DEA Controlled Substances

Application tip 1: In section 4 of the 225 application, the State License Number does not apply in the state of Colorado, leave the first entry blank.   

Application tip 2: In section 6 of the 225 application, a UCD researcher is exempt from having to pay the application fee. To use this exemption: 1) check the box to claim the exemption and 2) enter the contact information for the chair of the applicant's department.   

Once the DEA registration is received, a copy of the registration must be forwarded to EHS via email. Email registration to EHS​.

• The registration process will take 4-8 weeks to complete. Heavy registration periods will lengthen the process time.
• The process includes a visit or phone interview by the DEA to review security measures, and my require submission of photographs.
• Upon receipt, email​ a copy of the DEA Certificate of Registration to EHS, inserting "ATTN: Reverse Distributor Program" in the subject line.

• Practitioner registrations cannot be simultaneously used for both research and patient care
• Only faculty can apply for registration
• Ordering controlled substances must be completed in MarketPlace
• Procurement of controlled substances must involve at least two separate laboratory members
• Controlled substances must be included in the laboratory's online chemical inventory
• Registration holders are subject to annual audits by EHS

Local DEA officials have stipulated these requirements for controlled substance cabinet security. A cabinet: 

• May be used only for storage of controlled substances issued under a single license 
• Must be non-transportable and physically secured (contact Facilities to initiate a work order) 
• Must be lockable 
• Must be “substantially constructed,” which excludes use of cabinets with glass doors   

The DEA diversion investigator conducting the pre-registration review has sole discretion to determine whether the security requirements have been met.   

Controlled substances may be stored only at the location indicated on the registration. A controlled substance may be transported to a different location for research purposes only, with these stipulations:   

• May only be carried by the researcher or his/her agent 
• May only be transported during business hours 
• May not be in the registrant’s/agent’s possession while off-duty   

Specific security requirements are outlined in federal regulation 21 CRF 1201.71.

DEA license-holders must complete the following inventories: 

• Initial inventory, per federal regulation 1304.11(b). 
• Initial and subsequent biennial inventories, per 1304.11(c). 
• Ongoing use logs, per 1304.22(c). Logs must be stored in a separate location from the controlled substances. 
• All inventories and destruction paperwork must be kept for a period of two years, and be made available for inspection.

Loss, theft, spills, or diversion of any kind of a controlled substance must be reported immediately to: 

1. DEA Denver field office, 720-895-4040,  
2. University Police Department, 303-724-4444, and
3. EHS, 303-724-0345

In addition, a Report of Theft or Loss of Controlled Substances (DEA Form 106) must be submitted to the DEA, by the registered licensee only, within one business day of discovery.

The DEA prohibits disposal of controlled substances in the sink or trash.

When a controlled substance is no longer needed or has been abandoned,  complete a Chemical Waste Disposal request to  dispose of the unwanted substance in a proper and legal manner. 

Destruction documentation will be sent to the licensee. Contact EHS if the documentation is not received within 14 days. 

It is the licensee’s responsibility to ensure a new DEA registration is in place at a new location before removing any controlled substance from the university. 

If the licensee is to leave the university without moving the registered controlled substance, one of the following must be completed: 

1. Transfer the controlled substance to another researcher, or 
2. Contact EHS for disposal