Controlled Substances FAQs

Can you work with a controlled substance outside of the schedules on the registration?

• No. Per DEA regulation, a researcher may only conduct research with controlled substances in those schedules for which the registration was issued. Regulation Link

Can a New York State Department of Health Class 4 licenses be transferred or amended to another individual faculty member?

For example, the license holder is retiring and another principle investigator is taking over the program.

• Class 4 licenses are not transferrable.  The faculty member must apply for their own license.

Does the state need to issue a license before the applicant can apply for a DEA registration?

• Yes

Are separate DEA registrations required for separate locations?

• A separate registration is required for each principal place of business or professional practice where controlled substances are stored, administered, or dispensed by a person.
• Since a DEA registration is required for separate locations, a state license is also required for each separate location where controlled substances are stored.

Does the NYSDOH license need to be displayed?

• A controlled substances license shall be permanently displayed in the place to which it applies. Regulation Link

Does the DEA registration need to be displayed?

• The registrant shall maintain the certificate of registration at the registered location in a readily retrievable manner and shall permit inspection of the certificate by any official, agent or employee of the Administration or of any Federal, State, or local agency engaged in enforcement of laws relating to controlled substances. Regulation Link

How long must controlled substances records be kept?

• The NYSDOH requires all records pertaining to controlled substance be retained for 5 years. Although the DEA requires a minimum of two years, we must follow the more stringent state requirements.
  State Regulation Link
  DEA Regulation Link