Sciencemadness Discussion Board - TONS of Reagents and Glassware - LabDirect

you are in the US, and after a cursory glance i see two DEA LIST ONE precursors?

*edit* wish you luck, but legit or not, I don't see that turning out well....

[Edited on 5-8-2021 by arkoma]

The quantities offered here fall well below the DEA-established reporting thresholds in 21 CFR Part 1310. I cannot speak for what kind of licenses LabDirect has, but I do not see any of the chemicals from §1310.04(g) listed on their website. As long as they can legally receive and dispense List I and List II chemicals, there is little concern given the quantities listed on their website.

There should be more legal disclaimers, though. One would assume they have some form of legal representation.

I am not a lawyer, so please take what I say with a grain of salt, and feel free to correct me if I am wrong.

monolithic - 8-5-2021 at 10:11

Nice website, I'll be sure to use it when I need some more reagents. I really admire your ambition to set up such a large business with warehousing and everything.

you are in the US, and after a cursory glance i see two DEA LIST ONE precursors?

*edit* wish you luck, but legit or not, I don't see that turning out well....

[Edited on 5-8-2021 by arkoma]

If one meets all of the reporting/know your customer requirements, if there are even such requirements for the reagent/quantity sold, then there is no risk. https://www.justice.gov/sites/default/files/open/legacy/2014...

enlight - 8-5-2021 at 18:59

I figure I should ask this question in public view for everybody's reference: If I, for example, wanted to buy 1g of potassium permanganate, or 10 of magnesium oxide, would I have to meet an MOQ or pay a minimum lot charge? They are cheap chemicals, and I'm wondering if it is worth the effort on your end.

In my case, I would like to be able to procure a wide array of useful reagents in small quantities (hobby chemistry). I ask only because this can be very labor-intensive for the supplier.

vano - 8-5-2021 at 21:43

Hi Richard. Where you live?

enlight - 8-5-2021 at 23:56

Quote: Originally posted by vano

Hi Richard. Where you live?

Looks like it's in or around Conneticut, USA.

monolithic - 9-5-2021 at 10:14

I just checked out his website in more detail. Great to have many of these chemicals available to amateurs but some of these are quite surprising, like dimethyl sulfate and carbon tetrachloride. I would be vetting the hell out of any amateurs that purchased these.

[Edited on 5-9-2021 by monolithic]

LabDIRECT - 9-5-2021 at 11:37

you are in the US, and after a cursory glance i see two DEA LIST ONE precursors?

*edit* wish you luck, but legit or not, I don't see that turning out well....

[Edited on 5-8-2021 by arkoma]

In case you’re interested, the regulations for DEA list 1, 2 and watchlisted chemicals are very different than people generally assume.

Pages 28-30 of the DEAs Chemical handlers manual (https://www.justice.gov/sites/default/files/open/legacy/2014...) lays out the quantities of each list 1, 2 and watchlisted chemical under which transactions are exempted. Most are under 1 kg, as long as there’s no obvious suspicion that the person ordering is doing so for illicit activities. It also lays out all the other exemptions in detail, of which there are a lot.

Despite what people think, the DEA is not looking to kill independent chemistry or kick in the doors of chemists buying 60ml of acetic anhydride. They are looking to stop cartels and mob bosses from buying hundreds of kilograms of precursors.

Whether we think the DEAs stated mission in and of itself is counterproductive or not, the fact is they have actually done a reasonable job carving out exemptions for legitimate independent researchers and chemists — it’s the major suppliers who have decided to put blanket policies in place out of sheer convenience that do nothing but hurt the legitimate small scale chemists out there, instead of taking the time to get to know their customers and follow the laws as written.

LabDIRECT - 9-5-2021 at 12:08

I figure I should ask this question in public view for everybody's reference: If I, for example, wanted to buy 1g of potassium permanganate, or 10 of magnesium oxide, would I have to meet an MOQ or pay a minimum lot charge? They are cheap chemicals, and I'm wondering if it is worth the effort on your end.

In my case, I would like to be able to procure a wide array of useful reagents in small quantities (hobby chemistry). I ask only because this can be very labor-intensive for the supplier.

If you don’t mind paying the shipping, we’re happy to special order you whatever small quantities you want! One of the biggest reasons I started this company was seeing tiny quantities of reagents listed for barely any less than quantities 10 times as much. It was just pure greed as far as I could see.

Obviously the smaller quantities can’t be priced exactly linearly- IE half the price for half as much and so on — just due the fact that there are fixed costs that don’t decrease with size like the cost of labor, packaging, labels, shipping to some extent, etc. but we try to get it as close as humanly possible.

Our entire business model has always been based on doing right by our customers first and foremost and never charging more just because everybody else is or because we can. We would rather work a little harder and make a little less with every sale but know that every customer is walking away with a big smile, excited to come back again and again and saying “I wish that’s the way everybody did business”.

So if you see something that’s not listed in the quantity you want, just use the contact us/special order box and we will take care of it manually for you.

LabDIRECT - 9-5-2021 at 12:16

Quote: Originally posted by vano

Hi Richard. Where you live?

Our Warehouse, Lab and Office is located in Old Saybrook, Connecticut, USA.

And like I said before, if anybody is in Connecticut and wants to come visit, talk chemistry/run some fun reactions, etc., just DM me! I’m usually here but give me a heads up before hand so you don’t come by when we’re gone.

LabDIRECT - 9-5-2021 at 12:29

Quote: Originally posted by monolithic

I just checked out his website in more detail. Great to have many of these chemicals available to amateurs but some of these are quite surprising, like dimethyl sulfate and carbon tetrachloride. I would be vetting the hell out of any amateurs that purchased these.

[Edited on 5-9-2021 by monolithic]

Hahaha. Yes. Add Hydrofluoric acid to that list too- When we get into extraordinarily dangerous or toxic chemicals, we do require you sign a waiver and provide some assurances that you have the proper knowledge/education and PPE to use it safely before we can ship.

That said, CCL4 is actually pretty benign as far as these things go. Besides being a bit carcinogenic (and absolute murder on the environment), it’s not actually likely to kill anyone without Darwinian levels of stupidity being involved so we don’t actually require a waiver for it. That said, we only have one overseas partner that stocks it and it can be a headache to order in quantity. We don’t typically have more than a liter or two on hand at a time which is why we only list fairly small quantities.

LabDIRECT - 9-5-2021 at 12:38

Hubba hubba!

I have ordered from you twice so far, and both orders have gone smoothly! I am glad to see you are also offering glassware. Is there any equipment you are also looking to get rid of? Heating mantles, rotovaps, vacuum pumps, etc.?

With COVID still kicking, international orders have been so unreliable. As an American, it's refreshing to see a domestic source of useful reagents that's willing to sell to hobbyists.

I will probably be DMing you soon. You appear to have quite the selection!

Great to hear! I know there’s a couple of Science Mandness guys I’ve talked to that have ordered from us, as well as a couple Youtubers that did some unboxings and whatnot too but good to see you here as well!

We only have Glassware for now but I do have three or four vacuum pumps kicking around here as well as a refrigerator compressor conversion vacuum pump and an aspiratior or two, as well as a ton of rotovap traps, and a few bits of associated Buchi glassware - Flasks, vapor tubes, etc. - DM me or email me and I’ll try and send you some pictures.

Depending on how the glassware goes, we’d definitely like to get into equipment as well.

enlight - 10-5-2021 at 07:53

You seem very knowledgeable! Thank you for taking the time to answer these questions.

zed - 10-5-2021 at 16:33

Ebay pulling ADs?

It is generally because competitors, or people who think they are your competitors, are complaining to Ebay.

Complaining.... in an attempt to screw you up. You could think of it, as industrial espionage.

Less business for you, means more business for them.

earpain - 12-5-2021 at 07:44

I like what you're trying to do here.
As a hobbyist and home R&D researcher for some maybe future ventures, there are some solvents, for example, that recently have become a real pain to get.

Do you price match at all?
There's 1 Ebay vendor and 2 Amazon vendors last I checked that charge $60 for a gallon of dichloromethane.
Which really shouldn't cost anymore than acetone at the hardware store but, eh, such is life.

I made an order, and it was at my door two days later. $60 included shipping. And the product very satisfactory .in terms of purity(re-claimed by re-distilling countless times).

To be honest none of your listed items I would consider to be a good deal.

But I understand how it goes, especially just starting out.

LabDIRECT - 12-5-2021 at 09:07

Quote: Originally posted by zed

Ebay pulling ADs?

It is generally because competitors, or people who think they are your competitors, are complaining to Ebay.

Complaining.... in an attempt to screw you up. You could think of it, as industrial espionage.

Less business for you, means more business for them.

Exactly what I was thinking - according to the ebay research tools, we were by far the top selling for nearly every item - Nitric, Sulfuric, Chloroform, Ether, we were selling 30-40 each per month from the moment we came in. Nobody else's items - that they have been selling continually for YEARS (at jacked up prices) - have ever been pulled.

It really underscores just how sleazy most of these people are. It's not enough to gouge the community for years, they're so greedy that when a competitor comes along with better prices, better service, better products, instead of getting better and lowering their prices to compete, they just lower their standards and pull underhanded stunts to try to keep their monopoly. Sad

arkoma - 12-5-2021 at 09:31

Very good. Alkyl halide synthesis requires suspect chems, as do a few other things. I hope that you under stand my trepidations, LE here in the States is not known for having a sense of either humor or decency.

LabDIRECT - 12-5-2021 at 09:41

Quote: Originally posted by earpain

I like what you're trying to do here.
As a hobbyist and home R&D researcher for some maybe future ventures, there are some solvents, for example, that recently have become a real pain to get.

Do you price match at all?
There's 1 Ebay vendor and 2 Amazon vendors last I checked that charge $60 for a gallon of dichloromethane.
Which really shouldn't cost anymore than acetone at the hardware store but, eh, such is life.

I made an order, and it was at my door two days later. $60 included shipping. And the product very satisfactory .in terms of purity(re-claimed by re-distilling countless times).

To be honest none of your listed items I would consider to be a good deal.

But I understand how it goes, especially just starting out.

Thanks! I really feel strongly that making chemistry accessible to more people is both critically important to the future of science as a whole - and hopefully demystify things enough to help undo the unreasonable fear of everything "chemicals" and chemistry that society has somehow acquired.

But as for price matching, it depends - for DCM, yes! We just acquired a new supplier so the price will be changing to 49.99 per gallon for tech grade. I'm changing the prices today

As for the pricing in general, I'm always happy to hear more about what you're thinking specifically! Our pricing model is to buy in the largest quantities possible and pass the savings on. This obviously means the best sellers are what will see the biggest drop. Take diethyl ether for example - we're 10-20$ cheaper than anyone else.

Also keep in mind that our pricing includes free shipping - everyone else's prices look good until you process through checkout and they tack an extra 20$+ on for fedex. Our shipping costs are typically in the range of 10-15$ per package.

And in addition, we include a QR code for 10% off the full total of future orders in every package so factor that in as well.

And of course you're getting the best product and service possible. But I want this company to be a part of - and to grow and evolve along with - the community, and to be tuned into the needs of the community. I'd love to hear everyone's wish list of reagents - if we can get a better idea of what people need most and what they can live without, we can focus on bigger orders for more popular items, which will lower the prices a LOT.

I'm going to start a new thread about it so be sure to post!

OK I like this guy!

earpain - 12-5-2021 at 11:41

But as for price matching, it depends - for DCM, yes! We just acquired a new supplier so the price will be changing to 49.99 per gallon for tech grade. I'm changing the prices today

As far as my consumer hobbyist tentacles reach, you are now crowned cheapest source of all mighty DCM!
Thank you thank you!
-e
(Our states border, too. Perhaps I'll come say hi once car is repaired)

[Edited on 12-5-2021 by earpain]

LabDIRECT - 16-5-2021 at 08:32

Quote: Originally posted by earpain

But as for price matching, it depends - for DCM, yes! We just acquired a new supplier so the price will be changing to 49.99 per gallon for tech grade. I'm changing the prices today

Hahahah - we shall wear the crown with humble humility. And absolutely! Please do. Anytime you feel like coming down, just send us a message end let us know what day and time works for you and we’ll make it work.

Sorry for any delay getting back to anyone btw, my second coronavirus shot has kicked my ass over the past couple days

[Edited on 16-5-2021 by LabDIRECT]

ChemTalk - 16-5-2021 at 21:03

>> Thanks! I really feel strongly that making chemistry accessible to more people is both critically important to the future of science as a whole

Richard, we want to wish you luck. Making chemistry accessible to more people is a large part of the ChemTalk non-profit mission, so we are really happy whenever we see other people who have similar goals. I'm sure we will be in touch!

monolithic - 17-5-2021 at 10:13

As a follow up, I bought some reagents from LabDIRECT. This was something the company does not normally stock and so it was a custom order. LabDIRECT (Richard) was very responsive and easy to communicate with, and my reagents arrived quickly, securely packed, and at a good price. Will definitely do business with them again.

arkoma - 18-5-2021 at 06:26

gonna say what i told the kids that opened the marijuana dispensary in texarkana--"please keep your T's crossed and I's dotted, we need you in business"

Now could you clarify a finer point for me? WHAT exactly are you required to do, and what am i required to do if say, i wanted several hundred grams of my favorite halogen? KI is a pain in the ass, and it takes a boatload of it (I) to halogenate anything.

enlight - 18-5-2021 at 14:53

21 CFR part 1310.04 (§1310.04) states the following:

Quote:

For listed chemicals for which no thresholds have been established, the size of the transaction is not a factor in determining whether the transaction meets the definition of a regulated transaction as set forth in §1300.02 of this chapter. All such transactions, regardless of size, are subject to recordkeeping and reporting requirements as set forth in this part and notification provisions as set forth in part 1313 of this chapter.

Unfortunately, iodine does not have an established threshold. §1310.08 does make an exception for iodine solutions, but it also establishes a reporting threshold:

Quote:

Domestic and international transactions of Lugol's Solution (consisting of 5 percent iodine and 10 percent potassium iodide in an aqueous solution) in original manufacturer's packaging of one-fluid- ounce (30 milliliters) or less, and no greater than one package per transaction.

If anybody knows of any exceptions for iodine that are not covered in the above articles, let me know.

S.C. Wack - 18-5-2021 at 15:21

WHAT exactly are you required to do, and what am i required to do if say, i wanted several hundred grams of my favorite halogen?

Import, export, and distribution of threshold amounts of list 1 chems requires DEA registration. The seller is required to positively ID the customer and keep records, they must be registered also.

BTW as far as "cartels and mob bosses" goes...it doesn't take much to be considered a cartel or mob boss in some places...the chemical doesn't have to be on any list either.

[Edited on 18-5-2021 by S.C. Wack]

LabDIRECT - 19-5-2021 at 08:17

gonna say what i told the kids that opened the marijuana dispensary in texarkana--"please keep your T's crossed and I's dotted, we need you in business"

Now could you clarify a finer point for me? WHAT exactly are you required to do, and what am i required to do if say, i wanted several hundred grams of my favorite halogen? KI is a pain in the ass, and it takes a boatload of it (I) to halogenate anything.

Sure! I assume you're talking about elemental/prilled Iodine? The DEA manual states that anything under 400g is exempted from reporting unless it's a "suspicious" order. Here's what they say about that:

Quote:

The law, 21 U.S.C. § 830 (b)(1)(A), requires that each regulated person shall report to the Attorney General any regulated transaction involving an extraordinary quantity of a listed chemical, an uncommon method of payment or delivery, or any other circumstance that the regulated person believes may indicate that the listed chemical will be used in violation of the law. (....) When a regulated person suspects that an order may be intended for illicit purposes, good practice requires that every reasonable effort be made to resolve those suspicions. In addition to making the required reports, the transaction should not be completed until the customer is able to eliminate the suspicions. The distributor may have to forego some transactions. When DEA reviews distributor decisions, minor events are not cause for government action. (...)

So if we know you and you're ordering 250g of I2 with, say, HgO and benzene, something that makes it obvious it's for legitimate chemistry, that's clearly not suspicious and we're not required to submit any paperwork for anything under 400g. But if someone we don't know comes along and fills out a special order form as Tweak and says "Hey bro, can you hook me up with 399g I2, a pound of Aluminum Sulfate, and 500g Red Phosphorous? Oh and can I pay with bitcoin and I need you to ship it to a vacant lot under the name John Doe." then we have to submit a report. Appendex E on page 38 of the DEA Chemical Handlers Manual (43 of the PDF) gives a good list of examples of what constitutes a suspicious order.

I couldn't agree more about staying on the right side of the laws and we definitely aren't lackadaisical about it, but the fact is that these exemptions were put in place specifically so people like us are able to continue to do chemistry within the law. The fact that most suppliers treat everyone as guilty until proven innocent isn't because it's the law, it's because it's easier for them - and the fact that the major institutions they do sell to will pay pretty much any price they ask means they can afford to turn away legitimate amateur chemists and independent researchers by default. We believe that the vast majority of customers genuinely have the same passion for science we do and deserve to be treated as such unless they prove otherwise, and we're willing to put in a bit more legwork getting to know our customers and verifying things if it means a stronger independent chemistry community.

Keras - 19-5-2021 at 08:41

Sure! I assume you're talking about elemental/prilled Iodine? The DEA manual states that anything under 400g is exempted from reporting unless it's a "suspicious" order.

Frankly, 400 g of iodine isn't that much. Iodine is quite heavy, so 400g is only about 3 mol. The same molar amount of phosphorus would be 100 g only…

Texium - 19-5-2021 at 08:50

It’s plenty if you typically work on a sub-molar scale

LabDIRECT - 19-5-2021 at 09:10

WHAT exactly are you required to do, and what am i required to do if say, i wanted several hundred grams of my favorite halogen?

You got it. And to clarify, the record keeping requirements are not anything exclusive to the DEA or chemical sales, and there's not really any requirements beyond what is mandated of any business in the US. If you buy a pound of cheddar cheese from Walmart.com, they are required to keep a record of the transaction information on file for x years, and it's the same here. There's no requirement to submit them, etc, or anything beyond filling them away (that doesn't apply to ephedrine, pseudoephedrine, or phenylpropanolamine however - for those you are required to submit a full transaction report monthly regardless of quantity, but we don't sell those obviously.)

Quote:

BTW as far as "cartels and mob bosses" goes...it doesn't take much to be considered a cartel or mob boss in some places...the chemical doesn't have to be on any list either.

That's definitely not wrong - it's definitely possible for someone to act suspiciously enough to raise red flags even if they aren't buying any Listed/Watched items. Again I direct anyone to page 38 (PDF p43) of the DEA Chemical Handlers Manual - the fact that it's up to the discretion of distributers to determine what is and isn't suspicious means that some places will flag anything on the list even if there's no other reason to (or in fact, additional reasons NOT to) believe its actually suspicious. But I feel distributers should always try their best to clear any doubts or questions up and get to understand the customer, what they are trying to do, what they're like, etc. They shouldn't just shut them down and file a report for orders of non listed/watched chemicals as a first reaction. Doing so is just wasting taxpayer resources and in fact, the DEA manual even specifically states: "When DEA reviews distributor decisions, minor events are not cause for government action."

LabDIRECT - 19-5-2021 at 09:30

21 CFR part 1310.04 (§1310.04) states the following:

Quote:

Unfortunately, iodine does not have an established threshold. §1310.08 does make an exception for iodine solutions, but it also establishes a reporting threshold:

Quote:

If anybody knows of any exceptions for iodine that are not covered in the above articles, let me know.

Not sure if that's outdated or what but the DEA's current listings for List II indicates that Iodine (elemental not solution) has a 400g threshold for domestic sale. I attached the relevant table of appendix B.

As far as other exceptions, the big one would be for imports - if it's not a domestic sale, any I2 coming directly from an overseas supplier is not regulated and there is no threshold amount/limit.

We don't sell in over 400g quantities domestically, and while it would technically be legal for us to just dropship from our overseas suppliers, it's enough of a grey area that we feel more comfortable passing anyone with larger orders off to our overseas suppliers directly.

Keras - 19-5-2021 at 10:25

Quote: Originally posted by Texium

It’s plenty if you typically work on a sub-molar scale

I mean, yeah, sure. But don’t expect to fill a big flask of MeI with 400g of I₂. 1 mole MeI ~ 70 mL… so 3 would be 200 mL, and that’s with a 100% yield…

student - 19-5-2021 at 10:56

This discussion of iodine is confusing and surprising the heck out of me!

So much energy here has been poured into, for example, the production of elemental phosphorous on the grounds that it can't be legally purchased in the United States, it being on the DEA List 1 of chemicals. All this time I was lead to believe that List 1 chemicals were treated basically the same as controlled substances, for which sale or possession is a most heinous crime. While it seems contradictory that phosphorous is on legal match boxes and iodine is in legal OTC antiseptic, we also see this craziness in opium poppy seeds legally sold at grocery and hardware stores, while fields for cultivation remain illegal.

So what am I missing here? I thought the difference between list 1 and list 2 is that there is a threshold for purchasing such ubiquitous solvents as acetone (list 2), while there is none for ergotamine (list 1). So what is the difference? I would like to know, because while I could legally buy highly useful PCl3, for example, it would cost many times more than elemental phosphorous, bleach and HCl, and us hobbyists are on a small budget, not making sales.

Quote: Originally posted by Keras

Frankly, 400 g of iodine isn't that much. Iodine is quite heavy, so 400g is only about 3 mol. The same molar amount of phosphorus would be 100 g only…

Even if the limit to buy is 400 grams that would be great, if there is no limit to how many times such an order could be placed. Besides, I use iodine mainly to stain TLC. Do you know how many TLC could be stained with 400 grams of iodine?

enlight - 19-5-2021 at 11:04

One could argue that 21 CFR §1310 is more applicable 21 USC §830, due to the former being an interpretation of the latter by the DEA. It appears that the DEA Chemical Handler's Manual was published in 2004, but the attached CFR entry (revised 04-01-2020) expounds the provisions of 21 USC §830.

The distinction is statutory vs. regulatory and I have no professional experience interpreting either of the two, so I can't attest to which is most applicable.

Along with all this nonsense I've stated, as long as your recordkeeping is hygienic, you should not have an issue

That being said, I would definitely consider taking a close look at the attached document.

Attachment: CFR-2020-title21-vol9-sec1310-04.pdf (249kB)
This file has been downloaded 405 times

S.C. Wack - 19-5-2021 at 15:06

The iodine law was changed almost 14 years ago, it was likely mentioned here...see the Federal Register July 2 2007 pp. 35920-35931 for the final rule and discussion. "Household products such as 2 percent iodine tincture/solution and household disinfectants containing iodine complexes will not be adversely impacted by this regulation. Additionally, the final rule exempts transactions of up to one-fluid ounce (30 ml) of Lugol's Solution."

Keras - 20-5-2021 at 00:51

Quote: Originally posted by student

I don’t take part in the legal discussion since I’m outside the US, as my stubborn use of British English testifies. But yeah, if you use iodine for TLC staining or Grignard initiation, you’re more than fine with 400g. You won’t feel cramped until you start using iodine as a nucleophile.

macckone - 20-5-2021 at 10:05

The confusion revolves around statutory, regulatory and advisory output of agencies.
Statutory is hard and fast, it is law.
However if an agency puts out regulatory and advisory guidance that contradict each other, then the least stringent portion prevails. Ie. you can't tell people to do it one way and then punish them because you put out contradictory information.
Simply keeping credit card and shipping information on file is adequate for non-suspicious transactions.
I am not a lawyer and the DEA may differ in their interpretation but that is my understanding.

paying with a credit card and ordering to a business is not generally suspicious.
paying with bitcoin for local pick up would be suspicious (and not meet ID requirements).

reporting requirements are annually I believe.

LabDIRECT - 21-5-2021 at 18:51

One could argue that 21 CFR §1310 is more applicable 21 USC §830, due to the former being an interpretation of the latter by the DEA. It appears that the DEA Chemical Handler's Manual was published in 2004, but the attached CFR entry (revised 04-01-2020) expounds the provisions of 21 USC §830.

The distinction is statutory vs. regulatory and I have no professional experience interpreting either of the two, so I can't attest to which is most applicable.

Along with all this nonsense I've stated, as long as your recordkeeping is hygienic, you should not have an issue

That being said, I would definitely consider taking a close look at the attached document.

That's the great thing about US law - it's so tangled up in itself, trying to unravel it is a nightmare. According to that document, the info on no-threshold transactions is dated [54 FR 31665, Aug. 1, 1989] but the document seems to be newer than the current DEA Manual... But assuming that DOES supersede the manual, this seems like a very relevant excerpt:

Quote:

§ 1310.05 Reports.
(a)(1) Each regulated person must report to the Special Agent in Charge of
the DEA Divisional Office for the area in which the regulated person making
the report is located any regulated transaction involving an extraordinary
quantity of a listed chemical, an uncommon method of payment or delivery, or any other circumstance that the regulated person believes may indicate that the listed chemical will be used in violation of this part. The regulated person will orally report to the...

So again, that would seem to indicate it's basically left up to the distributor to determine what constitutes an extraordinary/suspicious quantity for no-threshold transactions based off the guide in the manual, with the only requirement for legitimate/non suspicious transactions being record-keeping.

Thank you for the research by the way and I welcome your input. For a small fish in a big pond, every bit of support really goes a long way.

LabDIRECT - 21-5-2021 at 19:48

The iodine law was changed almost 14 years ago, it was likely mentioned here...see the Federal Register July 2 2007 pp. 35920-35931 for the final rule and discussion. "Household products such as 2 percent iodine tincture/solution and household disinfectants containing iodine complexes will not be adversely impacted by this regulation. Additionally, the final rule exempts transactions of up to one-fluid ounce (30 ml) of Lugol's Solution."

The fact that the DEA STILL haven't updated the documentation they point distributers to on their website is hard to wrap my head around - it seems like you're correct however as I pointed out in my last post, by making it a no-threshold item, it leaves it to the distributer to parse the guidelines and determine what is and isn't a suspicious amount. With all the contradicting guidance and documentation, I think ultimately it comes down to "Good Faith". I can't find any examples of the DEA going after a small company that was clearly making a good faith effort towards the spirit of the law.

You can find plenty of laws that have been counterproductive or that have hurt the chemistry community, but as I said before, that's more down to the suppliers' reaction to the laws, not the laws themselves; the DEA has actually done a fairly decent job of carving out exceptions to make room for a healthy chemistry community. They aren't wasting money and manpower trying to hassle individuals who have a passion for thin-layer chromatography or who have a CRISPR kit in their garage. When you read their documentation regarding chemical supply and distribution, as well as the regs themselves, it's pretty clear they're designed to target large-scale illicit cartel chemistry (acetone, MEK, ether, south American country-specific laws, etc), or people who have no passion for science and zero chemistry knowledge trying to brew up kilos of methamphetamine in 2-liter coke bottles (ephedrine, pseudoephedrine, iodine, etc). The section about suspicious orders emphasizes how verifying the customer speaks knowledgeably about the chemistry is an important part of clearing up red flags, which says a lot about their attitude to the community, and to independent researchers and legitimate amateur/hobby chemistry as a whole IMO.

LabDIRECT - 21-5-2021 at 19:51

Quote: Originally posted by macckone

The confusion revolves around statutory, regulatory and advisory output of agencies.
Statutory is hard and fast, it is law.
However if an agency puts out regulatory and advisory guidance that contradict each other, then the least stringent portion prevails. Ie. you can't tell people to do it one way and then punish them because you put out contradictory information.
Simply keeping credit card and shipping information on file is adequate for non-suspicious transactions.
I am not a lawyer and the DEA may differ in their interpretation but that is my understanding.

paying with a credit card and ordering to a business is not generally suspicious.
paying with bitcoin for local pick up would be suspicious (and not meet ID requirements).

reporting requirements are annually I believe.

This. I think you laid it out perfectly.

Texium - 21-5-2021 at 20:31

Richard, it’s really nice to see such a responsive and transparent company that’s willing to support this community! I’m not practicing home chemistry currently, but I’m working on my PhD in a university research lab. Sometimes I have to order chemicals for my project. If we ever need something that you supply, I will try to order it from you first instead of giving more money to Sigma-Aldrich, Fisher, or VWR.

S.C. Wack - 21-5-2021 at 21:12

The fact that the DEA STILL haven't updated the documentation they point distributers to on their website is hard to wrap my head around

It was a one-time thing AFAIK...their budget must not be big enough now...has anyone in the past 10 years (outside of academic publishing) made a pdf that wasn't converted powerpoint slides? The dumbing down, the progressively lower standards, the shoddification of the country would be obvious to anyone of a certain age, if it wasn't for the unawareness black hole which came with that.

The entire part 1310 "records and reports of listed chemicals and certain machines" of a newer 21 CFR has to be read as a single document, to see the forest.

[Edited on 22-5-2021 by S.C. Wack]

Keras - 21-5-2021 at 22:28

The dumbing down, the progressively lower standards, the shoddification of the country would be obvious to anyone of a certain age, if it wasn't for the unawareness black hole which came with that.

Unfortunately, that happens everywhere on this globe, so you'd rather use ‘world’ here.

Hey- and halcyon days are behind us guys… (half-joking, but half only).

[Edited on 22-5-2021 by Keras]

LabDIRECT - 22-5-2021 at 05:27

Quote: Originally posted by Texium

Richard, it’s really nice to see such a responsive and transparent company that’s willing to support this community! I’m not practicing home chemistry currently, but I’m working on my PhD in a university research lab. Sometimes I have to order chemicals for my project. If we ever need something that you supply, I will try to order it from you first instead of giving more money to Sigma-Aldrich, Fisher, or VWR.

Thanks Texium! We feel it's so important to be open and transparent, as well as accessible to the entire community. I know so many people who got into chemistry professionally due to an interest that began here, or reddit, or youtube - if these communities are left to wither, it would be a TREMENDOUS loss for the entire discipline.

Best of luck with the PhD! I'd love to hear your thesis! I've personally been working closely with a few other Doctoral/Masters candidates currently (a few at UConn, one at Virginia Tech and another on the west coast) to supply them with whatever they need their research - the kind words and great feedback we've been getting really gives us the best kind of motivation possible. We love doing whatever we can to support research and education and try to give students and professors whatever discounts we can so be sure to email us before you order and let us know it's you!

LabDIRECT - 22-5-2021 at 05:40