PREVENTING DRUG 

ABUSE

Low Participation by

Pharmacies and 

Other Entities as 

Voluntary Collectors 

of Unused 

Prescription Drugs

Report to Congressional Requesters

October 2017

GAO-18-25

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-25, a report to 

congressional requesters

October 2017

PREVENTING DRUG ABUSE

Low Participation by Pharmacies and Other Entities 

as Voluntary Collectors of Unused Prescription Drugs

What GAO Found

GAO found that about 3 percent of pharmacies and other entities eligible to 

collect unused prescription drugs for disposal have volunteered to do so. The 

Drug Enforcement Administration (DEA) authorizes these entities to dispose of 

unused drugs to help reduce their potential misuse. Analysis of DEA data shows 

that as of April 2017, 2,233 of the 89,550 (2.49 percent) eligible entities—that is,

certain entities already authorized by DEA to handle controlled substances—had 

registered with DEA to use disposal bins to collect unused prescription drugs. 

Most—about 81 percent—of the authorized collectors were pharmacies, followed 

by hospitals or clinics. GAO also found that participation rates varied by state, 

though in 44 states less than 5 percent of the state’s pharmacies and other 

eligible entities had registered to become authorized collectors.

Percentage of Eligible Entities Authorized by DEA to Collect Unused Prescription Drugs Using 

Disposal Bins, April 2017

Stakeholders cited several factors that may explain why relatively few 

pharmacies and other eligible entities have registered with DEA as authorized 

collectors of unused drugs. Most notably, stakeholders representing authorized 

collectors told GAO that because participation is voluntary, the cost associated 

with maintaining a disposal bin—which includes purchasing and installing the bin

according to DEA requirements and paying for the destruction of its contents—is 

an important factor to weigh against potential benefits. DEA noted that availability 

of disposal by law enforcement agencies also contributes to low participation.

View GAO-18-25. For more information, 

contact Debra A. Draper at (202) 512-7114 or 

draperd@gao.gov.

Why GAO Did This Study

In 2015, 3.8 million Americans reported 

misusing prescription drugs within the 

last month, and deaths from 

prescription opioids have more than 

quadrupled since 1999. About half of 

the people who reported misusing 

prescription drugs in 2015 received 

them from a friend or relative. 

One way to help prevent this kind of 

diversion and potential misuse is by 

providing secure and convenient ways 

to dispose of unused, unneeded, or 

expired prescription medications. The 

Secure and Responsible Drug 

Disposal Act of 2010 authorizes

pharmacies and other entities already 

authorized by DEA to handle controlled

substances to also collect unused 

prescription drugs for disposal. In 

2014, DEA finalized regulations for the 

implementation of the Act, establishing 

a voluntary process for eligible entities 

to become authorized collectors of

unused prescription drugs using 

disposal bins.

GAO was asked to review participation 

among authorized collectors that 

maintain disposal bins. In this report 

GAO describes (1) participation rates 

among entities eligible to collect 

unused prescription drugs and (2) 

factors that affect participation. GAO

analyzed the most currently available 

DEA data from April 2017 on entities

eligible to participate and those 

participating as authorized collectors. 

GAO also conducted interviews with 

DEA officials and a nongeneralizable 

sample of 11 stakeholder organizations 

selected to illustrate different types of

authorized collectors and long-term 

care facilities. GAO is not making any 

recommendations. DEA provided 

technical comments, which GAO

incorporated as appropriate.
Page i GAO-18-25 Workplace Safety and Health

Letter 1

Background 4

About 3 Percent of Eligible Pharmacies and Other Entities 

Voluntarily Participate as DEA-Authorized Collectors of Unused 

Prescription Drugs 7

Stakeholders Cited Cost and Other Factors as Affecting Decision 

to Become DEA-Authorized Collectors of Unused Prescription 

Drugs 13

Agency Comments 17

Appendix I Entities Eligible to Register with DEA to Become Authorized 

Collectors and Participating Collectors, by State, April 2017 18

Appendix II GAO Contact and Staff Acknowledgments 20

Tables

Table 1: Entities Eligible to Register with the Drug Enforcement 

Administration (DEA) to Become Authorized Collectors of 

Unused Prescription Drugs, and Participating Collectors, 

by Type, as of April 2017 8

Table 2: Participation Rates of Authorized Collectors of Unused 

Prescription Drugs among Pharmacies and Other Eligible 

Entities, by Urban and Rural Location, as of April 2017 10

Figures

Figure 1: Steps Involved In the Collection of Unused Prescription 

Drugs Using Disposal Bins 7

Figure 2: Percentage of Pharmacies and Other Eligible Entities 

Authorized by the Drug Enforcement Administration 

(DEA) to Collect Unused Prescription Drugs, April 2017 9

Figure 3: Estimated Percentage of Population Who Lived within 5 

Miles of a Drug Enforcement Administration (DEA) 

Prescription Drug Disposal Bin, by State, April 2017 12

Contents
Page ii GAO-18-25 Workplace Safety and Health

Abbreviations

DEA Drug Enforcement Administration

Disposal Act Secure and Responsible Drug Disposal Act of 2010

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Page 1 GAO-18-25 Workplace Safety and Health

441 G St. N.W.

Washington, DC 20548

October 12, 2017

The Honorable Charles E. Grassley

Chairman

Judiciary Committee

United States Senate

The Honorable Joni K. Ernst

United States Senate

The misuse of prescription drugs is widespread and contributes to 

overdoses and deaths. Federal data show that in 2015, 3.8 million 

Americans reported misusing prescription drugs within a 1-month period 

and that prescription drug misuse was the second most common type of 

illicit drug use, after marijuana use.1 The misuse of prescription drugs has 

also contributed to the nation’s opioid epidemic and the overdoses 

associated with it, as 91 people in the United States die each day, on 

average, from an opioid overdose, including overdoses involving 

prescription opioids and heroin. Furthermore, the number of deaths 

resulting from prescription opioids has more than quadrupled since 1999.2

About half of the people who reported misusing prescription drugs in 2015 

received them from a friend or relative.3 One way to help prevent this type 

of diversion of prescription drugs from their intended users and the 

resulting potential for abuse is by providing secure and convenient 

disposal mechanisms for unused, unneeded, or expired prescription 

medications. Under the Secure and Responsible Drug Disposal Act of 

2010 (“Disposal Act”), the Drug Enforcement Administration (DEA) may 

 1

See Center for Behavioral Health Statistics and Quality, Key Substance Use and Mental 

Health Indicators in the United States: Results from the 2015 National Survey on Drug 

Use and Health, HHS Publication No. SMA 16-4984, NSDUH Series H-51, (September 

2016).

2

Centers for Disease Control and Prevention, Understanding the Epidemic, 

https://www.cdc.gov/drugoverdose/epidemic/index.html, accessed July 5, 2017.

3

According to the National Survey on Drug Use and Health data from 2015, of the people 

who misused pain relievers, about 41 percent reported that a friend or relative provided 

the drug for free, about 9 percent reported that they bought the drug from a friend or 

relative, and about 4 percent reported that they took the drug from a friend or relative 

without asking. See Center for Behavioral Health Statistics and Quality, Results from the 

2015 National Survey on Drug Use and Health: Detailed Tables, (September 2016). 

Letter
Page 2 GAO-18-25 Workplace Safety and Health

authorize eligible retail pharmacies and other entities—which are certain 

entities already authorized by the DEA to handle controlled substances—

to also collect unused prescription drugs from the public.4 In September 

2014, DEA finalized regulations for the implementation of the Disposal 

Act, providing pharmacies and other eligible entities the option to register 

with DEA to become authorized collectors of unused controlled 

prescription drugs using collection receptacles, which are bins used to 

collect drugs meant for disposal.5 The regulation establishes 

requirements participating entities must meet, such as installing the 

disposal bin securely to a permanent structure and making the bin 

inaccessible to the public when an employee is not present.

You requested that we review DEA’s requirements for authorized 

collectors of prescription drugs and participation rates. In this report, we 

describe

1. participation rates of eligible pharmacies and other entities as DEAauthorized collectors of unused prescription drugs, and

2. factors that affect voluntary participation as authorized collectors of 

unused prescription drugs.

To describe the rates of eligible pharmacies and other entities that 

participate as DEA-authorized collectors of unused prescription drugs 

using disposal bins, we analyzed DEA data as of April 20, 2017, the most 

current data available at the time of our analysis. We determined the 

number and percentage of eligible entities participating as authorized 

collectors nationwide, by state, and by type of entity.6 We also determined 

 4

Pub. L. No. 111-273, 124 Stat. 2858 (Oct. 12, 2010). According to the Controlled 

Substances Act, the term “controlled substance” means “a drug or other substance, or 

immediate precursor, included [by DEA in one of five classification schedules.]” 21 U.S.C. 

§ 802(6). A controlled substance is placed in a respective schedule based on whether it 

has a currently accepted medical use in treatment in the United States and based on its 

relative abuse potential and likelihood of causing dependence. The order of the schedules 

reflects substances that are progressively less dangerous and addictive. The term 

“controlled substance” as used in this report includes controlled prescription drugs such as 

opioid pain relievers. For simplicity, in this report, we use the term “prescription drugs” to 

refer to controlled prescription drugs.

5

We use the term “disposal bin” to refer to collection receptacles. 

6

For the purposes of this report, we include Washington, D.C., when we refer to data for 

states. We did not analyze data on authorized collectors in U.S. territories or international 

military locations. As of April 2017, of the 1,493 DEA eligible entities located in territories 

or international military locations only 4 were participating as authorized collectors—3 in 

Puerto Rico and 1 in the Northern Mariana Islands. 
Page 3 GAO-18-25 Workplace Safety and Health

the number of eligible and participating authorized collectors in rural and 

urban areas, using DEA’s data and Rural-Urban Commuting Area codes.7

Finally, we analyzed DEA’s data and data from the U.S. Census Bureau’s 

American Community Survey 5-year population estimates for 2011 

through 2015 to estimate the number of individuals and the percentage of 

the U.S. population living within varying distances of a DEA authorized 

collector’s disposal bin.8 For all data used in these analyses, we 

interviewed knowledgeable officials and reviewed related documentation 

and, based on these steps, determined that the data were sufficiently 

reliable for our purposes. Our review is limited to DEA-authorized 

collectors that use disposal bins to collect unused prescription drugs from 

the public. Other methods of drug disposal by eligible entities and all 

methods of disposal by law enforcement agencies, which do not require 

DEA authorization to dispose of controlled substances, are outside the 

scope of our work.9

 7

Rural-Urban Commuting Area codes characterize all Census tracts regarding their rural 

and urban status using Bureau of Census Urbanized Area and Urban cluster definitions in 

combination with work-commuting data. We used the most recent zip code version of the 

Rural-Urban Commuting Area codes, version 3.1, which are based on 2010 Census data. 

Zip codes defined as urban and suburban by code were grouped as “urban” and the 

remainder were grouped as “rural.” We obtained additional information on Rural-Urban 

Commuting Area codes from the University of North Dakota’s Center for Rural Health. 

8

The American Community Survey 5-year estimates are updated annually and are based 

on data collected continuously from a sample of households during the entire 60 month 

period. We used the 5-year estimates rather than 1-year estimates because they are 

based on larger sample sizes and thus are more reliable. These data were the most 

current data available at the time of our analysis. To conduct this analysis, we calculated 

the distance between the central point of each zip code and the nearest DEA authorized 

collector’s disposal bin. For some zip codes, depending upon whether their central point is 

located just within the distance threshold or just beyond it, a portion of their population 

may be unintentionally included in or excluded from the population subtotal and total, thus 

introducing a small degree of error in the percentage calculation. The radius of each 

distance category was not limited by state boundaries, and we chose these distance 

thresholds based on a review of available information on convenient distances for 

accessing pharmacies. 

9

79 Fed. Reg. 53,520 (Sept. 9, 2014) (codified at 21 C.F.R. pt. 1317). DEA regulations 

provide for three methods for disposing of prescription drugs: (1) disposal bins; (2) a mailback program, where packages are made available for the public to ship prescription 

drugs to collectors for destruction; and (3) take-back events, where federal, state, and 

local law enforcement collect prescription drugs for destruction. DEA may authorize 

eligible entities to use disposal bins or the mail back program, while law enforcement 

agencies may use all three methods without the need for authorization by DEA. For the 

purposes of this report, we use the term “authorized collector” to refer to those pharmacies 

and other DEA-authorized entities that offer a disposal bin.
Page 4 GAO-18-25 Workplace Safety and Health

To describe the factors that affect voluntary participation as authorized 

collectors of prescription drugs, we interviewed DEA officials. In addition, 

we conducted interviews with 11 stakeholder organizations—8 selected 

because they represent different types of authorized collectors, such as 

pharmacies and reverse distributors, and 3 selected because they 

represent long-term care facilities.10 Our findings cannot be generalized 

beyond the stakeholder organizations we interviewed.

We conducted this performance audit from November 2016 to October 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The DEA, within the Department of Justice, is responsible for ensuring 

the availability of controlled substances for legitimate uses while 

preventing their diversion through its administration and enforcement of 

the Controlled Substances Act and its implementing regulations.11 Under 

the Controlled Substances Act, all persons or entities that manufacture, 

distribute, or dispense controlled substances are required to register with 

DEA, unless specifically exempted. DEA regulates these entities to limit 

diversion and prevent abuse. For example, DEA regulates 

pharmaceutical companies that manufacture controlled substances, 

health care providers who prescribe them to patients, and pharmacies 

that dispense them.

 10We selected stakeholders from among those that had publicly available comments on 

the processes for disposing of controlled substances and asked stakeholders we 

interviewed for additional recommendations. Among the 8 authorized collector stakeholder 

organizations we interviewed, 5 represented pharmacies, 1 represented hospitals with 

pharmacies, and 2 represented reverse distributors. Reverse distributors are typically 

waste management companies that acquire controlled substances from other entities 

authorized to handle controlled substances for the purpose of return or destruction. Longterm care facilities are not authorized collectors, but pharmacies and hospitals 

participating as authorized collectors are able to also maintain disposal bins in long-term 

care facilities. 

11The Controlled Substances Act was enacted in 1970 to regulate and facilitate the use of 

controlled substances, including certain prescription drugs such as opioid pain relievers, 

for legitimate medical, scientific, research, and industrial purposes while preventing them 

from being diverted for illegal uses. Pub. L. No. 91-513, tit. II, 84 Stat. 1236, 1242-84 

(codified as amended at 21 U.S.C. § 801 et seq.).

Background
Page 5 GAO-18-25 Workplace Safety and Health

In October 2010, the Disposal Act amended the Controlled Substances 

Act to allow the public to deliver unused controlled substances to an entity 

authorized by DEA to dispose of the substances.12 DEA was given 

responsibility for promulgating the implementing regulations, and the 

Disposal Act stipulated that the regulations should prevent diversion of 

controlled substances while also taking into consideration public health 

and safety, ease and cost of implementation, and participation by various 

communities. In addition to disposal bins, DEA’s regulations describe two 

other options for the public to transfer controlled substances for the 

purpose of disposal: mail-back programs and take-back events. Law 

enforcement agencies may use all three methods of drug disposal without 

the need for authorization by DEA.13 The Disposal Act stipulates that the 

regulations cannot require an entity to participate in or establish any of 

the disposal options.

To participate as authorized collectors of unused prescription drugs, 

eligible entities—retail pharmacies, hospitals/clinics with an on-site 

pharmacy, narcotic treatment programs, reverse distributors, distributors, 

and drug manufacturers that are already authorized by DEA to handle 

controlled substances—must modify their DEA registration.14 According to 

DEA officials, such modification is free and simple to do. Eligible retail 

pharmacies or hospitals/clinics that become authorized collectors are able 

to install and maintain disposal bins in long-term care facilities in addition 

to their own location. DEA’s website contains a public search feature to 

identify authorized collectors located near a specific zip code or 

address.15

 12Specifically, the law allows disposal by ultimate users, which it defines as people who 

have lawfully obtained and who possess a controlled substance for their own use or for 

the use of a member of their household.

13The National Association of Drug Diversion Investigators maintains a website with a 

search feature for the law enforcement locations that accept unused prescription drugs 

(see http://www.rxdrugdropbox.org). An official from the National Association of Drug 

Diversion Investigators said that the website includes those locations for which agencies 

have chosen to provide information.

14Authorization to be a collector is subject to renewal, and if an authorized collector 

ceases its disposal activities it must modify its DEA registration to reflect the change. 

15See https://apps.deadiversion.usdoj.gov/pubdispsearch/spring/main. 

Requirements for 

Authorized Collectors of 

Unused Prescription 

Drugs
Page 6 GAO-18-25 Workplace Safety and Health

Authorized collectors must install, manage, and maintain the disposal 

bins following DEA regulations. For example, under DEA’s regulations for 

maintaining the disposal bins,

• the disposal bin must be securely fastened to a permanent structure, 

securely locked, substantially constructed with a permanent outer 

container and removable inner liner, and have a small opening that 

allows contents to be added but not removed;

• the bin must also prominently display a sign indicating which types of 

substances are acceptable;16

• users must dispose the unused prescriptions into the collection 

receptacle themselves without handing them to staff at the 

pharmacy;17

• the disposal bin must typically be located in an area where an 

employee is present and near where controlled substances are 

stored, and the bin must be made inaccessible to the public when an 

employee is not present;18

• the inner liner of the disposal bin must meet certain requirements, 

including being waterproof, tamper-evident, tear-resistant, opaque, 

and having the size and identification number clearly labeled; and

• the installation and removal of inner liners must be performed under 

the supervision of at least two employees of the authorized collector.

DEA regulations also require that all controlled substances collected in 

the disposal bin’s inner liners must be destroyed in compliance with 

applicable federal, state, and local laws and rendered non-retrievable. 

According to DEA regulations, non-retrievable means that the physical 

and chemical conditions of the controlled substance must be permanently 

altered, thereby rendering the controlled substance unavailable and 

unusable for all practical purposes. Authorized collectors are permitted to 

 16Only schedule II-V controlled substances and non-controlled substances are acceptable. 

Schedule I controlled substances, controlled substances that are not lawfully possessed 

by the ultimate users, and other illicit or dangerous substances are not permitted. 

17A long-term care facility may dispose of controlled substances on behalf of a user who 

resides in or previously resided at the facility.

18Disposal bins in a hospital must be located in an area monitored by employees regularly 

and cannot be located near an area where emergency or urgent care is provided. 

Additionally, bins in narcotic treatment programs must be located in a room with controlled 

access and without any other controlled substances.
Page 7 GAO-18-25 Workplace Safety and Health

destroy the inner liner on their premises if they have the capacity to do so. 

If not, the inner liners can be transported to a separate location to be 

destroyed. Typically, in this case, an authorized collector contracts with a 

reverse distributor to periodically remove, transport, and destroy the inner 

liners. DEA regulations require that two reverse distributor employees 

transport the inner liners directly to the disposal location without any 

unnecessary stops or stops of an extended duration. Authorized 

collectors must document certain information, including inner liner 

identification numbers and the dates that each liner is installed, removed, 

and transferred for destruction. The authorized collectors must maintain 

these records for 2 years. Figure 1 summarizes the steps involved in the 

collection of unused prescription drugs.

Figure 1: Steps Involved In the Collection of Unused Prescription Drugs Using Disposal Bins

About 3 percent of pharmacies and other eligible entities have voluntarily 

chosen to become DEA-authorized collectors of unused prescription 

drugs, according to DEA data. As of April 2017, 2,233 of the 89,550 (2.49 

percent) of eligible entities—which are already authorized by DEA to 

handle controlled substances—had registered to use disposal bins to 

collect unused prescription drugs. Most of the authorized collectors—

about 81 percent—were pharmacies, followed by hospitals or clinics. 

(See table 1). Narcotic treatment programs, reverse distributors, and 

distributors made up approximately 1 percent of the authorized collectors.

About 3 Percent of 

Eligible Pharmacies 

and Other Entities 

Voluntarily Participate 

as DEA-Authorized 

Collectors of Unused 

Prescription Drugs
Page 8 GAO-18-25 Workplace Safety and Health

Table 1: Entities Eligible to Register with the Drug Enforcement Administration (DEA) to Become Authorized Collectors of 

Unused Prescription Drugs, and Participating Collectors, by Type, as of April 2017

Number of entities eligible to 

become authorized collectors 

Number of

authorized collectors 

Percentage of

eligible entities participating

as authorized collectors 

Pharmacy 69,192 1,803 2.6

Hospital/Clinic 17,442 405 2.3

Narcotic Treatment Program 1,523 16 1.1

Reverse Distributora 62 8 12.9

Distributor 777 1 0.1

Manufacturer 554 0 0

Total 89,550 2,233 2.49

Source: GAO analysis of DEA data. | GAO-18-25

a

Reverse distributors are typically waste management companies that acquire controlled substances 

from other entities authorized to handle controlled substances for the purpose of return or destruction.

We also found that participation rates varied by state, though in most 

states relatively few of the eligible entities had registered with DEA to 

become authorized collectors of unused prescription drugs. In 44 states, 

less than 5 percent of the eligible entities had registered. (See figure 2 

and appendix I for more information on the participation rates of 

authorized collectors in each state). As of April 2017, Connecticut, 

Missouri, and Maine had the lowest participation rates, with 0.11, 0.22, 

and 0.70 percent, respectively.19 In contrast, North Dakota had the 

highest participation rate, with 32.0 percent of its pharmacies and other 

eligible entities registered to be authorized collectors. The state with next 

highest participation rate was Alaska, with 8.96 percent. In North Dakota, 

the state’s Board of Pharmacy provides funding for authorized collectors 

to purchase and maintain the disposal bins. According to a board official, 

the board decided to fund these activities to increase participation rates 

and plans to continue its funding indefinitely using revenue generated 

from prescription drug licensing fees it collects.

 19According to DEA officials, two states—Missouri and Hawaii—have state-level laws or 

regulations that prohibit retail pharmacies from installing bins to collect prescription drugs 

from the public. As of April 2017, Missouri had four authorized collectors and Hawaii had 

six authorized collectors—all hospitals or clinics located on military bases or at Veterans 

Health Administration facilities. According to DEA officials, registrants located on military 

bases or at Veterans Health Administration facilities are federal entities and not subject to 

state pharmacy laws. 
Page 9 GAO-18-25 Workplace Safety and Health

Figure 2: Percentage of Pharmacies and Other Eligible Entities Authorized by the Drug Enforcement Administration (DEA) to 

Collect Unused Prescription Drugs, April 2017
Page 10 GAO-18-25 Workplace Safety and Health

In addition, our analysis shows that about 82 percent of all authorized 

collectors were located in urban areas as of April 2017. However, when 

comparing the entities registered to be authorized collectors with the total 

number of eligible entities, we found that a larger percentage of the 

eligible entities in rural areas became authorized collectors compared 

with those in urban areas (see table 2).

Table 2: Participation Rates of Authorized Collectors of Unused Prescription Drugs among Pharmacies and Other Eligible 

Entities, by Urban and Rural Location, as of April 2017

Total number of pharmacies

and other entities eligible to 

become authorized collectors 

Number of

authorized collectors

Percentage of pharmacies

and other eligible entities registered

to participate as authorized collectors

Urban 78,071 1,836 2.35 

Rural 11,436 395 3.45

Source: GAO analysis of DEA data. | GAO-18-25

Note: The Rural-Urban Commuting Area codes used to determine urban and rural locations did not 

include the zip codes of 43 pharmacies and other entities eligible to become authorized collectors, 2 

of which were participating as authorized collectors. These 43 entities are not included in the table.

The data we obtained on the number of eligible and participating 

authorized collectors and their locations are the only available DEA data 

on the use of disposal bins to collect unused prescription drugs. 

According to DEA officials, the agency does not collect any other 

information on the use of disposal bins, such as the extent to which the 

bins are used, or the amount and types of prescription drugs deposited 

into the bins. For example, to minimize the risk of diversion, DEA 

regulations do not allow authorized collectors to open and inspect the 

inner liners of the disposal bins, so information on their contents cannot 

be collected.20 According to DEA officials, the agency is not responsible 

for collecting information on the amount and types of prescription drugs 

destroyed through the disposal bins. DEA officials told us that the agency 

 20In contrast, DEA collects and publishes information on the weight of the prescription 

drugs collected and destroyed through DEA’s national take-back days, during which DEA 

partners with local law enforcement twice a year to collect and destroy prescription drugs 

brought in by the community. DEA reported that during its April 29, 2017 national takeback day, about 450 tons of drugs were collected at more than 5,000 collection sites.
Page 11 GAO-18-25 Workplace Safety and Health

views its responsibility solely as giving pharmacies and other eligible 

entities the opportunity to become authorized collectors.21

Though we do not have information on the extent to which individuals use 

DEA’s prescription drug disposal bins, we were able to estimate that as of 

April 2017, about half of the country’s population lived less than 5 miles 

away from a pharmacy or other DEA-authorized entity offering a 

prescription disposal bin. In 21 states, at least 50 percent of the state’s 

population lived within 5 miles of a prescription disposal bin. (See 

figure 3).

 21DEA officials noted that the agency requires authorized collectors to keep records 

related to the disposal bins, such as records of when a disposal bin’s inner liner is 

installed, removed, and then destroyed. DEA officials told us that any entity authorized to 

handle controlled substances, including authorized collectors, may be subject to periodic 

DEA inspections. For example, DEA officials told us that each of the agency’s 21 regional 

offices conducts inspections of at least 10 pharmacies per year, without regard to whether 

the pharmacies are authorized collectors. According to officials, DEA may review the 

records kept by authorized collectors as part of these inspections.
Page 12 GAO-18-25 Workplace Safety and Health

Figure 3: Estimated Percentage of Population Who Lived within 5 Miles of a Drug Enforcement Administration (DEA) 

Prescription Drug Disposal Bin, by State, April 2017

While close to half of the nation’s population lived less than 5 miles from a 

disposal bin as of April 2017, the availability of nearby disposal bins 

varied significantly for people depending on whether they lived in an 

urban or a rural area. Specifically, about 52 percent of the population in 

urban areas lived less than 5 miles away from a disposal bin, compared 
Page 13 GAO-18-25 Workplace Safety and Health

to about 13 percent of the population in rural areas. Furthermore, about 

44 percent of the population in rural areas lived even further away—more 

than 30 miles away from a disposal bin. An exception to this is North 

Dakota, where about 86 percent of its urban population and about 64 

percent of its rural population lived within 5 miles of a disposal bin.

According to officials from the 11 stakeholder organizations we 

interviewed—which represent authorized collectors and long-term care 

facilities—several factors may explain why relatively few pharmacies and 

other eligible entities have chosen to become authorized collectors of 

unused prescription drugs. These factors include the associated costs of 

participating, uncertainty over proper implementation, and participation in 

other, similar efforts for disposing of unused prescription drugs.

Costs: Stakeholders said that the costs associated with purchasing, 

installing, and managing the disposal bins is a factor that explains the 

relatively low rate of participation. One stakeholder told us that many 

eligible entities may decide that the benefit of participating does not 

outweigh the costs associated with doing so. Specifically, stakeholders 

told us that the major costs associated with participating include

• the one-time cost of purchasing and installing a disposal bin;

• the ongoing costs to train personnel to manage the bins; and

• the cost of contracting with a reverse distributor to periodically dispose 

of the bin’s inner liner and contents.

Stakeholders gave varying examples of the specific costs associated with 

these investments. For example, one stakeholder estimated the yearly 

costs of maintaining a disposal bin ranged from $500 to $600 per 

location; another stakeholder said that the cost is thousands of dollars per 

location per year, but did not provide a specific estimate. These 

stakeholders added that costs can increase if the disposal bins fill more 

quickly and need to be emptied more often than expected.

For their part, officials from the reverse distributor stakeholders we 

interviewed cited incinerating hazardous waste, the availability of 

incinerators, and the cost of personnel as factors that increase the cost of 

their services for authorized collectors. One reverse distributor 

stakeholder told us that there are not many incinerators available, 

requiring them to travel long distances to incinerate collected waste. The 

other reverse distributor stakeholder added that DEA’s requirement that a 

Stakeholders Cited 

Cost and Other 

Factors as Affecting 

Decision to Become 

DEA-Authorized 

Collectors of Unused 

Prescription Drugs 
Page 14 GAO-18-25 Workplace Safety and Health

second employee be present during the transportation and disposal 

increases the cost of their services.

While some stakeholders speculated that costs are a reason for low 

participation, a few stakeholders told us that the benefits are worth the 

costs. In fact, two stakeholders we spoke with told us that the benefit to 

the communities was so important that they decided to provide funding to 

retail pharmacies, alleviating an individual pharmacy’s concern about the 

cost of installing and maintaining the disposal bins. We found that as of 

April 2017, over a quarter of the 2,233 authorized collectors using 

disposal bins received external funding to pay for the costs associated 

with installing and maintaining the disposal bins. In addition, stakeholders 

told us that some localities have enacted laws known as extended 

producer responsibility ordinances, which require that pharmaceutical 

manufacturers pay for certain costs associated with drug disposal. When 

asked about the costs associated with operating disposal bins, DEA 

officials told us that addressing cost issues with eligible participants falls 

outside of their responsibilities.

Uncertainty: Stakeholders also told us that uncertainty regarding how to 

comply with aspects of DEA’s regulations for prescription drug disposal 

bins affected their decisions to participate. One stakeholder added that 

many eligible entities decide not to participate because uncertainties over 

participation requirements could result in inadvertent non-compliance with 

DEA’s regulations.

As an example of their uncertainty over some of the requirements 

governing the disposal bins, officials from both of the reverse distributor 

stakeholders we interviewed cited DEA’s non-retrievable standard for 

destruction of the inner liners of the bins. DEA requires that the method of 

destruction be sufficient to render all controlled substances nonretrievable, meaning that the physical and chemical conditions of the 

controlled substances must be permanently altered and unusable in order 

to prevent diversion for illicit purposes. Both reverse distributor 

stakeholders told us that they are uncertain about whether certain 

disposal methods meet this standard, and they said that the agency has 

not provided further guidance on how reverse distributors can meet this 

requirement. DEA officials told us that the agency responds to questions 

about whether a specific method of destruction meets the non-retrievable 

standard by telling the registrant to test the remnants after destruction, to 

see if any components of the controlled substance are still present. In its 

summary of the regulations implementing the Disposal Act, DEA stated 

that in order to allow for the development of various methods of 
Page 15 GAO-18-25 Workplace Safety and Health

destruction, the agency did not require a specific method of destruction as 

long as the desired result is achieved.22 However, DEA officials stated 

that to their knowledge, incineration is the only method known to meet the 

non-retrievable standard to date, but the officials hoped other methods 

will be developed in the future.

When asked about the guidance they provide to authorized collectors of 

unused prescription drugs or those eligible to become authorized 

collectors, DEA officials told us that they post frequently-asked questions 

on their website, routinely answer questions from participants and others, 

and give training presentations at conferences that include information on 

the disposal bins. In our prior work, we found problems with DEA’s 

communication and guidance to stakeholders. In 2015, we recommended 

that DEA identify and implement cost-effective means for communicating 

regularly with pharmacies and other entities authorized to handle 

controlled substances.23 DEA agreed with the recommendation, and 

officials told us that, starting in August 2017, these entities can subscribe 

to DEA’s website to receive notifications when it is updated with new

guidance.

Stakeholders also noted that some DEA requirements related to disposal 

bins may conflict with other state and federal requirements governing the 

transportation and disposal of hazardous waste, which includes some 

controlled substances. For example, the two reverse distributor 

stakeholders told us that some incinerator permits issued by states 

require that hazardous waste be examined before incineration; however, 

DEA requirements do not allow the contents of the liners to be examined, 

even at the time of incineration. To address the incinerator permit 

requirements, one reverse distributor told us that they use the 

Environmental Protection Agency’s hazardous waste household 

exemption, which treats the liners as household waste and thereby allows 

incinerator facilities to destroy the liners without examining the contents or 

violating their state permit.24 In addition, some stakeholders raised 

 22See 79 Fed. Reg. 53,520, 53,522 (Sept. 9, 2014).

23See GAO, Prescription Drugs: More DEA Information about Registrants’ Controlled 

Substances Roles Could Improve Their Understanding and Help Ensure Access, 

GAO-15-471 (Washington, D.C.: June 2015). 

24Environmental Protection Agency regulations exclude household waste collected from a 

personal residence from the definition of hazardous waste. 40 C.F.R. § 261.4(b)(I). The 

agency has stated that this exclusion applies even when personal residence waste is 

collected at another location. 
Page 16 GAO-18-25 Workplace Safety and Health

concerns that DEA’s regulations may conflict with other federal 

regulations. For instance, one stakeholder noted that they recently 

learned that transporting the disposal bin’s inner liners could violate 

Department of Transportation regulations. DEA officials told us that they 

were aware of this, explaining that the conflict was between DEA’s 

requirement that controlled substances be transported in liners and the 

Department of Transportation’s requirement that this type of waste be 

transported in sturdy containers. According to DEA officials, this conflict 

has been resolved by the Department of Transportation allowing reverse 

distributors to place the liners inside sturdy containers kept on trucks.

Participation in or Availability of Similar Efforts: Stakeholders said 

that some pharmacies and other eligible entities were already 

participating in other, similar efforts that allow for the safe disposal of 

controlled substances, and therefore they did not want to invest additional 

resources into participating as authorized collectors using disposal bins. 

For example, the Centers for Medicare & Medicaid Services has an 

established process that long-term care facilities use to dispose of their 

unused controlled substances.25 As a result, all of the long-term care 

stakeholders told us that long-term care facilities may choose not to 

partner with pharmacies interested in placing disposal bins within their 

facilities because it adds significant cost and effort without any additional 

benefit. Furthermore, pharmacy stakeholders noted that because of the 

availability of other prescription drug collection efforts in their 

communities, they did not think that maintaining a disposal bin at their 

locations was needed. For example, two of the stakeholders explained 

that local law enforcement precincts already had a similar type of disposal 

bin in place to collect unused prescription drugs.26 DEA officials told us 

that they were aware of other options for the public and entities such as 

long-term care facilities that are not registered as authorized collectors to 

dispose of controlled substances. The officials also indicated that the 

availability of disposal options at law enforcement agencies contributes to 

 25The Centers for Medicare & Medicaid Services requires that nursing homes keep 

records of the usage, disposition, and destruction of all controlled substances and conduct 

periodic reconciliation of records at least monthly, among other requirements. See 

Centers for Medicare & Medicaid Services, “State Operations Manual Appendix PP –

Guidance to Surveyors for Long Term Care Facilities.”

26Federal, state, tribal, or local law enforcement may collect controlled substances from 

ultimate users using disposal bins, among other methods. According to DEA officials, law 

enforcement entities do not have to register to handle controlled substances. These 

disposal bins are not included in DEA data and are outside the scope of our analysis. 
Page 17 GAO-18-25 Workplace Safety and Health

the low participation rates among pharmacies as authorized collectors of 

unused prescription drugs.

We provided a draft of this report to the Department of Justice for 

comment. DEA, part of the Department of Justice, provided technical 

comments, which we incorporated as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Attorney General of 

the United States and the Administrator of DEA. In addition, the report will 

be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-7114 or draperd@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix II.

Debra A. Draper

Director, Health Care

Agency Comments
Appendix I: Entities Eligible to Register with 

DEA to Become Authorized Collectors and 

Participating Collectors, by State, April 2017

Page 18 GAO-18-25 Workplace Safety and Health

Number of authorized collectors

Number of entities eligible to 

become authorized collectors

Percentage of

eligible entities participating

as authorized collectors

AK 19 212 8.96

AL 20 1,687 1.19

AR 12 998 1.20

AZ 56 1,463 3.83

CA 184 8,117 2.27

CO 56 1,205 4.65

CT 1 909 0.11

DC 4 220 1.82

DE 7 323 2.17

FL 131 6,529 2.01

GA 34 2,819 1.21

HI 6 376 1.60

IA 63 954 6.60

ID 13 407 3.19

IL 90 2,795 3.22

IN 63 1,721 3.66

KS 19 1,012 1.88

KY 29 1,486 1.95

LA 30 1,701 1.76

MA 29 1,676 1.73

MD 38 1,835 2.07

ME 3 428 0.70

MI 147 2,896 5.08

MN 57 1,313 4.34

MO 4 1,845 0.22

MS 12 1,089 1.10

MT 29 398 7.29

NC 89 3,541 2.51

ND 88 275 32.00

NE 23 647 3.55

NH 6 376 1.60

NJ 30 2,409 1.25

NM 25 701 3.57

NV 11 668 1.65

NY 85 5,780 1.47

Appendix I: Entities Eligible to Register with 

DEA to Become Authorized Collectors and 

Participating Collectors, by State, April 2017
Appendix I: Entities Eligible to Register with 

DEA to Become Authorized Collectors and 

Participating Collectors, by State, April 2017

Page 19 GAO-18-25 Workplace Safety and Health

Number of authorized collectors

Number of entities eligible to 

become authorized collectors

Percentage of

eligible entities participating

as authorized collectors

OH 75 3,570 2.10

OK 27 1,260 2.14

OR 38 924 4.11

PA 73 3,895 1.87

RI 4 251 1.59

SC 19 1,705 1.11

SD 4 313 1.28

TN 46 2,011 2.29

TX 133 7,413 1.79

UT 46 782 5.88

VA 50 2,182 2.29

VT 7 201 3.48

WA 118 1,824 6.47

WI 58 1,474 3.93

WV 14 728 1.92

WY 8 206 3.88

Total 2,233 89,550 2.49

Source: GAO analysis of Drug Enforcement Administration (DEA) data. | GAO-18-25
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 20 GAO-18-25 Workplace Safety and Health

Debra A. Draper (202) 512-7114 or draperd@gao.gov

In addition to the contact name above, Elizabeth H. Curda (Director), Will 

Simerl (Assistant Director), Kathryn Richter (Analyst-In-Charge), Nick 

Bartine, Giselle Hicks, Jessica Lin, and Emily Wilson made key 

contributions to this report. Also contributing were Muriel Brown and 

Krister Friday.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101287)
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