Be sure to conduct inventories of your controlled substances in accordance with regulatory requirements. The Massachusetts Department of Public Health Drug Control Program issues Massachusetts Controlled Substance Registrations, and the Drug Enforcement Administration issues federally regulated controlled substance registrations allowing for the storage and use of regulated controlled substances.
When registrations are first issued, an initial inventory must be conducted, which is a physical inventory of the controlled substances in the registrant’s possession. If there are no controlled substances present, a record of zero should be made. Additional physical inventories of the controlled substances in possession must be made on a biennial basis, with the inventory date taking place within two years of the previous inventory. Of course a perpetual inventory of all controlled substances must be maintained on an ongoing basis, and there are specific recordkeeping requirements for this perpetual inventory. As best practice, some facilities opt to conduct monthly physical inventories in addition to the required biennial inventories.
Be sure to maintain documentation of the necessary inventories, and ensure the initial and biennial physical inventories are conducted.