The Association for the Healthcare Environment (AHE) is asking the Drug Enforcement Administration (DEA) to reconsider part of a proposed rule on controlled-substance disposal that AHE officials say would require needless manual record-keeping of automated information.

AHE also is asking DEA to clarify what it means by a "non-retrievable substance" so there is no uncertainty about what method of destruction of controlled substances is acceptable to DEA.

DEA proposes that hospitals be required to maintain a paper record of controlled-substance destruction as part of a proposed rule on management and disposal of such substances, which is addressed in the Safe and Responsible Drug Act of 2010.

In a Feb. 19, 2013, letter to DEA Administrator Michele M. Leonhart, AHE states that the requirement would burden clinicians with more paperwork because essential data related to substance disposal already are maintained through the use of automated dispensing cabinets and machines. The added paperwork would reduce time spent for patient care, AHE says.

DEA proposes that destroyed substances become "non-retrievable," which it defines as "permanently altering its physical and/or chemical state through irreversible means to render it unavailable or unusable."

AHE wants clarification because the proposal does not specify how the substances should be destroyed. For example, it is unclear if new technology such as sequestration sinks meets the DEA requirement.

The proposal does not state whether substances rendered non-retrievable can be shipped or transported as solid waste without additional documentation or monitoring by the Department of Transportation.

The proposed rule also says flushing does not render drugs non-retrievable but in many smaller health care settings it is the only short-term option available, according to AHE. Flushing meets the non-retrievable definition and needs to remain an option, AHE says.