Can we record the weight of injectable drugs on our logs instead of the mls?

The short answer is no.  You can certainly INCLUDE weight on the logs, but the regulations require the records to be maintained by UNIT or VOLUME.

Weight is a great tool for inventory measuring but should not be used as the method to record patient transactions.  The regulation requires the registrant to maintain a record of each transaction that includes the QUANTITY of the drug.   

21 CFR 1304.22(c) states: 

“… records shall be maintained of the number of units or volume of such finished form dispensed, including the name and address of the person to whom it was dispensed, the date of dispensing, the number of units or volume dispensed, and the written or typewritten name or initials of the individual who dispensed or administered the substance...”

https://www.ecfr.gov/current/title-21/part-1304/section-1304.22#p-1304.22(c):

Another problem with using weight as the measurement for logs…there is a false belief that 1cc of product directly translates to 1 gram of weight.  In a single transaction, the difference is very minute, but over the course of a 100ml bottle, there will be an underreporting of the drug.  Example:  by assuming one ml equals exactly one gram, the contents of a 100ml bottle of drug would be 100 grams.  However, some drugs can weigh up to 1.05 grams per ml.  If one is just interchanging volume for weight, when that person extracts 100 grams of the substance from the bottle, he/she would have only extracted 95.24 mls of the product.  The DEA is concerned that the “excess” can easily be diverted.  In addition, most injectable drug bottles are overfilled a small amount during production, so that adds to the possibility of diversion of the excess.
 
Then there’s the problem of the logs matching the medical records.  Every state veterinary practice act requires the veterinarian to record all drugs administered or dispensed in the patient’s medical record.  Most all of them specifically require the name of the drug, the DOSAGE and the QUANTITY to be recorded.  If the medical records are in one measurement (quantity) and the logs are in a different measurement (grams), it’s very difficult to catch problems, especially with drugs that may be given in ultra small increments (like 0.02 ml of buprenorphine).
 
We have not personally seen a hospital cited or fined by the DEA for using weight on the logs instead of volume measurements, but we've had discussions with several agents where they tell us they HATE that method and will usually be “more thorough” during an audit because of the easy way things can be hidden or obfuscated when strictly using weight as the measurement.
 
Having said all that…it’s perfectly OK to use weight as a management tool if it helps spot problems such as a starting weight does not match the last ending weight which indicates a missed entry.  However, the DEA agents conducting audits don’t like it and we can certainly envision them saying “not good enough” at some point.

 

 

Did You Know...?

The federal DEA makes their regulations easily accessible on the internet at:

https://www.ecfr.gov/current/title-21/chapter-II