Disposal of pharmaceutical waste in dental offices is regulated as medical waste which includes emergency drugs, patient prescriptions, partially used and expired over-the-counter medications. Specific requirements vary in different states, although dental practices in California must abide by some of the strictest medical waste regulations which include the following record-keeping, storage, and disposal requirements and are good practices for any dental office.
Medical waste in the dental office must be segregated and collected in a leakproof container with a tightfitting lid, labeled “Pharmaceutical waste – incineration only”. Pharmaceutical waste can be stored for 90 days on-site from the date the container is filled and ready to be disclosed. Medical waste must be picked up by a medical waste hauler that is registered with the California Department of Public Health.
Most Common Regulations Violated by Dental Practitioners
Some of the most common regulations that are violated by dental practitioners include failing to maintain the required documentation including inventory records, failing to store controlled substances according to regulations and failing to dispose of controlled substances according to regulations. Other violations include prescribing outside the scope of the dental practice, prescribing without a documented dental provider and patient relationship established, and insurance fraud.
Record Keeping Requirements
Record-keeping requirements for prescribing and dispensing controlled substances in a dental office include maintaining records for all controlled substances. Records must be readily retrievable and available for inspection by regulatory entities including state law enforcement and the DEA. Federal law requires that all inventory records be kept on site for immediate review and all DEA registrant information and authorized power of attorney documentation with any DEA Forms 222 be onsite and available for immediate review. If any other records are maintained at a different location such as invoices for purchasing schedule III through Schedule IV controlled substance drugs should be available in no less than two business days.
Purchase and disposal records must be maintained for at least two years with some states requiring records to be kept for up to five years. Biennial inventory must be completed on the same day with particular office staff designated to manage this critical documentation.
Storage of Controlled Substances in Dental Offices
Controlled substances must be stored in a well-constructed metal safe or cabinet that is locked at all times with limited access to only a few specified individuals. The dental practitioner that holds the DEA registration number is fully responsible for proper storage of controlled substances. The dental practitioner is also fully responsible for any possible drug diversion that occurs. It is a good idea to also keep prescription pads in a locked cabinet.
Disposal of Controlled Substances in Dental Practices
Disposal of controlled substances in dental practices should be done by a DEA registered reverse distributor. This includes contaminated, defective, or expired controlled substances. The DEA requires that DEA Form 41 be completed, submitted and approved prior to destruction if a reverse distributor is not used. Under no circumstances should controlled substances be flushed for destruction by the dentist or office staff.
Prevent Drug Diversion with Due Diligence Practices
Dental practitioners can prevent drug diversion of controlled substances with due diligence practices that include:
- Performing a background check on all employees
- Completing a thorough patient intake and documenting everything including the drug, dose, quantity and indication
- Properly storing medications and prescriptions
- Maintaining proper inventory records of controlled substances
- Reporting any suspected or known criminal activity
C2R Global Manufacturing offers pharmaceutical waste disposal solutions with Rx Destroyer™ ready to use chemical drug destruction products. We offer turnkey solutions including DEA compliance consulting, waste haulers and mail back options. Contact us to learn more about DEA compliant pharmaceutical waste disposal solutions for dental practitioners.