From the document "The drug kit must remain secured in the ambulance at appropriate temperatures at all times. These kits are not intended to be stored within the EMS facility."

From the document:

"If (intravenous) solutions must be stored within the EMS facility, the agency must first obtain a CSR for the purpose of storing these solutions in the EMS facility at the address on the application."

Unclear why IV solutions would be specifically called out to address in-station storage when there is a long list of regulated medical equipment (such as needles, IV catheters etc) that require similar protections for secure storage. Additionally, requiring a separate CSR for the sole purpose of storing these medical supplies creates a high regulatory burden for larger EMS agencies with multiple stations under a single agency umbrella. 

Several aspects of the proposed BOP guidance seem out of step with The DEA's proposed rules on the amended Controlled Substances Act. Perhaps waiting for the DEA's rules to be finalized prior to writing the BOP guidance document should be considered to prevent having differing guidance published.  

Some examples:

DEA rules have proposed:

-permitting storage in facilities without requiring a separate registration for each individual site (e.g. firehouse)

-allowing one for one medication exchange with a hospital following a patient care episode even if the EMS agency's primary routine means of medication handling is agency-based.

In section II of the BOP document, EMS Preparation of its Own Kits Model:
Storage of Schedule II-VI Drugs within EMS Facility for Preparation of Drug Kits:

"Under this model, the EMS facility is solely responsible for preparing and securely storing drug kits for its own use, and replacing drugs within the kits as used for patient administration. The EMS agency does not exchange kits or drugs with a hospital pharmacy."