DEA Biennial Inventory for Vet Clinics

What the rule requires

Every DEA registrant required to keep records must take an initial inventory of controlled substances on hand when controlled-substance business begins. ¹

After that initial inventory, the registrant must take a new inventory of all controlled substances on hand at least every two years; the inventory may be taken on any date within two years of the previous biennial inventory date. ¹

The inventory must be a complete and accurate record of controlled substances on hand, maintained in written, typewritten, or printed form at the registered location. ¹

What to record

The inventory must show whether it was taken at opening of business or close of business on the inventory date. ¹

Separate records must be maintained for each registered location; do not combine inventories across locations. ²

Keep every inventory and other Part 1304 record available for inspection for at least two years unless your state requires a longer period. ³

Practical worksheet

List each controlled substance separately by drug name, finished form, strength, container size, number of containers, and total quantity on hand. ¹

For a clinic with no controlled substances on hand at startup, the initial inventory still needs a record showing zero controlled substances on hand. ¹

When a substance is newly controlled, a registrant that already possesses it must take an inventory of that substance on the effective scheduling date. ¹