As others have said, it is the individual, not the institution, that is licensed to work with DEA scheduled compounds. The researcher has to demonstrate a legitimate need and appropriate expertise to conduct research with controlled substances and the requirements are particularly demanding for schedule 1. I would be stunned if a general stockroom contained any scheduled compounds. My understanding is that access to controlled substances must be restricted to those who hold the appropriate DEA license. Perhaps are you referring to List 1 compounds? These are common compounds that can be used in the synthesis of controlled substances. No license is required to purchase and use them but one may be asked to provide additional information when placing an order.
On Jun 17, 2016, at 08:24, David C. Finster <dfinster**At_Symbol_Here**WITTENBERG.EDU> wrote:
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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