Created 08/20/2010
Investigators using controlled substances in research must take appropriate steps to safely store and secure the substances to prevent unauthorized access, use or diversion. This applies to the use of controlled substances when obtained under the Washington University registration or under an individual investigator registration.
This document provides the key elements of an appropriately managed research facility in which controlled substances are used and stored.
It is the responsibility of the Principal Investigator (PI) to assure that appropriate security is in place, that the research team is appropriately educated on the use of controlled substances and that any diversion of controlled substances is immediately reported to Danforth Campus Police Department (314-935-5555) or WUSM Protective Services (314-362-4357).
For further information, please refer to the Washington University Policy for Use of Controlled Substances in Laboratory and Animal Research. A list of Recommended Narcotic Storage Cabinets is also available.
The Drug Enforcement Agency (DEA) also provides information on security, which can be reviewed at https://www.deadiversion.usdoj.gov/GDP/(DEA-DC-057)(EO-DEA217)_Researchers_Manual_Final_signed.pdf.
Guidelines
- Identify the employees who will be delegated access to the controlled substances and assure that the appropriate DEA NADDIS/NCIC background check has been completed by Human Resources and that the NADDIS/NCIC check verifies the employee is eligible to have access to controlled substances. Restrict access to only those employees who need access to the controlled substances to complete their responsibilities.
- Controlled substances must be stored in a secure location with appropriate access only through a key or combination lock. The storage location must have at least a two-key security system in place. The exact level of security depends on the amount and type of controlled substances stored, as well as general building security, but examples of common scenarios are below:
- Locked, non-glass cabinet or drawer integral to laboratory casework within a locked laboratory. The key must only be accessible to those who have completed and passed the background check described in #1 above.
- Key padded entrance to the building and a locked cabinet securely bolted to the wall with the key accessible only to those individuals meeting the requirements described in Step 1.
- Locked laboratory door and safe bolted to the floor or wall with a limited access key or confidential combination.
- Access the list of Recommended Narcotic Storage Cabinets for additional information on storage options.
- Controlled substances must not be stored in any container, locked or not, that can be easily removed from the laboratory (e.g. fireproof document box, tackle box, etc.)
- If an investigator obtains controlled substances from DCM/DAF stockrooms for use in IACUC approved research and also from vendors or governmental agencies under an individual registration, the controlled substances must be stored in separate, secure storage units.
- The receipt, use and disposal of all controlled substances must be documented on the Aliquot Log. Please see the Washington University Controlled Substances website for access to all forms.
- Annual inventories of all controlled substances must be conducted. Annual Inventory Form