A PLEA FOR
WEAPON OF MASS DESTRUCTION DESIGNATION
FOR ILLICITLY MANUFACTURED FENTANYLS:
ADDRESSING A CLEAR AND PRESENT DANGER

The U.S. Government is considering designation of illegal fentanyl as a Weapon of Mass Destruction (WMD). This would enable the Department of Justice, Department of Homeland Security, Drug Enforcement Agency (DEA), Department of Defense and other relevant federal agencies to better coordinate their efforts and immediately publish the necessary administrative directives to eliminate the threat posed by these deadly substances.

Federal Statute (18 U.S. Code § 2332a) states that “any weapon that is designed or intended to cause death or serious bodily injury through the release, dissemination, or impact of toxin or poisonous chemicals, or their precursors” 1 would be defined as a WMD. Illegal fentanyl and its analogues, especially carfentanil, are such toxins, capable of causing mass deaths or biological impairment.

Illegally imported fentanyl seizures in 2018 totaled almost 5,000 lbs., which is more than 1.2 billion lethal doses and enough to kill four times the population of the U.S. In the first six months of 2019, seizures went up 2. In August 2019, law enforcement officers took down a major trafficking conspiracy in Virginia and seized 66 pounds of illegal fentanyl; the DEA confirmed the amount intercepted was enough to kill 14 million people 3. That same month, the Mexican Navy, in cooperation with the U.S., made a seizure of 51,000 lbs. of illegal fentanyl 4; enough to kill 11.5 billion people. The U.S. DEA estimates that less than 10% of all illicit drugs are being captured 5. An EPA report in 2018 indicates that the threat of these quantities to the environment could be devastating 6. The following list compares lethal doses of fentanyl and its more powerful analogue, carfentanil, with the highest-class nerve agent Sarin, which is currently designated as a WMD

Agent
Carfentanil 7
Sarin 8
Fentanyl 9

158 lb. Person: Deadly Dose
.02 mg
50 mg
2 mg

We urge all relevant federal agencies to aggressively confront this threat by naming illegal fentanyl and its analogues Weapons of Mass Destruction.

James Rauh
Families Against Fentanyl

1 https://www.law.cornell.edu/uscode/text/18/2332a
2 https://www.dhs.gov/news/2019/04/24/mcaleenan-through-innovation-partnership-and-prevention-dhs-confronting-opioid
3 http://via.fox8.com/9JWuQ
4 https://www.foxnews.com/media/opioid-crisis-fentanyl-china-mexico-florida
5 https://web.stanford.edu/class/e297c/poverty_prejudice/paradox/htele.html
6 https://www.epa.gov/sites/production/files/2018-07/documents/fentanyl_fact_sheet_ver_7-26-18.pdf
7 https://gandaracenter.org/?s=carfentanil
8 https://www.encyclopedia.com/social-sciences-and-law/law/crime-and-law-enforcement/sarin-gas
9 https://en.wikipedia.org/wiki/Fentanyl

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