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Controlled Substances: Managing Inventory

Learn how to manage controlled substances (CS) inventory online and maintain CS Usage Logs onsite.

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Online: CS inventory

Manage your CS inventory online in the CSUA application:

  1. Go to the CSUA application.
  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 assigns a container ID and generates a corresponding CS Usage Log for each item upon receipt of new shipments. Orders and the corresponding CS Usage Logs can be picked up by Authorized Personnel from the CS program by appointment. Authorized Personnel must document the CS use on the provided CS Usage Log to record each CS dispensation from the original container at the time it is dispensed. 

Requirement for Authorized Personnel

Principal Investigators are required to keep CS Usage Logs in a designated CS Log Book on site and in the EH&S approved storage area (see CS Log Book below). CS Usage Logs must be readily available for periodic audit by EH&S and/or the Drug Enforcement Administration (DEA).

  • The physical amount of CS in the original container must equal the remaining amount recorded on the Usage Log at all times. 
  • Only approved CS Authorized Personnel are permitted to use CS in accordance with the protocols listed on the CSUA. 
  • Do not share CS with non-Authorized Personnel (refer to CSUA for Authorized Personnel list). 
  • Do not dispense or log out CS for use by others.

Routine use

  • Enter each dispensation of CS on the Usage Log at the time of use. The individual listed under “Person Dispensing Substance” on the Usage Log must be the one administrating the CS in the experiment/animal. (See a sample completed Usage Log.)
  • Do not dispense more CS from the original container than what is needed for the same day’s experiments.  
  • Do not alter contents of original container.  Do not add anything to or make solutions in the original container. The CS Usage Log records the usage of the container’s contents as originally supplied.
  • Controlled substances shall not be transferred from the original containers for storage and/or inventory purposes.
  • Record the amount dispensed and the amount remaining in the same units as documented on the first line of the log sheet.
  • If using CS on large animals, include the animal identification number in the "Reason for Use" section.
  • If making a solution/dilution, log the amount dispensed from the original container on the CS Usage Log at the time the mixture is made.
  • Do not record the usage of a solution/dilution on the CS Usage Log for the original container. If desired, you can record the amount dispensed from the solution/dilution by printing a CS Solution Usage Log.
  • Track the use of buprenorphine by logging out each of the 5 single-use ampoules individually.
  • Print additional pages for the CS Usage Logs if needed.

Inventory checks

CS Inventory checks are required at the time of CSUA renewal and Biennial Inventory. It is also recommended to make periodic checks at the following times:  

  • Changes in CS Authorized Personnel or Lab Contacts
  • During quarterly self-audits (monthly for high use labs)

Record these inventory checks on CS Usage Logs as a new line item. Under the “Amount Dispensed” column, enter “0”, and under the “Reason for Use / Animal Protocol / Species” column, write “Inventory check/ Balances Match.”

Report log discrepancies, suspected misuse, or theft to the EH&S Controlled Substances Program Manager and PI immediately.

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

Broken vials

  • Record broken vials on the CS Usage Log, fill out the box at the bottom of the form and submit a copy to the CS program.
    • Broken vials can be recorded on the CS Usage Log by making a note that is initialed by the individual responsible for the accident and co-signed by the PI.
    • Record the date of empty bottle disposal and initial the Usage Log.
  • Promptly upload or send a copy of the completed CS Usage Log to the CS program:
  1. Go to the online CSUA Application.
  2. In the CSUA Application, select the My Inventory tab.
  3. Search for and select the broken vial’s container ID.
  4. Select the View/Edit button to open the Inventory Details Page.
  5. Change the "Remaining Amount" value to 0, and upload the CS Usage Log.
  • Alternatively, send a copy of the CS Usage Log to ehscs@ucsd.edu, Mail Code 0090, or fax (858) 822-0561.
  • Keep the original CS Usage Log in the CS Log Book for three years after the date of disposal. 

On site: CS Log Book

CS Log Books contain all documents pertaining to the CSUA and the CS inventory disposition. These documents include the CSUA, the CS Requisition Supplemental forms, CS Usage Logs, and CS Disposal Chain of Custody forms. CS Log books are provided by EH&S.

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 CS Log Book:
    • Your Controlled Substance Use Authorization (CSUA) Summary
    • PI-signed Controlled Substance Requisition Supplemental form for each CS order
    • CS Usage Logs; (see sample Usage Log)
    • All disposal and return receipts
  • Secure the CS Log Book in the CS Storage Area. Read CS Storage Requirements.
  • Ensure only approved Authorized Personnel have access to CS.
  • Retain CS Usage Logs in the CS Log Book for a minimum of 3 years after the complete use of container contents or disposal by EH&S.

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

Biennial inventory

Requirement

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

Notification of biennial inventory

The CS Program will notify the PI and CSUA Lab Contact(s) of the biennial inventory date at least 30 days in advance by email. The email details will include:

  • The specific date to conduct the biennial inventory
  • Instructions for submitting the biennial inventory through the CSUA Application 

Dispose of unwanted inventory

If you no longer need CS, Listed Chemicals, or California Precursors, use the online CSUA Application’s My Inventory tab to submit a request to dispose of remaining inventory. See the Controlled Substances: Disposal to learn how to return CS to EH&S for disposal.

Self-assessment

Expect an audit of your lab twice per year to evaluate compliance with UC San Diego’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 the CS Program. Movement between certain UC San Diego facilities may be prohibited. 

Notify EH&S of the move or closure

For CS moves within UC San Diego

Moving Services must not transport CS.

Get approval to store CS inventory:

  • New CS storage sites must be approved by the CS Program before relocating inventory. Contact the Controlled Substances Program, (858) 534-1362 or (858) 534-9016, for CS storage consult and approval.
  • Your CS inventory can be temporarily stored at a secure EH&S facility during your move.
  • See CS: Storage Requirements to ensure your new storage facility is in compliance.

Amend your CSUA using the online CSUA application when relocating or closing your existing CS storage site:

  1. Go to the CSUA application.
  2. In the CSUA application, use the My CSUA tab to amend Section 4 - CS Storage Site.
  3. The CS Program will follow up with the lab regarding the change.

All parties will be notified if the new storage location is approved. 

For CS moves off campus or lab closure (deactivating a CSUA)

Transfer of CS to another institution or PI is prohibited. Unused CS must be returned to the CS Program.

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.