United States
Hong KongLoss and theft
Theft or significant loss of controlled substances is reported to DEA on Form 106. The registrant must also notify DEA upon discovery of the theft or significant loss.
A short, precise topic with one form number and one judgment built into it.
The form
DEA Form 106 reports theft or significant loss of controlled substances.
Form 222 orders Schedule I and II substances. Two forms, two purposes, and the exam pairs them as distractors.
Notification and the report
A registrant notifies DEA upon discovery of a theft or significant loss, and completes the report. The discovery, not the conclusion of an investigation, starts the obligation. On discovery.
Not every discrepancy is a reportable loss. The registrant assesses factors such as the quantity and schedule involved, whether there is a pattern, and whether the circumstances suggest diversion. A single tablet unaccounted for once is a different matter from a recurring shortfall in a Schedule II product, and the regulation expects that judgment rather than a fixed threshold.
What a technician does
Notices and reports internally, immediately and accurately. Deciding whether something is a significant loss, and filing with DEA, sits with the registrant.
A technician who quietly adjusts a count to make it balance has turned a discrepancy into a records problem and possibly into an allegation. Never adjust the count.
Why accuracy matters more than tidiness
The records exist so that what came in, what went out and what is held can be reconciled. A record altered to remove a discrepancy destroys the only evidence that the discrepancy existed. Two forms, two purposes.
The related obligations
- Records kept at least two years, 21 CFR 1304.04
- Biennial inventory within two years, 21 CFR 1304.11
- Security requirements for storage, which is where losses are prevented rather than detected
What to hold
Form 106 for theft or significant loss, notification on discovery, significance is a registrant judgment, and never adjust a count to balance.
Common questions
Which form reports controlled substance theft?
DEA Form 106.
When does the obligation start?
On discovery of the theft or significant loss.
Is every discrepancy reportable?
No. The registrant judges significance from quantity, schedule, pattern and circumstances.
What does a technician do?
Report internally, immediately and accurately. The filing decision is the registrant's.
What must never happen?
Adjusting a count to make it balance. That destroys the evidence.