8.1 Controlled Substance Schedules: Federal CSA & Utah-Specific Scheduling
Key Takeaways
Every substance controlled under the federal Controlled Substances Act is also controlled in Utah, along with the substances in Utah's own schedules and list (Utah Code § 58-37-107).
Gabapentin became a Utah Schedule V controlled substance on May 1, 2024, although it is not controlled federally (Utah Code § 58-37-108(2)(e)(iii)).
Utah Schedule III includes any substance containing any quantity of a derivative of barbituric acid, which covers butalbital combination products that federal law exempts.
A codeine combination product is Schedule V at no more than 200 mg per 100 mL and Schedule III at no more than 1.8 g per 100 mL or 90 mg per dosage unit.
Utah Schedule I includes tianeptine, phenibut, and the kratom alkaloids 7-hydroxymitragynine and mitragynine pseudoindoxyl.
8.1 Controlled Substance Schedules: Federal CSA & Utah-Specific Scheduling
Blueprint item 2.1 covers "requirements for drug uses, limitations, or restrictions." For controlled substances, the starting point is the drug's schedule, which determines prescription, refill, record, inventory, and storage rules.
Two sets of schedules
- Federal: 21 U.S.C. § 812 and 21 CFR Part 1308 (DEA, with HHS and FDA scientific input).
- Utah: Utah Code § 58-37-108 (Schedules I–V; formerly § 58-37-4) and § 58-37-109 (listed controlled substances, mostly synthetic cannabinoids and cathinones). In addition, § 58-37-107(2) makes every substance listed in the federal Controlled Substances Act a controlled substance in Utah.
When Utah places a drug in a more restrictive schedule than federal law, or controls a drug federal law does not, Utah pharmacies follow the Utah schedule (Section 1.2). Utah's Controlled Substance Advisory Committee (Title 58, Chapter 38a) advises the Legislature on scheduling, and additions are made by statute. When the federal government reschedules an FDA-approved pharmaceutical composition of a Schedule I substance, Utah automatically follows (§ 58-37-108(3)).
The five schedules
| Schedule | Criteria | Examples |
|---|---|---|
| I | High abuse potential; no accepted medical use; lack of accepted safety | Heroin, LSD, MDMA, psilocybin; in Utah also tianeptine, phenibut, 7-hydroxymitragynine, and mitragynine pseudoindoxyl |
| II | High abuse potential; accepted medical use; severe dependence | Morphine, oxycodone, hydrocodone (all products since 2014), fentanyl, methadone, hydromorphone, tapentadol; amphetamine, methylphenidate, lisdexamfetamine; cocaine; pentobarbital; dronabinol oral solution (Syndros) |
| III | Less abuse potential than I or II; moderate or low physical or high psychological dependence | Buprenorphine, ketamine, anabolic steroids (for example, testosterone), dronabinol capsules (Marinol), codeine combinations of up to 90 mg per dosage unit (Tylenol with Codeine #3 and #4); in Utah, any substance containing a derivative of barbituric acid (so butalbital/acetaminophen/caffeine is Schedule III in Utah) |
| IV | Low abuse potential relative to III | Benzodiazepines, zolpidem, eszopiclone, carisoprodol, tramadol, modafinil, phenobarbital, phentermine, suvorexant |
| V | Low abuse potential relative to IV | Codeine cough preparations of up to 200 mg per 100 mL, diphenoxylate with atropine (Lomotil), pregabalin, lacosamide, brivaracetam; in Utah, gabapentin |
Narcotic combination thresholds
| Narcotic in combination with non-narcotic active ingredients | Schedule III | Schedule V |
|---|---|---|
| Codeine | ≤ 1.8 g per 100 mL, or ≤ 90 mg per dosage unit | ≤ 200 mg per 100 mL or per 100 g |
| Dihydrocodeine | ≤ 1.8 g per 100 mL, or ≤ 90 mg per dosage unit | ≤ 100 mg per 100 mL or per 100 g |
| Opium | ≤ 500 mg per 100 mL or per 100 g, or ≤ 25 mg per dosage unit | ≤ 100 mg per 100 mL or per 100 g |
| Diphenoxylate | n/a | ≤ 2.5 mg with at least 25 mcg atropine sulfate per dosage unit |
| Difenoxin | n/a | ≤ 0.5 mg with at least 25 mcg atropine sulfate per dosage unit |
Single-entity codeine is Schedule II. A liquid with 240 mg of codeine per 100 mL plus guaifenesin is above the Schedule V limit and is Schedule III.
Utah-specific scheduling: what changes in practice
Gabapentin (Schedule V since May 1, 2024)
- New gabapentin prescriptions require a prescriber with a Utah controlled substance license and a DEA registration. Orders issued before May 1, 2024, including their refills, were not affected.
- Pharmacies took an initial gabapentin inventory in May 2024 and include gabapentin in each annual controlled-substance inventory.
- Dispensing continues to be reported to the CSD, which has tracked gabapentin since 2019 as a drug of concern.
- Schedule V prescription rules apply: refills are valid for one year from issuance (§ 58-37-304(6)(f)), and EPCS is required unless an exemption applies.
- Dispensing medical practitioners may not dispense gabapentin, and gabapentin samples may not be distributed in Utah (DOPL gabapentin fact sheet).
- Veterinarians acting within veterinary scope are exempt (§ 58-37-308).
Butalbital products
Because Utah's Schedule III covers "any substance that contains any quantity of a derivative of barbituric acid," butalbital/acetaminophen/caffeine products that DEA treats as exempted prescription products are Schedule III in Utah. The CSD rule notes that butalbital dispensing must be reported (R156-37f-203(8)).
Emerging substances
Utah has placed tianeptine ("gas-station heroin"), phenibut, and the potent kratom alkaloids 7-hydroxymitragynine and mitragynine pseudoindoxyl in Schedule I, and lists dozens of synthetic cannabinoids and cathinones in § 58-37-109. Kratom products are separately regulated, and a 2026 statute addresses 7-hydroxymitragynine in kratom products (§ 58-37-406).
Medical cannabis
Marijuana remains federally Schedule I. Utah's medical cannabis program operates under Title 26B, Chapter 4, Part 2 and Title 4, Chapter 41a. A medical cannabis pharmacy under Title 4, Chapter 41a is exempt from pharmacy licensure under Chapter 17b (§ 58-17b-302(1)(b)). Providing pharmacy medical provider services in a medical cannabis pharmacy is not unprofessional conduct (§ 58-17b-502(3)(a)), but violating the cannabis statutes is (§ 58-17b-502(1)(o)). Class A and B pharmacies do not dispense medical cannabis under the Pharmacy Practice Act. FDA-approved cannabidiol products placed in federal Schedule V are Utah Schedule V (§ 58-37-108(2)(e)(ii)).
Scheduling traps
- Hydrocodone combinations are Schedule II. Apply CII rules: no refills, the 30-day presentation window, and the one-month supply limit.
- Dronabinol: capsules are Schedule III; oral solution is Schedule II.
- Gabapentin in Utah is a Schedule V controlled substance, not just a "drug of concern."
- Fioricet-type products are Schedule III in Utah.
A pharmacist receives a prescription for a liquid containing 240 mg of codeine per 100 mL with guaifenesin. What is its schedule?
Schedule II
Schedule V
Schedule III
Schedule IV
What is gabapentin's legal status in Utah?
It is a federal Schedule V drug that requires DEA Form 222 orders
It is a Utah Schedule IV drug limited to five refills in six months
It is not controlled in Utah, but its dispensing is reported to the CSD
It has been a Utah Schedule V controlled substance since May 1, 2024, even though it is not federally controlled
How is butalbital/acetaminophen/caffeine (without codeine) classified for a Utah pharmacy?
As a non-controlled prescription drug, because federal law exempts it
As Schedule II, because butalbital is a barbiturate
As a Schedule III controlled substance, because Utah Schedule III includes any substance containing any quantity of a derivative of barbituric acid
As Schedule V, because it is a combination product
Which substance does Utah list in Schedule I?
Tramadol
Tianeptine
Buprenorphine
Pregabalin
Sections you finish are checked off in the contents.