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  • jwgilbreath

Hello all!—keep a watch on this! Fioricet

As many of you may be aware, DEA is considering removing Fioricet from the DEA exemption list. As of October 8, 2023, it is still listed on the exemption list. In fact, the list was updated on September 25, 2023! I do not know when this removal will occur.

Some companies have already been sending out products with a C-III on the bottle. That even includes Watson, who owns the rights to the name brand of the Butalbital/Acetaminophen/Caffeine 50mg/300mg/40mg. Again, theoretically it's still on the exemption list.

If you do receive product with the C-III mark on it, you will need to consider if you want to internally handle as a controlled substance. If so, remember the requirements for initial inventory. As for DEA form 106s for theft/loss it may be difficult to send in to the DEA if the product is not listed in the electronic system of the DEA. Remember from a previous post I noted that the DEA now requires that 106s are all completed electronically. You need to decide the best route about the communications.

If/When it is officially listed, personally I would complete an "official" initial inventory. The "official" initial inventory absolutely needs to be in your DEA required inventory files. Hopefully by the time this occurs, the drugs will be on the pull down list on the electronic DEA form 106 page.

Remember this is how I would handle...BUT....if you have questions you may want to ask your legal counsel as I cannot give you legal counsel and remember my company will not give legal counsel. My options are just my own. I am just trying to help put information on your radar. 😊

If I see if officially moving to C-III I will try to let you know in the blog!

Thanks everybody!

Jay G

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