Environmental Health & Safety

Controlled Substances

The use and possession of "Controlled Substances" is strictly regulated by the Drug Enforcement Administration (DEA). The DEA has issued TSRI a registration that permits the use and possession of schedule III-V as-well-as certain schedule II controlled substances. A list identifying controlled substances and their corresponding schedule is available via the Department of Justice Web site. Under the terms of TSRI's registration possession, use and storage of schedule II controlled substances is limited to:

Authorization Process

Principal Investigators requiring controlled substances must provide Environmental Health and Safety with the following information:

• A listing of each individual that may have access to the controlled substances (order, sign for receipt, use). Have each identified individual sign next to their name.


• Details describing the mechanism utilized to secure the controlled substances (double locking mechanism-a lock box in a locked cabinet). Note that if you use a box/cabinet with a lock, only individuals identified above may have access to the keys and/or combination. It is unacceptable to have the keys left in the lab (keys allowing access to the controlled substances must be in the possession of individuals identified above).


• A sketch of the lab indicating which cabinet will be utilized for securing the controlled substances


• A completed "Controlled Substance Questionnaire" for each individual identified above


• A written agreement to maintain an accurate inventory of the controlled substances(s). An inventory form will be provided by EH&S, but an equivalent form is acceptable.


• Committing to immediately report any suspected loss or theft of controlled substances.

An application/amendment form can be found here. If you are applying for a new authorization complete the form in its entirety and attach a map that shows the location of the storage area. To amend an active authorization fill out the top of the form and only the sections needing to be amended.

EH&S will review all the material submitted and evaluate security mechanisms. DEA must be advised of our intention to add a new controlled substances storage location and they may choose to conduct a site visit. All attempts will be made to keep delays to an absolute minimum; to assure adequate time, please plan on at least a four week delay between submitting the paperwork and receiving authorization to order controlled substances. This four week delay assumes that all security measures are in place when the paperwork is submitted and that the DEA does not have any unusual requirements/questions associated with the use, storage, transfer and/or disposal of the controlled substances.

Use of Controlled Substances

Controlled substances must be handled in conjunction with the following guidelines. Controlled substances:

• May only be used, ordered, transferred, accessed, etc. by individuals who have been approved by EH&S.


• Must be kept secure at all times.


• May only be stored in accordance with, and at the specific location approved by EH&S and the DEA (per the Principal Investigator's correspondence to EH&S).


• May not be stored with any other materials (inclusive of prescription drugs). Items that are not controlled substances may not be stored in the inner/outer "cabinet/box" that is utilized to store the controlled substance. The only exception being the controlled substance paperwork/inventory records.


• Must be accompanied by complete and accurate record keeping.


• Must be disposed via Environmental Health and Safety. Call the EH&S waste line at 4-4093 and leave a message indicating your need to dispose of a controlled substance.


• That are listed as Schedule I require that the PI obtain their own DEA registration. EH&S will assist in this very detailed process.


• That are listed as Schedule II must be limited to those items identified above--if you have a need for other Schedule II materials contact EH&S as soon as possible.


• May not be transported/transferred without the approval of EH&S (see next section for details)


• That are lost/stolen or suspected to be lost/stolen must be immediately reported to EH&S.

Transfer of Controlled Substances

Each transfer will be handled on a case by case basis.
Each request to transfer controlled substances must provide the following:

• The name of the material to be transferred


• The quantity and strength of the material to be transferred


• The name of the individual/institution that the material is being transferred to


• The reason for the transfer


• A copy of the proposed recipient's DEA registration


• The mechanism by which you propose transferring the material


• If the transfer involves schedule I or II controlled substances a completed DEA 222 order form must be provided (the DEA 222 form must be completed by the requesting individual/institution)

Ordering/Receiving of Controlled Substances

• Lab submits completed Purchase Requisition to Office of Sponsored Program (OSP)


• Purchase Requisition is forwarded from OSP to Procurement


• Procurement forwards Purchase Requisition to EH&S


• EH&S approves (as appropriate) the order and returns the purchase requisition to Procurement


• Order is placed


• EH&S picks up all orders of controlled substances from receiving


• EH&S verifies the material is exactly as ordered


• EH&S delivers the controlled substance(s) along with inventory sheets to the lab
  
  (NOTE: controlled substances are only delivered to authorized individuals and authorized locations)


• Lab members sign for and store the material