From: David C. Finster <dfinster**At_Symbol_Here**>
Subject: [DCHAS-L] DEA Form 510 question
Date: Fri, 17 Jun 2016 12:24:27 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 7AB8F8BFE46C5446902F26C10EBF4AEAB3B362BE**At_Symbol_Here**

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:   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?






David C. Finster
Professor, Department of Chemistry
University Chemical Hygiene Officer
Wittenberg University


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