When issued a DEA registration, initial inventory must be an actual physical count of all controlled substances; if there is no stock on hand, the registrant should make a record showing zero inventory.

When issued a DEA registration, initial inventory must be an actual physical count of all controlled substances; if there is no stock on hand, the registrant should make a record showing zero inventory.

• A. An initial inventory must be an actual physical count of all controlled substances.
• B. If there is no stock on hand, the registrant should make a record showing zero inventory.
• C. A sampling of substances may be used.
• D. Inventory is not required.

Answer: (A)

Initial inventory is about establishing a precise starting point for controlled substances as soon as the DEA registration becomes effective. The essential requirement is that this inventory must be a real, on-hand count of every controlled substance, not an estimate or a sample. You count each substance and record the exact amount. If there is no stock on hand, you still need a record showing zero inventory to prove you performed the count and document that nothing is on hand. This is why the statement about a physical count is the best answer—the core rule is the actual physical counting. The other ideas, like taking a sample or saying inventory isn’t required, don’t meet the DEA’s documented-count requirement.

Initial inventory is about establishing a precise starting point for controlled substances as soon as the DEA registration becomes effective. The essential requirement is that this inventory must be a real, on-hand count of every controlled substance, not an estimate or a sample. You count each substance and record the exact amount. If there is no stock on hand, you still need a record showing zero inventory to prove you performed the count and document that nothing is on hand. This is why the statement about a physical count is the best answer—the core rule is the actual physical counting. The other ideas, like taking a sample or saying inventory isn’t required, don’t meet the DEA’s documented-count requirement.