Letter to Mr. Werner Sipp, President, International Narcotics Control Board - Take Action to Regulate Fentanyl

Letter

Dear Mr. Sipp:

We write to urge the International Narcotics Control Board to recommend designating N-Phenethyl-4-piperidinone (NPP) and 4-anilino-N-phenethyl-4-piperidine (ANPP), precursor chemicals of the drug fentanyl, as Table I substances under the United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (the Convention).

As you may be aware, an influx of illicitly manufactured fentanyl, a synthetic opioid that is 50 to 100 times more potent than morphine, has contributed to a serious public health crisis in the United States. According to the U.S. Drug Enforcement Agency (DEA), 47,000 Americans died from drug overdoses in 2013; surpassing automobile crashes as the leading cause of injury death in the United States. While prescription opioids and heroin have served as the foundation of this epidemic, the growing trend of mixing heroin with fentanyl and its analogues have dramatically increased lethality rates among users. The U.S. Centers for Disease Control has reported that in one state alone, from 2014 to 2015, there was a 500 percent increase in fentanyl-related deaths. Over a two-year period, a single fentanyl lab in Mexico was linked to over 1,000 deaths in the United States. Because fentanyl is impossible to detect without advanced scientific laboratory equipment, distributors and users alike are often unaware of its presence in illicit drugs, which has further increased overdose rates.

As a result of recent international efforts to reduce illegal shipments of fentanyl, many traffickers are now seeking its precursors NPP and ANPP directly. The Wall Street Journal recently reported that traffickers often purchase these precursor chemicals from companies in China and, ship them to transnational criminal organizations located in Mexico, who then illicitly manufacture fentanyl on the U.S. border. Most troublingly, the unregulated purchase of NPP and ANPP is perfectly consistent with current international law. The DEA has already made designations relative to NPP and ANPP under U.S. law, which imposes certain licensing and approved use requirements in the United States. However, without collective international action it will be difficult to control international sales of NPP and ANPP, and impossible to slow illicit manufacturing of fentanyl.

We believe that the Convention could be a critical tool in regulating the sale and export of NPP and ANPP, thereby saving lives in the United States. We urge the Board to urgently consider adding these two chemicals to the list of Table I substances when it meets next month in order to help prevent the continued use of fentanyl and its analogues in illegal drug manufacturing.

Thank you again for your consideration of this issue, and for your public service.