The University of Iowa
Environmental Health and Safety

DEA Controlled Substance Secure Storage Guidelines

University of Iowa

DEA Controlled Substance Secure Storage Guidelines

Purpose: This document is to provide guidance to University of Iowa research personnel regarding the proper storage of small quantities of DEA controlled substances. DEA’s Office of Diversion Control website is: http://www.deadiversion.usdoj.gov/21cfr/cfr/1301/1301_72.htm
Note:  Although these guidelines were developed to be consistent with DEA guidelines, unique situations may cause DEA inspectors to require alternative storage solutions.

  • General storage rule

    • All controlled substances must be stored behind at least two differently keyed locks at all times.
    • For keyed lockboxes
      • Do not store the keys near the lockbox; and
      • Do not store the keys together.
    • For combination lock lockboxes
      • Only the registrant and as few responsible individuals as possible should know the combination.
      • Whenever anyone who knows the combination is terminated from employment, the combination(s) must be changed.

  • Schedule I and II substances (e.g., Pentobarbital is a Schedule II drug)

    • Must be stored in a safe or steel cabinet of substantial construction. 
      • If the safe or cabinet is less than 750 lbs., it must be mounted or secured to something of substantial construction (e.g., bolted to a wall or the floor, or the base imbedded in concrete).
      • The safe/cabinet should have an inner and outer door with the locks for each door keyed differently.
      • Standard “narcotics cabinets” can be purchased through a variety of resources, e.g.:

  • Schedule III, IV, and V controlled substances (e.g., Ketamine and Buprenorphine, are Schedule III controlled substances)

    • Should be stored using one of the following methods:
      • Preferred method: a wall mountable controlled substance lockbox with two doors and two locks (each lock is keyed differently). 
      • A single-lock lockbox that is stored in a drawer or cabinet that is secured at all times with a hasp and padlock.  The drawer and cabinet should be substantially constructed such as in a drawer that is part of either a bench or cabinet that is mounted to the wall or floor.
      • If a lab is not accessible to the public, then an option is to use a single-lock lockbox, stored in a drawer or cabinet in a room that is kept locked at all times.
      • Schedule III, IV and V substances can also be stored with Schedule I and II substances.

  • Cold storage for controlled substances

    • For storage at 4°C or colder, a single-lock lockbox in a refrigerator or freezer that can also be locked is permitted.  The room must also be lockable, and locked after hours.