How to Properly Dispose of Expired Controlled Substances and Narcotics

Handling expired controlled substances isn’t like tossing out an old bottle of ibuprofen. These drugs-opioids, benzodiazepines, stimulants, and other Schedule II-V narcotics-are tightly regulated because they carry real risks: addiction, diversion, environmental harm, and even death if they fall into the wrong hands. The DEA doesn’t just recommend proper disposal-it requires it. And failing to follow the rules can mean fines, loss of your DEA registration, or worse.

Why You Can’t Just Flush or Trash Them

You’ve probably seen those flyers saying to mix old pills with coffee grounds or kitty litter and throw them in the trash. That works for regular over-the-counter meds. But for controlled substances? Not even close.

The DEA explicitly says flushing or mixing expired narcotics with household waste is unacceptable if the drug can still be recovered. Why? Because someone-maybe a teenager, a pet, or a person struggling with addiction-can dig it out, crush it, or dissolve it. A single leftover oxycodone tablet can be enough to cause an overdose.

Even crushing or dissolving them in water isn’t allowed. That’s a common myth. The DEA’s position, confirmed by UCSF’s Environmental Health & Safety team in 2022, is clear: no incineration, no dissolution, no pouring down the sink. These methods don’t meet the legal standard of making the substance “non-retrievable.”

What the DEA Actually Requires

The rules come from Title 21 of the Code of Federal Regulations, especially Part 1317, which was finalized in 2014 after the Secure and Responsible Drug Disposal Act of 2010. The goal? Prevent diversion and ensure accountability.

The DEA divides disposal into two categories: inventory disposal and wastage.

Inventory disposal means getting rid of entire stockpiles-expired bottles, unused vials, or surplus pills you never used. This applies to larger quantities. For this, you must use a DEA-registered reverse distributor. These are licensed companies that collect, transport, and incinerate controlled substances under strict chain-of-custody rules. You can’t just call any waste company. They have to be DEA-registered.

Wastage is the small amount left in a syringe after giving a shot, or a few leftover tablets from a patient’s prescription. For these, you can dispose of them on-site-but only if two authorized people witness it, sign off on it, and document everything.

How to Dispose of Schedule II Substances (Like Oxycodone, Fentanyl, Adderall)

Schedule II drugs have the highest potential for abuse and dependence. That means the strictest rules.

You must use DEA Form 222 to transfer these to a reverse distributor. Since January 1, 2023, this form has been electronic-only through the DEA’s Electronic Registration System (ERS). Paper forms are no longer accepted. The system cuts processing time from over a week to under two days.

Once you submit the form, the reverse distributor schedules a pickup. Fees vary but typically range from $250 to $500 per pickup, depending on volume and location. In Houston, many clinics report wait times of 10-14 business days for a pickup, which can be frustrating if you’re trying to clear out expired stock.

You must keep records of every transfer for at least two years. That includes the date, quantity, DEA Form 222 number, and the reverse distributor’s name. If you’re audited and can’t produce those records, you’re in trouble.

What About Schedule III-V Substances (Like Hydrocodone, Xanax, Klonopin)?

These are still controlled, but the rules are slightly more flexible.

You can still use a reverse distributor-many practices do, for simplicity. But you also have another option: on-site disposal with two witnesses.

The process is simple:

1. Label the substance clearly: “Expired - Do Not Use.”
2. Store it separately from active inventory in a locked cabinet.
3. When ready to dispose, two authorized personnel (one must be the DEA registrant or their direct agent) must be present.
4. Witness the destruction: pour the liquid into a secure, non-retrievable container, or place solid pills into a sharps container with a non-retrievable liner (not a regular trash bin).
5. Document the date, time, substance name, quantity, and names of both witnesses.
6. Keep this log for two years.

Note: Even for Schedule III-V, you still can’t flush, pour down the sink, or mix with kitty litter. The DEA doesn’t allow any method that leaves the drug recoverable.

Who Needs to Follow These Rules?

It’s not just hospitals and pharmacies. If you’re a licensed prescriber, you’re responsible.

This includes:

• Hospitals and clinics
• Dental offices
• Veterinary practices
• Research labs
• Long-term care facilities
• Any entity with a DEA registration to handle controlled substances

A 2022 DEA audit of 417 dental offices found that nearly 19% had incomplete or missing disposal records. Many thought they were “safe” if they just kept the drugs locked up. They weren’t. Storage isn’t disposal.

Veterinary practices are especially at risk. According to the American Animal Hospital Association, only 42% of small animal clinics properly dispose of controlled substances. Many assume pet meds aren’t as tightly regulated. They are.

Documentation Is Non-Negotiable

The DEA doesn’t just want you to dispose of drugs. They want proof you did it right.

Every disposal event-whether it’s a reverse distributor pickup or a two-person wastage-requires a paper or digital record. The record must include:

• Date and time of disposal
• Name and DEA number of the registrant
• Name and quantity of the substance
• Method of disposal
• Names and signatures of all witnesses
• For reverse distributors: the DEA Form 222 number and receipt

These records must be kept for two years. That’s not a suggestion. It’s a federal requirement. DEA inspectors show up unannounced. If your logbook is missing or incomplete, you could face a warning letter, a fine, or even suspension of your DEA registration.

Training and Compliance

Every person who handles controlled substances-pharmacists, nurses, vet techs, researchers-must get trained.

The DEA requires:

• Initial 2-hour training when you start handling controlled substances
• Annual 1-hour refresher

But here’s the problem: a 2022 audit found only 67% of facilities met this requirement. Many think “I’ve done this for years” is enough. It’s not.

Training should cover:

• How to identify controlled substances by schedule
• Correct disposal methods
• Documentation requirements
• What counts as “wastage” vs. “inventory”
• How to use the ERS system for Form 222

Your facility’s compliance officer should track training completion. If you’re a solo practitioner, keep your own records.

What Happens If You Don’t Follow the Rules?

In 2022, the DEA conducted 1,847 compliance inspections. They issued 327 warning letters and levied $2.47 million in fines.

Common violations:

• Storing expired drugs without documenting disposal
• Using unregistered waste haulers
• One person disposing of controlled substances alone
• Failing to keep disposal logs
• Using improper methods like flushing or kitty litter

Fines start at $5,000 per violation and can climb to $100,000 for repeated offenses. Some practices have lost their DEA registration entirely.

And it’s not just about money. If a diverted drug causes harm-say, someone overdoses on a pill you didn’t properly dispose of-you could be held civilly liable.

What’s Changing Soon?

The DEA is rolling out the Electronic Inventory Management System (EIMS) by 2025. This will require real-time reporting of all controlled substance transactions-including disposals.

Right now, you submit Form 222 and wait. Soon, you’ll log disposal events as they happen. This means faster audits, fewer paperwork errors, and better tracking.

The market is also changing. Three companies-Stericycle, Daniels Health, and Drug and Laboratory Disposal, Inc. (DLD)-control over 80% of the reverse distributor market. Fees are rising 6-7% per year. Waiting longer for pickups is becoming common.

Practical Steps for Your Practice

Here’s what you should do right now:

1. Take inventory of all controlled substances in your facility. Separate expired, damaged, or unused ones.
2. Label everything clearly: “Expired - Do Not Use.”
3. Store them in a locked, separate container away from active inventory.
4. Determine if you’re doing inventory disposal (use reverse distributor) or wastage (two-person witness).
5. If using a reverse distributor, register for ERS and submit DEA Form 222 electronically.
6. If doing on-site wastage, train two authorized personnel and start logging every disposal.
7. Review your disposal logs for the past two years. Are they complete? Are they signed?
8. Schedule annual training for all staff who handle controlled substances.

Don’t wait for an audit to catch you off guard. Proper disposal isn’t just about following rules-it’s about protecting your patients, your staff, and your license.

Where to Find Help

If you’re unsure where to start:

• Use the DEA’s online disposal locator to find registered reverse distributors near you.
• Check your state’s pharmacy board website-some have additional rules.
• Contact your facility’s environmental health and safety (EHS) department if you’re in a hospital or university.
• For veterinary practices, the American Veterinary Medical Association offers free disposal guides.

There’s no shortcut. But there is a clear, legal path. Follow it.