DRCNet Response to the
Drug Enforcement Administration

Recordkeeping

The CSA requires that complete and accurate records be kept of all quantities of controlled substances manufactures, purchased, and sold. Each substance must be inventoried every two years. Some limited exceptions to the recordkeeping requirements may apply to certain categories of registrants.

From these records it is possible to trace the flow of any drug from the time it is first imported or manufactured through the distribution level, to the pharmacy or hospital that dispensed it, and then to the actual patient who received the drug. The mere existence of this requirement is sufficient to discourage many forms of diversion. It actually serves large drug corporations as an internal check to uncover diversion, such as pilferage by employees.

There is one distinction between scheduled items for recordkeeping requirements. Records for Schedule I and II drugs must be kept separate from all other records of the handler; records for Schedule III, IV, and V substances must be kept in a "readily retrievable" form. The former method allows for more expeditious investigations involving the highly abusable substances in Schedules I and II.