Controlled Substances and Precursor Chemical Disposal

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 mandates. 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?

  1. Controlled substances are expired, unwanted, or no longer required.
    • NOTE: Content must be present in containers.
  2. Research project is closed or terminated and controlled substances are still in supply.
  3. CSUA expires and has not been renewed.
  4. 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. Disposition accounts with the reverse distributor will be established by EH&S on behalf of DEA registrants. Once established, a DEA Registrant’s disposition account may be utilized for all future disposals while enrolled in USC’s CSUA program. EH&S will provide all packing materials and shipment services via FedEx. Fees associated with the destruction of expired, unwanted or no longer required controlled substances and FedEx services are paid for by EH&S. Follow the steps outlined below to dispose of controlled substances.

  1. Complete, scan to PDF, and email ehs-cs@usc.edu the following completed forms:
  2. EH&S will create an account for the DEA registrant with the reverse distributor, if one has not been established.
    • NOTE: Request DEA Form 222 for the disposal of all Schedule II drugs. Shipment of form will take 7-10 business days. A copy of the completed form will be sent with the shipment.
  3. DEA registrant will be notified by EH&S when the account with the reverse distributor is established to provide further instruction and to coordinate CS packaging, shipment, and disposal.
    • A Chain of Custody form will be signed when CS is transferred from the DEA registrant to the shipping company.
    • Forward a copy of the Chain of Custody form with required signatures to EH&S at ehs-cs@usc.edu.
  4. EH&S will notify the DEA registrant when the shipment has been successfully delivered to the reverse distributor.

Empty CS Containers

Controlled substance bottles that are void of content are not collected by EH&S. Dispose of empty containers by defacing the container labels and placing containers in glass waste or disposing of them as-is in pharmaceuticals 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). 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.