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Vulnerabilities

Large-scale methamphetamine production is very dependent on a consistent supply of bulk precursor chemicals such as ephedrine, pseudoephedrine, and P2P. Such supplies are available from companies producing the chemicals in relatively few countries, including China and India. Increased cooperation from these countries and the companies producing the chemicals could greatly disrupt methamphetamine production and availability.

Drug shipments entering the United States are vulnerable to detection and interdiction at POEs. Wholesale seizures at POEs are typically larger than seizures in the interior of the country because loads have not been divided for midlevel or retail distribution. However, DTOs employ spotters to closely monitor the flow of traffic through POEs. These spotters direct load vehicles in real time to specific lanes that they believe will have the highest chance for successful entry into the United States without inspection. Denying spotters clear visibility of the POE lanes through the use of lights or visual barriers would reduce the success of smugglers. Alternatively, implementing a process that would randomly direct vehicles to specific lanes would also deny spotters any advantage.

Seizures of illicit drugs from stash sites along the Southwest Border region result in a much greater loss to Mexican DTOs than seizures that take place after the drugs have been broken into smaller shipments for distribution in retail drug markets. Identifying load vehicles at POEs and then conducting controlled deliveries or simply tracking them to Southwest Border stash sites might be an effective method of detecting such sites and increasing drug seizures.

Domestic drug transportation in commercial tractor-trailers is vulnerable to highway interdiction. Because tractor-trailers typically travel interstates or larger U.S. highways to transport large drug shipments to domestic drug markets, nationally coordinated domestic surge operations to bring about intense and sustained interdiction efforts could increase the amount of drugs seized domestically.

The activities of Mexican DTOs are particularly vulnerable to detection when they attempt to expand drug distribution into new markets. When DTOs expand into new drug markets, they often lack a reliable network of distributors and security personnel in those new markets. As a result, they are more likely to deal with new, unproven local dealers, rendering the organization vulnerable to undercover law enforcement operations.

Highly addictive prescription opioids are primarily acquired by users through doctor-shopping. In states that have implemented comprehensive PDMPs,30 doctor-shopping has decreased. However, many individuals continue to acquire the drugs by simply travelling to doctors in nearby states where there are no such programs. State PDMPs that require nationwide data sharing would curtail the practice of traveling to neighboring states for prescription opioids and would most likely reduce doctor-shopping significantly.

Many prescription drug abusers, especially younger abusers, acquire CPDs through theft from family members or acquaintances who have legitimate prescriptions for the drugs. Often these drugs are unused and unneeded pills prescribed to treat pain for a temporary condition such as recovery from a surgery. Implementing a national incentive program for patients to return unused pills to collection facilities for proper disposal would reduce the diversion and misuse of CPDs (see text box).

Prescription Drug Disposal Programs

Concerns regarding drug diversion and environmental pollution resulting from uncontrolled disposal prompted a flurry of activity at the state, local, and federal levels in 2009. Many state and local law enforcement agencies followed Florida law enforcement's lead by conducting medicine take-back programs. Through these programs, people with leftover medications were encouraged to turn them in to law enforcement officers at specific locations. The take-back programs resulted in the collection of tens of thousands of pounds of prescription drugs. Broward County, Florida, law enforcement officers held the first Operation Medicine Cabinet (OMC) program in 2008. Since then, OMC programs have become increasingly popular and have been held in states such as Georgia, Indiana, Iowa, and New Jersey. Other states have held take-back programs similar to OMC using various names for the programs. Maine established a year-round take-back program using the mail service. The majority of drugs collected at all take-back events are noncontrolled substances, but many of the drugs are CPDs. Quantities of prescription drugs turned in during take-back events include the following:

  • Great Lakes, Earth Day 2009: 4 million pills
  • Illinois, 2008-2009: 90,000+ pounds of pills
  • Iowa, 2008: 1,029 pounds
  • Maine, 2009: 2,123 pounds noncontrolled and 252 pounds CPDs
  • Michigan, 2009: 6,866 noncontrolled pills and 1,483 CPDs (2-week span)
  • New Jersey, 2009: 9,000 pounds (3.5 million pills)
  • Salisbury, North Carolina, 2009: 157 pounds
  • Washington State, 2006-2009: 11,000 pounds
  • Watauga County, North Carolina, 2009: 40,000 pills, 12 gallons of liquid medication

Under the Controlled Substances Act (CSA), ultimate usersa do not have DEA registration numbers permitting them to distribute controlled substances; therefore, users are not permitted to distribute unused drugs even to those officers conducting take-back programs. However, it was determined that current take-back programs could use an exemption from registration that permits law enforcement officers to handle controlled drugs while acting in an official capacity. In early 2009, the DEA Office of Diversion Control began to seek comments on options to CSA amendments addressing individual disposal of patient-owned controlled substances. To amend the CSA, DEA is awaiting congressional action on several related pieces of legislation.

At the federal level, several bills (HR 1191 and companion SB 1336, and HR 1359 and companion SB 1292) were introduced in the House of Representatives in 2009 to amend the CSA. HR 1191 provides for disposal of CPDs through state take-back programs, while HR 1359 permits the consumer to deliver drugs for disposal. HR 1191 also recommended amending the Food, Drug, and Cosmetic Act to prohibit product labeling that proposed flushing of unused prescription drugs. Both bills were referred to the House Committee on Energy and Commerce and the House Committee on the Judiciary in 2009. DOJ has endorsed HR 1359 and SB 1292, since they afford the most flexibility.

At the state level, legislators in Florida, Maine, Minnesota, Oregon, and Washington introduced bills in 2009 that would require drug manufacturers to operate and pay for systems that facilitate the collection, transportation, and disposal of leftover prescription drugs. In California, a senate bill was being considered in 2009 that would require the state's Board of Pharmacy to work with other state agencies, local governments, drug manufacturers, and pharmacies to develop sustainable programs to manage the disposal of prescription drugs.

a. The CSA defines an "ultimate user" as a person who obtains a drug legally and possesses it for his or her own use, for a family member's use, or for use in an animal in the household.

Bulk cash shipments of illicit drug proceeds are at risk of seizure at stash houses in consolidation cities and in transit to and across the Southwest Border. DTOs have developed elaborate countermeasures to minimize this risk, such as choosing unassuming locations, limiting the number of individuals who have knowledge of the stash house sites, and moving bulk cash quickly through stash houses. However, a dedicated investigative team capable of developing and exploiting organizational intelligence in each of the leading bulk cash consolidation cities could result in significant bulk cash seizures in those cities. Moreover, enhanced interdiction efforts and rigorous outbound inspections of vehicles leaving the United States would very likely result in a sharp increase in bulk cash seizures.


Footnote

30. Currently, 40 states either have operating PDMPs or have passed legislation to implement them.


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