Storage and Security

DEA Registrants are responsible for providing and maintaining secure storage of their controlled substances inventory. The DEA Registrant must abide by the federally mandated DEA requirements outlined in 21 CFR Part 1301.72. All CS storage locations must be approved by the CS Program Manager before they may be used to store CS inventory.

Storage Requirements

Controlled substances security requirements are mandated based upon their Schedule (I-V) as follows:

  • Schedule I-II: Store in a locked drug safe, vault, or steel cabinet or drawer attached to the building structure, within a lockable room.
  • Schedule III-V: Store in a locked, substantially-constructed cabinet or drawer without wheels, within a lockable room.
  • Usage and Disposal Logs: store in locked storage unit with corresponding controlled substances.
    • Maintain Schedule I-II records separately from Schedule III-V records.

Schedule III through V controlled substances may be stored with Schedules I and II controlled substances given that the security standard for Schedule II drugs is maintained and their records are maintained separately.

Equipment

Install the following equipment to meet the standards outlined in 21 CFR Part 1301.72.

  • Storage Units: Must be secure enough to show when entry is forced.
  • Drawers: Must be inaccessible from the upper or lower drawers in the stack. Assign the top drawer of the stack to use as the storage facility, if possible. Cabinetry encasing the drawer must be adhered to the wall or floor or weigh more than 750 pounds.
  • Padlocks and Hinges: Mounting screws or bolts must be inaccessible when the door is closed and locked.
  • Safes and Steel Cabinet Equivalents: Must be cemented or bolted to the floor or wall or weigh more than 750 pounds.

Storage Restrictions

  1. Do not share controlled substances storage units with other DEA registrants that have separate DEA licenses.
  2. Do not transfer a controlled substance from its original container for storage purposes.

Secure Access Control

  • Grant CS access to an absolute minimum of authorized users, who shall be indicated on the DEA Registrant’s CSUA.
  • Keep storage key(s) in the physical custody of authorized users at all times.
    • Do not store keys or combination codes in accessible areas.
  • Retrieve keys or change combination codes when authorized users depart from their positions.
  • Update CSUA when authorized users depart or new authorized users are added.

Precursor Chemicals Storage

Principal Investigators (PIs) that require the use of precursor chemicals for research are responsible for ensuring the proper procurement, storage, use and disposal of precursor chemicals. Precursor chemical users must abide by the following requirements for storage, security, and recordkeeping:

  • Storage of precursor chemicals must follow the EH&S chemical storage requirements specific to the hazard classes of the chemicals (e.g. flammables, corrosives).
  • Do not store precursor chemicals with controlled substances.
  • Precursor chemicals must be disposed of as hazardous chemical waste per EH&S requirements.
  • PIs must provide effective controls and procedures to guard against theft or loss of precursor chemicals. Immediate knowledge of theft or loss must be reported to EH&S and DPS.
  • PIs must maintain invoices for each precursor chemical purchased for two years.
  • If research use of a precursor chemical generates one or more controlled substances, controlled substances requirements must be implemented and followed. Contact the CS Program Manager immediately at ehs-cs@usc.edu.