Disposal of expired, damaged, or otherwise unusable controlled substances (CS) follows concise procedural steps and is strictly regulated by the DEA. EH&S contracts with a licensed, reverse distributor to properly dispose of expired controlled substances in accordance with DEA regulations. This section describes requirements for the disposal of controlled substances and details items considered to be to exemptions, and their disposal processes. Please refer to the Waste Disposal of Controlled Substances Guide Sheet for a summary of the information below.
- When Do I Dispose of Controlled Substances?
- How Do I Dispose of Expired/Unwanted Controlled Substances?
- Empty CS Containers
- Broken or Damaged Containers
- Precursor Chemicals
- Orphaned Controlled Substances
When do I dispose of controlled substances?
CS is disposed of when:
- Controlled substances are expired, unwanted, or no longer required.
- NOTE: Content must be present in containers.
- Research project is closed or terminated and controlled substances are still in supply.
- DEA registration expires and has not been renewed.
- DEA Registrant terminates employment at USC.
How do I dispose of expired/unwanted controlled substances?
USC utilizes a reverse distributor to dispose of controlled substances. User accounts with the reverse distributor will be established by EH&S on behalf of DEA registrants. Biannual controlled substance disposal sessions will be hosted in the Spring and Fall. The reverse distributor, with administrative support from the EH&S controlled substance team and HazMat, will be on-site to assist in the disposal of expired or unwanted controlled substances. Fees associated with the destruction of these materials are paid for by EH&S. Follow the steps outlined below to initiate the disposal of controlled substances.
- Complete, scan to PDF, and email ehs-cs@usc.edu the following forms:
- Controlled Substance Waste Disposal Request Form
- Controlled Substance Use and Disposal Log and/or Controlled Substance Dilution Usage and Disposal Log for each CS to be disposed of.
- DEA registrant will be notified by EH&S when the controlled substance disposal session has been scheduled and a specialist will provide further instruction.
- Please confirm that either you or an Authorized User is available to meet with this team of professionals at the date, time and central location described by sending a response email to ehs-cs@usc.edu.
Empty CS Containers
Controlled substance containers that are void of content are not collected by EH&S. A controlled substance container is considered empty when there is no movable liquid or powder left in the container and the CS Usage and Disposal Logs show 100% usage. Dispose of empty containers by defacing the container labels and placing containers in non-hazardous glass waste.
Broken or Damaged Containers
Inadvertently broken or damaged controlled substance containers and resulting spill cleanup materials must be disposed of as hazardous chemical waste at Waste Pick-up Request. Ensure the Usage and Disposal Logs have been updated to reflect the loss of material and document the incident by completing the Controlled Substance Incident Report. Email completed report to CS Program Manager at ehs-cs@usc.edu. EH&S will work with labs to ensure they submit all necessary reports to the DEA (Form 106), if necessary. This must be completed within 24 hours of the reported loss.
Precursor Chemicals
Unused or expired precursor chemicals must be disposed of as hazardous chemical waste. Requests for waste disposal can be placed at Waste Pick-up Request. Refer to the Chemical Waste Disposal Guide Sheet for more information.
Orphaned Controlled Substances
Contact the CS Program Manager at ehs-cs@usc.edu for additional information.