The short version
- Two lawful routes exist: a DEA-registered medical officer, or a master requisition when no officer is accessible.
- The medical officer must be state-licensed, EMPLOYED by the owner or operator, and DEA-registered. A consultant fails the employment test.
- One registration covers a fleet only while every vessel shares a single owner or operator.
- The master route needs a written requisition on vessel stationery, and copy 2 of the record of sale must stay aboard.
- Two annual reports exist on different clocks: officer to registration expiry, master per calendar year.
Most operators discover the employment test the hard way. They appoint a respected consultant physician as medical officer, file everything correctly, and only later learn that the arrangement never satisfied the regulation.
This page sets out both routes, what each demands in practice, and which one fits which operation. Every claim cites the paragraph it comes from. For the service that supplies a qualifying medical officer, see Controlled Substances. For the paragraph-by-paragraph text, see our 21 CFR 1301.25 walkthrough.
Two routes, one decision
21 CFR 1301.25(a) permits controlled substances to be held, maintained and dispensed from medicine chests, first aid packets or dispensaries aboard vessels in international trade or between US ports, US Government merchant vessels, and other DEA-approved entities[1]. How you obtain them is the choice.
| Consideration | Route 1: medical officer | Route 2: master requisition |
|---|---|---|
| Who obtains the substances | A DEA-registered medical officer employed by you | The master or first officer, in person |
| Employment test | Must be your employee, a consultant does not qualify | Not applicable |
| Paperwork per purchase | Under the officer’s registration | Written requisition on vessel stationery, every time |
| Copies of the record of sale | Per the registration process | Triplicate: vendor, aboard, DEA within 15 days after month-end |
| Fleet coverage | One registration covers vessels under a single owner or operator | Per vessel, per purchase |
| Annual report | Officer report, dated to registration expiry | Master report, per calendar year |
| Best for | A fleet under one owner carrying controls routinely | An occasional purchase where no officer is accessible |
Route 1: the DEA-registered medical officer
Paragraph (b) sets three conditions and they are cumulative[1]. The officer must be a physician licensed by a state, must be employed by the owner or operator of the vessel, and must be registered with DEA, with the Form 223 details maintained at the principal office and readily retrievable.
The employment test is where programs failA consulting physician, however senior, is not employed by the owner or operator. If your medical officer is engaged as a contractor or advisor, the arrangement does not meet paragraph (b). This is the single most common defect we find in existing programs.
Registration applications run through DEA Form 224 and the Diversion Control Division[3].
Route 2: the master requisition
Where no medical officer is accessible, paragraph (d) allows the master or first officer to obtain controlled substances directly[1]. The process is specific and unforgiving:
- Personal appearance at the vendor, with photo identification
- A written requisition on vessel stationery carrying the official number, country of registry, name of the owner or operator, port and date, signed
- A record of sale in triplicate
Where the three copies goCopy 1 stays with the vendor together with the requisition. Copy 2 is furnished to the vessel officer and retained aboard. Copy 3 goes to the nearest DEA Division Office within 15 days after the end of the month in which the sale was made.
Copy 2 missing from the vessel is a routine finding. It is also entirely avoidable.
Does one registration cover a whole fleet?
Paragraph (c) permits a single registration to cover multiple vessels, but only while they share one owner or operator[1]. Introduce a second owner, through a joint venture, a bareboat charter or an acquisition, and that vessel needs its own registration or must use the requisition route.
Ownership structures change faster than compliance documents. If yours has changed since the registration was filed, a consulting assessment is the cheapest way to find out where you stand.
The two annual reports run on different clocks
This catches well-run programs. The medical officer report under paragraph (e) is dated to the expiry of the registration, and accounts in detail for each vessel plus a summary for all vessels under supervision[1]. The master report under paragraph (h) runs per calendar year[1].
Practical consequenceIf your registration expires in, for example, March, your officer report is a March-to-March document while your master report is January to December. Filing both against the same window is a reporting error.
Disposal of expired stock is governed separately, under 21 CFR part 1317[2].
Which route fits your operation
Answer three questions and the route usually decides itself.
- Do all your vessels share one owner or operator? If yes, a single registration is viable. If no, expect multiple registrations or the requisition route.
- Can you employ a physician, not retain one? If not, paragraph (b) is closed to you.
- How often do you purchase? Routine carriage favours the officer route. Occasional purchase favours requisition, with the paperwork discipline it demands.
Common questions
Can our consulting physician be the DEA medical officer?
No. 21 CFR 1301.25(b) requires the medical officer to be employed by the owner or operator. A consultant is not employed, so that route fails on its face[1]. This single point disqualifies more programs than any other. See Controlled Substances.
What are the three conditions for a medical officer?
State-licensed physician, employed by the owner or operator, and DEA-registered, with Form 223 details kept at the principal office and readily retrievable. All three, not two, per 21 CFR 1301.25(b)[1].
What happens if no medical officer is reachable?
Paragraph (d) allows the master or first officer to requisition directly. It requires personal appearance, photo identification and a written requisition on vessel stationery carrying the official number, country of registry, owner or operator, port and date[1]. Read the full walkthrough.
Where do the copies of the record of sale go?
Triplicate. Copy 1 stays with the vendor alongside the requisition, copy 2 is furnished to the vessel officer and retained aboard, and copy 3 goes to the nearest DEA Division Office within 15 days after the end of the month of sale[1]. Missing copy 2 aboard is a routine inspection finding.
Does one DEA registration cover our whole fleet?
Only while every vessel shares a single owner or operator. Add a second owner and you need a separate registration or the requisition route[1]. If your ownership structure is mixed, our consulting assessment maps it before you file.
How do we dispose of expired controlled substances?
Under 21 CFR part 1317[2]. Disposal is a documented process, not a discard. Ask us to review your chain of custody.
