Controlled Substances and waste

Proper disposal of controlled substances is important to reduce the risk of diversion and ensure safety and security within the laboratory or registered storage location.

For expired/unwanted controlled substances

Controlled substances that are expired, unwanted, or damaged (i.e., unused vials, expired dilutions, or broken/damaged containers with recoverable contents) must be transferred to a reverse distributor for destruction.  U-M Environment, Health & Safety (EHS) Hazardous Materials Management (HMM) program contracts with Drug and Laboratory Disposal (DLD) for reverse distribution.

Clearly label the substances for disposal (e.g., “to be disposed”, “do not use”, or “expired”).

Segregate the substances labeled for disposal from remainder of inventory within the secure storage location (i.e., safe, lock box).

Contact U-M EHS – Hazardous Materials to schedule a controlled substance pickup.

Email a completed DLD Controlled Substance Inventory List to EHS (address shown below).

Obtain a signed copy of the DLD Chain of Custody Form from EHS upon substance pickup, and file with the controlled substance records.

Record the disposal on the applicable inventory and usage log, and zero out the remaining balance.

If recoverable waste remains from unused volume in a syringe:

  • A witness must be present to observe the waste and to document the waste (via initials) on the applicable use log.
  • Record the waste amount on corresponding use log (e.g., Multiple Dose Log) and on DEA Form 41(link is external).
  • Waste the contents into the Rx Destroyer™ bottle, then shake the bottle several times to activate the ingredients.
  • When the content in the bottle has reached the fill line, use the hardener pellet to solidify the contents.
  • Once the contents have solidified, discard the bottle in the regular trash.

Laboratory Self-Disposal

For waste of "non-recoverable" contents

Residual amounts of non-recoverable waste may remain in the used (empty) syringes or vials after the administration or use of a controlled substance.  If this waste amount cannot be drawn out with a syringe (i.e., is non-recoverable), you may discard the empty controlled substance container in a biohazard sharps container. There is no need to record the disposal of the non-recoverable waste separately on the usage log if the container balance is zeroed out on the usage log upon disposal of that container.

For waste of "recoverable" contents

Using controlled substances in a laboratory procedure may result in recoverable waste amounts from unused doses in a syringe (e.g., 5 ml was drawn out of a vial or dilution, but only 4 ml was administered) or from container spillage.  The use of Rx Destroyer™ is the only U-M approved method of laboratory self-wasting.


*MUM-OHSA:  waste disposal guidelines
*Wastes and Spills
  • Emergency response covering accidental spills and personnel contamination, resulting from LMO/rDNA research
  • Decontamination and Disposal of GMOs
  • Biohazardous Waste Containers