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Disposal of Controlled Drugs Pharmaceuticals at Clemson University
Currently the only method of disposal of off specification and out of date Controlled Drugs that are regulated by DEA is through Reverse Distribution. Licensee's must file DEA form 41 to their local DEA office and also request a copy of the Companies currently approved by DEA to receive these controlled drugs. Then the licensee will follow the proper procedures provided by one of those companies in order to complete the transfer. The licensee must package and mail the materials to the reverse distribution company and keep all related records. EH&S cannot provide this service or be in possession of any controlled substances. Any controlled substances that inadvertently come into EH&S possession will be returned to the licensee immediately. Please take all precautions to not lose control of any Controlled Drug in this manner as this constitutes a serious violation of your License. DEA Controlled Drugs include all those containers labeled with a large "C" and respective Roman numerals as to their classification by DEA.
Sanitary Sewer Disposal of controlled substances and Pharmaceuticals is forbidden at Clemson University main campus. Our treatment plant has no industrial discharge permit for such materials. And many of them can be harmful to the environment.
EH&S can and will provide services for the other Pharmaceuticals that are NOT Controlled Drugs under DEA. These can be declared as Hazardous Wastes and we will pick them up and properly destroy them.
If you are unsure of whether your Pharmaceuticals are Controlled Substances (label is missing, compound made in the laboratory or very old stock before the common use of the large "C") you can consult lists from the Department of Justice, Drug Enforcement Division:
http://www.deadiversion.usdoj.gov/schedules/index.html
There you will find two links: one to the "List of Controlled Substances" (I, II, III, IV and V), and one to "Exempted Lists". If your Pharmaceutical is NOT on the List of Controlled Substances, declare it as a chemical waste in the normal fashion.
If you find your Pharmaceutical's name on the list of controlled substances, consult the "Exempted Lists." If you material is on the Controlled Substance list, but not the Exempted list, you have a controlled substance and EHS cannot dispose of it; contact the local DEA for disposal instructions (note however that this material may not be disposed of down the drain, as our POTW permit does not allow this). If it is on both lists, you have an exempted material.
If you do find that you have an Exempt item, we ask that you expressly declare this type of waste separately from any other wastes as an "Exempt Controlled Substance" on the disposal declaration form, and the Licensee will have to co-witness the destruction and documentation of destruction when we come to pick it up. The Licensee will have to place the declared material into some destructive media we will provide, and sign off on the destruction. This waste will then be further and permanently destroyed by incineration through the EH&S vendor.
