Controlled substance inventory management that finds a missing millilitre the day it is counted
Every milligram accounted for, with differences found in hours.
See one case, screen by screen ↓Software that keeps a DEA registrant's records of every Schedule I–V movement — receipts, withdrawals, waste, transfers and destruction — and the counts and inventories they tie to. Controlled Substance Inventory Management keeps a running balance per container and adds five agents that read the source records, reconcile each count and draft the inventories and loss notices for the registrant to sign.
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A research registrant must account for every movement of every Schedule I–V substance: the receipt against its Form 222 or CSOS order, each withdrawal, each waste, each transfer and each destruction, and an exact count of every open Schedule I–II container. Today those movements sit in four places — a paper usage log in the safe, a balance printout in a drawer, a lab notebook on the bench and a spreadsheet — and nobody adds them up until the monthly count or the biennial inventory.
So a difference is found weeks after the movement that caused it, when the printout, the person and the memory are gone. A waste that never reached the usage log looks exactly like a loss. And when a Schedule I–II shortfall cannot be explained, the written notice to the DEA field office is due within one business day of discovery, with Form 106 to follow — a significant-or-not call made by hand, under the clock.
Estimated split for one registration's inventory, after the physical count: about 2.5 days (20 working hours) by hand, about 1.7 hours with the agents.
Five agents read, post and reconcile every movement and start the loss clock; the registrant decides and signs.
Northwind Bio, Bay Campus, Building 4 — Wednesday, October 7, 2026, and the October count is in progress. Here is what happens when the last Cabinet B container is counted, screen by screen, in the working solution.
Dr. Haddad holds RH0412337 for Schedule I and RH0412349 for Schedules II–V. His vault ledger shows each container's received, withdrawn, wasted and transferred quantities, the expected balance, the count, the variance and the DEA record the receipt ties to. Safe A is 2.8 mg off on NWB-7731 HCl, already explained. Cabinet V1 in the vivarium is 4.5 mL short on pentobarbital, and its loss clock shows 31 hours left.
“If it is off by a milligram I want to know today, and I want to know why before I sign.”
Sam enters the Cabinet B count for fentanyl citrate 50 µg/mL, CS-1220, straight into its line, with Dana Okafor as witness. The ledger expects 16.8 mL: 20.0 mL received on Form 222 no. 261190305, less 3.2 mL withdrawn in five surgeries for protocol P-2287. The difference is −0.4 mL, outside the ±0.1 mL tolerance for a Schedule II solution, so the loss clock is armed while the agents read every record.
“If no record explains the −0.4 mL, the one-business-day clock for the DEA written notice starts now — notice due Oct 8, 17:00.”
The Intake reader reads 9 records — the usage log, the Form 222, the count sheet and six scanned surgery-notebook pages for protocol P-2287. On surgery notebook SR-2287-114, page 52, Lena Ortiz drew 1.0 mL on Oct 3, gave 0.2 mL to each of rats R-31 to R-33, and wasted 0.4 mL to the drug-waste bin when R-34 was excluded at weigh-in, witnessed by S. Patel. The usage log for that day shows 0.6 mL withdrawn and no waste.
Loss assessor: “Every millilitre explained by a witnessed waste that never reached the log — not a loss; clock not started.”
Of the three options — post the waste line and sign, treat as a possible loss, or ask Lena Ortiz first — he takes the recommended one. The signature carries its meaning, “I approve this waste line as the registrant”, and Lena co-signs as the person who wasted it. Sam Patel's witness is bound to the line.
Lena Ortiz: “I wasted 0.4 mL with Sam Patel and did not log it.”
A late waste line for Oct 3 is posted as a new line; nothing already posted is edited. CS-1220 balances, the line turns green, and the loss clocks panel moves fentanyl to explained. Pentobarbital in Cabinet V1, which nothing explains, keeps its clock.
“CS-1220 balances — 16.4 mL expected, 16.4 mL counted. The clock never started.”
On CS-1187, the Oct 5 usage-log line says 25.0 mg of NWB-7731 HCl for PK-118. Balance printout #1182 shows the vial going from 23.4973 g to 23.4695 g, and Lena's notebook PK-118-0412 records 27.8 mg dissolved in 2.78 mL. Three records agree on 27.8 mg, at confidence 0.97. Correcting line 8 balances the container to 0.0 mg; the original stays visible, struck through.
A correction needs the registrant and the person who logged it.
Every logged pentobarbital withdrawal matches an animal-protocol record and the count was witnessed, but the cabinet was opened on Oct 6 at 19:52 with no log line. The Loss assessor works through the significant-loss factors: quantity, substance, individuals linked, pattern over time, diversion potential and local trends. Its recommendation is to report as a significant loss.
“The agents do not name anyone — that is for your investigation.”
The notice to the Special Agent in Charge reports 4.5 mL of pentobarbital 390 mg/mL (1,755 mg), container CS-0950, lot PTV-2604, discovered at the witnessed monthly count on Oct 7 at 07:52. The Form 106 fields are filled, with corrective actions: the shared night-shift card disabled, weekly counts for Cabinet V1, an access review. It is due Oct 8 at 17:00 and goes only when the registrant signs; Form 106 follows by Nov 21.
The Building 4 biennial inventory for RH0412337 and RH0412349 is drafted as of opening of business, Oct 7, 2026 — within two years of Nov 1, 2024 — in 1 h 40 min from the day's counts and the ledger. Open Schedule I–II containers are counted exactly and kept separately; Schedule III–V may be estimated. The count was taken by Sam Patel and witnessed by Dana Okafor.
Every line links to its container and count sheet.
For RH0412337 the Record drafter assembles 12 sections from signed records — registration, biennial and monthly inventories, Form 222 and CSOS orders, receipts, usage logs with Schedule I–II kept separate, Form 41 destruction, loss reports, corrections and the storage and key lists. It runs to 142 pages, and flags the two signatures still open before it is ready.
“An inspector asks for the pack first. It has to exist before they arrive.”
The same October count, seen by the five people who carry it — what their month looked like, and what it looks like now.
Five agents read, post and reconcile every movement and start the loss clock; the registrant decides and signs.
Reads balance printouts, notebook entries, usage logs, CSOS and Form 222 receipts, invoices and destruction records into movements — container, substance, quantity and unit, person, protocol and time — quoting the passage for every value.
Posts receipts, withdrawals, waste, transfers, destructions and counts to each container's running balance in time order, with Schedule I–II entries in their own ledger.
Compares expected and counted balances under the tolerance for each schedule and form, then searches every source record for the explanation.
Assesses an unexplained shortfall against the significant-loss factors, starts the one-business-day notice clock at discovery and drafts the written notice and the Form 106 fields.
Drafts monthly and biennial inventories, destruction records and inspection packs for e-signature.
Decides every difference and e-signs. The agents propose; a named person decides.
Ask about a count, a shortfall, a deadline or a rule — or tell it what to change. Every answer points to its record.
Why was the fentanyl 0.4 mL short?
It was a witnessed waste that never reached the usage log. On Oct 3 Lena Ortiz drew 1.0 mL, gave 0.6 mL to three rats and wasted 0.4 mL when the fourth was excluded — surgery notebook SR-2287-114, p. 52, witness Sam Patel. You signed the late waste line; CS-1220 balances and the clock never started.
Why is Safe A off by 2.8 mg?
One transcription error — not a loss. On Oct 5 Lena Ortiz weighed 27.8 mg of NWB-7731 HCl for PK-118: the balance printout and her notebook agree. The usage log says 25.0 mg. Correcting line 8 balances the container to 0.0 mg. It needs your signature and Lena's.
What happens with the Pentobarbital shortfall?
CS-0950 in Cabinet V1 is 4.5 mL short and not explained: no usage record covers it, the count was witnessed, and the cabinet opened Oct 6 at 19:52 with no log line. The Loss assessor rates it significant. The written notice to the DEA field office is due within one business day — by Oct 8, 17:00; the Form 106 within 45 days, by Nov 21. Both are drafted for your signature.
What does the biennial inventory need?
At least every two years, as of opening or close of business (21 CFR 1304.11). Open Schedule I–II containers: exact count. Schedule III–V: estimate unless a container holds more than 1,000 units. Your Building 4 inventory — as of opening of business Oct 7, within two years of Nov 1, 2024 — is drafted and ready to sign. It stays on site; it is not sent to the DEA.
13 screens from the working solution, on its sample data. Pick one to see it large.
Tolerances, counts, rules and signatures are settings. Changes take effect at once and are on the audit trail; a tolerance change re-checks every container.
| Setting | Default | Choose from |
|---|---|---|
| Tolerance · Schedule I–II powders | ±0.2 mg (balance readability 0.1 mg, exact count) | Step up or down |
| Tolerance · Schedule I–II solutions | ±0.1 mL (exact count) | Step up or down |
| Tolerance · Schedule III–V solutions | ±0.2 mL (estimate permitted) | Step up or down |
| Count cadence | Monthly · first business day | Monthly · first business day · Weekly for Schedule I, monthly for others · Biennial only |
| Witness on every count | On — a second person signs the count sheet | On · Off |
| Unexplained Schedule I–II shortfall | Treated as a possible loss; starts the one-business-day clock | On · Off |
| Corrections signed by | Registrant + person who logged | Registrant + person who logged · Registrant only |
| Loss notices | Reviewed by the compliance lead, signed by the registrant | Registrant + compliance lead · Registrant only |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample lab data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published requirements (21 CFR 1301.76(b): written notice of a theft or significant loss within one business day of discovery, DEA Form 106 within 45 days; 21 CFR 1304 on records and inventories). People, companies, registrations and containers named on this page are fictional — characters and sample data in the working solution.
Software that keeps a DEA registrant's records of every Schedule I–V movement — receipts, withdrawals, waste, transfers and destruction — and the counts and inventories they tie to. Controlled Substance Inventory Management keeps a running balance per container and adds five agents that read the source records, reconcile each count and draft the inventories and loss notices for the registrant to sign.
When a count is entered on a container's line, the expected balance is compared with it at once under the tolerance for that schedule and form. A difference outside the tolerance turns the line red, and the agents read the usage logs, balance printouts, notebook scans, receipts and access logs for the explanation.
The one-business-day clock for the written notice to the DEA field office starts at discovery and shows on the line. The Loss assessor works through the significant-loss factors and drafts the notice and the Form 106 fields. The registrant reports it as a significant loss, or records why it is not, and signs.
Yes. The Record drafter drafts monthly and biennial inventories by schedule from the day's counts and the ledger — exact counts for open Schedule I–II containers, estimates where permitted for Schedule III–V — with every line linked to its container and count sheet, ready for the registrant's signature.
No. The agents never send anything to the DEA without the registrant's signature, never close a variance and never name a person as responsible — that is for the registrant's own investigation.
Yes. Posted lines are never edited; a correction is a new line signed by the registrant and co-signed by the person who logged the original. Every correction, loss decision, inventory and destruction is the registrant's, e-signed with its meaning, and destruction records carry two witnesses.
Yes. Tolerances for Schedule I–II powders and solutions and for Schedule III–V, the count cadence, who receives count sheets, witnesses, rules, signatures and loss-notice review are all settings. A tolerance change re-checks every container at once, and every change is on the audit trail.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your registrations, SOPs, storage locations and a sample of past usage logs and count sheets — and it goes live once every quality gate has passed. We will walk you through it on your own records first.
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