21 Code For Federal Regulation Parts 1305, 1311 Page 7
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67The DEA Certification Authority (CA) will issue digital certificates, which will serve as
an electronic equivalent of the Form 222. DEA must serve as the CA because a digital certificate
is the functional equivalent of a Form 222 that the CSA requires DEA to issue. In the same
manner as DEA pre-prints the registration information on the paper order forms that are issued to
registrants, DEA will enter the registration information in extensions within the certificates that
are issued to registrants and those granted power of attorney by registrants.
As DEA explained in the NPRM, the process of digitally signing an order is technically
complicated (the software uses several complex algorithms to create an encrypted digest of the
text), but the user needs only to activate the key and then enter one or two key strokes to sign an
order or validate it. Existing electronic order systems will have to be PKI-enabled, which can be
done with commercially available toolkits. DEA has been working with industry to develop
systems and procedures that allow PKI-enabling existing systems to reduce the cost of
implementation.
CSOS Certificates
All of the information currently preprinted on the Form 222 will be part of the extension
data of the CSOS digital certificate, which will be included with each order that is digitally
signed. Attaching the digital certificate, with the registration information in the extension data,
to an electronic order signed with the digital signature is the functional equivalent to DEA pre-
printing the registrant information on the paper forms, thus creating an electronic equivalent of
the Form 222.
A CSOS certificate will be valid until the DEA registration under which it is issued
expires or until the CSOS CA is notified that the certificate should be revoked. Certificates will
be revoked if the certificate holder is no longer authorized to sign Schedule I and II orders for the
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