Over the past few months, Titan Group has been asked several times if the AAHA Controlled Substance Logs books are “DEA compliant” in the states of Arizona and California. Titan Group is aware that each individual state(s) has their own set of controlled substance regulations that either emulate the DEA federal standard or actually enhance it. Before we delve deeper into what constitutes a “DEA-compliant” logbook, remember this statement: “Each registrant who maintains an inventory of controlled substances must maintain a complete and accurate record of the controlled substances on hand and the date that the inventory was conducted.” That quote is right out of the Code of Federal Regulations (CFR) and does not mandate that a DEA registrant use one method of recordkeeping over another. The key is that the records must be complete and accurate and readily available for a regulatory inspection.
The common reoccurring theme surrounding what is required in a logbook is that the book must be bound. Besides the “bound” requirement, the logbook must be maintained by the DEA registrant and include at a minimum all of the following information: drug name, container size, strength of medication, bottle number, date of dispensation, explanation of use, lot number (if available), expiration date, amount added to logbook, amount used, running balance, initials of authorized employee, and witness initials for wasting. At a minimum, your logbook should be maintained in accordance with the recordkeeping requirements of §1304.04 of the CFR. If you are utilizing electronic logbooks, the law does not specify that you must print out paper copies; they just must be current and readily available for inspection.
Simply put, DEA controlled substance logbooks must contain information capable of maintaining accurate counts of your controlled substances. Titan Group has been in veterinary facilities throughout the United States and the one thing we stress is, if the DEA knocks on your door and you can tell them with the utmost confidence the whereabouts of every drug that enters your doors, goes into your safe, is administered to an animal, or is sent to the reverse distributor, you will never have a problem. The DEA requires you to keep accurate records and account for all of your controlled substances. In our opinion, the use of bound controlled substance logbooks such as the AAHA Unopened and Opened Container Logs meet the minimum requirements for use in all 50 states.
—Jack Teitelman, retired DEA Supervisory Agent and CEO of Titan Group, DEA Compliance Experts (titangroupdea.com)