Destruction of controlled substances by licensed dealers (CSP-GUI-020): Guidance
On this page
- Before applying for a destruction
- Obtaining authorization for a destruction
- Conducting the destruction
- After the destruction
- Loss or theft
- Unannounced compliance verification by a Controlled Substances Program inspector
Before applying for a destruction
Environmental and safety considerations
Prior to applying for a destruction, you must ensure that the proposed destruction method complies with all applicable federal, provincial and municipal environmental protection legislation and will not present any health or safety hazards.
Storage and security
The Senior Person in Charge (Senior PIC), Qualified Person in Charge (QPIC) or an Alternate QPIC (A/QPIC) is responsible for ensuring that adequate measures are in effect for the secure storage of unserviceable controlled substances. You must store products awaiting destruction in an approved secure environ, such as a safe or vault, specified on your dealer’s licence. You should have an appropriate system in place to ensure that the value of the controlled substances stored in your secure environ does not exceed the maximum street value permitted under your licence.
If the product will be destroyed at a disposal company that is not a licensed dealer, a QPIC and qualified witness from the responsible licensed dealer must maintain security of the shipment during transportation and be present during the destruction process until the controlled substances are destroyed.
If you only handle post-consumer returns, they must be stored in a secure, restricted-access area with sufficient space to prevent diversion. As these products are typically mixed with other prescription and non-prescription medications and have no known illicit street value, they do not count toward the maximum street value permitted under your licence.
If you handle serviceable stock, unserviceable stock and post-consumer returns, ensure that the serviceable stock and unserviceable stock are stored separately from the post-consumer returns.
Obtaining authorization for destruction
Unserviceable stock
Destructions under $750,000 – Unwitnessed destructions
If the total street value of the destruction is less than $750,000, you may destroy the controlled substances without the presence of a Controlled Substances Program (CSP) inspector after receiving authorization from the CSP. You are required to submit a destruction application for review at least 10 business days in advance of the planned destruction date.
Destructions $750,000 and above – Witnessed destructions
If the total street value of the destruction is more than $750,000, you must contact the CSP to schedule a witnessed destruction with the presence of CSP inspector(s) at least 25 business days in advance of the planned destruction date.
Application requirements
All applications concerning the destruction of controlled substances will only be accepted using the national destruction application template. Contact the CSP at destructions@hc-sc.gc.ca to obtain further information on the application process and service standards.
Before destroying any unserviceable drug products containing controlled substances, you must submit a destruction application to the CSP. Once the application has been reviewed and accepted, you will receive an authorization from the CSP allowing you to destroy the controlled substances on the date proposed in the application.
All applications must contain, at minimum, the following:
- Your name, title (if applicable) and municipal address;
- Active licence number;
- Date of the application;
- A unique destruction identification number;
- The reason for destruction;
- The date, time and location of the destruction;
- A brief outline of the proposed method of destruction;
- The total street value and the total weight of all the substances to be destroyed;
- Name and qualification of the witnesses (refer to section Witness requirements), including the province of registration for those registered as health professionals; and
- A signed attestation indicating that the proposed method of destruction conforms with all applicable federal, provincial and municipal environmental legislation and that all information submitted in support of the application is correct and complete to the best of the QPIC or A/QPIC’s knowledge.
The QPIC and/or A/QPIC should conduct a complete reconciliation of the controlled substances for destruction and enter this information into the table provided in the application form. The table should contain the most accurate and up to date information of the products including the following:
- Product name;
- Drug identification number (DIN), if any;
- Dosage form/bulk;
- Strength per unit of controlled substance and the unit of measurement (such as mg, mg/ml, percent);
- Total quantity for destruction (such as dosage units, volume, net weight, number of packages, skid weight);
- Name of controlled substance active ingredient, as listed on the licence (such as lorazepam);
- Street value of controlled substance per unit (such as $25,000/kg for lorazepam);
- Total quantity of controlled substance active ingredient weight in kg;
- Conversion factor (see below paragraph);
- Total weight of the substances to be destroyed (including the weight of packaging components if available); and
- Total street value.
In order to determine the quantity of a controlled substance in its base form, the following formula can be used to calculate the conversion factor, which is used when a product contains controlled substances in a salt derivative form.
Conversion factor = [molecular weight of base] / [molecular weight of salt]
The International Narcotics Control Board (INCB) also provides a list of common derivatives in the Yellow List and Green List. These lists include tables that show conversion factors for drugs in their ester, ether and salt forms, calculated on the basis of the pure anhydrous drug content.
The street value of the substances to be destroyed should be calculated using the prices listed in the Directive on Physical Security Requirements for Controlled Substances and Drugs Containing Cannabis. It is your responsibility to contact the CSP to confirm the street value if a controlled substance is not on the list.
It is important to ensure that applications are correct and complete to the best of the QPIC or A/QPIC’s knowledge. Applications requiring amendments or further clarification may take longer to process. When the application is inadequate, it will be sent back to you and it will not be processed until the inadequacies are addressed. Examples of this may include, but are not limited to, missing required fields, incorrect conversion factor use, or missing signatures.
Multiple destruction applications
You can submit a maximum of two unwitnessed destruction applications with the same proposed date of destruction. The following requirements have to be met for the applications to be accepted:
- Each destruction must have a unique destruction identification number;
- Each destruction must take place at a different time if the same witnesses are listed;
- Witness packets and relevant documents, such as the Certificate of Destruction, must indicate destruction times as proposed; and
- Each destruction must be transported and destroyed separately, if it is destroyed off-site.
Changes to authorized destruction applications
If you need to make any changes to the original authorized destruction application, notify the CSP by email at minimum 1 business day prior to the scheduled date of destruction.
You must submit an amended destruction application for any changes to an authorized destruction, specifying all the changes and an explanation for the changes. Such changes can include, but are not limited to, changes in witness(es) and/or the date/time of destruction. Any change to the list of controlled substances to be destroyed, including the quantity, requires a new application to be submitted to the CSP for review. Once the amendment has been submitted, the previous authorization is no longer valid.
If you are not able to carry out the destruction as scheduled due to unforeseen circumstances (e.g., incinerator malfunction, witnesses unavailable), you must notify the CSP by email within 24 hours of the previously authorized date. An amended and signed application with the new proposed date and all applicable changes must be submitted to the CSP at least 1 business day prior to the new destruction date.
Post-consumer returns
Following implementation of the CSR on October 1, 2026, licensed dealers specializing in destruction must submit an application and obtain authorization for destruction from the CSP before destroying finished products that have been previously returned by an individual for the purposes of destruction, also known as post-consumer returns.
Post-consumer returns do not have a street value as they can be mixed in with other controlled and non-controlled substances.
These destructions typically do not require the presence of a CSP inspector, unless deemed necessary.
You are required to submit a destruction application for review at least 10 business days in advance of the first planned destruction date.
Application requirements
All applications concerning the destruction of post-consumer returns will only be accepted using the national destruction application template. Contact the CSP at destructions@hc-sc.gc.ca to obtain further information on the application and service standards.
Before destroying any post-consumer returns, you must submit a destruction application to the CSP. Once the application has been reviewed and accepted, you will receive an authorization from the CSP allowing you to destroy post-consumer returns within a specified validity period.
All applications must contain, at minimum, the following:
- Licensed dealer’s name, address and valid controlled drugs and substances licence number;
- Date of the application;
- A unique licensed dealer application ID;
- The location of destruction;
- A brief outline of the proposed method of destruction;
- A list of authorized personnel to act as witnesses during the destruction validity period, mentioning their name, position, and qualification, including the province of registration for those registered as health professionals; and
- A signed attestation indicating that the proposed method of destruction conforms with all applicable federal, provincial and municipal environmental protection legislation and that all information submitted in support of the application is correct and complete to the best of the QPIC or A/QPIC’s knowledge.
You are not required to include the total quantity of controlled substances as this cannot be determined for post-consumer returns. Instead, you must record the identifier marked on the collection container of the post-consumer returns and the number of collection containers being destroyed. This information does not need to be submitted to the CSP with your application. However, these records must be retained on-site and made available upon request by CSP inspectors.
Upon approval, the CSP will issue a destruction authorization specifying the validity period during which post-consumer returns may be destroyed. You are not required to obtain a separate destruction authorization for each individual destruction conducted within the validity period. The validity period will start from the date the application was approved by the CSP.
Changes to authorized destruction applications
You must provide an amended destruction application for any changes to an authorized destruction, specifying all the changes made to the initial application, as well as an explanation for the changes. Such changes can include, but are not limited to, changes in the method of destruction and list of witnesses.
Conducting the destruction
Witness requirements
The destruction is required to be carried out in the presence of at least two of the following persons:
- At least one of the witnesses must be the Senior PIC, QPIC, or an A/QPIC; or
- The second witness can be a person who works for or provides services to the licensed dealer and holds a senior position (such as Manager, Vice President, etc.).
No other person shall be present at the destruction unless their presence is required for one or more of the following reasons:
- To physically handle the controlled substances;
- To operate the equipment used to destroy the controlled substances;
- To undertake the destruction (which may be one of the qualified witnesses);
- To act as a witness;
- To observe the destruction in an official capacity as a CSP inspector; or
- To carry out law enforcement duties as a police officer.
You may have more than two witnesses present if required for security or operational reasons, provided their presence does not reduce the security of the controlled substances. Witnesses cannot leave the destruction site until all controlled substances are destroyed.
When a destruction takes place off-site, you are responsible for ensuring all witness requirements are met. This includes the qualified personnel maintaining security during transportation, and witnessing the destruction of the controlled substances.
Destructions that require witnessing by CSP inspectors
You are required to implement occupational health and safety measures that are necessary to reasonably ensure the safety of the inspector(s) and other personnel during the witnessing of the destruction. The inspector(s) may contact you to confirm that safety measures are in place prior to scheduling a destruction date.
The CSP inspector(s) will conduct product reconciliation at your site, witness transportation of the products (if applicable) and witness the destruction of the products. You need to ensure that there is adequate time for the inspector(s) to conduct their duties prior to destruction.
In situations where significant deficiencies are identified during reconciliation, the destruction may be halted and you may be required to submit a corrective action plan to the CSP prior to the destruction taking place.
Depending on the total street value of the destruction, the use of an escort to ensure the security during transportation should be evaluated and discussed with the CSP.
Methods of destruction
The method of destruction must alter or denature the controlled substances to such an extent that consumption has been rendered impossible or improbable. You should be aware that the method of destruction may vary from substance to substance depending on its chemical or physical properties. It is your responsibility to ensure that all controlled substances are adequately destroyed by the proposed method of destruction.
Incineration is the preferred method of destruction; however, other methods of destruction may be considered for the instances listed under section Denaturation. You are encouraged to consult the respective controlled substance monographs when determining appropriate methods of destruction.
You must carry out destructions in compliance with all applicable federal, provincial, and municipal environmental legislation or bylaws.
Incineration
The incinerator must:
- Retain all controlled substances on, or above, any grate contained therein until they are destroyed;
- Only have one opening, excluding the chimney. Should there be more than one such opening, then all openings must be under the constant vision of the witnesses unless the openings are locked in such a manner that controlled substances cannot be removed without the witnesses’ knowledge; and
- Reach a temperature of at least 400 °C during the destruction cycle.
Denaturation
Chemical destruction (denaturation) can be used in instances where:
- Incineration will not meet federal, provincial or municipal environmental laws;
- Incineration may result in a health hazard to either those destroying the controlled substances or to the general public;
- The type of material being destroyed may damage an incinerator or is incompatible with incineration; or
- There is no incinerator available in the vicinity of the licensed dealer.
In your application, you should provide a description of the method of destruction, such as the quantity of denaturing agent to be used, the period of time the mixture will be stirred/settled, and what will be done with the resulting chemical waste components (i.e. incinerated as pharmaceutical waste).
The following are examples of denaturing methods:
- Mixing the products with strong acids such as hydrochloric acid, nitric acid, sulfuric acid, or strong base such as concentrated sodium hydroxide and disposing of waste products in accordance with environmental regulations; or
- Mixing the products with radioactive or halogenated waste and disposing of waste products in accordance with environmental regulations; or
- Mixing the products with a combination of denaturing agents and incinerating the waste.
After the destruction
Record-keeping
Within 24 hours of completing the destruction, the two witnesses and the person undertaking the destruction must sign and date a witness declaration containing the following:
- The name and title of the witnesses;
- The date, time, location and method of the destruction;
- The unique destruction identification number; and
- A statement indicating that the witnesses attest to witnessing the destruction of all the controlled substances listed in the application.
You must retain and maintain the original records at your site for at least 2 years in a manner that permits an audit to be made at any time. These records must be easily retrievable upon request by Health Canada.
Submitting records to the Controlled Substances Program
For licensed dealers destroying unserviceable stock, you must forward the witness declaration to the CSP within 15 business days of the destruction date. The witnesses and person undertaking the destruction must sign the application form.
For licensed dealers destroying post-consumer returns, there is no requirement to send the witness declaration to the CSP after the destruction has occurred. However, you are responsible for completing this document after each post-consumer returns destruction.
Loss or Theft
You must report any loss or theft to Health Canada. Please refer to Guidance on reporting loss or theft of controlled substances and precursors (CS-GD-005). This applies equally to unserviceable stock and to post-consumer returns.
You are responsible for taking all reasonable steps necessary to protect controlled substances against loss or theft.
Unannounced compliance verification by a Controlled Substances Program inspector
All destruction applications with a street value of less than $750,000 may be subject to compliance verifications by CSP inspector(s) to verify that the information listed in the application is accurate and that the requirements of the destruction process are met.
In situations where significant deficiencies are identified during a compliance verification, the destruction may be halted and you may be required to submit a corrective action plan prior to receiving subsequent authorizations for destruction.