DEA’s Non-Retrievable Standard Simplified
DEA (Drug Enforcement Agency) defines their non-retrievable standard as: Non-retrievable means, for the purpose of destruction, the condition or state to which a controlled substance shall be rendered following a process that permanently alters that controlled substance’s physical or chemical condition or state through irreversible means and thereby renders the controlled substance unavailable and unusable for all practical purposes. The process to achieve a non-retrievable condition or state may be unique to a substance’s chemical or physical properties. A controlled substance is considered “non-retrievable” when it cannot be transformed to a physical or chemical condition or state as a controlled substance or controlled substance analogue. The purpose of destruction is to render the controlled substance(s) to a non-retrievable state and thus prevent diversion of any such substance to illicit purposes.
My summary of DEA’s non-retrievable standard is disposal of a DEA controlled substance in such a manner that does not allow the possibility of the controlled substance to be retrieved.
DEA’s view on Medicine Disposal Devices (a.k.a., DEA Sequestration Devices). As of today, DEA has verbally and in writing only acknowledged incineration as meeting DEA’s non-retrievable standard. They have publicly commented that no commercially available DEA sequestration device by themselves meets their non-retrievable standard. So, if PAC-RX™ and similar devices do not meet DEA’s non-retrievable standard, why are many advertised as such? Good question for the DEA and the competing manufacturer brands.
Although the commercially available DEA sequestration devices by themselves do not meet DEA’s non-retrievable standard, they do serve a vital function as a tool to mitigate DEA drug diversion while the drug is stored prior to incineration. If your facility does not have an incineration option, consider the PAC-RX™ MailBACK™ disposal program where all drug waste is incinerated.
WARNING – Never place a used DEA sequestration device in the trash. This is highly likely a serious violation of state landfill and or local waste regulations. Despite EPA and DEA regulations, I continually run across healthcare facilities that are discarding used medicine disposal devices in the trash as they are under the impression from the manufacturer and label that it is OK.
Oh, by the way, EPA (US Environmental Protection Agency) also follows DEA’s stance on the commercially available medicine disposal devices.
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