For the final installment of our four-part blog series on sample medications, we will focus on the appropriate disposal of sample medications.

Posted in Risk Management on Thursday, February 23, 2017

For the final installment of our four part blog series on the handling and providing of sample medications, we will focus on the appropriate disposal of sample medications. 

As mentioned in our earlier blogs on this topic, providing sample medications to your patients puts the provider in the position of being a pharmacist. Therefore, before initiating this process, or if you are currently providing samples and have not done so as of yet, be sure to contact your local medical society and pharmacy board to determine what protocols are necessary for you to be compliant with state and federal regulations.

Guidelines for Disposing of Sample Medications

When samples are destroyed due to being outdated or recalled, the disposing needs to be done properly and a log should be maintained. 

The Drug Enforcement Administration (DEA) considers “a controlled substance dispensed for immediate administration…as pharmaceutical or drug waste”. 

The DEA released a letter, which can be viewed online, further explaining the guidelines for practitioners with regard to abiding by state, federal and local laws and regulations regarding disposal. 

Sample Medication Disposal Options

Some different options for disposal which may be available to you include:

• Local drug take back programs
• Pharmacy drug recycling programs
• Contacting a reverse distributor
• Returning the sample medications to the pharmaceutical representative/vendor (required in certain states)
• Donating the sample medications to a reputable charity organization such as Dispensary of Hope

If expired sample medications will be in your office until they can be disposed of properly by one of the above methods, be sure to isolate them in a separate area. This area should be away from your current inventory and have restricted access until the medications can be picked up. 

Returning Sample Medications to a Vendor or Third Party

In the case of returning sample medications to a vendor or third party, you should institute a written agreement with the assistance of your legal counsel.

This agreement should state that the vendor or third party is responsible for the proper handling and disposal of sample medications consistent with state and federal regulations once the medications leave your facility – this will be similar to your biohazard waste contract. The agreement should also discuss that the vendor or third party will hold you harmless in the event of any allegations with regard to improper disposal.

Sample Medication Disposal Log

With any disposal method you choose, be sure to maintain a log which notes the following:

• Name of the medication
• Lot number
• Expiration Date
• Amount disposed of (quantity and strength of dosages)
• Date of disposal
• Method of disposal
• Individual who disposed the drug

To view the prior blogs in our sample medication blog series, visit the links below:

1. Responsibly Receiving Sample Medications from Your Pharmaceutical Representatives
2. Safely Storing and Monitoring Medication Samples
3. Prudently Distributing Sample Medications to Your Patients