Usually the Federal DEA works with the State Drug Control Agency, each requiring registration/credentials for INDIVIDUALS.  A researcher cannot acquire a scheduled drug without these credentials.  Unless other parts of the country differ, I do not think academic institutions can register as sole procurement agent of drugs with the intent to distribute to faculty / researchers.  I know here in New England the license may show “University of…” on the first line, but an individual’s name follows with their own ID #, for both Federal and State.  We have over 50 researchers with licenses here at UConn. 

 

“List” chemicals differ from “Schedule” chemicals.  See (http://www.deadiversion.usdoj.gov/chem_prog/34chems.htm)

They are typically pre-cursor compounds.  By definition-

 

List I chemical means a chemical specifically designated by the Administrator in =A71310.02(a) of this chapter that, in addition to legitimate uses, is used in manufacturing a controlled substance in violation of the Act and is important to the manufacture of a controlled substance.

List II chemical means a chemical, other than a List I chemical, specifically designated by the Administrator in =A71310.02(b) of this chapter that, in addition to legitimate uses, is used in manufacturing a controlled substance in violation of the Act.

Examples are red phosphorous, iodine, nitroethane(List 1);  ethyl ether, acetone, sulfuric acid (List 2)

 

If, according to your statement,  that “(Most academic stockrooms would contain at least a few of the Schedule 1 chemicals.), I know the State Agent here would consider that a violation, and require ONE person to be licensed, and discourage the re-distribution to other individuals.

Stefan Wawzyniecki, CIH, CHMM

NRCC-CHO

University of Connecticut

 

 

Do academic institutions typically need to complete Drug Enforcement Agency Form 510 to register Schedule 1 chemicals?   (Most academic stockrooms would contain at least a few of the Schedule 1 chemicals.)

 

Section 2 of the Form 510 requires that the company identify itself as either “chemical distributor”, “chemical exporter”, ‘chemical importer”, or “chemical manufacturer”.    Academic institutions seem not to fall into any of these categories.  (I assume that research lab synthesizing new (or old) chemicals would not be categorized as “manufacturers.”)

 

Prudent Practices (2011), Section 10.E.4.1 on page 261, states that “A person using materials regulated by the DEA must obtain a user license or work under the direction of a person with such a license.”

 

A bit of surfing also gave:  http://www.riccachemical.com/Documents/regrequirements.pdf.   This chemical company has a synopsis of guidelines.  The first bullet point for List 1 Chemicals indicates that a company is not required to register if a company “purchases the product for internal use.”  Registration is only required “if you are going to purchase the product for resale.”

 

Can someone clarify this?

 

Thanks!

 

Dave 

 

David C. Finster
Professor, Department of Chemistry
University Chemical Hygiene Officer
Wittenberg University
937-327-6441
http://userpages.wittenberg.edu/dfinster/index.html