The University of Iowa

Orphaned Controlled Substances Disposal Procedure


  • 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.


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.


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