Designation of Alpha-Phenylacetoacetonitrile (APAAN), a Precursor Chemical Used in the Illicit Manufacture of Phenylacetone, Methamphetamine, and Amphetamine, as a List I Chemical
2016-12-20
DEA-2016-0019-0003
05:00:00
https://api.regulations.gov/v4/comments/DEA-2016-0019-0003
M. kyle
Graham
As a public health practitioner who does work on drug addiction and treatment, I support the DEAs pending regulation to designate alpha-phenylacetoacetonitrile and its isomers and salts as List I chemicals.Drug abuse and addiction in America has reached such epidemic proportions that the Surgeon General recently released a report titled Facing Addiction in America1. The year 2014 saw 27,100,000 current drug users and 47,055 drug overdose deaths, more than any previous year on record1. As the Surgeon General report so candidly, and correctly, states about drug addiction, the accumulated costs to the individual, the family, and the community are staggering...1. Simply trying to decrease addiction by treating those addicted is not enough. We need to prevent people from becoming addicted in the first place. The best way to achieve this is by decreasing drug supply.Alpha-phenylacetoacetonitrile (APAAN) is a chemical compound that is a non-scheduled precursor chemical pre-precursor to manufacture methamphetamine2. As other precursors around the world become more regulated and harder to supply, APAAN has become the replacement of choice among many criminal organizations2. Currently, APAAN has no recognized legitimate use outside of small quantities used in research and development and laboratory analytical purposes3.  Authorities now believe that traffickers in the Americas are turning to non-scheduled precursor chemicals to manufacture methamphetamine through alternative methods2. In fact, APAAN as a methamphetamine pre-precursor has become so popular that a Google search for alpha-phenylacetoacetonitrile uses returns multiple results on the very first page for how to use APAAN to manufacture phenyl-2-propanone, a precursor for manufacture of methamphetamine. Clearly something has to be done to decrease the illicit supply of APAAN in order to decrease the supply of methamphetamine in the US.The DEAs category of List I chemicals was established by the Chemical Diversion and Trafficking Act in 1988. These laws provide a system of regulatory controls and criminal sanctions to address both domestic and international diversion of important chemicals without interrupting access to chemicals destined for legitimate commerce4. While burdensome regulations can cause harm to the economy, this proposed rule regarding APAAN regulation would carry only minimal economic risks due to the low number of licit uses for APAAN. For those small numbers of institutions and personnel burdened by this regulation, it would be a small price to pay in return for decreasing rates of drug addiction in the US. Criminals and drug traffickers are creative, albeit misguided, people. You only have to look as far as the introduction of the shake and bake method of methamphetamine manufacture to understand how creative some drug manufacturers are. The only way to stay one step ahead of them is being creative ourselves about how to decrease the supply of illicit drugs. A great way to do that is by cutting off their precursors and pre-precursors for their drug manufacturing operations. You cannot make drugs if you do not have any of the ingredients. Its as simple as that.Drug addiction in the US has reached epidemic proportions. It kills people, destroys lives, wrecks families, and burdens society with the costs of increased law enforcement and health care expenditures1. A primary function of government is to protect the health and well-being of its citizens. Therefore the government has a role to play in fighting this battle against this addiction epidemic ravaging large swaths of America. Preventing people from becoming addicted in the first place would be far more effective at achieving this goal than treating people after the fact. In order to do that, the illicit drug supply must be decreased, and restricting the ingredients has been shown to make it harder for drug manufacturers to keep up supply. To that end, and as a public health professional, I support the DEAs proposed regulation to designate alpha-phenylacetoacetonitrile as List I Chemical.