The DEA provides guidance on the proper disposal of controlled substances. Based on DEA guidance, Emory University has a policy (http://policies.emory.edu/7.25) that covers the proper use and disposal of controlled substances for non-human subjects research. At this time, a DEA registered reverse distributor must be used to properly dispose of controlled substances.

The DEA registration holder (registrant) is responsible for making sure that all controlled substances are properly disposed of when:

• the substances expire;
• or the Registrant’s DEA registration is not renewed;
• or when the Registrant no longer conducts research at Emory University using controlled substances or leaves Emory University.

The registrant must establish an account with an approved reverse distributor vendor, and arrange with the DEA registered reverse-distributor to accept and dispose of controlled substances.  Reverse distributors receive controlled substances by pick-up from the registrant’s authorized location or delivery by a courier or contract carrier.

The registrant should keep:

• a biennial inventory of controlled substances in his/her possession,
• an inventory of controlled substances transferred to a reverse distributor
• the order, receipt and shipping records for materials in inventory,
• as well as any records evidencing disposition of the substances for 3 years (current year +2 years) from date record was created.

Before disposing of drugs, refer to Emory’s DEA Controlled Substances Policy –http://policies.emory.edu/7.25. After reviewing the policy, researchers should identify a reverse distributor from the list provided:

*NOTE: The Environmental Health and Safety Office does not endorse any individual reverse distributor and their products or services.

Contact the Emory University Office of Compliance if you have any questions regarding Controlled Substances and Dangerous Drugs: http://compliance.emory.edu/controlled-substances/index.html