Drug manufacturer labels are not considered a record of dispersal for controlled substances because they primarily serve as information for the end user regarding the product, including dosage, usage instructions, and safety information. They do not contain detailed information about the distribution or transfer of the controlled substances from one entity to another.
In contrast, invoices are considered records of dispersal as they document the sale and transfer of the controlled substances from the supplier to the purchaser. DEA 222 forms are specifically designed for the ordering and transfer of Schedule I and II controlled substances and are a vital part of controlled substances dispensing and distribution records. Institutional records, which would include inventory records, also track the movement and management of controlled substances within a facility. Therefore, the combination of these documents ensures compliance with regulatory requirements surrounding the handling of controlled substances, whereas manufacturer labels do not fulfill that role.