The University of Iowa
Environmental Health and Safety

Controlled Substances Disposal Procedure

Disposal

  • The laboratory notifies Environmental Health & Safety (EHS) that it has a controlled substance that needs disposal.
  • An EHS representative will visit the lab prior to disposal.
  • On the agreed upon date of disposal, EHS will bring a Controlled Substance Disposal Kit and provide directions on how to conduct the disposal.
  • Disposal will be conducted by the Registrant or their duly appointed authorized employee and witnessed by an EHS employee.
  • Disposal consists of blending an aqueous solution of the controlled substance within a container of kitty litter.
  • EHS will take possession of and dispose of the container of controlled substance/kitty litter blend.

Recordkeeping

Registrant/Authorized Employee makes a record of disposal in his/her usage log that includes:

  • Date of destruction
  • Method of destruction
  • Address of the location at which it was destroyed

Name and quantity of substance

  • Name(s) and signature(s) of the registrant’s authorized employee(s) and EHS staff who witnessed the destruction

The same information must also be recorded on DEA Form 41. A copy of the DEA Form 41 must be given to EHS. Each registrant must also keep a copy of the completed DEA Form 41 as required by 21CFR1304.22.

Reporting

The Registrant/Authorized Employee must submit a copy of the completed DEA Form 41 within 10 days of destruction of the compound.  Submit the completed and signed DEA Form 41 to the Special Agent in Charge at:

U.S. Department of Justice
Drug Enforcement Administration
Des Moines Resident Office
Federal Building, Room 937
210 Walnut Street
Des Moines, IA 50309

Per DEA’s requirements, the Registrant must also notify EHS that reporting to DEA has been accomplished by providing a copy of the report to the EHS Environmental Safety Compliance Coordinator (ESCS). If notification is not received, the EHS-ESCS will follow-up with the Registrant to ensure the required report is made.

Abandoned/Orphaned Drugs Disposal Procedure

Disposal

  • Laboratory/Department notifies Environmental Health & Safety (EHS) that they have a controlled substance needing disposal.
  • A departmental representative is identified to serve as a witness to destruction of the controlled substance.
  • An EHS representative will visit the lab prior to disposal.
  • EHS will notify DEA of the discovery of an orphaned/abandoned controlled substance.
  • Disposal will be conducted by an EHS employee and witnessed by a departmental representative.
  • Disposal consists of blending an aqueous solution of the controlled substance within a container of kitty litter.
  • EHS will take possession of and dispose of the container of controlled substance/kitty litter blend.

Recordkeeping

EHS will prepare a record of disposal that includes:

  • Date of destruction
  • Method of destruction
  • Address of the location at which it was destroyed
  • Name and quantity of substance
  • Names and signature of the departmental representative and EHS staff that witnessed the destruction

The same information will be recorded on DEA Form 41. EHS will keep a copy of the completed DEA Form 41, as required by 21CFR1304.22.

Reporting

A quarterly report of the destruction of abandoned /orphaned controlled substances that are performed by EHS staff will be submitted by EHS to DEA.