Expired Controlled Medicaitons

[Guest guest]

How is everyone disposing of their expired controlled medications?

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[Guest guest]

We use a company called Universal Solutions, Conyers, Georgia.

Phone#

Fax#

You call them for an authorization number and they send you an application for

reverse Form 222.

They have a lengthy and well documented process. You fill out an application

for each individual type of medication. You send the application to the DEA for

the reverse 222. Everything is signed by the holder of your controlled substance

certificate. When we started our very first

return of expired controlled medications, we started in Dec. 2004 and finally

shipped around

April 2005.

I am curious to see what other companies are out there.

Bert Lagarde

Marfa City/County EMS

Fax

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[Guest guest]

Hello,

Last year, McKinney Fire/EMS had a controlled substances violation

which lead to a wonderful relationship between us and the DEA/DSHS.

In all sincerity, it's been a horrible way to form a good

relationship with regulatory agencies.

There are several different issues you run into with proper

destruction of controlled substances. Schedule 2, (Morphine,

Fentanyl) vary differently from Schedule IV (Versed, Ativan, etc..).

The process of using a " Reverse Distributor " is the only legal way

to go about destruction. If you attempt to destruct the expired

controlled substances yourself you will violate either DEA or EPA

Code of Federal Regulations. You can find DEA's regulations under

the 21st CFR, Section 1307.21. Here is a hyperlink to visit the code

on the internet -

http://www.deadiversion.usdoj.gov/21cfr/cfr/1307/1307_21.htm

The humor of this code, is the DEA has a very loose interpretation

of the information included. Most of the code applies to Schedule 2

drugs, however your Sch. IV may be involved as well. You'll notice

that it's required to notify the local agent in charge on a DEA 41

of your preparation and intent to destroy controlled substances with

two weeks notice. The form of destruction used may be a " reverse

distributor " any other form of destruction, (i.e. – sink waste,

incineration, trash canning) is a violation of EPA code, plus if you

did use one of those methods, you would require a police officer to

witness.

LONG long story and not much fun. There is a local reverse

distributor that I've found, and they are very willing to assist

EMS. http://www.totalreturns.net/

Total Returns is in Marietta, Oklahoma, just across the river from

Gainesville, Texas. They are an excellent resource and their cost

is almost nothing. In fact, if you give them your other expired

drugs, often they can return them to the manufacturer for a refund!

If you would like more information, I am more than willing to

assist. During the Texas EMS Conference last fall and again this

fall, I teach a class called " Controlling Controlled Substances "

where I address many of these issues we face as administrators.

Please email or call, I'll have my information posted below:

McKinney Fire / EMS

Captain - EMS Coordinator

McKinney, Texas

O:

C:

F:

rgriffin@...

[Guest guest]

,

Thanks for your contribution, I'm sure it will assist others in not making

errors in operations as well as offering a low cost alternative to destruction

of our expired meds.

Hard lessons learned are usually lessons learned well. I'll certainly use the

knowledge your Department learned as an easy lesson for us!

Britton

Re: Expired Controlled Medicaitons

Hello,

Last year, McKinney Fire/EMS had a controlled substances violation

which lead to a wonderful relationship between us and the DEA/DSHS.

In all sincerity, it's been a horrible way to form a good

relationship with regulatory agencies.

There are several different issues you run into with proper

destruction of controlled substances. Schedule 2, (Morphine,

Fentanyl) vary differently from Schedule IV (Versed, Ativan, etc..).

The process of using a " Reverse Distributor " is the only legal way

to go about destruction. If you attempt to destruct the expired

controlled substances yourself you will violate either DEA or EPA

Code of Federal Regulations. You can find DEA's regulations under

the 21st CFR, Section 1307.21. Here is a hyperlink to visit the code

on the internet -

http://www.deadiver sion.usdoj. gov/21cfr/ cfr/1307/ 1307_21.htm

The humor of this code, is the DEA has a very loose interpretation

of the information included. Most of the code applies to Schedule 2

drugs, however your Sch. IV may be involved as well. You'll notice

that it's required to notify the local agent in charge on a DEA 41

of your preparation and intent to destroy controlled substances with

two weeks notice. The form of destruction used may be a " reverse

distributor " any other form of destruction, (i.e. – sink waste,

incineration, trash canning) is a violation of EPA code, plus if you

did use one of those methods, you would require a police officer to

witness.

LONG long story and not much fun. There is a local reverse

distributor that I've found, and they are very willing to assist

EMS. http://www.totalret urns.net/

Total Returns is in Marietta, Oklahoma, just across the river from

Gainesville, Texas. They are an excellent resource and their cost

is almost nothing. In fact, if you give them your other expired

drugs, often they can return them to the manufacturer for a refund!

If you would like more information, I am more than willing to

assist. During the Texas EMS Conference last fall and again this

fall, I teach a class called " Controlling Controlled Substances "

where I address many of these issues we face as administrators.

Please email or call, I'll have my information posted below:

McKinney Fire / EMS

Captain - EMS Coordinator

McKinney, Texas

O:

C:

F:

rgriffin@mckinneyte xas.org

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