UC Comment Letters

This comment letter responds to the Drug Enforcement Agency (DEA)'s Advanced Notice of Proposed Rulemaking on Controlled Substance Destruction Alternatives to Incinceration, issued on October 31, 2023. UC explains that it currently uses reverse distributors to destroy controlled substances used in research and clinical care, but that limited reverse-distributor capacity can force institutions to store expired or unusable substances longer than intended. UC asks DEA to allow or clarify that controlled substances purchased or used for research or clinical care may be rendered non-retrievable on-site, including through hardening agents or activated carbon under documented chain-of-custody, two-witness handling, and DEA Form 41 recordkeeping procedures.