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Perspectives From the DEA on What Can and Cannot Be Done Via Drug Take-Back Programs
Vickie Seeger
Drug Enforcement Administration, Washington, DC

The Drug Enforcement Administration’s (DEA) mission with respect to illicit controlled substances, such as heroin and ecstasy, is to eliminate them outright. The DEA’s role, however, is much more complex when it comes to licit controlled pharmaceuticals. On one hand, the DEA prevents, detects, and eliminates the diversion of controlled pharmaceuticals from legitimate channels to illegal use, while at the same time ensuring their availability for legitimate medical and scientific purposes. To facilitate these goals, the Controlled Substances Act (CSA) established a closed system of controlled substance distribution encompassing manufacturers, distributors, pharmacies, and physicians. Components of this closed system include scheduling of all controlled substances; registration of all controlled substance handlers; and recordkeeping for accountability, security, and manufacturing quotas, all under the DEA’s oversight.

The CSA does not require patients (ultimate users) to register with DEA. Therefore, once the controlled substances are dispensed to the patient, the medications are outside of the closed system of distribution and not subject to CSA recordkeeping requirements. Currently, there is no regulatory allowance for unused patient medications to be routinely returned to a DEA registrant for disposal or reuse.

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