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Controlled substances from order to destruction: DEA Forms 222, 106 and 41

6 min lesson 2 min for the key points

Fact-checked October 15, 2026

PTCB topic: Controlled substance handling: ordering to destruction

In 30 seconds
  • Form 222 (or CSOS) orders Schedule I-II drugs; it is valid 60 days.
  • Theft or significant loss: tell DEA in writing within 1 business day.
  • Then file DEA Form 106 within 45 days.
  • On-site destruction needs two employee witnesses and a Form 41 record.
  • Only the patient puts drugs in a collection receptacle, never staff.

Key facts

  1. DEA Form 222 (or a CSOS electronic order) is required for each distribution of a Schedule I or II controlled substance; Schedules III-V are received on invoices.
  2. A supplier may ship the balance of a partly filled Form 222 within 60 days; no Form 222 is valid more than 60 days after it was executed.
  3. On receipt, the pharmacy records on its Form 222 copy the number of containers received for each item and the date received.
Show all 7 key factsShow fewer
  1. Theft or significant loss: written notice to the DEA Field Division Office within 1 business day of discovery, then DEA Form 106 within 45 days.
  2. Biennial inventory at least every 2 years: exact count for opened Schedule I-II containers; estimates allowed for Schedule III-V unless the container holds more than 1,000 units.
  3. On-site destruction: two employees handle and witness until the drug is non-retrievable, recorded on DEA Form 41.
  4. Controlled substance records, including Form 222 copies, are kept for at least 2 years.

Quick check1 question · 2 more at the end

A retail pharmacy wants to order Schedule II controlled substances from its wholesaler without using DEA's electronic ordering system (CSOS). Which DEA form does it use?

Full lesson

Each part starts with its main idea. Open a part when you want the details.

The short answer: Schedule I-II drugs are ordered on DEA Form 222 or through CSOS; orders expire after 60 days. Theft or significant loss is reported to DEA in writing within 1 business day, then on Form 106 within 45 days. Destruction needs two employee witnesses and a Form 41 record. Collection receptacle deposits are made only by the patient.

1 Which DEA form does what?Three form numbers cover most of the controlled substance chain, so learn them as a set. 1 min

Three form numbers cover most of the controlled substance chain, so learn them as a set. The 2026 PTCE outline lists receiving, storing, ordering, labeling, dispensing, returning, take-back, loss or theft, and destruction in one knowledge area.

Form Purpose Key timing
222 (or CSOS electronic order) Order or transfer Schedule I-II drugs Valid 60 days
106 Report theft or significant loss Within 45 days (after a 1-business-day written notice)
41 Record destruction When drugs are destroyed, with two witnesses' names and signatures
2 How are controlled substances ordered and received?Schedule II drugs need an official order, while Schedules III-V move on ordinary invoices. 1 min

Schedule II drugs need an official order, while Schedules III-V move on ordinary invoices. Only the registrant (or someone holding its power of attorney) signs a Form 222.

  • Form 222: a single sheet listing one supplier. The pharmacy keeps a copy and sends the original. An altered or defective form is not filled; a new one is issued.
  • CSOS: DEA's electronic system for ordering controlled substances without the paper form, signed with a DEA-issued digital certificate.
  • Partial shipments: the supplier may ship the rest within 60 days of the order date.
  • Receiving Schedule II: record the number of containers received for each item and the date on the pharmacy's copy (or electronic record).
  • Receiving Schedules III-V: keep the invoice or packing slip with the date received.
3 How are they stored, counted and labeled?Federal law requires secure storage and accurate records, kept for at least 2 years. 1 min

Federal law requires secure storage and accurate records, kept for at least 2 years. The main rules:

  1. Storage: a securely locked, substantially constructed cabinet, or dispersed throughout noncontrolled stock to obstruct theft.
  2. Records: Schedule II records and paper prescriptions are filed separately; Schedule III-V records are separate or readily retrievable.
  3. Biennial inventory: at least every 2 years. Opened Schedule I-II containers get an exact count; Schedule III-V may be estimated unless the container holds more than 1,000 tablets or capsules.
  4. Label: date of filling, pharmacy name and address, prescription number, patient name, prescriber name, directions and cautionary statements.
4 What happens after a theft or loss?A theft or significant loss triggers two federal reports. 1 min

A theft or significant loss triggers two federal reports. First, notify the DEA Field Division Office in writing within 1 business day of discovery. Then file a complete DEA Form 106 online within 45 days. Losses during shipment from a supplier are the supplier's to report.

5 How do returns, take-back and destruction work?Every controlled substance leaving the pharmacy for disposal follows a documented route. 1 min

Every controlled substance leaving the pharmacy for disposal follows a documented route. A pharmacy's own stock may be:

  • Returned to the supplier or manufacturer (Schedule II needs an order form).
  • Sent to a reverse distributor. For Schedule II, the reverse distributor issues the Form 222 to the pharmacy. For III-V, the pharmacy keeps a record of what it sent. The reverse distributor files Form 41 when it destroys them.
  • Destroyed on site by a method that makes the drug non-retrievable. Two employees handle and witness it and record it on Form 41.

Patients' drugs are different. A pharmacy registered as a collector may keep a collection receptacle for Schedule II-V (and, if it chooses, noncontrolled) drugs near the pharmacy counter. Only the patient deposits the drugs; staff may not take them by hand, and the contents are never counted or sorted. Two employees install and remove the inner liner. Law enforcement runs take-back events.

6 What the technician does 1 min
  • Checks shipments against the Form 222 copy or invoice and records what arrived.
  • Reports suspected losses to the pharmacist at once.
  • Directs patients to the receptacle or other take-back options rather than accepting their drugs.

Common mistakes

The traps students fall into most. Read these before you practice.

  • Watch out: Form 106 reports theft or loss, not destruction (Form 41) or ordering (Form 222).

  • Watch out: When Schedule II drugs go to a reverse distributor, the reverse distributor issues the Form 222, not the pharmacy.

  • Watch out: Staff never take a patient's drugs by hand for a collection receptacle; the patient deposits them.

  • Watch out: Pharmacies may disperse controlled substances among noncontrolled stock; a Class V safe is only for a few very potent substances such as carfentanil.

How to remember it

Count up the form numbers: 41 destroys, 106 reports, 222 orders. Then add the clocks "1 day, 45 days, 60 days." They stand for the theft notice, Form 106 and order validity.

Self-check:

  1. Which form records an on-site destruction, and how many witnesses sign it?
  2. Who issues the Form 222 when Schedule II drugs go to a reverse distributor?
  3. A customer hands you leftover pills for the drop box. What do you do?
Check yourself

Try it: 2 questions

  • 2 questions
  • Federal Requirements
  • 5 min in exam mode

Questions are original practice items written to the published exam content, not real exam questions.

Finished this lesson? It is marked done when you finish the questions above. You can also mark it yourself.
Sources (7)
  1. eCFR: 21 CFR part 1305 Orders for Schedule I and II controlled substances
  2. eCFR: 21 CFR part 1304 Records and reports of registrants
  3. eCFR: 21 CFR part 1301 Registration (security controls, theft and loss reporting)
  4. eCFR: 21 CFR part 1317 Disposal
  5. eCFR: 21 CFR 1306.14 Labeling of substances and filling of prescriptions
  6. DEA Diversion Control Division: Controlled Substance Ordering System (CSOS)
  7. DEA Pharmacist's Manual (2022 edition)

Written with AI and checked against the sources above by a separate review step. No pharmacist reviews this content. How we make our content. For exam study only, not medical or legal advice; in practice also follow your state's rules and your pharmacy's policies. HealthcareExams is independent and not affiliated with PTCB.

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