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DEA Drug Schedules for EMS: What Schedule II Means and What Each Schedule Requires

The five federal controlled substance schedules, which ones EMS agencies commonly carry, and the records each schedule needs now that the agency is the DEA registrant.

By Denny Munson, Founder · Published November 2, 2026 · 7 minute read

The short answer: the Controlled Substances Act sorts drugs into five schedules by their potential for abuse and whether they have an accepted medical use. Schedule I has no accepted medical use. Schedule II has the highest abuse potential of the drugs medicine uses, and it is where most EMS opioids sit: fentanyl, morphine and hydromorphone. Ketamine is Schedule III, and midazolam, diazepam and lorazepam are Schedule IV. Schedule II carries the strictest ordering, counting and recordkeeping rules.

The five schedules at a glance

Schedule What it means Examples Common in EMS
I High potential for abuse, no currently accepted medical use Heroin, LSD, ecstasy None
II High potential for abuse, accepted medical use, use may lead to severe dependence Fentanyl, morphine, hydromorphone, meperidine, methadone, oxycodone Fentanyl, morphine, hydromorphone
III Moderate to low potential for dependence, less than I and II Ketamine, buprenorphine, anabolic steroids, Tylenol with codeine Ketamine
IV Low potential for abuse relative to III Midazolam, diazepam, lorazepam, alprazolam, tramadol Midazolam, diazepam, lorazepam
V Lower potential for abuse than IV, limited quantities of certain narcotics Cough preparations with small amounts of codeine Rarely carried

Examples from the DEA's drug scheduling list. What your agency carries is set by your medical director and your state protocols, not by this table.

What are Schedule 2 drugs?

Schedule II (often written Schedule 2 or C-II) covers drugs with a currently accepted medical use and a high potential for abuse, where misuse can lead to severe psychological or physical dependence. For an EMS agency, that usually means the opioid analgesics on the rig. Schedule II is also where federal rules are tightest, so it is the part of the controlled substance program an investigator looks at first.

What the schedule changes in your records

Under the PPAEMA rule, which took effect March 9, 2026, the EMS agency is the DEA registrant. The schedule of each drug decides how it is ordered, counted and filed.

Record Schedule II Schedules III to V
Ordering DEA Form 222, or the electronic CSOS equivalent Ordinary invoice and receipt records
Biennial inventory Exact count or measure of every container An estimate is allowed for an opened container, unless it holds more than 1,000 tablets or capsules
Filing Kept separate from all other records Kept separate, or readily retrievable from other records
Retention At least two years under federal rules. Some states require longer.
Destruction DEA Form 41 for stock destroyed by the registrant
Theft or significant loss DEA Form 106, with the clock starting when the loss is discovered

Most EMS agencies count every vial of every schedule at every shift anyway. The difference that bites is filing: if Schedule II records are mixed into the same binder or report as everything else, they are not kept the way the rule expects.

Three practical habits

  1. Tag every product with its schedule in your formulary list, so reports can split Schedule II from III to V without anyone sorting by hand.
  2. Run the biennial inventory as a real count, at every station, unit and vault, on a set date, opening or close of business.
  3. Watch for schedule changes. DEA does move drugs between schedules. Check the DEA list when your formulary changes, and update the schedule on the product record.

Where software fits

Emergency Logs Narcotics Tracking keeps the controlled substance inventory vial by vial and builds the schedule-specific records from the counts, transfers and waste crews already log. The PPAEMA Report Pack prints a biennial inventory with Schedule II listed separately, a Form 41 destruction record, a theft and loss review that tracks the Form 106 deadlines, and a receipt log that flags Schedule II deliveries without a Form 222 or CSOS number. For the full rule, read the PPAEMA guide for EMS agencies.

This article is general information, not legal advice. Your DEA registration, your state's rules and your medical director's orders decide what applies to your agency.

Sources

Narcotics Tracking

Every vial, every schedule, on record

Daily counts, transfers, waste with witnesses and the DEA records, priced per agency with no per-seat fees.

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Denny Munson, founder of Emergency Logs
Denny Munson
Founder, Emergency Logs

Denny spent 33 years in fire and EMS before building Emergency Logs. Built by First Responders, for First Responders.

Questions

DEA Drug Schedule FAQs for EMS

Schedule II drugs have a currently accepted medical use and a high potential for abuse that may lead to severe dependence. Examples on the DEA list include fentanyl, morphine, hydromorphone, meperidine, methadone and oxycodone. In EMS, Schedule II is usually the opioid analgesics carried on the rig.

It is a drug placed in Schedule II under the federal Controlled Substances Act. Schedule II has the strictest rules of any drug medicine uses: orders go on DEA Form 222 or its electronic CSOS equivalent, every container is counted exactly in the biennial inventory, and the records are kept separate from all other records.

There are five. Schedule I has no accepted medical use. Schedules II through V have accepted medical uses, with abuse potential falling from II to V. Ketamine is Schedule III, and benzodiazepines such as midazolam, diazepam and lorazepam are Schedule IV.

Commonly fentanyl, morphine or hydromorphone (Schedule II), ketamine (Schedule III), and midazolam, diazepam or lorazepam (Schedule IV). Your medical director and state protocols decide the actual list.

For the federal biennial inventory, an estimate is allowed for an opened Schedule III to V container unless it holds more than 1,000 tablets or capsules. Schedule II always needs an exact count. Most EMS agencies count every vial of every schedule at every shift, and state rules or your SOP may require it.

At least two years under federal rules, and readily retrievable for inspection. Some states require longer, so check your state's rule.

Keep Schedule II Where It Belongs

See a count, a waste and a biennial inventory in Emergency Logs, with Schedule II kept on its own.

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