I don't really consider it SI exactly, but I do consider it similar. I've done similar things while trying to stop SI and realized it was almost always for the same reasons that I would SI in the first place.
Are you taking them for the reason they were prescribed and just taking more or are they extra pills leftover from something and you don't actually still need them? If you don't actually need them for anything anymore I think you should throw them away. Pain pills are addictive and even though you said its not near the max dose it could get closer and closer to it once the amount you're taking now starts to not work as well.
Sorry if I asked any questions you already answered