21 Code For Federal Regulation Parts 1305, 1311 Page 28
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67limited to ten items. With the electronic orders, they will be able to submit a single order
covering all controlled substance and other prescription drugs being purchased from the supplier.
The combined orders should reduce the orders that need to be logged, tracked, and handled by
both purchasers and suppliers.
Electronic orders should also bring faster receipt of controlled substances. Under the
present system, the purchaser has the choice of sending the order by overnight service at
considerable cost, mailing it and waiting several days, or sending the order back with the
delivery truck, which may not be returning directly to the distributor. In most cases, the
purchaser is likely to have to wait at least two days and possibly four or five days when the order
is mailed or is shipped back by truck. If the distributor that receives the order cannot fill it, the
distributor may endorse it to another distributor and ship it on to another distribution point,
further delaying the final shipment. Electronic orders will be received almost instantly and can
be shipped the same day. This speed may allow purchasers to order only when they need an item
and limit the quantity of controlled substances that they stock. Limiting the quantity of Schedule
I and II controlled substances in stock reduces the possibility of diversion and the cost of
security.
With the Form 222, if a supplier cannot fill all of an order, the supplier may endorse the
entire order over to another supplier. The order cannot be divided and filled in part by one
supplier and in part by a second, even if both suppliers belong to the same company. Because
each location holds a separate registration, a distributor with multiple locations must maintain
stocks of all Schedule I and II controlled substances at each location to be able to fill orders for
these substances from that location. Some distributors have created centralized systems where
all orders are processed through the central distribution office, which then transmits parts of the
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