Comprehensive controlled substance recordkeeping is the backbone of DEA compliance, and the DEA wants to see that your practice is tracking the full cycle of substances in your facility. That means that even expired drugs that have been disposed of should be accounted for in your controlled substance records.

Why you need an expired drug protocol

Unfortunately, many veterinary professionals don’t take the time to maintain proper records for their expired drugs, which is understandable, given already pressing demands and hectic work schedules. But neglecting these records can inadvertently thrust your practice into a DEA-related emergency, with the potential to shut down business operations and accrue massive fines.

Maintaining up-to-date records of expired drugs is also critical to practice and patient safety because it will prevent old and unsafe substances from being dispensed to pets. Furthermore, expired drugs in your practice present a big opportunity for diversion and improper usage.

How to implement it

To get started, establish a regular auditing process for your existing controlled substance records. For most practices, I recommend auditing records weekly, at the very least. During each audit, check for substances that are expired or soon will be. Expired drugs should be promptly identified and removed from current stock. Store the expired substances away from your other drugs in a secure location where only the DEA registrant and any authorized witnesses have access. Once you’ve identified an expired drug, whether it is opened or unopened, you must log the substance in your records.

Expired drug disposal

All expired drugs should be properly disposed of through a reverse distributor using DEA Form 41. Contact your nearest DEA field office to obtain the form or get a copy and complete instructions from the DEA website. Once completed, you will need to dispose of the drugs through a licensed reverse distributor. Be sure to log the date the substance was disposed of and get a witness signature of the disposal for your records.

Implementing an expired drug process will ensure you are maintaining accurate controlled substance records and guarantee that you and your team are staying safe and DEA compliant.

Ensure your practice is meeting the DEA’s stringent recordkeeping requirements with the newly updated edition of the AAHA Controlled Substance Logs.

About the author

Jack Teitelman is a contributor to the AAHA Controlled Substance Logs and a retired DEA supervisory special agent who spent 26 years gaining extensive experience in all facets of complex criminal drug-conspiracy investigations. As founder and CEO of TITAN Group, Teitelman directs a team of leading DEA compliance and state regulatory compliance experts and investigators to ensure that veterinary clients receive the highest quality services and support.

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