When veterinarians dispense controlled substances to clients, the clients have few legal methods to dispose of any remaining drugs later. The Drug Enforcement Administration is seeking additional methods for disposal of controlled substances by human patients and animal owners. The AVMA believes law enforcement agencies are the appropriate group to undertake the task.
The DEA has granted temporary permission for some pharmaceutical take-back programs by law enforcement agencies that have requested authorization. On Jan. 21, the DEA published a notice in the Federal Register requesting comments on additional options for the disposal of controlled substances by users.
According to the notice, the DEA is seeking disposal options that protect public health and safety, minimize the possibility of diversion, are consistent with existing federal laws and regulations, and provide sound environmental solutions.
Members of the AVMA Clinical Practitioners Advisory Committee, meeting Feb. 26-27, discussed a desire to support appropriate disposal methods. Nevertheless, the CPAC wishes to limit a potential burden on veterinarians—if the DEA were to task veterinarians to take back controlled substances they had dispensed previously, dispose of the drugs, and keep the accompanying records. The CPAC drafted a policy stating that the AVMA believes law enforcement agencies should dispose of controlled substances from users.
On March 10, in a special meeting, the AVMA Board of Governors approved the policy "Client Disposal of Controlled Substances" in time to submit comments to the DEA by the March 23 deadline. The letter to the DEA states that the AVMA supports appropriate disposal of controlled substances but wants to limit any unnecessary economic burden on veterinary practices, most of which are small businesses. The letter concludes that drug take-back programs are best left in the hands of law enforcement.