Controlled Substance Transfer

This section describes requirements for the transfer of controlled substances. Controlled Substances, in small quantities, can be transferred between two DEA registrants with valid registrations and USC CSUAs.

Definitions

Transferor: DEA Registrant transferring controlled substance(s) to another DEA Registrant.
Recipient: DEA Registrant receiving controlled substance(s) from another DEA Registrant.

Transfer Criteria

The following criteria must be met in order to transfer controlled substances between DEA registrants:

  • Transferer and recipient must have valid DEA registrations and CSUAs.
  • CS being transferred must be schedule II, III, IV, or V drug.
  • CS being transferred must be approved in the recipient’s DEA registration and CSUA.
  • Transferer and recipient must be located on the same campus (i.e., HSC or UPC).
    • Under no circumstances may a CS be transferred between the campuses or to other institutions.
  • Transfer must be approved by the CS Program Manager.

Procedure to Transfer

The following procedures must be completed to comply with the Controlled Substance Transfer policy:

  1. Formerly request for CS transfer approval by completing the CS Form E-Controlled Substance Transfer Form.
    • Transferer must complete Section A.
    • Recipient must complete Section B.
  2. Submit completed form to the CS Manager at ehs-cs@usc.edu for approval.
    • Approved form will be signed and emailed back to transferer and recipient as receipt of approval.
  3. Transferer and recipient must each maintain a copy of the Controlled Substance Transfer form signed by the EH&S CS Manager.
  4. Transferer and recipient must immediately document CS transfer on subsequent Usage and Disposal Logs and maintain record for two years following disposal.
  5. During transit, controlled substances shall be placed in robust sealed secondary containment and may be carried by hand or pushed on a hand cart by an Authorized User.