the public health emergency.

Once the Secretary of HHS has ended the state of emergency, the original DEA Form 222 must be sent to the supplier. The supplier is required to attach the original with the faxed or emailed copy and maintain with their usual CI-II records. 123 Compliant Logistics also recommends keeping a copy of the DEA Exception Letter with your faxed or emailed DEA Form 222. A copy of the official DEA Exception Letter can be found here.

Preventing Errors

Because of the overwhelming fast pace essential workers have had to maintain, it’s important to regularly remove expired or damaged pharmaceuticals from stock shelves to prevent unnecessary errors.

Accelerating the Process

This DEA exception allows 123 Compliant Logistics to quickly issue a DEA Form 222 and authorize shipment of CII, CIII-V and non-controlled pharmaceuticals – all in one email or fax. We have easy-to-use, no contract destruction options for large and small quantities.

Contact us by chat, email or phone. We are here to help!

Arizona May 1 Inventory – Emergency Statutes

AZ Emergency Statutes

Every year on May 1st, Arizona pharmacies are required to complete an inventory of all controlled substances on hand. The Arizona State Board of Pharmacy (ASBP) has offered an alternate annual inventory day of September 1st to help alleviate the additional strain of conducting an inventory. Arizona pharmacies may also submit a request to their ASBP Compliance Officer for an alternate day of their choosing. ASBP has published this and other emergency statutes and rules here and will continue to update this document regularly.

Why Annual Inventory is Important

With the insurmountable stress the COVID-19 pandemic has put on the healthcare industry, ensuring continued operation of pharmacies is more important than ever. An annual inventory is essential during this demanding time. It’s mandate has been put in place to prevent diversion and ensure adequate, uninterrupted supply of pharmaceuticals to the communities we serve.

We Can Help

Destruction of your expired, short-dated, and damaged pharmaceuticals before your annual inventory will keep your work load to a minimum. 123 Compliant Logistics is Arizona’s only DEA registered Reverse Distributor. We have programs for large and small quantities. We also offer pick-up service for qualified customers.

Contact us by Phone, Email or Chat. We are here to help!

May 1st is Coming Fast for Arizona

It’s that time again to conduct State Board of Pharmacy Required Annual Inventory here in Arizona. We’re ready to take all your excess material so you don’t have it on May 1st. As Arizona’s only DEA Reverse Distributor, we offer pickup service

and are eager to help you get your inventory in great shape! If you need to change your annual inventory date to September contact your ASBP Compliance Officer.

Reach out today (602) 612.4140 or chat with us online

Is Coronavirus waste special?

Q: Should medical waste or general waste from healthcare facilities treating PUIs and patients with confirmed COVID-19 be handled any differently or need any additional disinfection?

A: Medical waste (trash) coming from healthcare facilities treating COVID-2019 patients is no different than waste coming from facilities without COVID-19 patients. CDC’s guidance states that management of laundry, food service utensils, and medical waste should be performed in accordance with routine procedures. There is no evidence to suggest that facility waste needs any additional disinfection.

More guidance about environmental infection control is available in section 7 of CDC’s Interim Infection Prevention and Control Recommendations for Patients with Confirmed COVID-19 or Persons Under Investigation for COVID-19 in Healthcare Settings.

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