First, relax, I was taking a stab at the regs themselves, not pharmacies or pharmacists. I specifically didn't mention what schedules as it is nuanced depending on said schedule, and most people that have never dealt with it don't really know or care about the different schedules. A schedule 2 is much, much different as to the level of effort you must go through to sell, store, dispense, etc as you alluded to. You also are omitting some info when you state that you have to submit a 222 form to the DEA, as you only have to do that for a schedule 2. I'm not sure what kind of mix of controlled drugs human pharmacies (I worked in the Vet industry) dispense in regards to schedule, but I'd assume that it's MOSTLY C3-C5. And I'm not discounting the points you made about keeping track of every tablet that falls off the counter at the volume a human pharmacy is doing. However, the fact is the estimate requirement for C3-C5 for some reason still applies to returned bottles. It makes no sense as I'm assuming your point to the pharmacy/store level comment you made is that you can't estimate how many pills you are dispensing. Perhaps the investigator that was doing my audit, as well as her supervisor was mistaken. Remember the Buprenorphine recall a few years ago? It was a shit show. The recall notice stated that it should have been returned directly to the mfg, however I had clinics sending me back partial syringes and vials that I somehow was supposed to keep track of the exact ml left in the container, according to my auditor. Exactly how do I measure whats left in the vial? My point was I had the exact same problems you do, but without the legal leeway. As it turned out I didn't get into any actual trouble, but I was given a hard time about it none the less.
