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Veterinary Forum July 2007 (Vol 24, No 7)

Business Skills: Disposing of Expired Drugs

by Philip Seibert, Jr., CVT

    Editor's Note: In this article, OSHA expert Phil Seibert explains the requirements for disposing various drugs and chemicals that we use in our practices. Mr. Seibert is well-recognized in veterinary medicine as being an expert on OSHA compliance and government regulations. His advice on these matters is always concise and worth the effort to follow. — Stephen Fisher, DVM, Column Editor

    The Environmental Protection Agency (EPA) is the agency that regulates the stream of waste disposal in the United States. In addition to following recommendations from the agency, veterinarians and their staff should advise pet owners about the proper disposal of expired or unused drugs.

    For example, the most recent recommendation from the EPA regarding disposal of patches is to wrap them in tissue, seal them in a plastic zip-top bag and dispose of the bag in regular trash. The EPA also recommends that the patches not be flushed down the toilet because the plastic material in the patch is not biodegradable.

    For other drugs, such as tablets and capsules, the agency likewise recommends placing the tablets or capsules in a zip-top bag, then adding about a teaspoon of water to make the contents dissolve. The bag should be sealed and disposed of in the regular trash. For liquid medications, some kitty litter should be placed in the zip-top bag and then the medication squirted or slowly poured into the litter until completely absorbed. Again, disposing of the sealed bag in regular trash is recommended.

    Information released by the agency suggests that a substantial amount of medications that pass through the human digestive process make it into sewer treatment plants or end up in surface water. This likewise is a concern in veterinary medicine because animals urinate and defecate freely in the environment. Chemical drugs, such as chemotherapeutics and antibiotics, are of special concern.

    Controlled substances

    The Drug Enforcement Agency (DEA) has regulations guarding the disposal of controlled substances. The regulations, however, vary according to whether an unused dose or unused stock is being discarded.

    When an amount of controlled substance is drawn up and allocated for a particular patient, the full amount that is drawn up (e.g., 10 cc) and the amount actually administered to the patient (e.g., 8 cc) must be recorded in a log. The unused portion of the drawn-up dose should be discarded either in a sink or toilet. There are no specific requirements for logging witnesses to the disposal of unused doses.

    Unused stock, however, is more highly regulated. Unused stock of controlled substances are those that were procured for general use in a facility or for dispensing to clients but were not allocated or used before the expiration date.

    The DEA recently changed its procedures for discarding these drugs. The registrant, that is, the veterinary clinic or hospital, is now required to contract with a "reverse distributor" to dispose of the unused stock of controlled substances. A reverse distributor is a company that, for a fee, is authorized to accept and destroy expired drugs. There are considerable differences in the fees these distributors charge, so veterinarians should investigate accordingly.


    Chemotherapy waste, both outdated and unused drugs, must be disposed of as hazardous waste and not as biohazardous waste. These chemicals are disposed of in yellow chemotherapy waste containers and not in red biological waste containers. In some instances, biohazardous wastes are "inactivated" by chemical disinfection during processing, and because a disinfectant could react with other chemicals, especially chemotherapeutics, regulations require special packaging for disposal. Chemotherapy waste must be picked up for disposal by a licensed waste transporter.

    For more information:

    Environmental Protection Agency: EPA website for unwanted pharmaceuticals in the environment. Available at www.epa.org/nerlesd1/ chemistry/pharma/faq.htm#disposal.

    Reverse Distributor Listing for Disposing of Controlled Drugs. Available at www.safetyvet.com/images/RevDist.pdf.

    Seibert P Jr: The Complete Veterinary Practice Regulatory Compliance Manual, ed 5. Calhoun, Tenn., Veterinary Practice Consultants, 2006.

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