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Controlled Substances: Managing Inventory

Learn how to manage CS inventory online and maintain CS Log Sheets onsite.

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Online: CS inventory

Manage your CS inventory online in the CSUA application:

  1. Go to the CSUA application: https://ehs.ucsd.edu/csua
  2. Under the My Inventory tab, select the Manage Inventory option to view and update CS inventory.

Update remaining amounts at these times:

On site: CS Log Sheets

CS Usage Log Sheets

EH&S provides a CS Usage Log Sheet for each CS container when an order is picked up by the researcher. Each container is labeled with a unique identification number for ease of inventory tracking. Researchers will use the CS Log Sheet to account for dispensation of the controlled substance in the lab.

Requirement for researchers

Principal investigators are required to keep CS Log Sheets on site in a separate Log Book (see CS Log Book below) and available for periodic audit by EH&S and/or the Drug Enforcement Administration.

The amount of CS in the lab must equal the amount recorded on the Log Sheet at all times.

Routine use:

  • Enter each dispensation of CS on the Log Sheet at the time of use. (See a sample completed Log Sheet.)
  • If using CS on large animals, include the animal identification number in the "reason for use" section.
  • Track Buprenorphine as a box with 5 single-use ampoules on 1 Log Sheet.
  • Print additional CS Log Sheets (PDF) if needed.

Inventory Checks

It is recommended to make periodic checks of the CS inventory you have on-hand. Record these on log sheets as a new line item. Under the “Amount Dispensed” column, enter “0.” Under the “Reason for Use / Animal Protocol / Species” column, write “Inventory check/ Balances Match.”

These inventory checks can be conducted during Biennial Inventory, when there are changes in lab management, during self-audits, monthly or quarterly.

Empty or broken vials:

  • Record empty or broken vials on the Log Sheet and submit a copy to EH&S.
    • Broken vial – If a CS container breaks, enter it on the Log Sheet, initialed by the individual responsible for the accident and co-signed by the PI.
  • Close out the Log Sheet of an empty or broken container by completing the box at the bottom of the first page of the Log Sheet.
  • Record the date of empty bottle disposal and initial the Log Sheet.
  • Promptly upload or send a copy of the completed Log Sheet to the CS Program Manager. Follow these steps:
    • Go to the CSUA application: https://ehs.ucsd.edu/csua
    • In the CSUA application, select the My Inventory tab.
    • Search for the item you want to clear from your inventory.
    • Select the View/Edit button. Change the Remaining Amount value to 0, and upload the Log Sheet.
    • Or, send the Log Sheet to Mail Code 0089 or fax (858) 822-0561.

On site: CS Log Book

Follow these rules for CS Log Books:

  • Keep separate Log Books for Schedule I-II substances and Schedule III-V substances.
  • File copies of these documents in the Log Book:
    • Your Controlled Substance Use Authorization (CSUA) Summary
    • PI-signed Controlled Substance Requisition Supplemental form for each CS order
    • CS Log Sheets; (see sample log sheet)
    • All disposal and return receipts
  • Retain Log Sheets in the CS Log Book for a minimum of 3 years after complete use of container contents or disposal by EH&S.

Important: Report Log Sheet discrepancies, suspected misuse, or theft to the CS Program Manager, (858) 534-1362, immediately.

Biennial inventory

Requirement

The federal Drug Enforcement Administration (DEA) and UCSD PPM 516-7 require an inventory be conducted and documented every 2 years. PIs must declare their inventory status even if there is zero CS in stock when biennial inventory is taken.  The Biennial Inventory is a snapshot of the department’s on-hand Controlled Substance inventory at the “close of business” for that day.  For UCSD’s Biennial Inventory purposes, the “close of business” is 4pm.

Notification of biennial inventory

EH&S will notify the PI and CSUA Lab Contact(s) in at least 30 days in advance by e-mail. You will receive:

  • Specific date to conduct biennial inventory by 4pm
  • Detailed instructions for completing and documenting biennial inventory on the CSUA Web application

Dispose of unwanted inventory

If you no longer need CS, listed chemicals, or California precursors, use the online CSUA application Inventory tab to submit a request to dispose of remaining inventory. Select the CSUA and click Search.

Important: There can be no remaining items in inventory when a CSUA is deactivated.

Self-assessment

Expect an audit of your lab twice per year to evaluate compliance with UCSD's DEA registration. Unannounced spot-audits may be performed.

Recommended self-assessment frequency is based on usage:

  • Labs using 0–5 vials of CS per year, perform self-assessment once per quarter.
  • Labs using more than 5 vials of CS per year, perform self-assessment monthly.

Lab move or closure

Relocation of CS during lab moves or closures is strictly regulated and must be approved by Environment, Health & Safety.

Notify EH&S of the move or closure:

Moving within UCSD

Important: Moving Services must not transport CS.

Get approval to store CS inventory:

New CS storage sites must be approved by the CS Program Manager before relocating inventory. Your CS inventory can be temporarily stored at a secure EH&S facility during your move.

Amend your CSUA

Use the CSUA Web application to amend your CSUA when your existing CS storage site changes in any way:

  1. Go to the CSUA application: https://ehs.ucsd.edu/csua
  2. In the CSUA application, use the My CSUA tab to amend Section 4 - CS Storage Site.

Moving off campus or closing the lab (deactivating a CSUA)

Transfer of CS to another institution or PI is prohibited. Unused CS must be returned to EH&S.

Shipping restrictions

Federal DEA regulations prohibit shipping CS to other institutions or facilities in most cases.

  • For shipping exceptions, like chemically inactivated CS, contact the CS Program Manager, (858) 534-1362.

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Notice: Disposal of hazardous waste using sinks, intentional evaporation, or as regular trash is against the law. Campus laboratories must abide by strict state and federal waste disposal requirements. You may be held liable for violations of applicable laws.