New Interpretations of DEA Regulations?

Over the past 24 hours, we have received numerous calls from AVMA members with concerns regarding interpretation of DEA regulations. We have been engaged in ongoing discussions with DEA on issues pertaining to the veterinary profession for several years, and this is the first we have heard of this particular interpretation. While we do not agree with this interpretation, we are in the process of learning more. Stay tuned.

5 thoughts on “New Interpretations of DEA Regulations?

  1. @Dr. Kimberly May

    Hello – I received one of these emails and am concerned because other mobile practitioners in the area have returned Sherry Pendleton’s call. At this time she informs them that it is illegal to transport DEA controlled substances in his/her truck. Another colleague contacted an AVMA rep who agreed that it would be negligent and against the Veterinary Practice Act to not carry euthanasia solution and diazepam at a minimum.

    A significant part of my practice is at-home euthanasia. I would appreciate more information as to what the AVMA advises with regards to carrying DEA drugs.

    According to multiple sources on VIN, the enforcement of this rule varies widely by region.

    Thank you,

    Mary Pride Clark

    Mary Pride Clark, DVM

    PO Box 31
    Coloma, CA 95613

  2. We’ve posted more information on NOAH, our online discussion groups for AVMA members. To get to the discussions, click on the NOAH link on the upper right side of the AVMA home page. You’ll need to log in with your member ID number and your password. Once NOAH launches, go to the “Practice Management/Legal Topics” section. The thread is titled “DEA enforcement concerns.”

  3. As promised, here’s an update on the situation: several veterinarians in California recently received requests from DEA to confirm their place of business. For many of these veterinarians, their place of business is also their home address – a practice which is commonplace in veterinary medicine. This led to concerns that the DEA was altering its enforcement of regulations.

    Our DEA contacts in Washington, D.C., say this is “just a regional office confirming that the home address is, in fact, the principal place of business for this registrant.” In general, home addresses are frowned upon by the DEA as storage places for controlled substances; this resulted from concerns about practitioners (not just veterinarians) having controlled subtances delivered to their home address for personal use/abuse and not use in accordance with the Controlled Substances Act.

    If you receive a request of this kind from the DEA, our contact instructs veterinarians to declare on the follow-up form that the home address is the principal place of business and send it back. While not absolutely necessary, confirmation of the home being registered as a business with the state would also be helpful.

    Veterinarians do need to be aware that the listed principal place of business is where the DEA expects that the controlled substances are stored securely with the log-book, in accordance with the Controlled Substances Act. Any veterinarian who lists their home as the principal place of business should be prepared that the DEA may conduct a spot-check to confirm compliance with the regulations.

    Looking for more information about compliance with the Controlled Substances Act? We have guidance on DEA compliance for veterinarians on our site at

  4. What DEA regulations are being interpreted differently and what is the new interpretation??