Controlled substances from order to destruction: DEA Forms 222, 106 and 41
PTCB topic: Controlled substance handling: ordering to destruction
- 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
- 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.
- 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.
- 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
- 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.
- 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.
- On-site destruction: two employees handle and witness until the drug is non-retrievable, recorded on DEA Form 41.
- 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?
Correct answer: C.
Schedule I and II controlled substances must be ordered on a DEA Form 222 or with a digitally signed electronic order through CSOS. Schedules III-V are ordered like other drugs, and the pharmacy keeps the invoice or packing slip as its receiving record. Keep the three form numbers apart: 222 orders, 106 reports theft or loss, 41 records destruction.
A DEA Form 106 reports a theft or significant loss of controlled substances.
B DEA Form 41 records the destruction of controlled substances.
C Correct: a DEA Form 222 (or its electronic CSOS equivalent) is required for each distribution of a Schedule I or II controlled substance.
D An invoice is the receiving record for Schedule III-V drugs; it cannot be used to order Schedule II drugs.
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:
- Storage: a securely locked, substantially constructed cabinet, or dispersed throughout noncontrolled stock to obstruct theft.
- Records: Schedule II records and paper prescriptions are filed separately; Schedule III-V records are separate or readily retrievable.
- 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.
- 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:
- Which form records an on-site destruction, and how many witnesses sign it?
- Who issues the Form 222 when Schedule II drugs go to a reverse distributor?
- A customer hands you leftover pills for the drop box. What do you do?