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Security Manual
> Preface
Preface
Over 770,000 manufactures, distributes, pharmacies, and other
handlers of controlled substances are registered with DEA. The vast
majority of this group complies with controlled substances laws and
regulations in a responsible and law abiding manner, and has
self-regulation programs consistent with the highest standards. DEA
relies upon these programs and concentrates its resources on the more
serious problems of both practitioner and non-practitioner diversion.
Handlers of controlled substances must be aware of the various
diversion methods, which include illegal sale, falsified prescription
orders, burglary, employee theft, loss in-transit, robbery, and
customer/patient theft. However, willful and intentional diversion by
manufacturers, distributors and dispensers is another source of
diversion.
A critical first step in diversion prevention is employee screening;
concern with personnel security must start before and employee is hired.
Pre-employment screening to identify potential security problems is
important when choosing new employees to work in or around areas where
controlled substances are handled. The screening program should include
a careful evaluation of the applicant's
personal and previous employment references. Criminal background checks
with local law enforcement authorities and with DEA are equally
important. Similar precautionary measures should be taken before
transferring established employees to new jobs in areas where controlled
substances are manufactured, processed, stored, shipped, dispensed, or
handled in any way.
The areas which must be protected against theft and diversion vary
greatly depending on the type of business. Manufacturers must be alert
for pilferage at every level of drug handling, from the receipt of raw
material, through all phases of manufacturing and processing, to
finished product storage and shipping. They must be watchful for
pilferage of production rejects and of returned of damaged merchandise.
They must be alert to the theft of dosage form drugs, bulk raw material,
equipment, and even chemical precursors. They must be certain that all
controlled substances are secure throughout the entire manufacturing and
distribution process. Many of the concerns also apply to controlled
substance distributors.
Security problems confronting a pharmacist are no less serious. The
pharmacist must secure the controlled substances storage and
prescription compounding areas. As in the case of larger drug handlers,
a key factor in protecting against theft and diversion is limiting
employee access. Access to all controlled substances should be
restricted to the minimum number of employees needed to perform the
tasks related to these drugs.
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