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.
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General storage rule
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All controlled substances must be stored behind at least two differently keyed locks at all times.
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For keyed lockboxes
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Do not store the keys near the lockbox; and
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Do not store the keys together.
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For combination lock lockboxes
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Only the registrant and as few responsible individuals as possible should know the combination.
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Whenever anyone who knows the combination is terminated from employment, the combination(s) must be changed.
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Schedule I and II substances (e.g., Pentobarbital is a Schedule II drug)
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Must be stored in a safe or steel cabinet of substantial construction.
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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).
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The safe/cabinet should have an inner and outer door with the locks for each door keyed differently.
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Standard “narcotics cabinets” can be purchased through a variety of resources, e.g.:
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Health Care logistics: www.hcl-intl.com
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Harloff: www.harloff.com/products/
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Medicus Health: www.medicus-health.com/
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Schedule III, IV, and V controlled substances (e.g., Ketamine and Buprenorphine, are Schedule III controlled substances)
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Should be stored using one of the following methods:
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Preferred method: a wall mountable controlled substance lockbox with two doors and two locks (each lock is keyed differently).
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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.
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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.
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Schedule III, IV and V substances can also be stored with Schedule I and II substances.
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Cold storage for controlled substances
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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.
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