When Documentation Isn’t Enough: Why ASHP and ISMP Recommend Random Waste Testing

Proper disposal of controlled substances is both a regulatory and clinical responsibility. But documentation alone doesn’t confirm that the medication labeled as “waste” actually contains what it should. Without verification, there’s no way to know if the drug was diverted, diluted, or never present in the first place.

Why Random Testing Matters

Even with strong documentation procedures, the risk of controlled substance diversion remains—especially in high-risk, high-volume areas like anesthesia, perioperative care, and sterile compounding. That’s why guidance from leading safety and pharmacy organizations now emphasizes the need for random testing of injectable waste.

Random testing provides a real-world check on waste practices. It supports compliance efforts, strengthens diversion monitoring programs, and offers a layer of assurance that internal policies are working in practice—not just on paper.

What the Guidelines Say

• ASHP (2022) recommends testing waste in areas with higher potential for diversion. The goal: confirm that the drug recorded as waste is present, unaltered, and not replaced with a substitute like saline.

• ISMP (2023) encourages the use of technologies like refractometers or spectroscopy to test injectable waste—particularly high-alert medications such as fentanyl—on a randomized basis.

Both organizations recognize that physical verification is a necessary step to close gaps in the medication-use process. Testing doesn’t need to happen every time—but without it, hospitals lack critical visibility.

Verifying Waste with Technology

Solutions like WasteWitness® use Raman spectroscopy to verify drug identity at the point of waste—no need to open vials or handle liquid. This allows for fast, automated checks that fit into existing workflows and produce audit-ready results.

By randomly testing what’s labeled as “waste,” compliance teams can better detect red flags, reduce risk, and improve oversight—without disrupting care.

Final Thought

ASHP and ISMP have made it clear: physical testing of controlled substance waste is more than a good idea—it’s becoming a best practice. For pharmacy, compliance, and safety teams, it's a critical tool to ensure waste documentation reflects reality.

References

• ASHP Guidelines on Preventing Diversion of Controlled Substances. Am J Health-Syst Pharm. 2022.

• ISMP Medication Safety Alert. Acute Care Edition. Vol. 28, Issue 5. March 9, 2023.