Name the gap.
Write down the entry, bottle, or period. “We think it was March” is not a record; a date, a bottle number, and a quantity are.
A one-page resource
The controlled-substance inspection checklist.
What a U.S. veterinary clinic should be able to produce when someone asks. Print it, walk the register, and fix the gaps before they become a conversation.
Vet Logbook · field resource
Controlled-substance inspection checklist
For U.S. veterinary clinics. Walk each line against your register; a checkmark means you could produce it today.
1. The register itself
The record should be current, legible, and available for inspection.
A register for every controlled substance the clinic stocks or dispenses.21 CFR 1304.04
Entries are current — no multi-day back-filling.Good practice; your policy
Each dispense entry shows date and time, drug and strength, quantity, patient and client, the staff member, and the witness.21 CFR 1304.22(c)
Client name and address are captured where your registration or state requires them.Confirm your state rule
Mistakes are corrected with a visible correction — not erased or overwritten.Good practice; audit integrity
Records are retained for at least two years, or longer if your state requires.21 CFR 1304.04(a)
2. Acquisitions and Form 222
Every controlled substance that came in should be traceable to a supplier and an order.
Supplier, invoice, drug, quantity, lot, and expiry are recorded for each receipt.21 CFR 1304.21 / 1304.22
Schedule II receipts have the executed DEA Form 222 on file, with serial and execution date.21 CFR Part 1305
Receipts are linked to the bottle or package that entered inventory.21 CFR 1304.21
A Schedule II receipt missing a Form 222 has been identified and resolved.Clinic control
3. Dispensing, waste, and custody
The movement out of the register should be as clear as the movement in.
Every dispense has a patient, client, reason, amount, staff member, and witness.21 CFR 1304.22(c); clinic policy
Waste and destruction records show the quantity, date, method, and a witness.21 CFR Part 1317; clinic policy
Returned, expired, or unusable stock is separated and documented.Clinic policy
The bottle balance after each movement can be explained.Clinic control
4. Reconciliation and counts
A count that cannot explain a variance is an open question.
Periodic counts are documented, with the counter and a witness.Clinic policy
Every variance has a resolution note or an open investigation.Clinic policy
An end-of-day or shift summary shows dispenses, waste, and flags.Clinic policy
5. Biennial inventory
A full count at least every two years, signed and retained.
The last full inventory is dated within two years of the previous one.21 CFR 1304.11(c)
All controlled substances on hand are included, not a sample.21 CFR 1304.11(c)
The inventory records who counted and who witnessed, with date and time.21 CFR 1304.11(e)
The completion record is retained with the register.21 CFR 1304.11; 1304.04
6. Theft or significant loss
Time matters. Know the clock before it starts.
The clinic knows who notifies the DEA Field Division in writing within one business day of discovery.21 CFR 1301.76(b)
A complete DEA Form 106 can be filed within 45 days.21 CFR 1301.76(b)
Incident evidence, notice copies, and the current status are kept together.Clinic policy
The clinic has a written escalation path for a suspected diversion.Clinic policy
7. State PMP reporting
Only if your state requires it — and the requirement can differ for veterinary dispensing.
The clinic knows whether its state PMP requires veterinary dispensing reports.State PMP rule
The reporting period’s ASAP file is saved with the submission.State PMP rule
The portal confirmation and any rejection/resubmission clock are recorded.State PMP rule
8. Access and audit
Who could change the record, and what did they change?
Roles are assigned: owner, admin, pharmacist, technician, read-only.Clinic policy
Staff sign entries with their own PIN; a second staff member witnesses.Clinic policy
The audit trail shows who changed what, and when.Clinic policy
The clinic can export the register without the vendor’s help.Clinic policy
Vet Logbook · vetbooklog.com · Reviewed October 20, 2026
Summary only. Not legal advice. Confirm with your state board, DEA field office, or counsel.
If you find a gap
Fix the record before the meeting.
Most gaps are not exotic. They are a missing witness, an unexplained variance, or a Form 222 that never made it into the file.
Document the correction.
A correction that explains the original is stronger than a clean page. Keep the original visible and record who corrected it and why.
Ask before assuming.
State rules and registration types differ. When the answer matters, ask your board or counsel — not a vendor’s marketing page.
How to use this
Print it. Walk it. Sign the date.
This checklist is deliberately short enough to use. Print a copy for the register, mark what you can produce today, and put a name and date against the gaps.
It covers federal recordkeeping points from 21 CFR Parts 1301, 1304, and 1305. It does not replace your state board’s requirements, your DEA registration obligations, or your own written policy.
One useful habit: pick a random month, ask for one drug’s full history, and try to reconstruct the bottle balance from the record. If you can do it in minutes, the register is doing its job.
Reviewed October 20, 2026 · Next review: January 2027
The checklist, in software
Make the next inspection boring.
Log a sample dispense, watch the audit row, and see the export. Two minutes, no account.
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