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Controlled Substances Program. Controlled Substances Schedule I-V based on the propensity for addiction. Requires a DEA registration Specific inventory requirements, background checks and maintenance of files. Listed Substance
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Controlled Substances Program Controlled Substances • Schedule I-V based on the propensity for addiction. • Requires a DEA registration • Specific inventory requirements, background checks and maintenance of files. Listed Substance • List I or List II based on the importance in manufacturing of controlled substances • No registration necessary for research use. • Established thresholds for some items, no thresholds for others. California Precursors • Includes Federal List and more.
Controlled Substances Program • Program Development objective: Establish automatic processes where possible. Minimize unnecessary impact on researcher. • Assumptions: People ordering controlled substances don’t know that they are ordering a controlled substance. • Requirements analysis – 21 CFR 1300 – 1310, DOE Order 580.1A, and UC BUS 50 is completed • Benchmarking is completed • Process development is almost completed. • Policy documents are in development. • Communications Plan is in development. • Implementation Plan is in development.
Controlled Substances – User Group LSD – Scott Taylor, Nina Hahn PBD/JBEI – Tim Lease, Henrik Scheller, Ellen Ford Procurement – Shanna Wells Protective Services – Brian Strock Property – Cynthia Lytle/Brian More´ Supplier – Ken Blackwell (GSS) Facilities Receiving – Tim Montoya/Jon Cleveland
Controlled Substances - Benchmarking Benchmarked institutions: PNNL, LLNL, several UCs, SLAC, Sandia - Livermore Results: Some required the PI to be registered with DEA vs the institution Half didn’t do background checks All required and internal “registration” and training Most identified the use of controlled substances through experiment reviews, protocol reviews, chemical ordering systems, or hazard reviews.
Listed Substances • Listed substances with thresholds for single transactions.
Listed Substances • Listed substances with thresholds for single transactions.
Listed Substances No thresholds • Ephedrine and Pseudoephedrine, salts, optical isomers and salts of optical isomers • Ergocristine and its salts • Gamma Butyrolactone (GBL) • Hypophosphorous acid and salts • Iodine (elemental crystals, >2.2% solution) • N-phenyl-4-piperidone (NPP) • Phenylpropanolamine, salts, optical isomers and salts of optical isomers • Red and white (yellow) phosphorus
Questions? How do you want this program communicated?