DPS MOU - Controlled Substances & Glassware

THE DEPARTMENT OF PUBLIC SAFETY MEMORANDUM OF UNDERSTANDING PRECURSOR CHEMICALS AND LABORATORY APPARATUS IMPLEMENTATION PLAN

DPS MOU Quick Compliance Guide


 
IMPLEMENTATION AT TEXAS A&M UNIVERSITY OF THE OCTOBER, 1995 TEXAS HIGHER EDUCATION COORDINATING BOARD MEMORANDUM OF UNDERSTANDING ON CONTROLLED LABORATORY APPARATUS AND CHEMICALS 

The Texas Department of Public Safety (DPS) and the Texas Higher Education Coordinating Board (HECB) signed a Memorandum of Understanding (MOU) that establishes responsibilities on institutions of higher education for implementing and maintaining a program for reporting information concerning controlled substances, controlled substance analogues, chemical precursors, and chemical laboratory apparatus used in educational or research activities.  This document defines the requirements and procedures necessary for compliance with the MOU by Texas A&M University at Galveston.  Full text of the MOU is available from the TAMUG Safety Department (741-4055).

The objective of this plan is to define institutional procedures for the use of controlled items (chemical precursors and certain laboratory equipment and glassware) in the facilities of Texas A&M University at Galveston.  

Please distribute the Implementation Plan to all persons affected. Post "IMPORTANT NOTICE" (BELOW) in areas where controlled items are ordered, received, used or stored.

The following is a list of the controlled items including precursor chemicals, laboratory apparatus and glassware whose purchase, use, transfer and disposal must be monitored.

Precursor Chemicals Laboratory Apparatus
Methylamine Condensers
Ethylamine Distilling apparatus
D-Lysergic acid Vacuum dryers
Erogtamine tartrate Three-necked flasks
Diethyl malonate Distilling flasks
Malonic acid Tableting machines
Ethyl malonate Encapsulating machines
Barbituric acid Filter funnels, Buchner funnels, & separatory funnels
Piperidine Erlenmeyer flasks, two-necked flasks, single-necked flasks, round-bottom flasks, thermometer flasks, &filgering flasks
N-Acetyl anthranilic acid
Pyrrolidine Soxhlet extractors
Phenylacetic acid Transformers
Anthranilic acid Flask heaters
Ephedrine Heating mantles
Pseudoephedrine Adapter tubes
Norpseudoephedrine
Phenylpropanolamine
Controlled Substance Analogue

 


“Controlled substance analogue” is a substance that is substantially similar in chemical structure to that of a controlled substance or has central nervous system activity that is substantially similar to, or greater than that of a controlled substance. 

NOTE: The MOU does not establish any de minimis quantities of precursor chemicals nor size of glassware or equipment.

Prescription and non-prescription medicinal formulations are exempted.

The following procedures and requirements are necessary for TAMUG to comply with the MOU.  

1. RESPONSIBLE PARTY: any person who uses or has access to, or control of the listed items, including investigators, laboratory personnel, instructors, laboratory storeroom personnel, purchasing agents and surplus property personnel. 

2. MAINTAIN PURCHASE ORDER RECORDS: Purchase orders that include controlled items should be marked with an asterisk, highlight or some other similar manner readily distinguishable from all other items appearing on the purchase order.  Purchase records are to be maintained according to State and Federal requirements, and are subject to DPS audit.

3. DO NOT SELL, FURNISH OR TRANSFER any controlled items (including surplus property) to a person or entity not holding a DPS permit or waiver, unless the recipient is specifically exempted by law or rule.  Every sale, furnishing or transferring of a controlled item leaving the immediate campus (where the specific controlled item is stored and inventoried)  should be reported (by the 15th day of the next month) to the DPS on a Nar-22 Form.  The Safety Officer will assist the TAMUG Surplus Property and Inventory Department in compliance with the MOU.

4. REPORT TO THE TEXAS A&M UNIVERSITY AT GALVESTON  POLICE promptly upon discovery of a readily unacceptable discrepancy, pilferage or theft of a controlled item.  UPD is responsible for forwarding the report to DPS.

5. SECURITY

a. The Director of Safety and University Police has primary responsibility for all matters associated  with security and law enforcement on the TAMUG Campus.

b. Maintain locked storage for controlled precursor chemicals and controlled substance analogues.   Strictly limit access to these chemicals.  Use records should be maintained.

c. Limit access to storerooms containing listed items to authorized personnel.  Lock storage areas when unattended.

d. All doors and windows into any rooms in which controlled items are used or stored must be locked when authorized personnel are not present.

6. NOTIFICATION AND AWARENESS

a. Departments and units affected by the MOU should post in prominent and strategic location(s), notices to inform personnel of the MOU and of the steps necessary for compliance. See "IMPORTANT NOTICE " in Appendix E.

b. Encourage personnel to be alert and attentive to the disappearance of controlled items and to report such losses as appropriate.

7. ASSISTANCE FROM THE TEXAS DEPARTMENT OF PUBLIC SAFETY

Upon request, the DPS will provide technical advice to the institution and will assist UPD in investigating losses, etc. covered by the MOU.

If there are any questions concerning these documents, please contact the Director of Safety, TAMUG Safety Department (741-4055).  Contact the Chief of the University Police (740-4545) for assistance with security and police