Controlled Substances

Controlled Substances are chemicals or drugs whose manufacture, possession, and use are regulated by the government. The U.S. Drug Enforcement Administration (DEA) lists controlled substances into five schedules(link is external). This classification is based on their accepted medical treatment and use in the United States, potential for abuse, and likelihood for causing dependence when abused. .

Precursor Chemicals are chemicals and solvents regulated by the DEA, State of California Department of Justice and the Office of the Attorney General (CA-DOJ) in order to prevent the illicit manufacture of controlled substances.

The DEA maintains a list of federal (List 1) precursor chemicals. The State of California maintains a list of precursor chemicals(link is external) which includes all federal List I Chemicals plus a few additional chemicals.

Precursor chemicals and List I Chemicals are chemicals that have legitimate uses and also have the potential to be used in the manufacture of controlled substances.  State and federal laws require campus vendors to uphold stringent regulations regarding distribution of these chemicals.

• Federal list(link is external) (List I Chemicals).
• State of California list(link is external) (Federal List plus a few additional chemicals).

Time to receive List I and California precursor chemicals:

4-6 weeks. The State of California requires vendors to hold materials for 21 days after purchase. . It is also possible that if the hazard class requires shipment by ground transportation additional time may be required to receive the shipment.

• Ordering:
  • Do not combine precursor orders. Only one precursor chemical per Bearbuy cart will be processed
  • The BearBuy cart must be reviewed and personally approved by the PI (no proxies such as lab managers or safety coordinators)
  • Mark the box ‘Buyer Intervention’ to indicate processing by campus controlled substances buyer
  • Include an Intended Use Statement with your requisition.
• Pick-up:
  • The notice of delivery will indicate where the item can be picked up.

Administrative controls:

Chemical must be added to the laboratory Chemical Inventory on the day of the receipt. Store listed chemicals according to their hazard type. List I and California precursor chemicals must be stored within a room that's under human surveillance or locked when not staffed.

Logbooks and Daily Management:

• All purchase records and logbooks for controlled substances must be maintained for at least 2 years and usage logs must be kept in your secure storage location with the controlled substances.
• The balance should always represent the amount on hand in your storage location.
• For creating dilutions of controlled substances: print and use Controlled Substance Diluted Solution Usage Log for record keeping

Campus-wide Annual CS Inspections

EH&S will conduct annual inspections of all controlled substance storage locations to verify recordkeeping practices and authorized personnel access. Inspection reminders will be sent and scheduled with the appropriate lab contact.

Campus-wide Biennial Inventory:

In addition to annual inspections,EH&S will conduct a biennial inventory of all controlled substance locations on campus in a single business day. Once every two years, EH&S inspectors will visit each location and document the amount of controlled substance on hand in compliance with Code of Federal Regulations 1301.11.

Note: Notify EH&S immediately of any missing or spilled controlled substances: (510) 365-4472.

Principal Investigators (PIs) are responsible for providing and maintaining secure storage for their CS inventory that meets these criteria:

Store CS according to schedule number:

• Schedule II: Store in a safe or steel cabinet equivalent.
• Schedule III-V: Store in a locked drawer or cabinet that is inaccessible from above or below.

Install the following equipment according to these standards:

• Padlocks and hinges:
  • Must have the mounting screws or bolts of the hasp inaccessible when the door is closed and the lock is fastened.
• Safes and steel cabinet equivalents:
  • Must be cemented or bolted to the floor or wall, or weigh more than 750 pounds.
• Keys and codes:
  • Must not be readily accessible in a nearby drawer or desk.
  • Must only be issued and carried by individual authorized researchers or staff.
• Storage units:
  • Must be secure enough to show forced entry.
• Drawers:
  • Must be inaccessible from the upper or lower drawers in the stack. Assign the top drawer of the stack, if possible.