When to conduct inventory of newly scheduled drugs?

[Lucidity84]

Say drug A was a non scheduled drug, but the DEA decides to place drug A in schedule IV on March 3, 2015 and the effective date is April 4, 2015. Do you have to do inventory exactly ON the effective date (April 4, 2015)? Is there some flexibility? Can you conduct the inventory a few days before or after?

"On the effective date of a rule by the Administrator pursuant to§§1308.45, 1308.46, or 1308.47 of this chapter adding a substance to any schedule of controlled substances, which substance was, immediately prior to that date, not listed on any such schedule, every registrant required to keep records who possesses that substance shall take an inventory of all stocks of the substance on hand. Thereafter, such substance shall be included in each inventory made by the registrant pursuant to paragraph (c) of this section." http://www.deadiversion.usdoj.gov/21cfr/cfr/1304/1304_11.htm

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[Ackj]

Say drug A was a non scheduled drug, but the DEA decides to place drug A in schedule IV on March 3, 2015 and the effective date is April 4, 2015. Do you have to do inventory exactly ON the effective date (April 4, 2015)? Is there some flexibility? Can you conduct the inventory a few days before or after?

"On the effective date of a rule by the Administrator pursuant to§§1308.45, 1308.46, or 1308.47 of this chapter adding a substance to any schedule of controlled substances, which substance was, immediately prior to that date, not listed on any such schedule, every registrant required to keep records who possesses that substance shall take an inventory of all stocks of the substance on hand. Thereafter, such substance shall be included in each inventory made by the registrant pursuant to paragraph (c) of this section." http://www.deadiversion.usdoj.gov/21cfr/cfr/1304/1304_11.htm

When NY changed their scheduling for hydrocodone and tramadol a while back, we were told to do it either close of business the night before, or open of business the day of.

 

[type b pharmD]

When NY changed their scheduling for hydrocodone and tramadol a while back, we were told to do it either close of business the night before, or open of business the day of.

This !

 

[Old Timer]

When NY changed their scheduling for hydrocodone and tramadol a while back, we were told to do it either close of business the night before, or open of business the day of.

This and only this......... Anything else would be, well, stupid....

 

[Old Timer]

Say drug A was a non scheduled drug, but the DEA decides to place drug A in schedule IV on March 3, 2015 and the effective date is April 4, 2015. Do you have to do inventory exactly ON the effective date (April 4, 2015)? Is there some flexibility? Can you conduct the inventory a few days before or after?

"On the effective date of a rule by the Administrator pursuant to§§1308.45, 1308.46, or 1308.47 of this chapter adding a substance to any schedule of controlled substances, which substance was, immediately prior to that date, not listed on any such schedule, every registrant required to keep records who possesses that substance shall take an inventory of all stocks of the substance on hand. Thereafter, such substance shall be included in each inventory made by the registrant pursuant to paragraph (c) of this section." http://www.deadiversion.usdoj.gov/21cfr/cfr/1304/1304_11.htm

O.k. think it through. When does it become effective? That's when you have to account for every pill. If it becomes effective on date X, you must do an inventory either at the close of business on date x-1 or before opening on date x. You could to it earlier as long as you keep a perpetual inventory and also do a count either at the close of business on date x-1 or before opening on date x.

 

[Lucidity84]

Thank you for everyone's feedback, this was helpful.