Reporting of Unusual events or activities involving Controlled Substances
Roswell Park workforce who use, store or transfer controlled substances in research, must report immediately (upon discovery) to Roswell Park Public Safety, Roswell Park Drug Diversion, and The Office of Research Subject Protection for any of the following events:
- All unresolved discrepancies in inventory relating to Controlled Substances
- Possible loss or theft/diversion of Controlled Substances
- Improper removal of Controlled Substances from Roswell Park premises
- Any signs that a Controlled Substance may have been interfered or tampered with (such as broken, empty or cracked containers, broken seals, or lack of efficacy)
- Signs that a co-worker may be impaired due to self-administration of Controlled Substances
- Discovery of misplaced or unsecured Controlled Substances
- Any other situations where laws, regulations, policies or procedures relating to Controlled Substances may not have been followed
Reporting theft or loss
Roswell Park Personnel who use, store or transfer Controlled Substances in research, must report any theft or loss of unknown origin to the following, in the order listed:
- Public Safety
- Pharmacy Department
- Office of Research Subject Protection
- Research Diversion Prevention Committee. This committee will determine who will complete Form 10-6 and submit to the DEA
Best practices & actions
“Significant loss” is a subjective term, not defined by the federal Controlled Substance Act. Consider the following when determining whether to report a loss:
- The quantity of loss in relation to business type. Document non-significant loss; Report significant loss
- Is the loss is associated with theft? Report
- Is the loss waste during use of the substance in laboratory? Document
- Are there patterns of loss over time? Report
- Does the substances have a high potential for diversion or theft? Report
Non-significant loss caused by miscounts or clerical errors must still be documented on the usage logs, including a short explanation and the user initials.
References and resources
- DEA Form 106. Form for use by the DEA Registrant only
- DEA Theft/Loss Procedures & Information. Additional procedural information regarding the reporting of a controlled substance theft or loss
Questions
Roswell Park Public Safety
Phone: 716-845-3069 (non-emergency)
Jillianna Wasiura
Director, Diversion Prevention
Phone: 716-845-3425
Email: Jillianna.Wasiura@RoswellPark.org
DEA, Buffalo District Office
270 Michigan Ave. Ste 200, Buffalo, NY 14203
Investigative Matters or TDS: 716-846-6030
Fax: 716-843-2154