As 2025 wraps up, it’s a perfect time for DEA registrants, especially those in veterinary medicine, to reflect on recordkeeping practices, storage procedures, and overall controlled-substance compliance. Unlike OSHA, the DEA does not publish an annual “Top 10” violation list, but inspection trends consistently reveal the same weak points year after year.

Understanding these common citations helps facilities strengthen their programs, reduce risk, and avoid costly enforcement actions. Let’s walk through a year-end review of the most frequently cited DEA standards and compliance failures, with practical takeaways for veterinary practices.

1. Improper or Non-Compliant Storage of Controlled Substances

CFR Reference: 21 CFR §1301.72

One of the most common citations across all healthcare settings, including veterinary facilities, is noncompliant storage. DEA regulations require that controlled substances be stored in a substantially constructed, securely locked cabinet or safe. But many facilities fall short in areas such as:

• Safes under 750 lbs. not being bolted or affixed
• Refrigerators storing controlled substances without being locked or secured
• Keys left accessible, unsecured, or stored in predictable locations
• Multiple people sharing a controlled-substance key with no key-control log
• Satellite storage areas (treatment rooms, anesthesia stations, barns, mobile units) being unsecured
  

For veterinarians who frequently use mobile units, farm trucks, or satellite treatment areas, storage mistakes are one of the most common reasons for DEA citations.

2. Incomplete or Inaccurate Recordkeeping

CFR Reference: 21 CFR §1304.04 & §1304.21

Recordkeeping violations are consistently among the top DEA citations nationwide. The DEA requires a complete and accurate “chain of custody” for every controlled substance from the moment it enters the facility until its final disposition.

Common violations include:

• Missing or incomplete usage logs
• Failure to record waste or disposal
• Math errors or unexplained discrepancies
• No documented reconciliation of on-hand quantities
• Failure to keep biennial inventory (or performing it incorrectly)
• Not performing inventory when:
  • a new drug schedule is released
  • a new practitioner joins the registrant location
• Biennial Inventory documents lacking required data:
  • Date
  • Time (open or close of business)
  • Exact quantities
  • Drug strength and formulation
  • Registrants name and registration number
  • Registrants signature
    

For hospitals using multidose vials, improper logging, especially when dealing with syringe/hub residual, is a frequent source of confusion and citation.

3. Failure to Report Significant Loss or Theft

CFR Reference: 21 CFR §1301.76(b)

DEA registrants are required to report significant loss or theft within one business day using DEA Form 106. Many facilities are cited for:

• Failing to report quickly
• Misclassifying a loss as “waste”
• Rewriting logs to “fix” discrepancies without reporting
• Delayed reporting because staff tried to “figure it out internally”
  

The DEA expects transparency, not certainty. If there is any question whether a loss is significant, registrants must report immediately.

4. Unauthorized Access or Delegation of Controlled Substance Handling

CFR Reference: 21 CFR §1301.90–92 & §1301.72(d)

DEA registrants must maintain strict supervision over anyone handling controlled substances. Violations occur when:

• Non-licensed staff have unsupervised access
• DEA numbers are shared
• Keys or safe codes are given to unauthorized personnel
• Contracted workers (cleaning crew, maintenance, relief staff) have incidental access
  

In veterinary medicine, this is particularly risky because many facilities rely heavily on our technicians. While technicians may administer controlled substances under supervision, they cannot be granted unsupervised access to storage unless state law explicitly authorizes it.

5. Improper Disposal or Destruction of Controlled Substances

CFR Reference: 21 CFR §1317.90–95

Common citations include:

• Destruction performed without a reverse distributor
• Lack of documentation for expired drugs awaiting destruction
• Failure to separate expired medications from active inventory
• Not properly logging wasted drugs from partial doses
• Storing expired drugs in unlocked or unmonitored areas
  

Expired controlled substances remain subject to the full DEA requirements until they are properly destroyed and documented.

6. Using an Outdated or Incorrect Address, Name, or Email on DEA Registration

CFR Reference: 21 CFR §1301.12 & §1301.71

This issue has increased dramatically now that the DEA sends renewal notices exclusively by email. Frequent citations include:

• Registrants failing to update their email address after changing jobs
• Registrations listing a former employer’s address
• Mobile veterinarians practicing at locations not listed on their certificate
• Failure to update business name changes
  

When renewal notices go to outdated email accounts, registrants unknowingly allow their DEA certification to lapse, putting them at risk of fines, inability to order controlled substances, and referral for investigation.

7. Failure to Secure Controlled Substances During Transport

CFR Reference: 21 CFR §1301.75(b)

Veterinarians who perform farm calls or use mobile units often transport controlled substances. Citations occur when:

• Controlled substances are left in unlocked vehicles
• Drugs are taken home overnight
• Transport bags are not locked
• Unused drugs from a visit are not immediately returned to primary storage
  

DEA requires secure storage at all times, including during transit.

New Year, New Opportunities

As 2025 ends, reviewing the DEA’s most frequently cited compliance issues offers a valuable opportunity to strengthen your controlled-substance program. While the DEA does not publish an official Top 10 list, inspection trends show the same problem areas year after year:

• Storage
• Recordkeeping
• Inventory
• Reporting loss
• Disposal
• Transport
• Registration accuracy
  

Improving systems in these areas protects your license, your team, your patients, and don’t forget to include your reputation.