Logging Excess Quantites

How do we keep our logs straight when most of the bottles of our injectable drugs contain more than the amount on the label?

It’s hard to get upset at getting more than what you pay for, but when it comes to injectable controlled substances, it presents a challenge.  In today’s high-speed manufacturing and packaging operations, it’s common for liquids such as injectables to have more substance in the bottle than the label indicates.  It’s just easier to check that containers have AT LEAST the required amount (usually by weight) than it is to ensure they have the EXACT amount.  So, don’t be surprised when there are 11 milliliters in a bottle labeled 10 milliliters.

If the log shows the balance on hand of the bottle is zero or near zero and there is still some product left in the bottle, keep using the product and keep logging it. 

There will be a negative balance on hand until the bottle is actually empty,
but it’s important to “call it like it happens.” 

If the extra drugs in the bottle are used, they must be recorded!    For example, in an overfilled bottle case, the log could indicate the bottle’s balance on hand is -.055 milliliters.  When the bottle is actually empty, the final entry would be “adjustment – bottle empty” and then 0.55 milliliters would be ADDED to the balance to bring it to zero. See the example below.

DO NOT waste the extra amounts in a bottle in order to maintain perfect logs.  There is an increased chance of the extra drug being diverted since it's "unaccounted for."  During an audit, perfectly balancing injectable logs are a possible sign of diversion and the DEA questions the accuracy of those logs.

Example of a controlled drug log showing how to document an overage in an injectable medication vial. Back to DEA Questions Page

 

Did You Know...?

The Controlled Substance Act and related regulations do not contain the word "log" as a requirement, however, maintaining a perpetual log is the most practical method to comply with the requiremtn to "maintain a record of each transaction" that is accurate, complete and will help identify possible diversion.

To learn more about practical logging options, check out The Complete Veterinary Practice Controlling Controlled Drugs Manual.