How do DEA registrants best protect against errors and mishandling?
Seven best practices on controlled substances inventory and record-keeping:
- 1. Each registered DVM has a 'working inventory'
- 2. Transfer Schedule 2s via 222 Form
- 3. Number bottles/vials when received
- 4. Log drugs by individual bottle
- 5. Match log to bottle/vial
- 6. Inventory regularly
- 7. Record wastage and shortages
This is the last of a four-part series examining best practices for handling controlled substances in a veterinary hospital. The posts are derived from information in drip.vet's Opioid 411 Anytime course.
Inventory and Record-keeping of Controlled Substances
Every DEA registrant needs her or his own “working inventory.” That way, they are each responsible for keeping their own inventory correct. When a registrant is working, that’s the inventory that’s used.
Yes, it means that a larger practice has multiple open vials and bottles, but these drugs are usually cheap and it’s better in the long run because the inventory control is much tighter. This practice shifts the liability away from the main practice owner or registrant over to some of the associates.
If you're doing this and are transferring Schedule 2’s to another registrant’s inventory, you have to fill out and submit that 222 Form.
We like to number each bottle or vial with a unique identifier as soon as it’s received into inventory. Each bottle is opened in order and it has its own log book page. Once it’s emptied, we place that page into a separate record storage. This allows us to track the bottles much more efficiently and take inventory much faster.
I suggest that you take inventory much more frequently than the regulations require. Remember the advice to take an inventory every two years? A best practice would be to take an inventory once a quarter, and that seems to be the sweet spot for our practices.
Be sure to record any waste, shortages and other discrepancies in your inventories as soon as they occur. You will be surprised how much injectable is lost in the hubs and needles, and you should note that occasionally.
Previous posts in the series:
Best Practices for Administration of Veterinary Controlled Substances
Safe Dispensing of Controlled Substances
Veterinary Team Best Practices for Handling Opioids
Related post:
drip.vet's Opioid 411 in mandated states
drip.vet's Opioid 411 courses are RACE-approved continuing education covering opioid prescribing by veterinarians in precise detail. This course provides students with a broad range of expert level knowledge on subjects including: The Opioid Crisis in America, DEA Laws and Regulations, Identifying and Stopping Misuse, Opioids in Practice and Best Practices. For more information, click the image below:
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