Guest guest Posted September 15, 2008 Report Share Posted September 15, 2008 Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. Thanks, Wayne Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 --- Not only do they have to be locked up, but a shift change inventory log is supposed to be maintained. It is not just a DSHS regulation, but also falls under the guidelines of the DEA. In my service, we have them under lock and key as well as a numbered seal that must be broken to gain access. In fact, our key is the same key used to access city businesses NOX boxes. The key can only be retreived after entering a personal code and that event is stored in a data base. Sounds like over-kill, but there is no question as to who last gained access to the narcotics. In texasems-l , Wayne D wrote: > > Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. > > I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. > > Thanks, > Wayne > > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 , Just one quick comment, I would suggest that you call your regional DEA office and request a visit. I did this exact thing and asked the DEA to review my entire operation for compliance. I found them to be open and honest as to what REALLY are the facts about narcotic storage and record keeping. I found all the things that I thought were true, weren't. They explained EVERYTHING that an EMS system needs to be aware of and the necessary recordkeeping and forms. You will be very surprised as to what the real rules are. EMS providers are considered mid-level practitioners and are not specifically defined in the current codes for DEA. It was one of the better thoughts that I had. P. Naughton, LP Assistant Fire Chief Ciyt of Shavano Park Fire/EMS From: texasems-l [mailto:texasems-l ] On Behalf Of JAMES Sent: Tuesday, September 16, 2008 08:31 To: texasems-l Subject: Re: Narcotic Security --- Not only do they have to be locked up, but a shift change inventory log is supposed to be maintained. It is not just a DSHS regulation, but also falls under the guidelines of the DEA. In my service, we have them under lock and key as well as a numbered seal that must be broken to gain access. In fact, our key is the same key used to access city businesses NOX boxes. The key can only be retreived after entering a personal code and that event is stored in a data base. Sounds like over-kill, but there is no question as to who last gained access to the narcotics. In texasems-l <mailto:texasems-l%40yahoogroups.com> , Wayne D wrote: > > Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. > > I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. > > Thanks, > Wayne > > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 But here is the rub. As I understand the air ambulance business (and I can very well be wrong as I'm just now learning about this stuff) States are not able to regulate the air medical industry? Louis N. Molino, Sr. FF/NREMT-B/FSI/EMSI LNMolino@... - Narcotic Security Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. Thanks, Wayne Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 Not true as well as the narcotic issue is not true, it is a myth that has existed for as long as I can remember. Lee Narcotic Security Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. Thanks, Wayne Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 Lee you confused me? Are you saying that both the regulatory issue and narcotics thing are untrue? My thought based on prior conversations on this and other lists was that states could not regulate air services as they were a part of the interstate commerce system hence federal jurisdiction trumps state. Matters such as billing and this topic included. Could you clarify your comments? Louis N. Molino, Sr. FF/NREMT-B/FSI/EMSI LNMolino@... Sent via BlackBerry by AT & T Narcotic Security Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. Thanks, Wayne Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 Yes, for instance in Texas all air-medical programs have to have a DSHS EMS License and have to meet the minimum licensure requirements for rotor/fixed wing A/C plus stuff in the regular provider rules. If a state elects to mandate CAAMS accreditation as a requirement to obtain a provider license (OK and NM have already done this) then they are still being regulated by the state. As for the FAA/ICC etc etc, that is not so much with the medical side as it is with the operational side (aviation side) of the program in regards to stuff such as pilot issues (pay) and the like. As for the narcotic issue such as double locking that is also not required, this is a hospital DEA rule. This is to the best of my knowledge unless something has changed that I am not aware of. Lee Narcotic Security Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. Thanks, Wayne Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 Lee, Are you able to provide evidence as to the double-locking and securing of narcotics not being required? Thanks, Joe Percer, LP On Tue, Sep 16, 2008 at 8:58 PM, Lee < L@...> wrote: > Yes, for instance in Texas all air-medical programs have to have a DSHS > EMS > License and have to meet the minimum licensure requirements for rotor/fixed > wing A/C plus stuff in the regular provider rules. If a state elects to > mandate CAAMS accreditation as a requirement to obtain a provider license > (OK and NM have already done this) then they are still being regulated by > the state. As for the FAA/ICC etc etc, that is not so much with the medical > side as it is with the operational side (aviation side) of the program in > regards to stuff such as pilot issues (pay) and the like. As for the > narcotic issue such as double locking that is also not required, this is a > hospital DEA rule. > > This is to the best of my knowledge unless something has changed that I am > not aware of. > > > Lee > > Narcotic Security > > Correct me if I'm wrong on this, but is there not a section in 157.11, that > states that narcotics have to be under lock and key while on an in-service > ambulance? I'm aware that some of the air medical services where having > their medics carry them on their person while on duyt, but that DSHS had > told some of them that this did not meet the rule. So, they have locked > those up on their aircrafts. > > I'm guessing that this same thing would apply to ground providers that > still > have their medics carry narcotics on their person while on duty. I don't > like this because one may forget and leave their shift and carry those > narcs > home. > > Thanks, > Wayne > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 Ok that all sort of makes sense to me. Thanks. Louis N. Molino, Sr. FF/NREMT-B/FSI/EMSI LNMolino@... Sent via BlackBerry by AT & T Narcotic Security Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. Thanks, Wayne Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 Not off the top of my head but I am sure someone on the list will be able to produce it within a short time frame. This was something that I researched years ago when I directed a municipal EMS agency, the information I received (and thus using for this conversation) originated from the Dallas DEA office. Lee From: texasems-l [mailto:texasems-l ] On Behalf Of ph Percer Sent: Tuesday, September 16, 2008 8:00 PM To: texasems-l Subject: Re: Narcotic Security Lee, Are you able to provide evidence as to the double-locking and securing of narcotics not being required? Thanks, Joe Percer, LP On Tue, Sep 16, 2008 at 8:58 PM, Lee < L@... <mailto:L%40techproservices.net> > wrote: > Yes, for instance in Texas all air-medical programs have to have a DSHS > EMS > License and have to meet the minimum licensure requirements for rotor/fixed > wing A/C plus stuff in the regular provider rules. If a state elects to > mandate CAAMS accreditation as a requirement to obtain a provider license > (OK and NM have already done this) then they are still being regulated by > the state. As for the FAA/ICC etc etc, that is not so much with the medical > side as it is with the operational side (aviation side) of the program in > regards to stuff such as pilot issues (pay) and the like. As for the > narcotic issue such as double locking that is also not required, this is a > hospital DEA rule. > > This is to the best of my knowledge unless something has changed that I am > not aware of. > > > Lee > > Narcotic Security > > Correct me if I'm wrong on this, but is there not a section in 157.11, that > states that narcotics have to be under lock and key while on an in-service > ambulance? I'm aware that some of the air medical services where having > their medics carry them on their person while on duyt, but that DSHS had > told some of them that this did not meet the rule. So, they have locked > those up on their aircrafts. > > I'm guessing that this same thing would apply to ground providers that > still > have their medics carry narcotics on their person while on duty. I don't > like this because one may forget and leave their shift and carry those > narcs > home. > > Thanks, > Wayne > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 You know Louis, sometimes I am not as dumb as I look!!!! LOL Lee Narcotic Security Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. Thanks, Wayne Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 It would not be possible As for me I have a face for radio. Louis N. Molino, Sr. FF/NREMT-B/FSI/EMSI LNMolino@... Sent via BlackBerry by AT & T Narcotic Security Correct me if I'm wrong on this, but is there not a section in 157.11, that states that narcotics have to be under lock and key while on an in-service ambulance? I'm aware that some of the air medical services where having their medics carry them on their person while on duyt, but that DSHS had told some of them that this did not meet the rule. So, they have locked those up on their aircrafts. I'm guessing that this same thing would apply to ground providers that still have their medics carry narcotics on their person while on duty. I don't like this because one may forget and leave their shift and carry those narcs home. Thanks, Wayne Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 Chief, Thanks for the info. I am just a grunt in my service and follow the rules imposed on me by management. It would appear that my management is not as well informed as they should be(No Surprise There) Thanks Again > > > > Correct me if I'm wrong on this, but is there not a section in > 157.11, that states that narcotics have to be under lock and key > while on an in-service ambulance? I'm aware that some of the air > medical services where having their medics carry them on their person > while on duyt, but that DSHS had told some of them that this did not > meet the rule. So, they have locked those up on their aircrafts. > > > > I'm guessing that this same thing would apply to ground providers > that still have their medics carry narcotics on their person while on > duty. I don't like this because one may forget and leave their shift > and carry those narcs home. > > > > Thanks, > > Wayne > > > > > > > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 Here's the law. Make of it what you will. Code of Federal Regulations Section 1301.75 Physical security controls for practitioners. (a) Controlled substances listed in Schedule I shall be stored in a securely locked, substantially constructed cabinet. ( Controlled substances listed in Schedules II, III, IV, and V shall be stored in a securely locked, substantially constructed cabinet. However, pharmacies and institutional practitioners may disperse such substances throughout the stock of noncontrolled substances in such a manner as to obstruct the theft or diversion of the controlled substances. © This section shall also apply to nonpractitioners authorized to conduct research or chemical analysis under another registration. (d) Carfentanil etorphine hydrochloride and diprenorphine shall be stored in a safe or steel cabinet equivalent to a U.S. Government Class V security container. [39 FR 3674, Jan. 29, 1974, as amended at 39 FR 17838, May 21, 1974; 54 FR 33674, Aug. 16, 1989; 62 FR 13957, Mar. 24, 1997] Gene Gandy, JD, LP > > Joe, you're asking Lee to prove a negative and I'm surprised he fell > for it. There is no state law or TDH rule with any specific language > that requires locking up the narcs. Even DEA doesn't require mid- > level practicioners to lock up the narcs. They require pharmacies to > be secure, but they don't tell you how to do it and the double > locking tale is a myth. I won't try to prove it, but instead would > ask you or anyone to prove otherwise. If a law or rule exists, > someone should be able to find it and provide a citation proving me > wrong. Places where you might start your search are the TDH office at > , and the DEA at . The DPS is involved too, > and maybe even the board of pharmacies. > > Good luck, Bill > > > > > > Lee, > > > > Are you able to provide evidence as to the double-locking and > securing of > > narcotics not being required? > > > > Thanks, > > > > Joe Percer, LP > > > > > ************** Psssst...Have you heard the news? There's a new fashion blog, plus the latest fall trends and hair styles at StyleList.com. (http://www.stylelist.com/trends?ncid=aolsty00050000000014) Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 16, 2008 Report Share Posted September 16, 2008 Joe, you're asking Lee to prove a negative and I'm surprised he fell for it. There is no state law or TDH rule with any specific language that requires locking up the narcs. Even DEA doesn't require mid- level practicioners to lock up the narcs. They require pharmacies to be secure, but they don't tell you how to do it and the double locking tale is a myth. I won't try to prove it, but instead would ask you or anyone to prove otherwise. If a law or rule exists, someone should be able to find it and provide a citation proving me wrong. Places where you might start your search are the TDH office at , and the DEA at . The DPS is involved too, and maybe even the board of pharmacies. Good luck, Bill > > Lee, > > Are you able to provide evidence as to the double-locking and securing of > narcotics not being required? > > Thanks, > > Joe Percer, LP > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 17, 2008 Report Share Posted September 17, 2008 You know, most people are only concerned with double triple quadruple locking and accounting for Schedule 2's. But the rule for storage is the same for II-V. Hmmmmmmmmm Subject: Re: Re: Narcotic Security To: texasems-l Date: Wednesday, September 17, 2008, 3:14 AM Here's the law. Make of it what you will. Code of Federal Regulations Section 1301.75 Physical security controls for practitioners. (a) Controlled substances listed in Schedule I shall be stored in a securely locked, substantially constructed cabinet. ( Controlled substances listed in Schedules II, III, IV, and V shall be stored in a securely locked, substantially constructed cabinet. However, pharmacies and institutional practitioners may disperse such substances throughout the stock of noncontrolled substances in such a manner as to obstruct the theft or diversion of the controlled substances. © This section shall also apply to nonpractitioners authorized to conduct research or chemical analysis under another registration. (d) Carfentanil etorphine hydrochloride and diprenorphine shall be stored in a safe or steel cabinet equivalent to a U.S. Government Class V security container. [39 FR 3674, Jan. 29, 1974, as amended at 39 FR 17838, May 21, 1974; 54 FR 33674, Aug. 16, 1989; 62 FR 13957, Mar. 24, 1997] Gene Gandy, JD, LP > > Joe, you're asking Lee to prove a negative and I'm surprised he fell > for it. There is no state law or TDH rule with any specific language > that requires locking up the narcs. Even DEA doesn't require mid- > level practicioners to lock up the narcs. They require pharmacies to > be secure, but they don't tell you how to do it and the double > locking tale is a myth. I won't try to prove it, but instead would > ask you or anyone to prove otherwise. If a law or rule exists, > someone should be able to find it and provide a citation proving me > wrong. Places where you might start your search are the TDH office at > , and the DEA at . The DPS is involved too, > and maybe even the board of pharmacies. > > Good luck, Bill > > > > > > Lee, > > > > Are you able to provide evidence as to the double-locking and > securing of > > narcotics not being required? > > > > Thanks, > > > > Joe Percer, LP > > > > > ************** Psssst...Have you heard the news? There's a new fashion blog, plus the latest fall trends and hair styles at StyleList.com. (http://www.stylelist.com/trends?ncid=aolsty00050000000014) Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 17, 2008 Report Share Posted September 17, 2008 But it's so much sexier to have a triple/quadruple chaindriven electronic fingerprint locking device. LOL. GG > > You know, most people are only concerned with double triple quadruple > locking and accounting for Schedule 2's. But the rule for storage is the same for > II-V. Hmmmmmmmmm > > > > From: wegandy1938@wegandy <wegandy1938@wegandy> > Subject: Re: Re: Narcotic Security > To: texasems-l@yahoogrotexasem > Date: Wednesday, September 17, 2008, 3:14 AM > > Here's the law. Make of it what you will. > > Code of Federal Regulations Section 1301.75 Physical security controls for > practitioners. > (a) Controlled substances listed in Schedule I shall be stored in a securely > locked, substantially constructed cabinet. > ( Controlled substances listed in Schedules II, III, IV, and V shall be > stored in a securely locked, substantially constructed cabinet. However, > pharmacies and institutional practitioners may disperse such substances > throughout the > stock of noncontrolled substances in such a manner as to obstruct the theft > or diversion of the controlled substances. > © This section shall also apply to nonpractitioners authorized to conduct > research or chemical analysis under another registration. > (d) Carfentanil etorphine hydrochloride and diprenorphine shall be stored in > a safe or steel cabinet equivalent to a U.S. Government Class V security > container. > [39 FR 3674, Jan. 29, 1974, as amended at 39 FR 17838, May 21, 1974; 54 FR > 33674, Aug. 16, 1989; 62 FR 13957, Mar. 24, 1997] > > Gene Gandy, JD, LP > In a message dated 9/16/08 10:02:26 PM, medicrescue22@medicresc writes: > > > > > Joe, you're asking Lee to prove a negative and I'm surprised he > fell > > for it. There is no state law or TDH rule with any specific language > > that requires locking up the narcs. Even DEA doesn't require mid- > > level practicioners to lock up the narcs. They require pharmacies to > > be secure, but they don't tell you how to do it and the double > > locking tale is a myth. I won't try to prove it, but instead would > > ask you or anyone to prove otherwise. If a law or rule exists, > > someone should be able to find it and provide a citation proving me > > wrong. Places where you might start your search are the TDH office at > > , and the DEA at . The DPS is involved too, > > and maybe even the board of pharmacies. > > > > Good luck, Bill > > > > > > > > > > Lee, > > > > > > Are you able to provide evidence as to the double-locking and > > securing of > > > narcotics not being required? > > > > > > Thanks, > > > > > > Joe Percer, LP > > > > > > > > > > > ************ * > Psssst...Have you heard the news? There's a new fashion blog, > plus the latest fall trends and hair styles at StyleList.com. > > (http://www.stylelishttp://www.sthttp://www.stylehttp://ww) > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 17, 2008 Report Share Posted September 17, 2008 According to the local field office for the DEA in San , there is no such rule. The rule states that you have to take reasonable precautions to ensure the security of narcotic that are in storage. There is no specific rule regarding narcotics on EMS units. P. Naughton Fax From: texasems-l [mailto:texasems-l ] On Behalf Of ph Percer Sent: Tuesday, September 16, 2008 20:00 To: texasems-l Subject: Re: Narcotic Security Lee, Are you able to provide evidence as to the double-locking and securing of narcotics not being required? Thanks, Joe Percer, LP On Tue, Sep 16, 2008 at 8:58 PM, Lee < L@... <mailto:L%40techproservices.net> > wrote: > Yes, for instance in Texas all air-medical programs have to have a DSHS > EMS > License and have to meet the minimum licensure requirements for rotor/fixed > wing A/C plus stuff in the regular provider rules. If a state elects to > mandate CAAMS accreditation as a requirement to obtain a provider license > (OK and NM have already done this) then they are still being regulated by > the state. As for the FAA/ICC etc etc, that is not so much with the medical > side as it is with the operational side (aviation side) of the program in > regards to stuff such as pilot issues (pay) and the like. As for the > narcotic issue such as double locking that is also not required, this is a > hospital DEA rule. > > This is to the best of my knowledge unless something has changed that I am > not aware of. > > > Lee > > Narcotic Security > > Correct me if I'm wrong on this, but is there not a section in 157.11, that > states that narcotics have to be under lock and key while on an in-service > ambulance? I'm aware that some of the air medical services where having > their medics carry them on their person while on duyt, but that DSHS had > told some of them that this did not meet the rule. So, they have locked > those up on their aircrafts. > > I'm guessing that this same thing would apply to ground providers that > still > have their medics carry narcotics on their person while on duty. I don't > like this because one may forget and leave their shift and carry those > narcs > home. > > Thanks, > Wayne > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 17, 2008 Report Share Posted September 17, 2008 , I would bet that most services are poorly informed as to the real rules, I was. I have been in EMS for 25 years and until the actual DEA sat down and told me the rules, most everything I thought was incorrect. P. Naughton Fax From: texasems-l [mailto:texasems-l ] On Behalf Of JAMES Sent: Tuesday, September 16, 2008 21:24 To: texasems-l Subject: Re: Narcotic Security Chief, Thanks for the info. I am just a grunt in my service and follow the rules imposed on me by management. It would appear that my management is not as well informed as they should be(No Surprise There) Thanks Again > > > > Correct me if I'm wrong on this, but is there not a section in > 157.11, that states that narcotics have to be under lock and key > while on an in-service ambulance? I'm aware that some of the air > medical services where having their medics carry them on their person > while on duyt, but that DSHS had told some of them that this did not > meet the rule. So, they have locked those up on their aircrafts. > > > > I'm guessing that this same thing would apply to ground providers > that still have their medics carry narcotics on their person while on > duty. I don't like this because one may forget and leave their shift > and carry those narcs home. > > > > Thanks, > > Wayne > > > > > > > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 18, 2008 Report Share Posted September 18, 2008 This was my point. TDH has no rules at all, and although DEA my have some language in the CFR's regarding narc control, they do not enforce it for midlevel providers like EMS and first responders. They will, however, get their panties in a wad over narc diversion or improper record keeping. We seem to be attempting to protect our narcs from theft by the public, but the real threat to narc security has the keys to the safe and is wearing the same uniform as the rest of the folks on the squad. Last year I attended a truly excellent presentation by the EMS Chief from McKinney on narc security. He was very clear about the these issues. Bill > > > Yes, for instance in Texas all air-medical programs have to have a DSHS > > EMS > > License and have to meet the minimum licensure requirements for > rotor/fixed > > wing A/C plus stuff in the regular provider rules. If a state elects to > > mandate CAAMS accreditation as a requirement to obtain a provider license > > (OK and NM have already done this) then they are still being regulated by > > the state. As for the FAA/ICC etc etc, that is not so much with the > medical > > side as it is with the operational side (aviation side) of the program in > > regards to stuff such as pilot issues (pay) and the like. As for the > > narcotic issue such as double locking that is also not required, this is a > > hospital DEA rule. > > > > This is to the best of my knowledge unless something has changed that I am > > not aware of. > > > > > > Lee > > > > Narcotic Security > > > > Correct me if I'm wrong on this, but is there not a section in 157.11, > that > > states that narcotics have to be under lock and key while on an in-service > > ambulance? I'm aware that some of the air medical services where having > > their medics carry them on their person while on duyt, but that DSHS had > > told some of them that this did not meet the rule. So, they have locked > > those up on their aircrafts. > > > > I'm guessing that this same thing would apply to ground providers that > > still > > have their medics carry narcotics on their person while on duty. I don't > > like this because one may forget and leave their shift and carry those > > narcs > > home. > > > > Thanks, > > Wayne > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 18, 2008 Report Share Posted September 18, 2008 You are quite correct about the diversion issues. However, I would issue this caveat about the CFR reg. Get it in writing. I say that because the issue is open to interpretation from one regional office to another. One cannot rely upon a verbal representation of any government representative. They're not bound by what they tell you. For example, if somebody from IRS tells you a certain item is deductible, later they can change their mind or say that the employee was misinterpreting the rules. They do that all the time. So, I recommend that you do keep your narcs locked up under ONE key. And keep your paperwork up to date. For example, do the daily count and tradeoff religiously. Good paper records will go a long way toward protecting you if there is a diversion. Gene G. > > This was my point. TDH has no rules at all, and although DEA my have > some language in the CFR's regarding narc control, they do not > enforce it for midlevel providers like EMS and first responders. They > will, however, get their panties in a wad over narc diversion or > improper record keeping. > > We seem to be attempting to protect our narcs from theft by the > public, but the real threat to narc security has the keys to the safe > and is wearing the same uniform as the rest of the folks on the > squad. Last year I attended a truly excellent presentation by the EMS > Chief from McKinney on narc security. He was very clear about the > these issues. > > Bill > > > > > > > Yes, for instance in Texas all air-medical programs have to have > a DSHS > > > EMS > > > License and have to meet the minimum licensure requirements for > > rotor/fixed > > > wing A/C plus stuff in the regular provider rules. If a state > elects to > > > mandate CAAMS accreditation as a requirement to obtain a provider > license > > > (OK and NM have already done this) then they are still being > regulated by > > > the state. As for the FAA/ICC etc etc, that is not so much with > the > > medical > > > side as it is with the operational side (aviation side) of the > program in > > > regards to stuff such as pilot issues (pay) and the like. As for > the > > > narcotic issue such as double locking that is also not required, > this is a > > > hospital DEA rule. > > > > > > This is to the best of my knowledge unless something has changed > that I am > > > not aware of. > > > > > > > > > Lee > > > > > > Narcotic Security > > > > > > Correct me if I'm wrong on this, but is there not a section in > 157.11, > > that > > > states that narcotics have to be under lock and key while on an > in-service > > > ambulance? I'm aware that some of the air medical services where > having > > > their medics carry them on their person while on duyt, but that > DSHS had > > > told some of them that this did not meet the rule. So, they have > locked > > > those up on their aircrafts. > > > > > > I'm guessing that this same thing would apply to ground providers > that > > > still > > > have their medics carry narcotics on their person while on duty. > I don't > > > like this because one may forget and leave their shift and carry > those > > > narcs > > > home. > > > > > > Thanks, > > > Wayne > > > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 18, 2008 Report Share Posted September 18, 2008 Received thanks Narcotic Security > > > > > > Correct me if I'm wrong on this, but is there not a section in > 157.11, > > that > > > states that narcotics have to be under lock and key while on an > in-service > > > ambulance? I'm aware that some of the air medical services where > having > > > their medics carry them on their person while on duyt, but that > DSHS had > > > told some of them that this did not meet the rule. So, they have > locked > > > those up on their aircrafts. > > > > > > I'm guessing that this same thing would apply to ground providers > that > > > still > > > have their medics carry narcotics on their person while on duty. > I don't > > > like this because one may forget and leave their shift and carry > those > > > narcs > > > home. > > > > > > Thanks, > > > Wayne > > > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 19, 2008 Report Share Posted September 19, 2008 Only addition to Gene's statement I could make is .. " All conveniently strapped to your waist like a terrorist in a one size fits most fanny pack. " <grin> Penny Engelking LP > But it's so much sexier to have a triple/quadruple chaindriven > electronic > fingerprint locking device. LOL. > > GG > > > . > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 19, 2008 Report Share Posted September 19, 2008 Like it was mention that it is all into interpretation of the field DEA office. All the DEA has under this topic is the following: Section 1309.71 General security requirements. (a) All applicants and registrants must provide effective controls and procedures to guard against theft and diversion of List I chemicals. Chemicals must be stored in containers sealed in such a manner as to indicate any attempts at tampering with the container. Where chemicals cannot be stored in sealed containers, access to the chemicals should be controlled through physical means or through human or electronic monitoring. ( In evaluating the effectiveness of security controls and procedures, the Administrator shall consider the following factors: (1) The type, form, and quantity of List I chemicals handled; (2) The location of the premises and the relationship such location bears on the security needs; (3) The type of building construction comprising the facility and the general characteristics of the building or buildings; (4) The availability of electronic detection and alarm systems; (5) the extent of unsupervised public access to the facility; (6) The adequacy of supervision over employees having access to List I chemicals; (7) The procedures for handling business guests, visitors, maintenance personnel, and nonemployee service personnel in areas where List I chemicals are processed or stored; (8) The adequacy of the registrant's or applicant's systems for monitoring the receipt, distribution, and disposition of List I chemicals in its operations. © Any registrant or applicant desiring to determine whether a proposed system of security controls and procedures is adequate may submit materials and plans regarding the proposed security controls and procedures either to the Special Agent in Charge in the region in which the security controls and procedures will be used, or to the Chemical Operations Section Office of Diversion Control, Drug Enforcement Administration, Washington, D.C. 20537 > > > > > > > Yes, for instance in Texas all air-medical programs have to have > > a DSHS > > > > EMS > > > > License and have to meet the minimum licensure requirements for > > > rotor/fixed > > > > wing A/C plus stuff in the regular provider rules. If a state > > elects to > > > > mandate CAAMS accreditation as a requirement to obtain a provider > > license > > > > (OK and NM have already done this) then they are still being > > regulated by > > > > the state. As for the FAA/ICC etc etc, that is not so much with > > the > > > medical > > > > side as it is with the operational side (aviation side) of the > > program in > > > > regards to stuff such as pilot issues (pay) and the like. As for > > the > > > > narcotic issue such as double locking that is also not required, > > this is a > > > > hospital DEA rule. > > > > > > > > This is to the best of my knowledge unless something has changed > > that I am > > > > not aware of. > > > > > > > > > > > > Lee > > > > > > > > Narcotic Security > > > > > > > > Correct me if I'm wrong on this, but is there not a section in > > 157.11, > > > that > > > > states that narcotics have to be under lock and key while on an > > in-service > > > > ambulance? I'm aware that some of the air medical services where > > having > > > > their medics carry them on their person while on duyt, but that > > DSHS had > > > > told some of them that this did not meet the rule. So, they have > > locked > > > > those up on their aircrafts. > > > > > > > > I'm guessing that this same thing would apply to ground providers > > that > > > > still > > > > have their medics carry narcotics on their person while on duty. > > I don't > > > > like this because one may forget and leave their shift and carry > > those > > > > narcs > > > > home. > > > > > > > > Thanks, > > > > Wayne > > > > > > > > Quote Link to comment Share on other sites More sharing options...
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