Controlled Substances

You are legally responsible for providing adequate and anti-theft storage for controlled substances. Although both the DEA and Wisconsin have storage requirements, Wisconsin's are more stringent. You will automatically be in compliance with the DEA if you follow Wisconsin's guidelines under form 2277, which include bolting or cementing storage boxes to the floor, if they weigh less than 750 pounds.

Standard office equipment will not meet storage requirements. Health Care Logistics, (800) 848-1633, gohcl.com, sells an approved narcotic cabinet, item 3706-01, for approximately $100-150. Contact UW Facilities Planning & Management or your building manager for mounting and associated costs.

After obtaining your required licensing, set up your own account with a vendor to order controlled substances. You must also complete DEA Form 222 when ordering schedule I and II substances. This form must be completed without errors and mailed to the vendor each time you order. When ordering from Midwest Veterinary Supply, they have provided a sample document on their website.

DEA 222 forms must be obtained by the registrant from the DEA website, additional information can be found here.

Important!

• Treat Forms 222 as if they are controlled substances, keeping both used and unused forms in a securely locked area.
• Never throw away unused DEA Forms 222. Return unwanted, defective or unused forms to DEA headquarters at the address listed in the instructions section on the back of the form.
• Follow the instructions on the back of the form VERY carefully. Vendors will return forms with even the slightest errors.
• Do NOT sign a DEA Form 222 before it is completed. This form is the equivalent of a prescription pad and you are legally responsible for its management.
• After placing an order, closely monitor its arrival. Once the shipment arrives, unpack and sign the packing slip, and put it in your lockbox as soon as possible. Maintain it in a secure area until it is in storage

Registrants are responsible for knowing Wisconsin's and the DEA's separate recordkeeping and inventory requirements. Get complete details on the Office of Diversion Control website and via Wisconsin Legislative Documents Chapter CSB 3, "Special Use Authorization."

Electronic records are acceptable as long as they cannot be altered or deleted and are easily separated from all other events.

Important!

• Once an inventory is completed it should be documented and filed away. Do not write on it again.
• Controlled substances awaiting disposal must be included in your inventory as long as they remain in your possession.
• When determining the number of units remaining in a container that has been opened: schedule I and II substances require an exact count or measurement; schedule III-V substances can be estimated unless the container holds more than 1000 tablets or capsules

Use RARC's DEA Inventory Report to capture information required for inventory records.

Use RARC's Controlled Substance Administration Log to capture information required for administration records.

Visit the DEA Office of Diversion Control website for regulatory information and resources.

Dispose controlled substances in a way that permanently and irreversibly alters the substance's physical or chemical state, rendering the drug nonretrievable and unusable. You may not flush substances down a drain or mix with kitty litter or coffee grounds to dispose as solid waste.

Fill out and retain DEA Form 41 for two years when you dispose a controlled substance. You are not required to submit it unless requested.

For disposal instructions, contact RARC animal program assessment specialists: apas@rarc.wisc.edu or contact DEA directly at (608) 210-4334 or DEA.registration.help@dea.gov.

New! The product Rx Destroyer may be used to dispose of many types of controlled drugs. This product is available on ShopUW+ and vendors such as Midwest Veterinary Supply. You should continue to fill out DEA Form 41 if you use this product to dispose of controlled substances. 

Storing of substances awaiting disposal

Separate expired substances from in-date and in-use drugs by placing them in a small container or plastic bag. If you have large stocks of expired or waste controlled substances, use a second lockbox to provide segregation.

Clearly label expired or waste materials with "Expired - Do Not Use in Live Animals."

Store controlled drugs awaiting disposal in the drug lockbox. You must include them in your inventory reports and count them towards your total inventory on hand while they remain in your possession.

Mail or fax a written report of theft or significant loss of your controlled substances to the DEA Milwaukee District Office within one business day of discovery.

Milwaukee District Office
4725 West Electric Ave
West Milwaukee, WI 53219-1627
Diversion phone: (414) 336-7370
Diversion fax: (414) 727-5454
Jurisdiction: Wisconsin

Then submit completed DEA Form 106 to the Milwaukee District Office and retain a copy in your records.

DEA also recommends reporting any instance of loss or theft to local police.

• Midwest Veterinary Supply
  Phone: (608) 834-3504, (608) 837-5188; (800) 362-9226
  Fax: (888) 372-3941
  https://www.midwestvetsupply.com/products
• Covetrus
  Phone: (855) 724-3461 (toll-free)
  Fax: (614) 659-1948
  https://northamerica.covetrus.com/
• Zoetis
  Phone: (888) 963-8471; (973) 660-7491
• Patterson Veterinary
  Phone: (800) 225-7911; (978) 353-6000
  Fax: (978) 353-6016
  https://www.pattersonvet.com/
  Mail completed DEA Form 222 to:
  Patterson Logistics Services Inc.
  Attn: Tobias Chappell
  925 Carolina Pines Blvd., Suite B
  Blythewood, SC 29016