Part 2 discontinued paper-record seal and label

Editorial approval scope: The team checked current source fidelity, scope boundaries, dates, arithmetic, reader usefulness, practical workflow, and general-information limitations.

Current rule checkpoint

Live 42 CFR 2.19(b)(1) requires legally retained discontinued-program paper records to be sealed in envelopes or other containers bearing the prescribed program, legal-authority, and retention-end information. Associated hard-copy media must be sanitized, and a responsible person must hold the records under Part 2 restrictions and destroy them after the period. The HHS fact sheet identifies February 16, 2026 as the compliance date for the amended framework.

The label carries operational facts

Under 42 CFR 2.19(b)(1), use an envelope or other container and identify the program name, citation to the retention authority, and the outside date. Verify that the label matches the record group and current legal calculation.

Seal the complete paper set

Inventory charts, indexes, loose pages, correspondence, billing records, logs, labels, microforms, photographs, fax output, and off-site boxes. Reconcile page or box counts, close gaps, seal the container, and record custodian, location, date, and seal identifier.

Sanitize production media

The rule expressly includes hard-copy media such as printer and facsimile ribbons and drums. Use the § 2.16 outcome of rendering patient-identifying information nonretrievable, with method, operator, date, verification, and exception evidence.

Build the retained-paper inventory first

List record class, patient or batch scope, date range, authoritative source, volume, boxes or envelopes, hard-copy media, legal authority, retention end, holds, owner, location, and responsible person. Reconcile active files, archives, working copies, printouts, labels, printer and fax media, photographs, microforms, and vendor-held paper.

Remove or destroy records that do not belong in the retained batch under another supported disposition path. Avoid sealing miscellaneous office files simply because they share a cabinet or box.

Use the prescribed label accurately

The section 2.19 label identifies the former program, cites the authority requiring retention, and gives a date no later than the applicable end. Populate each element from the approved retention decision. Use a durable, readable label tied to the inventory and container identifier.

Place only the necessary legal and custody information on the exterior. Avoid patient names, diagnoses, service labels, or other details that reveal SUD status. When a broader warehouse label is required, use a neutral code with the protected crosswalk stored separately.

Seal and protect the container

Select an envelope, box, cabinet insert, or other container suitable for volume, weight, duration, movement, and environmental conditions. Use tamper evidence or custody seals proportionate to risk. Record seal identifier, packer, witness or verifier, date, contents, page or file count, destination, and condition.

Control staging, loading, transport, receipt, storage, access, return, and resealing. A sealed box left in an open hallway or uncontrolled warehouse is not secure custody. Keep records away from water, fire, pests, extreme temperature, public view, and unapproved vendors.

Sanitize associated hard-copy media

Identify printer and facsimile ribbons, drums, films, carbon sheets, labels, photographs, microforms, and other media from which paper was produced or that retains an image. Apply the organization's section 2.16 sanitization process to make patient-identifying information non-retrievable.

Document media identifier or batch, method, operator, date, result, verifier, vendor, exception, and certificate. Do not assume replacement or removal from equipment is sanitization.

Govern opening, resealing, and final destruction

Require a documented lawful purpose, identity verification, approval, checkout, time, records accessed, copy control, and return for every opening. Record broken and new seals and reconcile contents. Investigate unexplained seal changes or missing files.

Before the label end date, notify the responsible person, recheck authority and holds, approve destruction, sanitize associated media, preserve proof, and update the inventory. If retention changes, apply a corrected controlled label without obscuring the original history.

Example

Eleven closure containers are inspected. Eight have complete inventory, seal, exact label, authority, retention date, custodian, location, and production-media treatment; three omit the authority citation. Readiness is 8 of 11 containers.

Paper seal-and-label checklist

• inventory exact records, copies, hard-copy media, authority, end date, and holds;
• populate the prescribed former-program, legal-authority, and end-date label;
• keep patient and SUD detail off the exterior and protect any code crosswalk;
• seal, identify, transport, receive, store, and inspect containers securely;
• sanitize printer, fax, photographic, microform, and related media; and
• log every opening and resealing, then destroy promptly after rechecking authority.

Sealing preserves custody; labeling preserves the disposition instruction. Neither replaces secure storage, controlled access, or final sanitization.

Inspect label readability and seal condition during every scheduled archive review.