Is Your Dry Carbon Drug Disposal System a Fire Hazard to Your Facility?  

May 12, 2022 | Solutions That Meet Regulations

Dry vs Wet Carbon Drug Disposal Systems 

DEA Registrants are required to follow DEA and EPA regulations for safe drug disposal. Often, Registrants utilize chemical digestion as their DEA-approved method of destruction. There are typically two types of carbon drug disposal systems: wet or dry. The wet system is delivered in a liquid while the dry version is delivered in a dry carbon state. Dry carbon is burnt charcoal broken down into small particulates or a powder. 

Dry carbon, by itself, cannot break down pharmaceutical compounds to the DEA’s non-retrievable standard. To activate the dry carbon, water needs to be added so the process of liquid transfusion can occur. 

When dry carbon drug disposal systems arrive at the facility, the carbon, in its current state is considered a fire hazard by the Occupational Safety and Health Administration (OSHA) and the Canadian Centre for Occupational Health and Safety (CCOHS). DEA Registrants looking to compliantly destroy drugs should know the risks of bringing a fire hazard into their facility. 

OSHA Classification  

In 2016, OSHA issued the OSHA FS 3878-2016 guidance on protecting workers from combustible dust explosions in the United States. OSHA defines combustible dust as, “a solid material composed of distinct particles or pieces, regardless of size, shape, or chemical composition, which presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations.” 

In this guidance, OSHA identifies carbonaceous materials, such as the charcoal utilized in dry carbon drug disposal systems, as examples of potentially combustible materials. According to OSHA, combustible dust can grow flash fires or explosions when they are in cloud form. “Workers in many industries who handle combustible solids may be exposed to combustible dust incidents that can cause catastrophic destruction, injuries and deaths.” 

Facilities that destroy drugs using dry carbon systems should be aware of the fire hazard to their employees. Employers should take the proper precautions to reduce this risk of fire or explosion. Supervisors who are aware of the fire hazard should take necessary precautions to protect workers and their facilities. 

OSHA advises that facilities that have dry carbon ensure all the dust is captured and contained in a room that is built to specially handle combustible dust. Additionally, areas that use dry carbon should be frequently and thoroughly cleaned. 

CCOHS Classification 

The Canadian Centre of Occupational Health and Safety (CCOHS) defers to the Hazardous Products Regulation (Workplace Hazardous Materials Information System (WHMIS) 2015) to define combustible dust as “ a mixture or substance that is in the form of finely divided solid particles that, upon ignition, is liable to catch fire or explode when dispersed in air.” 

CCOHS considers carbonaceous materials, such as charcoal or soot, as combustible dust. They further clarify that the hazard with carbonaceous dust is that they are combustible and can catch fire, create a flash fire, or cause an explosion, specifically deflagration. 

Deflagration is a term to describe explosions caused by ignited combustible dust. In deflagration, a burning substance releases heat, hot gases, and energetic particles or sparks that ignite and spread the fire. In a dust explosion, the deflagration happens so quickly that the heated air produces extreme air pressure that can blow out walls and destroy structures. 

Multiple provinces have issued additional guidance about CCOHS-classified combustible dust: 

Rx Destroyer Reduces Fire Hazard Threats 

Rx Destroyer™ provides drug disposal solutions with ready-to-use wet carbon drug disposal solution. Making drug disposal safe for your facility. Each 

container is pre-filled and delivered with our patented* wet carbon formula that begins neutralizing medications on contact because the carbon has already been activated and liquid transfusion is already occurring. 

When Rx Destroyer™ is used in a facility, there is no dry carbon, which would expose the facility and its employees to an OSHA and CCOHS fire hazard. 

Rx Destroyer™ provides drug disposal compliance through chemical digestion with safe, easy, and affordable options. Our family of products offer an unmatched range of container sizes to meet the needs of any environment and do not require water, batteries, or a contract. Contact us to learn how to easily implement Rx Destroyer™ products as part of your drug disposal and diversion prevention strategies.