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Controlled Substances Management for Vessels

DEA COMPLIANCE · 21 CFR 1301.25

Controlled Substances Management for Vessels

Under 21 CFR 1301.25, the controlled substances aboard your vessels run under a DEA-registered medical officer. We are that officer, and we own the registration, the records and both annual reports, so your fleet stays compliant without hiring a physician in-house.

Does this apply to your fleet?

If your vessels carry Schedule II-V medication, it does

21 CFR 1301.25 governs how you acquire, store, dispense, document and dispose of controlled substances at sea. Under paragraph (a) it applies to:

What compliance requires

Three moving parts, one physician accountable for all of them

Everything the regulation demands, on one screen. This is the burden you carry in-house, or hand to us.

1 The medical officer

2 The records aboard

3 The two annual reports

The gap inspectors find first

One registration covers a fleet, until it does not

A single registration covers every vessel you own, but only while they share one owner or operator. The moment that physician also serves a second owner, 21 CFR 1301.25(c) requires a separate registration at each owner principal office, or the Form 223 route. It is the most common gap we find, and an inspector finds it too.

Build it, or hand it to us

Every requirement above is yours to maintain, or ours

The honest split between staffing a DEA-registered physician in-house and outsourcing the medical officer to Discovery Health MD.

Requirement	In-house officer	Discovery Health MD
Licensed, employed physician	You hire & payroll	Provided
DEA registration structure	You build & maintain	Provided & maintained
Multi-owner rules, 1301.25(c)	You track per-owner	Handled
Requisitions & records of sale	Your crew & vendor	Documented & audited
Annual reports (e) and (h)	You track two clocks	Prepared & filed
Officer training	You build a program	Included

Who stands behind it

Directed by a board-certified emergency physician

Ann Jarris, MD, MBA, FACEP

CEO & CO-FOUNDER · BOARD-CERTIFIED EMERGENCY PHYSICIAN · FACEP

Co-founded Discovery Health MD in Seattle in 2016 to bring emergency-medicine expertise to crews working beyond the reach of shoreside care. Every controlled-substances program we run is directed by a physician, not an administrator.

Last reviewed: July 2026

References. 21 CFR 1301.25 (Registration regarding ocean vessels, aircraft, and other entities), ecfr.gov 21 CFR part 1317 (Disposal). Single Convention on Narcotic Drugs, 1961, Article 32. Convention on Psychotropic Substances, 1971, Article 14. Amendment history: 62 FR 13951 (1997), 79 FR 53561 (2014), 84 FR 68342 (2019).

Common questions

Answers buyers and search engines look for

Controlled substances must be dispensed under the general supervision of a medical officer who is a state-licensed physician, employed by the vessel owner or operator, and DEA-registered, per 21 CFR 1301.25(a) and (b). The officer need not be physically present, provided the person dispensing is responsible to that officer.

No. The registration attaches to the medical officer, held at the principal office of the owner or operator, or at another location provided the DEA Form 223 details are kept at the principal office in a readily retrievable manner, per 21 CFR 1301.25(b)(3).

Yes, under a single registration, provided all vessels share one owner or operator. If the officer serves more than one owner or operator, they must maintain a separate registration at each owner principal office, or use the Form 223 documentation route, per 21 CFR 1301.25(c).

The master or first officer may purchase controlled substances directly, without being registered, by personally appearing at the vendor with photographic identification and a written requisition on the vessel official stationery containing the vessel official number, country of registry, owner or operator, and port, per 21 CFR 1301.25(d).

No. Owners and operators are not deemed to import or export controlled substances purchased and stored in accordance with 21 CFR 1301.25(g), read with the 1961 Single Convention and the 1971 Convention.

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The rest of your medical program

MedChest

The controlled-substances portion of the chest

Consulting

Which rules apply to your fleet

Talk to a physician

Get a controls review of your fleet

We audit your logs, requisitions and chain of custody before the DEA does, and show you exactly where the gaps are.