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Controlled Substances: Managing Inventory

Learn how to manage controlled substances (CS) inventory, maintain CS Usage Logs and return CS to the Controlled Substances Program (CSP).

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

Online: CS inventory

Manage 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 Usage Log Sheets

CS Usage Log Sheets

The CSP 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 CSP 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 approved CS 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 CS 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 CS Usage Log at the time of use. The individual listed under “Person Dispensing Substance” on the CS Usage Log must be the one administrating the CS in the experiment/animal. See a sample completed CS Usage Log (PDF).
  • Do not dispense more CS from the original container than what is needed for the same day’s experiments.  
  • Do not alter contents of the original CS 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 CS Usage Log.
  • If using CS on USDA-covered species, include the animal identification number in the "Reason for Use" column.
  • If making a solution/dilution, log the amount dispensed from the original container to make the solution on the CS Usage Log at the time the mixture is made. Any chemical container, including CS dilutions, must be labeled with its contents, expiration dates and the final concentration of each component. If using dilutions in animals, see the UCSD Guidelines for Dilution, Mixture, and Use of Secondary Containers for Injectable Drugs Used in Animals for IACUC-approved dilution procedures and labeling.
  • Do not record the usage of a solution/dilution on the CS Usage Log meant for the original container. If desired, the amount dispensed from a solution/dilution container may be recorded by printing a CS Solution Usage Log (PDF).
  • Track the use of breakable Buprenorphine ampoules by logging each of the 5 single-use ampoules individually.
  • Print additional pages for the CS Usage Logs (PDF) 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 inventory checks at the following times:  

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

While conducting the inventory checks, assess the remaining amount in the CS container, review the CS Usage Log for mathematical errors and ensure the remaining log balance matches the physical amount. See sample CS Usage Log for details for proper log use.

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 CS Usage Log discrepancies, suspected misuse, or theft to the PI and CS Program Manager (ehscs@ucsd.edu or 858-534-9016) immediately.

On site: Expired Inventory

When a CS has reached the expiration date it must no longer be used in animal studies. Please refer to the IACUC policy regarding the use of expired materials in animals. These expired items should be labeled with “Expired Not for Use in Animals” and continue to be stored in the approved CS storage area until the item is disposed of with the Controlled Substances Program. Once the item has expired and has been labeled the researcher should submit a disposal request for the item.

On site: Empty CS container disposal

Empty vials

A controlled substance (CS) container is empty when there is no movable liquid or powder left in the container and the CS Usage Log shows 100% usage. Any CS containers, including dilutions that have movable liquid or powder must be returned to the CSP for disposal (ehscs@ucsd.edu or 858-534-9016).

How to dispose of a completely empty CS container:

  1. Deface the container’s label.
  2. Place the empty bottle(s) in a bag and tag them with a Hazardous Waste Tag:
    1. Content = Chemical Waste
    2. Chemical Waste = Lab Trash contaminated with chemicals
    3. Physical State= Solid
    4. Hazard Properties= ToxicWaste Tag
  3. Schedule a pickup of the items with EMF.

 Complete the CS Usage Log:

  1. Review the CS Usage Log for accuracy and completeness.
  2. Fill out the box for Option 1 at the bottom of the CS Usage Log.
  3. Promptly upload or send a copy of the completed CS Usage Log to the CSP:
    1. Upload:
      1. Go to the online CSUA application 
      2. In the CSUA Application, select the My Inventory tab
      3. Search for and select the empty vial's container ID
      4. Select the View/ Edit button to open the Inventory Details page
      5. Change the Remaining Amount to 0 and upload the CS Usage Log
    2. Alternatively, send a copy of the CS Usage Log to ehscs@ucsd.edu or fax (858) 822-0561
  1. Retain the original CS Usage Log in the CS Log Book for 3 years after the date of disposal.

Report CS Usage Log discrepancies, suspected misuse, or theft to the PI and CS Program Manager (ehscs@ucsd.edu or 858-534-1362) immediately. 

Refer to the Blink page for information and instructions on how to dispose of empty hazardous materials containers.

Broken vials

Notify the CSP about the broken vial(s) as soon as it is discovered. Inform the CSP of how much CS was in the bottle at the time the vial was broken, give a brief description of the incident, and provide pictures if possible.

  • Record broken vials on the CS Usage Log, fill out the box at the bottom of the form and submit a copy to the CSP.
    • 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 CS Usage Log.
  • Promptly upload or send a copy of the completed CS Usage Log to the CSP.
    1. Go to the online CSUA application.
    2. In the CSUA application, select the My Inventory tab.
    3. Search for and select the empty vial's container ID.
    4. Select the View/Edit button to open the Inventory Details page.
    5. Change the Remaining Amount 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 item 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 the CSP.

Follow these rules for CS Log Books:

  • Keep separate CS Log Books for Schedule I, II and Schedule III-V substances.
  • File copies of these documents in the CS Log Book:
    • Current CSUA Summary
    • PI-signed Controlled Substance Requisition Supplemental form for each CS order
    • CS Usage Logs; (see CS Usage Log, PDF)
    • All disposal and return receipts
  • Secure the CS Log Book in the approved CS storage area. Read CS Storage Requirements.
  • Perform regular lab self-assessments to ensure safety compliance, including the CS self-assessment to evaluate CS Program compliance throughout the year. 

 

Below are the document retention schedules and suggested retention binder locations for each of the required CS documents in the CS Log Book:

 

List of document retention schedules and suggested retention binder locations for each of the required controlled substance documents in the controlled substances Log Book

Document Type

Retention Schedule

Binder Tab Location

CS Self-assessment

Keep CS Self-assessments for the past three years

In front of CSUA tab

CSUA Summary

Keep the most current version of the CSUA Summary in the CS Log Book at all times

CSUA Tab

CS Requisition Supplemental Forms

Keep the PI signed CS Requisition Supplemental Forms in the CS Log Book from the time the order is placed until 3 years after the date of complete usage of the item(s), or the item(s) are disposed with the CS Program

CS Order Tab

Current CS Usage Log Sheets

Keep the CS Usage Log Sheets for the inventory items currently in use in the CS Log Book or with the CS items at all times

Current Logs Tab

Completed CS Usage Log Sheets

Keep the CS Usage Log Sheets for the inventory items that have been completely used up or disposed of with the CS Program for 3 years after the date of complete usage or disposal

Complete Logs Tab

Controlled Substance Disposal Chain of Custody Forms

Keep the Controlled Substance Disposal Chain of Custody Forms for 3 years after the date of item disposal with the CS Program

CS Disposals Tab

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 conducted. 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 CSP 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 CS, CS dilutions, Listed Chemicals, or California Precursors are no longer needed, use the online CSUA application's My Inventory tab to submit a request to dispose of remaining inventory. See Controlled Substances: Disposal to learn how to return CS to the CSP for disposal.

Alternatively, disposal requests can be made by contacting the CSP at ehscs@ucsd.edu.

Self-assessment

Expect an audit of the 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 CSP prior to the move. 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 CSP before relocating inventory. Contact the Controlled Substances Program, (858) 534-1362 or (858) 534-9016, for CS storage consult and approval.
  • The lab's CS inventory can be temporarily stored at a secure CSP facility during the move.
  • See CS: Storage Requirements to ensure the new storage facility is in compliance.

Amend the CSUA using the online CSUA application when relocating or closing the lab's 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 CSP 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 CSP.

  • Return unused inventory to the CSP:  
  • Deactivate the CSUA:

Shipping restrictions

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

  • For inquiries regarding CS shipments contact the CSP, (858) 534-1362.
For more information, contact EH&S Controlled Substances Program, (858) 534-1362 or (858) 534-9016.
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.