August 2016

CHAPMAN UNIVERSITY Controlled Substances & Precursor Chemicals Program

August 2016

CHAPMAN UNIVERSITY Controlled Substances & Precursor Chemicals Program

Table of Contents INTRODUCTION ............................................................................................................................................. 3

REGULATIONS ................................................................................................................................................ 4

CONTROLLED SUBSTANCES MANAGEMENT ................................................................................................. 4

Responsibilities ......................................................................................................................................... 4

1.0 Environmental Health & Safety................................................................................................. 4

2.0 Participating Faculty/Senior Research Staff .............................................................................. 5

3.0 Authorized Researcher .............................................................................................................. 6

4.0 Controlled Substances Distribution Office (EH&S or its authorized agent) .............................. 6

Use Authorization & Purchasing ............................................................................................................... 7

Central Receiving & Dispensing Process ................................................................................................... 8

Inventory & Recordkeeping ...................................................................................................................... 8

Storage & Security .................................................................................................................................... 9

Transfers ................................................................................................................................................. 10

Disposal ................................................................................................................................................... 10

PRECURSOR CHEMICAL MANAGEMENT ...................................................................................................... 11

APPENDIX A: SCHEDULES OF CONTROLLED SUBSTANCES ....................................................................... 12

APPENDIX B: FEDERAL DEA List I & II CHEMICALS and DEA Codes (as of 7/22/16) ....................................... 13

APPENDIX C: LIST OF CALIFORNIA DEPARTMENT OF JUSTICE PRECURSER CHEMICALS ............................ 15

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INTRODUCTION Research use of selected drugs and precursor chemicals are regulated by the Federal Drug Enforcement Administration (DEA) and California Department of Justice (CA-DOJ). To assist Chapman University personnel in compliance with these regulations and Chapman University policy, specific institutional requirements have been established for the management of controlled substances and precursor chemicals. Scope of Program & Institutional Registration: This document applies to all Chapman University personnel working with controlled substances, precursor chemicals and pharmaceutical substances. This Program and any future Chapman University Institutional Registration with the DEA covers Schedule II-V controlled substances regulated by the DEA (see Appendix A) and precursor chemicals regulated by the DEA (see Appendix B) and CA-DOJ (see Appendix C) used in research at all Chapman University campus locations. DEFINITIONS: Authorized Researcher - A Principal Investigator or laboratory member (e.g., staff, graduate students, undergraduate students, post-docs, visiting scholars and co-faculty) who are assigned by the Participating Faculty/Senior Research Staff to work with controlled substances within their laboratory. Controlled Substances Act (CSA) - Title 21 United States Code (USC) Controlled Substances Act (21 U.S.C. §801 et seq.) Drug Enforcement Administration (DEA) – the agency responsible for enforcing the controlled substances laws and regulations of the United States. Environment, Health and Safety (EH&S) – The administrative unit that manages the location’s Environment, Health and Safety programs. Program Administrator – person from Environment, Health and Safety charged with implementing and managing the Controlled Substances Program on a day-to-day basis. This person is also called Controlled Substance Officer. Responsible Official – personnel with responsibility for oversight of the Controlled Substance Program. This is the EH&S Manager/Director. Controlled Substances – Narcotic and non-narcotic drugs under the jurisdiction of the Federal Controlled Substances Act and the California Uniform Controlled Substances Act, including but not limited to those substances listed in 21 CFR §1308.11-1308.15 Listed Chemicals – Under federal law, any List I or List II chemical including a List I chemical specifically designated by the DEA Administrator in 21 CFR §1310.02(a), that in addition to legitimate uses, can be used in manufacturing a controlled substance in violation of the federal Controlled Substances Act, and any List II chemical specifically designated by the DEA Administrator in 21 CFR §1310.02(b), that in addition to legitimate uses is used in manufacturing a controlled substance in violation of the Act.

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Precursor Chemical – Under California pharmacy law, a precursor chemical is any chemical that may be used to create controlled substances, including but not limited to catalysts, direct precursors or crucial ingredients used in the production of controlled substances (see also California Health and Safety Code §11100).

REGULATIONS

Compliance with federal and state laws and university procedures governing controlled substances and precursor chemicals is required by all individuals and groups associated with Chapman University. These regulations include the following:

1. Code of Federal Regulations: Title 21, Chapter II (Parts 1300 to end) – These regulations

implement the Controlled Substances Act of 1970, the Diversion Control Amendments of 1984, 1985, 1986, 2011 and subsequent amendments (http://www.deadiversion.usdoj.gov/21cfr/cfr/index.html).

2. Health and Safety Code Division 10: California Uniform Controlled Substances

Act. (http://leginfo.legislature.ca.gov/faces/codes.xhtml).

CONTROLLED SUBSTANCES

MANAGEMENT Responsibilities 1.0 Environmental Health & Safety Chapman University’s Department of Environmental Health & Safety (EH&S) in the Office of Risk Management providers oversight, including policy development for any use of controlled substances for research purposes within the University. This includes:

1. Identifies need for new registrations, assesses current registration limitations, applies for,

maintains and renews DEA registrations. Liaison with DEA on registration issues. 2. To the extent that the University may hold a current DEA registration, oversees initiation

and maintenance of the institutional research registration for DEA Schedule II – V controlled substances.

3. Coordinates research authorizations for use and transfer of controlled substances involving the University’s DEA Registration.

4. Procures and dispenses orders for controlled substances used in research. 5. Performs periodic compliance inspections. 6. Coordinates the initial and biennial campus-wide inventories and submits report to the DEA.

This inventory must be conducted on a single day for all researchers covered under a University registration.

7. Develops and promulgate compliance tools. 8. Authorizes Purchase requisitions for acquisition of controlled substances from outside

vendors.

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9. Communicates with agencies on all compliance issues, including report lost or stolen controlled substances to the Department of Public Safety and the DEA within 24 hours

10. Provides for appropriate disposal of controlled substances (Schedule II-V) obtained under CU’s institutional DEA registration.

2.0 Participating Faculty/Senior Research Staff For the purpose of internal control, faculty whose work involves the use Schedule II – V controlled substances shall enroll such work and secure EH&S’s approval, which includes submittal of Chapman University’s Controlled Substance Purchase Request Application (Form 1) & Chapman University’s Controlled Substance Authorized Researcher Application (Form 2), and a “Start-up Lab Inspection.” The responsibilities of the participating faculty and Authorized Users are:

1. Comply with university, federal and state regulations pertaining to the possession of controlled

substances via adherence to Chapman University’s Controlled Substances & Precursor Chemicals Program.

2. Maintain strict control over inventory and security for controlled substances. 3. Ensure that controlled substances are NOT intermingled in any manner (usage, storage, etc.)

with those controlled substances owned by other individual(s) or other sources. 4. Ensure Schedule II controlled substance inventory and records are maintained separately from

Schedule III – V controlled substances. 5. Ensure necessary researcher authorization for individuals in the laboratory who are

assigned to work with controlled substances (e.g., staff, graduate students, post-docs, visiting scholars or co-faculty) and maintain documentation to verify currently authorized researchers.

6. Take the on-line Controlled Substances Training available from the EH&S Office. Also ensure that Authorized Researchers complete this training.

7. Provide training to Authorized Researchers on laboratory-specific operations involving controlled substances and precursor chemicals. Provide information on the health hazards of the substances, including local and systemic toxicity, and the conditions and situations that could result in exposure. Retain training records for at least one year.

8. Ensure Authorized Researchers receive, store, use, dispose of, and continually maintain usage log sheets and on-line chemical inventory management system for controlled substances per the University’s Program. Maintain usage logs for 2 years after complete use or disposal of controlled substance.

9. Ensure that periodic self-inspections are conducted minimally on a quarterly basis, using CU Controlled Substance Periodic Inspection Checklist (Form 7). Retain inspection records for at least one year. Assign more than one authorized researchers to conduct self-inspections.

10. Biennially, complete and submit to EH&S the physical inventory, as required by regulations and directed by the institutional program.

11. Prior to moving, contact CU Controlled Substances Program Office to seek approval for moving storage location of Controlled Substances.

12. Immediately report missing controlled substances to Environmental Health & Safety by calling (714) 532-7794 and emailing EHS@chapman.edu . EH&S will forward cases of suspected theft or diversion to Chapman’s Department of Public Safety. Any imminent safety threats are to be reported to Public Safety by calling 911 from any campus phone or local law authority if off-

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campus. 13. Ensure any delegated duties associated with this program are conducted in a timely manner.

3.0 Authorized Researcher

An Authorized Researcher is responsible for: 1. Submitting CU Controlled Substance Authorized Researcher Application (Form 2) to EH&S. 2. Take the on-line Controlled Substances Training available via EH&S. 3. Complying with university, federal and state regulations pertaining to the possession of

controlled substances via adherence to Chapman University’s Controlled Substances & Precursor Chemicals Program regarding: •Authorization • Ordering • Training •Security, receiving, storing, using, maintenance of usage log sheets, disposing of

controlled substances •Separately maintain Schedule II controlled substance inventory and records from

Schedule III-V controlled substances. •Reporting theft or loss of controlled substances.

4. If delegated by Participating Faculty/Senior Research Staff, participating in or

conducting program activities such as maintaining on-line inventory, periodic inspections, biennial campus-wide inventory, etc.

4.0 Controlled Substances Distribution Office (EH&S or its authorized agent)

1. Review relevant terms and conditions when drug order is delivered to Distribution Office from an outside vendor.

2. Receives and stores controlled substances including radioactive controlled substances in a secure cabinet or safe, including refrigeration if needed.

3. Maintains log book that contains the following information: PI, controlled substance, strength, form, date received from the carrier, initial and date for technician distributing substance to PI, and initial and name for PI representative picking up substance from distribution office.

4. Ensures that the date and quantity of drugs supplied to researchers is recorded on DEA 222 forms and other records.

5. Maintains records of all controlled substance transactions.

6. Notifies laboratory by phone or email when their orders are ready use. Releases orders to researchers who are listed as Authorized Recipients in the CSA and have signature cards on file.

7. At time of pick up, authorized recipient will verify accuracy of amount received by initialing log book.

8. If controlled substances are not claimed within 30 days of initial lab notification they will be destroyed.

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Use Authorization & Purchasing

Any University faculty or senior research staff member needing to purchase Schedule II – V controlled substances for research must gain EH&S use/ purchasing approval.

S t e p 1 : For use/ purchasing approval, prior to any initial request to purchase Controlled Substances under the Chapman University DEA registration, submit the following Form 1 and form 2 to EH&S:

1. CU Controlled Substance Purchase Request Application (Form 1) * - Identifies thecontrolled substances requested, names of the authorized researchers, and providesproof of legitimate research use including approval from one of the following:

• Institutional Animal Care and Use Committee (IACUC) for animalresearch,

• Institutional Review Board (IRB) for human subjects related research, or the applicant’sdepartment chairperson (if the applicant is the department chairperson or higher,approval must be obtained by the applicant’s supervisor).

NOTE: This process does not cover authorization requirements of the Institutional Animal Care and Use Committee (IACUC) or the Institutional Review Board (IRB) which must be separately secured through the Office of Research and Sponsored Program Administration (ORSPA), nor does it cover authorizations required to use Controlled Substances at a location not covered by the Chapman University DEA registration permit. Controlled substances used solely for research such as in synthesis and in vitro studies will not require IACUC or IRB approval. Faculty and senior research staff must independently seek authorization as appropriate from the IRB and/or IACUC if their research projects specifically involve: • Any Schedule I controlled substance;• Human research using any Schedule I or Schedule II controlled substance; or• Research for the treatment of drug abuse using any drug, Scheduled or not.

Applications are available at http://oag.ca.gov/research/research

* For Schedule II requests, submit a separate Form 1 because records for Schedule II ControlledSubstances must be maintained separately from Schedule III- V.

2. CU Controlled Substance Authorized Researcher Application (Form 2) – This formfulfills the regulatory requirement to fairly assess the likelihood of personnel tocommit a drug security breach. Authorization to access controlled substances will bedenied to any personnel who has been convicted of a felony offense relating tocontrolled substances or who, at any time had an application for DEA registrationdenied or registration revoked—in accordance with Section 21 CFR 1301.90.Requestors agree to consent to a University requirement for a current backgroundcheck. Names of all new Authorized Researchers are made available to the U.S. DrugEnforcement Administration (for screening of criminal history).

The form also communicates the Requestor’s responsibility to: • take the on-line Controlled Substances Training• obtain the requisite health and safety training on the hazards of working with

the controlled substance from his/her supervisor.• follow listed work practices as further detailed in the Controlled Substances &

Precursor Chemicals Program.

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S t e p 2 : EH&S will, after receipt and approval of Form 1 and Form 2, coordinate with the authorized researchers to conduct an inspection of the laboratory to verify that security, storage, training, recordkeeping requirements are met. Once that is complete and approved, EH&S will advise the authorized researcher of the process for requisitioning/purchasing drugs. S t e p 3 : The authorized researcher will create a Purchase Requisition via University-standard PeopleSoft processes. The researcher will use a Vendor on this list of EH&S Authorized Vendors. The researcher will attach a completed Form 1 to the online Purchase Requisition, which will be electronically routed to EH&S for review and approval. The purchase of controlled substances under the Chapman University Institutional License cannot be advanced without EH&S approval. Please consult with EH&S on large quantity purchases of precursor chemicals. For more information on Purchasing procedures, please see the related information in this document found at this link, and/or contact http://www.chapman.edu/faculty-staff/purchasing.aspx IMPORTANT: Under no circumstances can controlled substances be purchased using a P-Card, other credit card, or by any means other than through the University’s established Purchasing System via PeopleSoft. The management of controlled substances under the Chapman University DEA Registration creates a significant obligation to researchers to follow all elements of this Controlled Substances and Precursor Chemical Program Manual. A failure to follow established policies and procedures can result in a discontinuance of researcher authority to purchase controlled substances and may jeopardize the Institutional Registration that is held in the name of the University. This could result in a loss of the authority granted by the DEA to purchase controlled substances, impacting the entire Chapman University science research community.

Central Receiving & Dispensing Process

All authorized controlled substance purchases are delivered to the Authorized Purchaser at the address shown on the DEA Institutional License and will be received in accordance with guidelines provided in this manual and with Chapman University EH&S Policies and Procedures.

Inventory & Recordkeeping Per the Code of Federal Regulations- Title 21, Section 1304, complete and accurate records shall be kept of all controlled substances purchased, manufactured, transferred, or wasted.

FOR AUTHORIZED RESEARCHERS: Controlled Substance Logbooks Each authorized Faculty or Senior Research Staff Member in possession of controlled substances must maintain an up-to-date legible usage log of each controlled substance in possession using the CU Controlled Substances Usage Log (Form 3). Records must be kept locally for a minimum of two years from final disposition of the controlled substance. Logbooks shall be kept available for periodic audit by EH&S and the DEA.

FOR AUTHORIZED RESEARCHERS: Biennial Inventory Submission On a periodic two-year institutional cycle, beginning January 18, 2017, each Faculty or Senior Research

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Staff Member must submit a controlled substance inventory on the 3rd Wednesday of January every other year to EH&S using the CU Controlled Substances Biennial Inventory Form (Form 4). Researchers will be provided notice 30 days in advance of the date. Submit a separate Form 4 for Schedule II controlled substance inventory.

Storage & Security

The University’s overall security system involves a coordinated system of physical and administrative controls.

Public Safety: Chapman University’s Department of Public Safety has officers who continuously patrol the University and enforce public safety and security.

Building Systems: Chapman University’s buildings have card key or key systems to lock building after hours, with some facilities also having video cameras stationed at the entrances to buildings.

Storage: Controlled substances shall be stored in a securely locked, substantially constructed cabinet, located where access is limited. EXCEPTION: The following substances must be stored in a safe: Carfentanil, etorpine hydrochloride, and diprennorphine.

Access: Access within the laboratory must be limited to the smallest number of CU Controlled Substance Authorized Researchers necessary to perform related research activities to help assure complete accountability and reconciliation of any discrepancy that may result.

Screening of Authorized Researchers: All researchers intending to handle controlled substances, including faculty and senior research staff, are required to undergo background screening via submission of the CU Controlled Substance Authorized Researcher Application (Form 2).

Work Practices: Controlled substances must never be left unattended at any time. Discovery of an unattended controlled substance, or an unsecured storage area, exposes the institution to losing its registration.

Containers/ Labeling: Controlled substances must not be transferred from the original containers for inventory purposes. Identifying labels must not be removed from the original containers. If the substance is converted or diluted, the new container must be labeled properly.

Records and Disposing: Controlled substances storage and security requirements can be found in other sections of this manual, including sections on Inventory & Recordkeeping and Disposal. Loss or Theft: Any detected loss or theft of controlled substances must be reported immediately to Chapman University’s Public Safety Office at 714-997-6763 and the Risk Management / EH&S Office at 714-532-7794.

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Transfers Intra-Campus Transfers: Ownership of controlled substances may only be transferred to an individual covered under the University’s Program, and such transfer may only occur upon specific written approval granted by EH&S.

An intra-campus transfer of a controlled substance will be approved only if the following criteria are met:

1. The original inventory must have been acquired under the Chapman DEA registration. 2. The Faculty or Senior Research Staff Member receiving the substance(s) must submit a CU

Controlled Substance Purchase Request Application (Form 1) to EH&S and receive approval from EH&S for such transfer.

3. Both parties maintain documentation of any approved transfer.

Prohibition of Inter-Campus Transfers: Under no circumstances can controlled substances falling under the Institutional Registration be transferred into or out of the location as identified on the DEA Registration. Faculty/Researchers with dual appointments at Chapman University and other labs are prohibited from taking or transferring controlled substances into or out of those other laboratories. Al so, faculty with on - and off - campus laboratories is prohibited from taking or transferring controlled substances into or out of on - campus laboratories.

Disposal Controlled substances to be disposed must be properly accounted for, and are not allowed to be disintegrated, crushed into powder and dissolved in water for disposal. A request for waste pick up must be made to EH&S’s Hazardous Waste Program by submitting the CU Controlled Substances Disposal Request Form (Form 6) via email to EHS@chapman.edu or via fax to 714-464-4522.

Categories of Waste: 1. Wasted Controlled Substances - These include items such as unused tablets, injections,

oral liquid or preparations compounded in error, which contain controlled substances. 2. Expired Controlled Substances - These include controlled substances, which have exceeded their

shelf life, unwanted Controlled Substances classified as non-formulary drugs or a drug that has fallen into disuse.

Destruction of properly submitted controlled substances is managed by EH&S per the DEA’s requirements: http://www.deadiversion.usdoj.gov/21cfr_reports/surrend/index.html

NOTE: EH&S only manages the disposal of DEA controlled substances (Schedule II-V) obtained under CU’s institutional DEA registration; individual registrants are responsible for managing the disposal of their controlled substances per DEA requirements.

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PRECURSOR CHEMICAL MANAGEMENT

The mission of the DEA's and the CA-DOJ’s Precursor Chemicals Control Programs are to disrupt the illicit production of controlled substances by preventing diversion of chemicals used to make drugs. The illegal production of drugs such as methamphetamine, cocaine, heroin, and MDMA (ecstasy) requires enormous quantities of precursor and essential chemicals. These federal and state programs seek to minimize the regulatory burden on the legitimate chemical industry while instituting effective anti-diversion policies.

A DEA registration (or California Department of Justice registration) is required for purchasing precursor chemicals from vendors outside of California. If precursor chemicals are bought from a vendor within California, use of the registration may not be required. Note that when purchasing precursor chemicals from California-based vendors, a minimum 21-day hold processing period is required for such purchases to be completed.

Lists of regulated precursor chemicals are provided as follows: • Appendix B - Federal Drug Enforcement Administration List I and II chemicals • Appendix C - California’s Department of Justice Precursor Chemical List

Approval and Purchase Process - Use of Institutional DEA Registration

Any University faculty or senior research staff member needing to purchase precursor chemicals for research must submit the Chapman University Precursor Chemical Purchase Request Application (Form 5) to EH&S to initiate the approval process. A statement of intended use may be required.

Refer to Step 3 above under the section on Use Authorization & Purchasing. After receiving EH&S approval of the Purchase Request Application and online Purchase Requisition, the Requestor will place the order using a pre-selected vendor. A controlled substance shipment is delivered directly to the address reflected on the DEA Registration, where the authorized researcher is notified that the package can be picked up. This procedure will also apply to a shipment that contains both controlled substances and precursor chemicals. A shipment that only contains Precursor chemicals must be delivered directly to the chemical stockroom for receipt and entry into the chemical inventory system.

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APPENDIX A: SCHEDULES OF CONTROLLED SUBSTANCES

The Federal Drug Enforcement Administration (DEA) lists controlled substances into 5 schedules. These drugs are listed in the Controlled Substance Act (CSA) of 1970. Examples of drugs in each schedule are listed below – this is not a complete listing, for drugs not listed please use the hyperlinks included.

Section 812 of the Controlled Substances Act (21 U.S.C. §801 et seq.) (CSA) lists substances that were controlled in 1970 when the law was enacted. Since then, approximately 160 substances have been added, removed, or transferred from one schedule to another. The current official list of controlled substances can be found in section 1308 of the most recent issue of Title 21 Code of Federal Regulations (CFR) Part 1300 to end (21 CFR §1308) and the final rules which were published in the Federal Register subsequent to the issuance of the CFR.

This list describes the basic or parent chemical and do not describe the salts, isomers and salts of isomers, esters, ethers and derivatives which may be controlled substances. These lists are intended as general references and are not comprehensive listings of all controlled substances. Please note that a substance need not be listed as a controlled substance to be treated as a Schedule I substance for criminal prosecution. A controlled substance analogue is a substance that is intended for human consumption and is structurally or pharmacologically substantially similar to or is represented as being similar to a Schedule I or Schedule II substance and is not an approved medication in the United States. (See 21 U.S.C. §802(32)(A) for the definition of a controlled substance analogue and 21U.S.C. §813 for the schedule.)

Lists of Controlled Substances http://www.deadiversion.usdoj.gov/schedules/index.html

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APPENDIX B: FEDERAL DEA List I & II CHEMICALS and DEA Codes (as of 7/22/16)

Congress passed the Chemical Diversion and Trafficking Act (CDTA) in 1988 and subsequent amendments in 1993, placing under control 34 chemicals. These laws provide a system of regulatory controls and criminal sanctions to address both domestic and international diversion of important chemicals without interrupting access to chemicals destined for legitimate commerce. The CDTA created two categories for the controlled chemicals, as follows: The following chemicals have been specifically designated by the Administrator of the Drug Enforcement Administration as the listed chemicals subject to the provisions of this part and parts 1309 and 1313 of this chapter. Each chemical has been assigned the DEA Chemical Code Number set forth opposite it.

List I Chemicals (per 21 CFR 1310.02(a)):

(1) Anthranilic acid, its esters, and its salts 8530 (2) Benzyl cyanide 8735 (3) Ephedrine, its salts, optical isomers, and salts of optical isomers

8113 (4) Ergonovine and its salts 8675 (5) Ergotamine and its salts 8676 (6) N-Acetylanthranilic acid, its esters, and its salts 8522 (7) Norpseudoephedrine, its salts, optical isomers, and salts of optical isomers

8317 (8) Phenylacetic acid, its esters, and its salts 8791 (9) Phenylpropanolamine, its salts, optical isomers, and salts of optical isomers

1225 (10) Piperidine and its salts 2704 (11) Pseudoephedrine, its salts, optical isomers, and salts of optical isomers

8112 (12) 3,4-Methylenedioxyphenyl-2-propanone 8502 (13) Methylamine and its salts 8520 (14) Ethylamine and its salts 8678 (15) Propionic anhydride 8328 (16) Isosafrole 8704 (17) Safrole 8323 (18) Piperonal 8750 (19) N-Methylephedrine, its salts, optical isomers, and salts of optical isomers (N-Methylephedrine) 8115

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(20) N-Methylpseudoephedrine, its salts, optical isomers, and salts of optical isomers 8119

(21) Hydriodic Acid 6695 (22) Benzaldehyde 8256 (23) Nitroethane 6724 (24) Gamma-Butyrolactone (Other names include: GBL; Dihydro-2 (3H)-furanone; 1,2-Butanolide; 1,4-Butanolide; 4-Hydroxybutanoic acid lactone; gamma-hydroxybutyric acid lactone)

2011 (25) Red Phosphorus 6795 (26) White phosphorus (Other names: Yellow Phosphorus) 6796 (27) Hypophosphorous acid and its salts (including ammonium hypophosphite, calcium hypophosphite, iron hypophosphite, potassium hypophosphite manganese hypophosphite magnesium hypophosphite and sodium hypophosphite

6797 (28) N-phenethyl-4-piperidone (NPP) 8332 (29) Iodine 6699 (30) Ergocristine and its salts 8612

(b) List II chemicals:

List II Chemicals (per 21 CFR 1310.02(b)):

(1) Acetic anhydride 8519 (2) Acetone 6532 (3) Benzyl chloride 8570 (4) Ethyl ether 6584 (5) Potassium permanganate 6579 (6) 2-Butanone (or Methyl Ethyl Ketone or MEK) 6714 (7) Toluene 6594 (8) Hydrochloric acid (including anhydrous hydrogen chloride) 6545 (9) Sulfuric acid 6552 (10) Methyl Isobutyl Ketone (MIBK) 6715 (11)Sodium Permanganate 6588

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APPENDIX C: LIST OF CALIFORNIA DEPARTMENT OF JUSTICE PRECURSER CHEMICALS

HEALTH AND SAFETY CODE

SECTION 11100-11111

11100. (a) Any manufacturer, wholesaler, retailer, or other person or entity in this state that sells, transfers, or otherwise furnishes any of the following substances to any person or entity in this state or any other state shall submit a report to the Department of Justice of all of those transactions:

(1) Phenyl-2-propanone. (2) Methylamine. (3) Ethylamine. (4) D-lysergic acid. (5) Ergotamine tartrate. (6) Diethyl malonate. (7) Malonic acid. (8) Ethyl malonate. (9) Barbituric acid. (10) Piperidine. (11) N-acetylanthranilic acid. (12) Pyrrolidine. (13) Phenylacetic acid. (14) Anthranilic acid. (15) Morpholine. (16) Ephedrine. (17) Pseudoephedrine. (18) Norpseudoephedrine. (19) Phenylpropanolamine. (20) Propionic anhydride. (21) Isosafrole. (22) Safrole. (23) Piperonal. (24) Thionylchloride. (25) Benzyl cyanide. (26) Ergonovine maleate. (27) N-methylephedrine. (28) N-ethylephedrine. (29) N-methylpseudoephedrine. (30) N-ethylpseudoephedrine. (31) Chloroephedrine. (32) Chloropseudoephedrine. (33) Hydriodic acid.

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(34) Gamma-butyrolactone, including butyrolactone; butyrolactone gamma; 4-butyrolactone; 2(3H)-furanone dihydro; dihydro-2 (3H)-furanone; tetrahydro-2-furanone; 1,2-butanolide; 1,4-butanolide; 4-butanolide; gamma-hydroxybutyric acid lactone; 3-hydroxybutyric acid lactone and 4-hydroxybutanoic acid lactone with Chemical Abstract Service number (96-48-0). (35) 1,4-butanediol, including butanediol; butane-1,4-diol; 1,4-butylene glycol; butylene glycol; 1,4-dihydroxybutane; 1,4-tetramethylene glycol; tetramethylene glycol; tetramethylene 1,4-diol with Chemical Abstract Service number (110-63-4). (36) Red phosphorus, including white phosphorus, hypophosphorous acid and its salts, ammonium hypophosphite, calcium hypophosphite, iron hypophosphite, potassium hypophosphite, manganese hypophosphite, magnesium hypophosphite, sodium hypophosphite, and phosphorous acid and its salts. (37) Iodine or tincture of iodine.

(38) Any of the substances listed by the Department of Justice in regulations promulgated pursuant to subdivision (b). (b) The Department of Justice may adopt rules and regulations in accordance with Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code that add substances to subdivision (a) if the substance is a precursor to a controlled substance and delete substances from subdivision (a). However, no regulation adding or deleting a substance shall have any effect beyond March 1 of the year following the calendar year during which the regulation was adopted.

Form 1 – 8/16

CU Controlled Substance Purchase Request Application ***Submit to EH&S to EHS@chapman.edu or via fax at (714-464-4522) – Attention Controlled Substances Program Office***

1) Applicant (Faculty/ Protocol Director or Co-director):

Name:________________________________________________________________Last, First, M

Phone:

Title: _____________________________

Dept: _______________________ ______________________________________

E-mail Address: ____________________________________________________________

Account to bill: _________________________________________________

2) Controlled Substance(s) Requested: � New purchase ; OR, � Transfer (from another owner)

Substance Sched. If any ordering requirements, specify: Quantity: --Generic O.K? yes or no (circle) --If other than USP grade, specify

(II-V) (manufacturer, product #, etc.) Unit size # of units

Shipping preference/ urgency: _______________________________________________________

3) Use/ Storage Locations:

Building Room Security Measures (See Written Program for req’ts.) � Safe* � Securely locked, substantially constructed cabinet � Other:_______________________________� Safe* � Securely locked, substantially constructed cabinet � Other:_______________________________

* Required for storage of carfentanil, etorphine hydrochloride and diprenorphine

CSP Form1a – 2/09

4) Research Users of Listed Substance(s): NOTE: Each Research User (including the Faculty/Protocol Director or Co-director Applicant)

must initially submit an Authorized Researcher Application (CSP Form 2) to EH&S Name (Last, First, MI) Title Phone # SU ID#

5) Controlled Substances Use Approval:

Research Protocol (Title):____________________________________________________

______________________________________________________________________ Applicant to maintain copy of research protocol/Standard Operating Procedure on file for review by EH&S and

DEA.

Approval by either: � AICUC and/or IRB Protocol Approval (Protocol ID#: ____________________________)

OR

� Department Chair: Based on the nature of the research being conducted by the aforementioned Faculty/ Senior Research Staff Member, I certify that his/ her requested use of DEA Controlled Substance(s) as legitimate and necessary for their research efforts at Chapman University.

_______________________ ______________________________ ____________ Dept. Chair Signature Print Name Date

6) Certification - for the responsible Faculty/ Protocol director or Co-director

I, certify that the information provided above is accurate, and that I understand and willabide by the use requirements of the CU Controlled Substances and Precursor ChemicalsProgram.

Printname______________________________________Title________________________

Signature _______________________________________ Date__________________

Form 2 – 8/16

CU Controlled Substances- Authorized Researcher Application This is to be completed by each researcher seeking use authorization

***Submit to EH&S (ehs@chapman.edu) or via fax at (714-464-4522) – Attention Controlled Substances Program Office***

Researcher: _____________________________ Title:_________________________ Date of Birth_____________ Last, First, M.I.

Last 4 Digits of Social Security # _______ Email:_____________________________________________________

Phone: _____________ Responsible Faculty/Protocol Director or Co-director:_____________________________

Background Screening 1. Within the past five years, have you been convicted of a felony, or within the past two years, of any misdemeanor

or are you presently formally charged with committing a criminal offense? (Do not include any traffic violations, juvenile offenses or military convictions, except by general court-martial). If the answer is yes, furnish details of conviction, offense, location, date and sentence.

� Yes - Provide details as attachment � No

2. In the past three years, have you ever knowingly used any narcotics, amphetamines or barbiturates, other thanthose prescribed to you by a physician? If the answer is yes, furnish details.

� Yes - Provide details as attachment � No

Authorized Researcher Responsibilities: 1. Take Chapman University’s on-line Controlled Substances Training - Contact EH&S for information.

2. Receive laboratory-specific training and understand the:- general chemical safety, conditions and situations that could result in exposure;- health hazards of controlled substance, including local and systemic toxicity.

3. Follow the appropriate work practices as required in Chapman University’s Controlled Substances &Chemical Precursor Program, which include:- Properly store/ secure controlled substances to prevent unauthorized access.- Accurately record your controlled substance usage, transfer, disposal, and any other inventory fluctuations

via updating the Controlled Substance Usage Logbook (Form 3). - Properly dispose of controlled substances via EH&S’ Hazardous Waste Program.- Report any lost/ stolen controlled substances to Chapman University EH&S @ 714-532-7794.

Reporting Diversion of Controlled Substances The DEA requires (per 21 CFR, Part 1301.91) that an employee who has knowledge of drug diversion from their employer by a fellow employee has an obligation to report such information to a responsible security official of the employer. A failure to report information of drug diversion will be considered in determining the feasibility of continuing to allow an employee to work in a drug security area.

- Chapman University shall treat such information as confidential and shall take reasonable steps to protect the confidentiality of the information and the identity of the employee furnishing the information. All such reports can be made confidentially to the Chapman University EH&S @ 714-532-7794. EH&S will then forward the information to Public Safety.

- If an imminent safety threat exists, contact Chapman University’s Department of Public Safety.

Disciplinary Action for Employees who Engage in Illicit Activities (21 CFR, Part 1301.92) It is the position of the DEA that employees who possess, sell, use or divert Controlled Substances will subject themselves not only to State or Federal prosecution for any illicit activity, but shall also immediately become subject of independent action regarding their continued employment. Chapman University will assess the seriousness of the employee’s violation, the position of responsibility held by the employee, past record of employment, etc., in determining whether to suspend, transfer, terminate or take other action against the employee.

I certify the accuracy of the above information and that I have read, understood, and agree with the above statements; and authorize CU to make inquiries with the Federal Drug Enforcement Agency’s local field office for possible pending charges or convictions I may have.

Researcher Signature: _____________________________________ Date: _________________

Form 3- 8/16 Page___ of ___

Chapman University - CONTROLLED SUBSTANCE USAGE LOG1. One log sheet must be completed for each container of Controlled Substance. If the material is converted or diluted, start a

new log form to track that usage; reference the original container’s lot or serial # and original bottle # assigned by lab.2. Controlled Substance usage must be tracked on a per dose (use) basis and only by an Authorized Researcher. Record

total quantity of the substance to the nearest metric unit weight/volume or the total number of units finished form.

Ø Fill out grey boxes upon receipt: Participating Faculty/ Senior Research Staff: Building: Room:

Drug Name: Lot or Serial #: Container Amount:

Expiration Date: Strength: Form:

_____Table_____Injectable_____Elixir

Date Received or Generated Unique Bottle Number Assigned by Lab: Date Disposed – Indicate EH&S pickup time:

Date Protocol #

Amount Removed (in mls, tablets, etc.)

Amount Remaining (in mls, tablets, etc.)

Activity Type (e.g., prepare solution; administer to animal)

Species ID or No. of animals

Name of Authorized Researcher (print)

Initial

1

2

3

4

5

6

7

8

9

10

11

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13

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15

16

Form 3- 8/16 Page___ of ___

Date Protocol #

Amount Removed (in mls, tablets, etc.)

Amount Remaining (in mls, tablets, etc.)

Activity Type (e.g., prepare solution; administer to animal)

Species & ID #

Name of Authorized Researcher (Print)

Initial

17

18

19

20

21

22

23

24

25

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CSP Form 4- 8/16

BIENNIAL CONTROLLED SUBSTANCE INVENTORY FORM Chapman University Environmental Health & Safety- OH&S Program

INSTRUCTIONS: EH&S’s records indicate that you have procured the following controlled substances via EH&S.

1. Starting January 18, 2017, indicate the total quantity of the substance to the nearest metric unit weight/volume of the total number of units (for Schedule II, perform anexact count or measure of quantity). If applicable, provide the concentration and volume for solutions made from original container. - Only inventory controlled substances acquired from EH&S. (Do not include inventory acquired from other sources.) - Include any expired or waste controlled substances that are still in your possession. - Indicate zero quantities also.

2. The authorized researcher who performs the inventory must print and sign this form.3. Submit to EH&S’s Controlled Substances Program Office via email @ehs@chapman.edu fax at 714-464-4522 no later than 2:00 pm on the 3rd Wednesday in

January each subject year.Questions? Call EH&S - 714-516-5660

LABORATORY INFORMATION: Name of Faculty/ Senior Staff: Department/Building/Room Number:

Phone: E-mail Reasons for being Maintained:

Research

Inventory Date: January ___, 20___. Inventory recorded by (Print/Signature):

INVENTORY INFORMATION: EH&S records show that the Controlled Substances noted below were acquired under the University’s registration. Controlled Substance Schedule

Number Total Inventory Quantity on January __, 20___

Concentration Volume or WeightIn the Original Containers: Solution from the original #1:Solution from the original #2:

Concentration Volume or Weight In the Original Containers:

Solution from the original #1:

Concentration Volume or Weight In the Original Containers:

Solution from the original #1:

Concentration Volume or Weight In the Original Containers:

Solution from the original #1:

Form 5- 8/16

CU Precursor Chemical Purchase Request Application ***Submit to EH&S via ehs@chapman.edu or via fax at (714-464-4522) – Attention Controlled

Substances Program Office***1) Applicant (Researcher):

Name _________________________________Title____________________ Dept. ____________________ Last, First, M.I.

Phone _____________ E-Mail Address ______________________________________ Mail Code:______

Account to bill: _____________ - _________ - _____________[Use PTA Number in the format NNNNNNN-nnn-AAAAA)]

2) Faculty/Senior Research Staff:

Name _________________________________________ Title _________________________________ Last, First, M.I.

E-Mail Address ________________________________ Phone ______________ Fax ____________

3) Precursor Chemical(s) Requested:

Substance If any ordering requirements, specify: Quantity (if other than USP grade, specify) (manufacturer, product #, etc.) Unit Size # of units

Shipping preference/ urgency: ________________________________________________________

4) Precursor Chemical Use Approval:Research Protocol (Title):________________________________________________________________

If applicable, also provide IACUC and/or IRB Protocol Number

Building/Lab Room Where Stored & Used:____________________________________________ NOTE: Precursor Chemicals acquired via EH&S must be stored and used on the University campus identified in the DEA Institutional Registration.

Approval: By Faculty/ Senior Research Staff:

Based on the nature of the research being conducted above, I certify that this requested use of precursor chemicals as legitimate and necessary for their research efforts at Chapman University and that I understand and will abide by the use requirements of the CU Controlled Substances and Precursor Chemicals Program. http://www.chapman.edu/faculty-staff/environmental/_files/controlled-substances-precursor-chemicals-program-packet-draft.pdf

Print name ________________________________ Title____________________

Signature__________________________________ Date____________________

CHAPMAN UNIVERSITYCONTROLLED SUBSTANCES DISPOSAL REQUEST FORM

EH&S (ehs@chapman.edu - FAX 714-464-4522 CSA Number : CSA Expiration Date: Phone #: PI Name: Campus Location: Department: Building: Room:

Instructions

1. List the controlled substance name and strength (e.g. 100 mg/ml) in column 1, amount of controlledsubstance in column 2 (e.g. 3 packages of 100 tablets, 1 package with 33 tablets out of 100).Note: The exactamount of the controlled substance must be specified.

2. Completed form must be signed and dated by principal investigator or authorized user.

3. Send original copy of form to EH&S MS RISK or faxed or emailed. The PI must also keep a copy.

4. Upon receipt of complete form, EH&S will schedule the pickup of controlled substances. Legacy Materials

Chapman Program

(2) AMOUNT

FULL PARTIAL

(1) Controlled Substance

Name and Strength QTY PACKAGE

SIZE QTY PARTIAL

COUNT PACKAGE SIZE

(3) Controlled Substance Schedule

_______________________________________ Received By: PI or Authorized User Print Name, Sign and Date _______________________________

EH&S signature and pick-up Date Relinquished by:_______________________________________ _______________________________Print, Signature, Date Printed Name

Form 7 – 8/16

CU Controlled Substance Periodic Inspection Checklist

This checklist is to be completed minimally on a quarterly basis by the Participating Faculty/Senior Research Staff or his/her designated Authorized Researcher to ensure that the laboratory is meeting all regulatory and institutional requirements for research use of Controlled Substances. Retain this inspection checklist, including findings and corrective actions, for a minimum of 1 year. Contact EH&S- Controlled Substances Program at 714-516-5660 for questions or additional information. The List of Controlled Substances is available at: http://www.deadiversion.usdoj.gov/schedules/alpha/alphabetical.htm

Participating Faculty/Protocol Director: _________________________________ Inspection Date:__________

Inspected By: ________________________________________________________________________________

Building: ______________________ Room Numbers (Storage/Use Areas): ___________________________

Ø If No is checked for any item, complete “Follow-up Actions” on back of checklist. Y N N/A Approved Users/Training

1. List of Authorized Researchers is current?2. Have all authorized researchers completed the Controlled Substances Program Training online?On-line Inventory Verification 3. Is the controlled substances inventory included in CHIMERA?Physical Security Measures/Storage/Use 4. Key to approved substantially constructed lockable cabinet is maintained under the control of the

Participating Faculty/Senior Research Staff and/or other designated Authorized Researcher?5. All Controlled Substances are stored within secondary containment within in the approved

substantially constructed lockable cabinet?--Carfentanil etorphine hydrochloride a diprenorphine must be stored in a safe. 6. Schedule II Controlled Substances are stored separately from Schedule III-V?7. All Controlled Substances containers are labeled properly?8. Appropriate chemical carriers are used to transport controlled substance from approved substantially

constructed lockable cabinet to use location?Maintenance of CU Controlled Substance Usage Logs 9. CU Controlled Substance Usage Logs are stored along with the controlled substances in a securely

locked, substantially constructed cabinet?10. One log sheet is completed for each container including each dilution?11. All fields completed correctly?12. CU Controlled Substance Usage Logs (Form 3) for Schedule II substances are maintained separately

from those for Schedule III - V? 13. Physical Inventory matches Controlled Substance Usage Logs (Form 3) for each container?

Ø What to do if there is a discrepancy between the physical inventory and the usage log: Inform Participating Faculty/Senior Research Staff and call EH&S at 714-532-7794 immediately.

Form 7 – 8/16

Follow-up actions: Item # Description of Problem Corrective Actions (include date corrected)

Additional Comments: