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Best Practices for CS Waste in ER Setting: CSDPP Core Elements

Best Practices for CS Waste in ER Setting: CSDPP Core Elements


Drug diversion in health care systems is a serious issue in both the United States and Canada.  According to the Society of Hospital Medicine, the US and Canada are the two highest consumers of opioids worldwide per-capita.  Opioids and other controlled substances are diverted from healthcare facilities for nonmedical use contributing to unprecedented mortality due to opioid related deaths.

Drug diversion from hospitals leads to concerns for patient safety, harm to the one diverting drugs and significant liability risks to the healthcare organization.  Hospitals must be committed to following a strict CS diversion prevention program (CSDPP) which includes strict monitoring of CS waste in the ER setting. 

Hospitals across the country are facing a critical problem preventing the diversion of controlled substances.  For example, according to the American Society of Health-System Pharmacists (ASHP), there are several instances of “unexplained losses” of controlled substances such as an endoscopy clinic in the U.S. that realized $10,000 of propofol was unaccounted for.   While transactional errors may not equate to drug diversion, this is a serious issue which highlights areas of improvement in CS waste programs for hospitals, ER settings and acute care clinics.

A comprehensive CSDPP requires leadership oversight, organizational awareness, implementation and evaluation of the effectiveness of CS waste programs.  Hospitals should always work towards continual improvement to ensure strict compliance to their CSDPP and all federal regulations including DEA, EPA and Joint Commission regulations. 

Core Elements of CSDPP 

The core elements of a comprehensive CSDPP include:

Administrative Elements:


-Organizational Oversight

-Legal and regulatory requirements

Provider-Level Controls:

-Storage and security

-Chain of custody

-Internal pharmacy controls

-Prescribing, administration

-Returns, waste, disposal

System-Level Controls:

-Automation and technology

-Monitoring, surveillance

-Investigation and reporting

-Human resources management

These core elements must be applied consistently throughout healthcare organizations.

Risk Factors for Drug Diversion of Controlled Substances in Hospitals and ERs

There are several risk points for drug diversion in hospitals and ER settings.  Examples of the most common methods of drug diversion include:


-Removal of packing slip or purchase order from records

-Stolen DEA form 222 allows unauthorized individuals to order CS

-Compromised product container

Preparation and Dispensing:

-CS waste is removed from an unsecure waste container

-CS waste in a syringe is replaced with saline

-CS waste that is expired is diverted from a holding area


-Written prescriptions may be altered by the patient

-Prescriber may self-prescribe CS

-Prescription pads are stolen and forged


-CS waste is not properly witnessed and is diverted

-CS is diverted while a substitute drug is administered

-Medications may be documented as given but not administered to the patient

CS Waste and Removal:

-CS waste in a syringe is replaced with saline

-CS waste is stockpiled, leading to removal from an unsecure waste container

-Expired CS wastes is diverted from a holding area

Rx Destroyer™ Provides Solutions for CS Waste in the ER Setting 

Rx Destroyer™ provides safe, easy and affordable solutions for CS waste in the ER setting, hospitals, long-term care facilities, educational facilities, pharmacies and other industries.  Our disposal containers come in a range of sizes to accommodate any health care setting with a patented solution that quickly neutralizes medications, meeting DEA and EPA regulations.  Rx Destroyer™ helps to prevent drug diversion with easy CS waste disposal that does not require batteries or adding water.  Simply drop medication in the container and shake.

Our experienced staff provides compliance consultations, on-site and phone support and seamless implementation.  Facilities should always follow federal , state, local, facility, or tribal requirements for safe disposal.

Rx Destroyer™ is dedicated to saving water, saving lives…one prescription at a time.  We help our customers to understand the legal responsibilities of proper CS waste disposal and how to maintain compliance.  Contact us to learn how to get your facility compliant with proper CS waste in the ER setting and healthcare facilities.


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