The University does not need a license. It is the individual PI needs to get a State and a DEA License, and the University should maintain a list of all authorized users.
Because we have a researcher who manufactures(grows) under a NIDA grant, the individual has a manufacturer license, not the University. We are still an research / educational institution first, not a DEA manufacturer.
Our personnel have individual licenses as Researcher (II-V), Practitioner (Our Animal Care Vet), Researcher (I), Analytical Lab, Manufacturer, and a Manufacturer(Bulk) for the Gardens..
We also have an internal license form called the CONTROLLED SUBSTANCE INFORMATION and AUTHORIZED USERS LIST
that you may find helpful for inventory purposes.
If you have any other questions, just shoot me an e-mail.
Edward M. MovitzResearch & Environmental Compliance Officer / FSO
The University of Mississippi
100 Health and Safety Building
P.O. Box 1848
University, MS 38677-1848
O:+1-662-915-5433 | F: 662-915-5480
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From: DCHAS-L Discussion List <dchas-l**At_Symbol_Here**med.cornell.edu> on behalf of David C. Finster <dfinster**At_Symbol_Here**WITTENBERG.EDU>
Sent: Friday, June 17, 2016 7:24 AM
Subject: [DCHAS-L] DEA Form 510 question
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?
David C. Finster
Professor, Department of Chemistry
University Chemical Hygiene Officer
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