What is pharmaceutical reverse distribution, and what materials can they accept?

The reverse distribution system is a means to facilitate the return of and credit for pharmaceutical products. Health care providers, such as pharmacies, clinics, hospitals and veterinary clinics, can send unused products to a reverse distributor in order to receive credit from the manufacturer. Because the product is considered to have value, it is not regulated as a waste. Reverse distributors can also accept Drug Enforcement Agency (DEA) controlled substances, as long they have not been distributed to the end user.

Only pharmaceuticals that are eligible for credit should be sent to the reverse distributor. Reverse distributors are not waste management facilities and are not allowed to accept waste or waste-like materials, such as partial packages, compounded IV's, broken or spilled materials, patient's personal medications or samples from pharmaceutical representatives. Review the returned drug and waste drug reports and discuss credit rejections with the reverse distributor. Products that are never eligible for credits must be properly managed as a waste, and not sent to a reverse distributor.

The department's Guidance for Safe Management of Household Pharmaceuticals [PDF 2.4MB] allows reverse distributors to accept pharmaceutical waste from household collection events (Clean Sweeps). Under the terms of the guidance, reverse distributors may not accept controlled substances or any waste from businesses or institutions which may have brought their waste or unused pharmaceuticals to a collection event. All collected pharmaceuticals must be managed in accordance with the guidance memo.

Reverse distributors must properly manage any hazardous waste that is generated as part of their business activities or accepted from household collection events. For more information on the hazardous waste rule requirements, see the NR 600 series administrative rules at: http://www.legis.state.wi.us/rsb/code.htm [exit DNR]

For more information on collecting pharmaceuticals refer to the DNR hazardous waste program's Pharmaceutical Waste.