Controlled Substances: FAQ
Last Updated: March 3, 2024 7:39:46 AM PST
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Expand section Frequently Asked Questions
Are all drugs controlled substances (CS)?
No, most drugs are considered pharmaceuticals and are not CS. Examples of drugs that are not CS are Donepezil, Xylazine, and Atropine.
Search the U.S. Drug Enforcement Administration (DEA) List of Controlled Substances (PDF) to see if a drug is considered a CS. Another way to tell if a drug is a CS, is to check the label for the letter “C” with a Roman numeral I through V next to it (example: C-IV). This method will not work if the item was made prior to becoming scheduled.
What are schedule numbers and DEA codes?
The federal government assigns each CS a schedule number (I through V) according to its medicinal value, harmfulness, and potential for abuse or addiction. The DEA code is a 4-digit number assigned to each CS. Find schedule numbers and DEA codes at the DEA website.
A higher schedule number indicates the substance has more medicinal value and less potential for abuse or addiction. The letter "N" can also accompany the schedule number, signifying the substance is a non-narcotic. If the DEA website has "N" in the NARC column, the item is a non-narcotic and is denoted by the Roman numeral and an “N” (e.g., IIN). If the DEA website has a "Y" in the NARC column, the item is a narcotic and is denoted so by the absence of the "N" (e.g., II).
The most common CS used in research and their schedule numbers and DEA codes are:
Substance | Schedule | DEA Code |
---|---|---|
Ketamine | IIIN | 7285 |
Pentobarbital (e.g., Nembutal, Fatal Plus) | IIN | 2270 |
Buprenorphine | III | 9064 |
Fentanyl | II | 9801 |
Diazepam | IVN | 2765 |
Pentobarbital & non-controlled active ingredients (e.g., B-Euthanasia) |
IIIN | 2271 |
How do I manage my Authorized Personnel?
Use the CSUA application to manage your Authorized Personnel (AP). From the My CSUA tab, PIs and CSUA Lab Contacts can add or remove Authorized Personnel, assign privileges, upload PSDS Forms for Controlled Substances Program review, and view the approval status of individuals.
How to manage AP online:
- Go to the online CSUA application.
- Under the My CSUA tab, select My CSUA list.
- Select the appropriate CSUA and click the ‘View/ Amend CSUA’ button at the bottom of the screen.
- Using the navigation on the left side of the screen, click on section 3-Authorized Personnel to manage the AP list.
- Use the search utility at the bottom of the screen to find the person to be added.
- Click the radio button next to the name of the person to be added and click the ‘Add to Personnel List’ button.
- Designate the person’s additional responsibilities:
- Authorized Recipient – those with the privilege to pick up CS packages when they arrive at EH&S
- Storage Key/Code – those with access to the CS Storage Key or Combination Code
- Be sure to click the ‘Save’ button at the bottom of the page to save the changes
- Designate the person’s additional responsibilities:
When an individual is added to the AP list, an e-mail notification is automatically sent to the individual instructing them to complete 2 actions:
- Submit a Personnel Screening Data Sheet- Applicant form.
- Complete the required Controlled Substances Training eCourse on UC Learning Center.
See Controlled Substance Use Application, under "Manage Authorized Personnel" for more details.
Why do Authorized Personnel applicants need to fill out a Personnel Screening Data Sheet (PSDS)?
Diverting CS from research purposes is one way CS are acquired for illegal recreational use. The PSDS helps restrict CS access to Authorized Personnel, and identify and prohibit access to people with a criminal history of CS diversion or other disqualifications.
The PSDS also documents the individual’s acknowledgement of responsibility to notify the CSP of CS loss or diversion.
Where do I find the PSDS Form?
Select the appropriate PSDS Form (PDF) below:
- Individual Applicant – CSUA Lab Contacts and other individuals
- Principal Investigator – for PIs only
Read and follow instructions at the top of the form.
What do I do with empty CS bottles?
First, make sure all of the CS in the inventory has been accounted for on the CS Usage Log and make sure that the bottle is completely empty. The CSP defines completely empty, as no movable droplets or solids in the container. 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).
More information and stepwise instructions on how to dispose of empty CS containers can be found on the CS Disposals page.
What are "listed" chemicals?
Listed chemicals, are chemicals that may be used to manufacture CS and are regulated by the DEA. California’s Department of Justice has an overlapping list and are often referred to as precursor chemicals. List I chemicals and CAlifornia's precursor list of chemicals are controlled in order to prevent the illicit manufacture of CS. Examples of listed chemicals include Methylamine, Pseudoephedrine and Piperidine.
Why can't I order listed chemicals for my lab directly from the vendor?
Chemical vendors who sell, transfer, or furnish listed chemicals must report to the state or federal government who purchased the chemical and for what purpose. To facilitate in making this report, chemical vendors increasingly require a DEA registration number to purchase List I and California precursor chemicals.
To acquire listed chemicals for nonclinical (research or teaching) purposes, you must have a CSUA from Controlled Substances Program (CSP) prior to obtaining listed chemicals. CS orders are placed in the CSUA application. A DEA code and schedule number do not apply to these items.
How do I store my listed chemicals?
Store listed chemicals according to their hazard type described on Chemical Storage and Inventory Guidelines. List I and California precursor chemicals must also be stored in a Controlled Substances Program (CSP) approved locked storage area within a room that's under human surveillance or locked when not staffed.
Contact the CSP, (858) 534-1362 or (858) 534-9016, for a storage consultation prior to requesting listed chemicals.
How do I gain access to the CSUA application?
Only the PI, CS Lab Contacts, and Department Chair/Reviewer, as named in current or pending CSUAs, can access the online CSUA application through the “My Research Safety” portal. Once you click on “Controlled Substance Use Authorization,” your login will be authenticated through Single Sign On. Individuals will be able to access CSUA information as their role permits.
If you require login access to the CSUA application, please have either your PI or CS Lab Contact update the CSUA to list you as a Lab Contact in section 2 of the CSUA. At that time an email with the PSDS form and training requirement will be sent to become an authorized personnel. Mark Primary or Secondary lab contact at the top of the PSDS to designate CS Lab Contact status.
When does my CSUA expire?
CSUA’s are valid for one year and must be renewed annually through the CSUA application. Renewal reminders are sent to the PI and CSUA Lab Contacts up to 70 days in advance on the first of the month. The expiration date for a CSUA is located online via the CSUA application, under the My CSUA tab, in the right-hand column. Only the PI can renew a CSUA, and renewal extends the CSUA expiration date by a year. CS Lab Contacts can update the contents of a CSUA in preparation for the PI’s renewal. Overdue CSUAs will result in a stoppage of orders and inventory must be relinquished to the CSP.
How do I dispose of CS?
You must return all unused CS and CS dilutions to the Controlled Substances Program (CSP) for disposal. Use the My Inventory tab in the CSUA application to request a disposal. Request a disposal whenever a research project ends, the CSUA expires, the CS or CS dilution is no longer needed, the PI terminates employment, or the CS expires. For more information, contact the CSP.
What do I do with expired CS?
Any expired CS inventory and expired CS dilutions must be relinquished to Controlled Substances Program (CSP). Contact the CSP to schedule a time to relinquish the expired CS.
What do I do with expired pharmaceuticals (non-CS)?
Pharmaceuticals that are not CS are disposed through the Online Waste Tag Program (OTP). Look at the Pharmaceuticals Disposal page for more information.
What is Biennial Inventory? Why do I have to do it on a certain date?
The Biennial Inventory is an event when everyone under a DEA registration reports their inventory. This serves as a snapshot of the inventory on-hand on a particular date and is the basis for future DEA audits. If you have an approved CSUA, you must participate in the annual or Biennial Inventory process, even if there are zero CS inventory items in stock. The Biennial Inventory is a federal requirement of possessing CS. If Biennial Inventory report is not received, it can result in suspension of the CSUA and stoppage of any orders.
How do I record an error on a CS Usage Log(s)?
If an error is made and needs to be corrected, use a single strike-through to mark out the error, initial, date, and write a short explanation for the change.
How long should I keep my CS Usage Log(s)?
Once an item has been used up or disposed of, submit a copy of the item’s CS Usage Log(s) to the CSP. When the item has been reconciled in the online inventory, it will be removed from the inventory list. Retain the original CS Usage Log(s) in the CS Log Book for 3 years after the date of item’s complete use or disposal.
Where do I upload a CS Usage Log?
As each item is used up or disposed, review the item’s CS Usage Log for accuracy. Use the My Inventory tab in the CSUA application to upload a copy of the CS Usage Log. Alternatively, you may also submit a copy of the CS Usage Log to the Controlled Substances Program (CSP) by email ehscs@ucsd.edu, campus mail MC 0090 or fax (858) 822-0561. The item will be removed from the online inventory list once it has been reviewed and approved by the CSP. Retain original CS Usage Log in the CS Log Book for 3 years after the item’s complete use or disposal.
Why is there a 21 day wait for California Precursors?
There is a 21-day wait for orders of California Precursors because the CA Department of Justice takes the time to review each order’s proposed usage. Also note that California Precursors must be purchased from a California supplier.
Where do I get training? Is refresher training required?
People working with CS must take the CS online training. It is offered as an eCourse through UC Learning Center. Re-take this eCourse every 4 years to meet the refresher requirement.
Who do I contact if I have a question?
Direct any question to the EH&S Controlled Substances Program, (858) 534-1362 or (858) 534-9016.
For more information, contact the Controlled Substances Program, (858) 534-1362 or (858) 534-9016.