From: Darrell Crick <dcrick**At_Symbol_Here**CONCORD.EDU>
Subject: Re: [DCHAS-L] DEA Form 510 question
Date: Fri, 17 Jun 2016 17:52:11 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 24436B38-4BF1-46A8-8DC7-C5CD152DFFAF**At_Symbol_Here**
In-Reply-To <7AB8F8BFE46C5446902F26C10EBF4AEAB3B362BE**At_Symbol_Here**>

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.

Some analytical standards of controlled substances can be purchased without a DEA license. I have several of those that I use when teaching mass spectrometry to undergraduates. They are exempt from DEA control due to their low concentrations but we still store them in a special area and keep an inventory separate from the general chemical inventory.

Dealing with a bloated government agency is bad enough, but dealing with one that likes to incarcerate people for long periods of time demands extra vigilance. Proceed prudently.

Best Regards,


Darrell W. Crick, Ph.D.
Associate Professor of Chemistry
Department of Physical Sciences
Concord University
Campus Box 11
PO Box 1000
Athens, WV 24712

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:   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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