Controlled Substances Security Manual
Additional Security Measures
Although not specifically required by Federal law or regulation, the following additional security measures are recommended to enhance the overall security of non-practitioners as well as practitioners in some situations:
- For large operations, designate a specific individual to act as a security manager or supervisor.
- Routinely test alarm systems. At least annually, in the presence of the alarm contractor, conduct an on-site inspection and test of the entire alarm system to determine needed repairs and adjustments.
- Ensure that all alarm systems have at least 24-hour battery or other standby power sources in the event of commercial power failure.
- Use only balanced or biased magnetic contact switches and ensure motion detectors do not disclosed coverage by either by-pass or elimination of the walktest LEDs, if any.
- In addition to balanced or biased contacts, install Underwriters Lab (UL) approved heat detectors on vault doors.
- Ensure that all telephone junction boxes or rooms where alarm telephone circuits terminate are locked, tamper protected, and all labels or tags identifying these alarm circuits have been removed.
- Do not permit vault, safe or premises openings other than at scheduled times. Instruct your alarm contractor that unscheduled or telephone request for openings other than by prior written request or other secure pre-arrangement should be treated as an alarm or duress condition.
- Use UL approved locks and lock cylinders which are rated as "pick" or burglary resistant.
- Change all lock combinations at least annually or upon termination of any employee with knowledge of the combination(s), regardless if the reason for the termination,
- Use two supervisors to open all premises which are alarmed. One individual should remain a safe distance away from the premise entrance while the other enters and searches to be certain everything is alright, then signal by pre-arrangement to the other.
- Meet periodically with local and state law enforcement officials to discuss alarm response, criminal activity statistics, patrol frequency, and other pertinent matters.
- Develop robbery, hostage and kidnapping (extortion) contingency plans which are disseminated and made known to all employees from management on down.
- Enclose shipping/receiving areas in steel or chain link fencing, install day gates on loading platform doors, and adequately harden and secure other doors and openings to isolate and restrict access to the warehouse or manufacturing areas by drivers and other unauthorized individuals.
- Require that all shipping/receiving dock day gates are kept closed at all times when docks are not in use.
- Install local alarms or hard-wired day annunciation contact switches on all fire exits and other perimeter doors not authorized for employee or visitor use.
- If utilizing company-owned or leased vehicles for the pickup and delivery of controlled substances, do not mark them with the company name or other identification which would indicate the nature of your business.
- Isolate and secure office entry foyers or reception areas to prevent unauthorized entry. Entry from these areas should be remotely controlled by electronic locks or other automatic access devices after positive identification.
- Locate receptionists behind bullet resistant barriers which are equipped with a package receiver and telephone or intercom system for communications.
- Leave application forms for employment in the secured entry foyers or reception areas unless a secure pass through mechanism has been installed.
- Secure doors from office areas to warehouse, research, and/or manufacturing areas with key/combination locks, machine-aided manual access devices, or other suitable mechanisms.
- For larger operations, use a photo badge identification system for all employees and require other visitors such as tradesmen, contractors, vendors, etc. to wear special identification badges at all times when on the premises.
- Install closed circuit TV cameras to monitor vaults, shipping/receiving areas, manufacturing area, cages, etc. These need not be continuously monitored if video recording systems are employed.
- Issue and require the wearing of pocketless coverall type uniforms in the manufacturing areas vulnerable to pilferage of dosage form pharmaceuticals. The uniforms can be color coded to signify specific manufacturing areas.