DRCNet Response to the
Drug Enforcement Administration

Distribution

The keeping of records is required for distribution of a controlled substance from one manufacturer to another, from manufacturer to distributor, and from distributor to dispenser. In the case of Schedule I and II drugs, the supplier must have a special order form from the customer. This order form (DEA Form 222) is issued by the DEA only to persons who are properly registered to handle Schedules I and II. The form is preprinted with the name and address of the customer. The drugs must be shipped to this name and address. The use of this device is a special reinforcement of the registration requirement; it makes doubly certain that only authorized individuals may obtain Schedule I and II drugs. Another benefit of the form is the special monitoring it permits. The form is issued in triplicate: the customer keeps one copy; two copies go to the supplier who, after filling the order, keeps a copy and forwards the third copy to the nearest DEA office.

For drugs in Schedules III, IV, and V, no order form is necessary. The supplier in each case, however, is under an obligation to verify the authenticity of the customer. The supplier is held fully accountable for any drugs which are shipped to a purchaser who does not have a valid registration.

Manufacturers must submit periodic reports of the Schedule I and II controlled substances they produce in bulk and dosage forms. They also report the manufactured quantity and form of each narcotic substance listed in Schedules III, IV, and V, as well asthe quantity of synthesized psychotropic substances listed in Schedules I, II, III, and IV. Distributors of controlled substances must report the quantity and form of all their transactions of controlled drugs listed in Schedules I and II and narcotics listed in Schedule III. Both manufacturers and distributors are required to provide reports of their annual inventories of these controlled substances. This data is entered into a system called the Automated Reports and Consolidated Orders System (ARCOS). It enables the DEA to monitorthe distribution of controlled substances throughout the country, and to identify retail-level registrants that receive unusual quantities of controlled substances.