DRCNet Response to the
Drug Enforcement Administration
By the late 1980s, traffickers and clandestine laboratory operators discovered the ease with which ephedrine, a primary methamphetamine precursor, could be converted to methamphetamine. When the Chemical Diversion and Trafficking Act imposed controls upon the import, export and distribution of bulk ephedrine powder, drug traffickers switched to the diversion of ephedrine from international commerce and the use of ephedrine tablets, which were exempt under the law. When the Domestic Chemical Diversion Control Act effectively closed the ephedrine loophole in the law, clandestine lab operators switched to the use of pseudoephedrine as their methamphetamine precursor. Pseudoephedrine is a direct substitute for ephedrine for this purpose.
By the early 1990s, Mexican traffickers had become the major source in the U.S. of illicit methamphetamine. The magnitude of their involvement in the international diversion of ephedrine was discovered in 1994, when 3.4 metric tons of the chemical were seized at the Dallas/Ft. Worth airport. As a result of this initial seizure, it was determined that between June 1993 and December 1994, brokers from Switzerland alone supplied Mexican traffickers with at least 70 metric tons of ephedrine. An additional 100 tons are believed to have been diverted in a similar manner from a variety of international sources. This total of 170 tons could yield 136 tons of methamphetamine, which, at today's prices, would potentially generate a profit in excess of $3.2 billion, and would be enough to supply 12.4 million abusers with three 10-milligram doses a day for 365 days a year.
Recent diplomatic efforts undertaken by DEA's Office of Diversion Control with the foreign governments whose industry provides the major sources of raw material for methamphetamine production have virtually eliminated the massive diversion of ephedrine from foreign sources which the Mexicans had instituted. However, traffickers and lab operators continue to find ways to adjust to DEA's diplomatic and legislative initiatives. Now we have begun to see massive diversion of pseudoephedrine to substitute for ephedrine, and tablets containing ephedrine in combination with other substances such as guaifenesin, this time primarily from domestic distributors. Enforcement action recently undertaken against a single company reveals that it distributed approximately 68 metric tons of chemicals sufficient to produce 50 tons of methamphetamine in a single year. It is believed that virtually all of this material was diverted.
This paper provides an overview of DEA's accomplishments in combating clandestine methamphetamine production through chemical control regulatory and enforcement measures, and concludes with a brief discussion of plans for dealing with the traffickers' and clandestine lab operators' latest "adjustment" to these measures.
Gene R. Haislip
Deputy Assistant Administrator
Office of Diversion Control
Drug Enforcement Administration
PRECURSOR CHEMICAL CONTROL IN THE 1990's
Office of Diversion Control
There are two different aspects to DEA's effort to control the chemicals necessary to produce methamphetamine. One is working with foreign counterparts to cut off the supply of methamphetamine precursor chemicals to traffickers; the other is shutting down domestic "rogue" chemical companies which knowingly sell large quantities of the precursors to traffickers. This paper describes the steps that the Office of Diversion Control (OD) has taken in both respects, and the success which has thus far been achieved. This paper concludes with a brief discussion of needs for the future if ultimate success in attacking this particular drug problem is to be realized.
Methamphetamine is a purely synthetic central-nervous-system stimulant of the amphetamine family. Amphetamines were first synthesized in the late nineteenth century by a German scientist; the synthesis of methamphetamine is attributed to a Japanese chemist in 1919. Historically, methamphetamine has had therapeutic uses. It also has been widely abused for its powerful stimulant effects. Amphetamine derivatives, such as methamphetamine, were developed in both oral and intravenous form. They were promoted as nonaddictive. In 1937, amphetamine became available by prescription in tablet form. It was used in the treatment of hyperactive children, Parkinson's disease, depression, and narcolepsy. When narcolepsy patients reported loss of appetite, it was discovered that amphetamines also worked as an anoretic.
Japan was the first country to experience a methamphetamine epidemic. During World War II, large amounts of methamphetamine were produced for use by war-industry factory workers to aid output. Following the war, methamphetamine tablets, of which large quantities remained in store, were vigorously promoted by pharmaceutical companies and large quantities were sold to the Japanese public without prescription. Epidemic intravenous use of the drug soon followed.
Although a prescription was required in the U.S., during the 1950s large quantities of amphetamines were sold by drug companies to bogus companies in care of post office boxes. "Bennies" or pep pills, as they were known, were used for nonmedical purposes by college students, athletes, truckers, and housewives, as well as thousands of veterans returning from the war with amphetamine habits. Use of methamphetamine expanded across the U.S. in this decade as production of the drug increased significantly. Amphetamines were being marketed to treat obesity, narcolepsy, hyperkinesis, and depression, but were being taken primarily to increase energy, decrease the need for sleep, and elevate mood. In the 1960s, doctors in San Francisco began prescribing amphetamine injections for treatment of heroin addiction. Widespread abuse followed as San Francisco pharmacies began selling injectable amphetamines without prescriptions, or with crudely forged prescriptions, or through bogus telephone orders from users posing as doctors. "Script-writers" appeared: physicians who, for the cost of an office visit, would write prescriptions for the drugs. In 1962, federal, state and local law enforcement agencies cracked down; eventually, amphetamine and methamphetamine were controlled under the Drug Abuse Control Act of 1965. Subsequent control in Schedule II of the Controlled Substances Act (CSA) in 1970 placed restrictions, among other things, on the amounts of these drugs produced. Drug companies took their liquid, injectable products off the market, although they remained available to hospitals. In response to this market vacuum, illegal crystal-methamphetamine labs began to appear in the Bay Area (1).
Intravenous methamphetamine abuse in the U.S. became prominent in the late 1960s particularly in the Haight-Ashbury district of San Francisco, where speed, as all amphetamines came to be known, began replacing drugs such as LSD and mescaline in popularity. Public education, massive reduction of federally approved production quotas, and treatment of abusers brought this epidemic under control, although motorcycle gangs, in particular, remained involved in the clandestine production of methamphetamine. During the rise in cocaine and crack abuse in the early 1980s, bikers and "dopers" in rural areas, where cocaine was less plentiful and too expensive, continued to favor "crystal meth" or "crank," which was typically snorted or injected. They produced the drug in crude laboratories via a simple process. Among the general U.S. population, the methamphetamine problem increased steadily. Unlike the earlier epidemic, abusers today are not limited to urban areas, and more women are involved.
Extent of the Problem
The illicit domestic demand for stimulants such as methamphetamine has remained constant for many years. A sharp drop in production and abuse occurred following the implementation of the CDTA in 1989. But within the 1990s, reports of methamphetamine/speed abuse episodes have exceeded those seen in the peak of 1989, according to national Drug Abuse Warning Network data for 1994. In particular regions of the country the problem has been or continues to be more severe. Methamphetamine abuse remains a particularly severe problem in California and other southwestern states, such as Texas and Arizona. In fact, authorities in San Diego and the southern San Francisco Bay area report that methamphetamine is the number one drug of abuse in those locations. In San Diego in 1994, there were nearly 3,000 admissions to publicly-funded treatment programs for methamphetamine abuse, up from fewer than 600 in 1988.
Methamphetamine is abused for its stimulant effects; at therapeutic or slightly higher doses, the drug promotes feelings of euphoria, increased alertness and the perception of improved self-esteem and self-confidence, and feelings of power and importance. And its effects last longer than those produced by cocaine or crack. However, the drug often decreases performance and negatively affects the ability to perform tasks requiring thought and creativity. Ultimately, performance deteriorates due to sleep deprivation. Abusers of methamphetamine typically increase the dosage, as a tolerance to some of its effects, notably the euphoria, develops. Taken at higher levels, the drug may cause nervousness, irritability, and restlessness. With high doses taken chronically, psychotic reactions with paranoid delusions often mistaken for schizophrenia may occur. Methamphetamine is smoked, snorted and injected. Tolerance develops to the euphorigenic effects of methamphetamine, leading to higher and more frequent doses. The abuser may take methamphetamine in "binges" lasting several days with intervals of sleep, also lasting for days, between the binges. Repeated use of methamphetamine rapidly produces strong psychological dependence and a withdrawal syndrome consistent with physical dependence.
During the period 1989-1994, methamphetamine consistently accounted for 80 percent and more of clandestine lab seizures by DEA. Whereas the number of all clandestine lab seizures, including methamphetamine, declined from 1989 to 1993 in reaction to domestic chemical control legislation, since 1993 methamphetamine lab seizures have begun to increase, reflecting the heavy and increasing involvement of Mexican drug traffickers in the production of methamphetamine. Their role is described in greater detail below.
The Switch to Ephedrine/Pseudoephedrine
The earliest clandestine labs used the chemical phenyl-2-propanone, also known as phenylacetone or P2P, to produce methamphetamine. Prior to its control in 1980 in Schedule II as an immediate precursor to amphetamine and methamphetamine (for which it is used by legitimate industry), P2P was freely available. In response to a consistent high number of clandestine amphetamine and methamphetamine lab seizures throughout the 1970s, P2P was placed in Schedule II of the CSA. This scheduling of P2P resulted in a brief decline in the number of clandestine lab seizures. Traffickers adjusted to the scheduling of P2P by switching to production of this chemical from other uncontrolled chemicals. In 1989, DEA embarked upon a broad chemical control program based onlegislative authority. In the meantime, clandestine amphetamine/methamphetamine lab seizures once again increased.
In 1987 the first DEA seizure of a clandestine lab which employed the hydriodic acid/ephedrine reduction method of methamphetamine production occurred. Since then, seizures of labs employing the ephedrine reduction method have far outnumbered those using the P2P method each year; in 1994, it was more than six times as many. This relatively simple, high yield method of producing the drug results in a more potent isomer of methamphetamine. In fact, the stimulant properties of ephedrine have been known for centuries, having first been described by the Chinese over 5,000 years ago (2). Ephedrine is obtained from the ephedra plant, known to the Chinese as mahuang. Ephedrine also is produced via purely synthetic methods. Like ephedrine, for which it can be used as a direct substitute in the clandestine manufacture of methamphetamine, pseudoephedrine can be obtained from the ephedra plant or produced synthetically. Ephedrine is used legitimately as a bronchodilator for asthma, while pseudoephedrine is used as a nasal decongestant. Ephedrine is not produced in the U.S.; however, pseudoephedrine is produced in this country from imported ephedrine, as well as being imported itself. Major producing countries of ephedrine and pseudoephedrine are China, India, Germany and the Czech Republic.
Approximately 48,000 25 mg. ephedrine tablets are required to extract one kilo of pure ephedrine. One kilogram of ephedrine or pseudoephedrine, theoretically, will yield 0.92 kilos of methamphetamine. Actual yield in clandestine labs is typically in the range of 50 to 75 percent.
In 1989, a new clandestinely manufactured drug made from ephedrine, methcathinone or "cat," came to the attention of health and enforcement officials in the upper Michigan peninsula area. This highly addictive methamphetamine analog was, and continues to be, typically manufactured in small batches by individual clandestine lab "cooks." The vast majority of ephedrine used in methcathinone production is obtained from over-the-counter purchases of 25 mg. bottles of 1,000 or less tablets or capsules. Although clandestine cat labs eventually were seized in other areas of the country such as Wisconsin, Illinois, Missouri, and as far away as Washington, cat remains a relatively isolated problem and no involvement by large trafficking or polydrug organizations has yet been found. Methcathinone was placed into Schedule I of the CSA in October 1993.
A New Domestic Tool: The Chemical Diversion and Trafficking Act
A new tool to attack the clandestine methamphetamine production problem became available to DEA in 1988 with the amending of the CSA to include the Chemical Diversion and Trafficking Act (CDTA). The CDTA imposed reporting, record keeping and import/export notification requirements for regulated transactions in controlled chemicals. Under this law, bulk ephedrine became regulated; however, the law exempted over-the-counter ephedrine products such as tablets and capsules which are legally marketed or distributed under the Food, Drug and Cosmetic Act. At the time the CDTA was drafted in the mid-1980s, the widespread use of ephedrine to manufacture methamphetamine had not yet emerged. Under strong pressure from industry involved in the over-the-counter market of this product, the exemption was provided for ephedrine products lawfully marketed under the Food, Drug and Cosmetic Act.
By the late 1980s, however, traffickers and clandestine lab operators had discovered the ease with which ephedrine could be converted to methamphetamine. Bulk ephedrine powder eventually was encountered with greater frequency than P2P in clandestine lab seizures. Both
l-ephedrine and d-pseudoephedrine, which have very similar chemical structures, can be used to produce d-methamphetamine, a more potent version than the dl-methamphetamine produced via the P2P synthesis method. Within a month following enactment of the CDTA and the controls it placed upon ephedrine powder, the first encounter with ephedrine tablets at a clandestine methamphetamine lab seizure occurred. Traffickers had quickly realized that noncontrolled ephedrine tablets could easily be purchased in large quantities for conversion to methamphetamine. At the same time, DEA became aware of a number of mail order distributors aggressively marketing ephedrine tablets in 100 and 1,000-count bottles through ads in national magazines such as Cosmopolitan, High Times and Hustler. These mail order outfits and other retail distributors ostensibly sold the ephedrine tablets as bronchodilators, energy boosters, or diet aids. Criminal prosecution under the CDTA is possible even when exempt tablets are involved if the government can prove that the company sold the product knowing or having reasonable cause to believe that the tablets would be used to illegally manufacture a controlled substance. These distributors routinely disclaimed any knowledge of unlawful conduct, however. It became all too evident that the ephedrine tablet exemption contained in the CDTA provided traffickers a loophole that would have to be closed.
Recognizing that additional authority under the law was required to deal with rogue chemical companies, in addition to closing the ephedrine loophole, OD drafted the Domestic Chemical Diversion Control Act (DCDCA) in 1990. In November 1993 Congress passed the law; it became effective April 16, 1994. Regulations implementing the DCDCA became effective in August 1995. This law requires that all distributors, importers and exporters who distribute List I chemicals register with the DEA, as is required of controlled substances handlers under the CSA. This will allow DEA to deny registration to, or in future, revoke the registration of companies whose actions pose an imminent threat to the public health and safety, without proof of criminal intent. The DCDCA also removes the record keeping and reporting exemption for single entity ephedrine products and requires registration for distributors of these products. The law does not remove the exemption provided for over-the-counter pseudoephedrine products, although it provides a mechanism for dealing with this problem should it become necessary.
Traffickers have again reacted quickly to DEA's actions. There is some evidence of the use of over-the-counter combination products containing ephedrine. Also, clandestine lab operators have searched for other unregulated sources of methamphetamine precursors. This has led to the diversion of pseudoephedrine tablets for the illicit production of methamphetamine. Because of their chemical similarity, the illicit use of either ephedrine or pseudoephedrine yields the same quantity of controlled substance. By 1994, 28 clandestine methamphetamine labs using pseudoephedrine for precursor material were seized by DEA (3). It now appears that many tons of pseudoephedrine tablets are being supplied to the illicit drug traffic by a handful of mail-order distributors.
DEA became aware of the activities of Clifton Pharmaceuticals, an ephedrine/-pseudoephedrine tablet manufacturer located in western Pennsylvania, in early 1995. Clifton also transacted business under the names Nittany Pharmaceutical, Interglow Associates, and Valley Run Pharmaceutical. Import/export declarations being filed by several bulk importers of ephedrine and pseudoephedrine powder showed that massive quantities of ephedrine and pseudoephedrine were being imported into the U.S., and investigation revealed that Clifton Pharmaceuticals was the primary customer of all of these bulk importers. Further investigation quickly revealed that Clifton's primary customers were three mail order firms located in Florida and Kentucky, who were selling tremendous volumes of the two chemicals principally to buyers on the West Coast. The products shipped by these mail order firms were regularly being seized in clandestine laboratories in California and several other western states. In May 1995, a federal search and seizure warrant was executed at Clifton Pharmaceuticals following an undercover purchase of 20 million 60 mg. pseudoephedrine tablets, for which Clifton was paid $180,000. Seized at the plant were ephedrine, pseudoephedrine and phenylpropanolamine powder and tableted drug products which filled five 50-foot tractor trailers. The ephedrine and pseudoephedrine alone totalled 25 metric tons.
In the early 1990s, Nationwide Purveyors, Inc., of Pittsburgh, Pennsylvania, operated as a mail order supplier of ephedrine tablets selling millions of ephedrine 25 mg. tablets annually. An estimated 80 percent of this company's sales were ephedrine tablets, and it was identified as the source of ephedrine tablet supply in numerous DEA clandestine lab seizures throughout the U.S. In June 1992, the corporate officers and other employees of this company were arrested pursuant to a federal indictment returned by a grand jury in San Diego, California. The indictment alleged a conspiracy between the Nationwide defendants and co-conspirators from Southern California to divert approximately 9,000 pounds of ephedrine. In August 1993, the defendants were sentenced following guilty pleas to federal charges of conspiracy to manufacture methamphetamine, illegal distribution of a listed chemical, and money laundering. Sentences ranged from five years probation and 300 hours of community service for one company employee, to 20 years of imprisonment, 10 years supervised probation, and a $100,000 fine imposed on Nationwide's president.
Between October 1993 and May 1994, ephedrine tablets furnished by one Arkansas-based mail order distributor were encountered at several hundred clandestine labs in Arkansas and California. Based on this fact, the owner of the company was federally indicted on charges of money laundering and distribution of a listed chemical knowing that it would be used to manufacture methamphetamine. The owner was documented in undercover tape recordings as having knowledge that the ephedrine tablets he was selling were being used to make illegal drugs. Two million ephedrine tablets were seized at the owner's residence, and another eight to nine million were seized at his warehouse. He was sentenced in March 1995 to 41 months in prison, a $10,000 fine, and two years supervised release after prison.
The Mexican Traffickers
Following implementation of the CDTA, the nature of the methamphetamine traffic and its predominant suppliers changed. Mexican polydrug organizations with connections to Colombian traffickers replaced the outlaw motorcycle gangs as the primary methamphetamine producers, traffickers, and distributors in California and the western U.S. In 1990, shortly after passage of the CDTA, smuggling of precursor chemicals along the U.S./Mexican border increased significantly, reflecting the Mexican traffickers' preference for manufacturing the drug in the U.S. In this way, they avoided the more significant penalties associated with smuggling the final product, methamphetamine, across the border. These traffickers established large scale clandestine laboratories, staffed by previously unemployed or low-wage Mexican immigrants, which are capable of producing an average of 20 to 100 pounds of methamphetamine per process. The labs are typically established in remote locations throughout California, primarily in the southern part of the state (4). In fact, in 1994, California accounted for over 40 percent of all clandestine methamphetamine labs seized nationwide. DEA intelligence indicates that traffickers also are producing methamphetamine in mobile clandestine labs. Although these mobile labs generally have a smaller production capacity than stationary ones, they are a more difficult target for law enforcement.
Not only do Mexican traffickers operate labs in the U.S., but they produce the methamphetamine clandestinely in Mexico and smuggle the drug into the U.S. In their dominance of the U.S. market, these traffickers regard the Mexican/U.S. border as nonexistent, moving methamphetamine and its precursor chemicals in either direction across the border to facilitate their production and distribution needs. Methamphetamine distribution has been expanded by using established heroin, cocaine and marijuana distribution networks (4). The enormous profit involved in the trade of methamphetamine explains the lure of this drug to these traffickers. An investment of $500 in chemicals yields about one pound of methamphetamine, which sells for as much as $12,000 in California, to as much as $18,500 elsewhere in the U.S.
Although Mexican criminal organizations dominate the production and distribution of methamphetamine, other players in this illegal market include Asian gangs in northern California, Washington State, and other Asian groups in British Columbia which have penetrated the U.S. market. Outlaw motorcycle gangs never withdrew from this drug scene entirely, and there are indications that they are increasing the level of their activities.
The International Effort
In March 1994, the U.S. Customs Service at the Dallas/Ft. Worth airport seized 3.4 metric tons of ephedrine which was in transit to Mexico. This was the largest quantity of the chemical seized in the U.S. since passage of the CDTA. It was purely by chance that this ephedrine shipment happened to come within U.S. jurisdiction and thus to the attention of Customs and DEA. Brokered by a Swiss firm, the ephedrine, manufactured by an Indian company, was intended to be shipped from Zurich via Frankfurt to Mexico City. Because of flight scheduling, the ephedrine wound up on a flight which transited Dallas/Ft. Worth airport. It caught the attention of Customs because the proper export documentation was lacking, and the packaging had been visibly altered. It was subsequently determined that some of the information accompanying the shipment was false. It was notable that all of the cardboard drums containing this ephedrine had the manufacturer's labels removed, and the drum lids had been turned inside out and the broker's name concealed with black paint. Four months later, a 2.3 metric ton ephedrine seizure was once again made at the same location. In the fall of 1994, authorities intercepted 6.8 metric tons of the drug at Schipol airport in Amsterdam, which was destined ultimately for Mexico via Guatemala. These ephedrine seizures focused attention on the magnitude of ephedrine diversion by the Mexican organizations, and set in motion an effort to focus international attention on the ephedrine diversion problem and to take action to prevent such diversion.
From the initial discovery of large-scale ephedrine diversion through the Dallas/Ft. Worth airport, and through available shipping documents, DEA investigators documented numerous multi-ton and multi-kilo ephedrine and pseudoephedrine shipments destined for bogus or nonexistent Mexican firms. Many of these chemicals were being produced in the Czech Republic and brokered through Switzerland. It was determined that three Swiss firms were involved in this activity, and Swiss officials were able to confirm that at least 70 tons had been shipped over the past year. In addition, large volumes were originating in India and China and transiting the United Arab Emirates, the Netherlands, Germany, Guatemala, and other Latin American countries. Elaborate schemes to conceal the Mexican sources of funds for these ephedrine and pseudoephedrine purchases led back to all of these countries and even Thailand. It was very clear that the Mexican traffickers had established a virtually unlimited supply of precursor chemicals for their clandestine methamphetamine production.
With the knowledge of the massive scale of ephedrine diversion, and subsequently pseudoephedrine diversion, that was occurring, diplomatic efforts were swiftly undertaken with the exporting and transit countries involved. Close cooperation was developed initially with the Swiss, Czech and Indian governments, and with limited success with the Mexican and Guatemalan governments. It has been determined that as a result of these efforts, during the period March 1994 through May 1995, 19.7 metric tons of ephedrine have either been seized or shipment prevented, resulting in major disruption of the methamphetamine traffic. These 19.7 tons would have produced close to 16 tons of methamphetamine, and would have had a minimum street value of $160 million. But much remains to be done. Unfortunately, traffickers continue today to procure precursor chemicals, facilitated by the activity of unethical brokers.
The U.N. International Narcotics Control Board
An important aspect of the international effort concerning methamphetamine precursors has been the close working relationship that has been established with the U.N.'s International Narcotics Control Board (INCB), and the important contribution the INCB has made by focussing its attention on this problem. The INCB has taken a significant interest in the diversion of methamphetamine precursors. In the summer of 1994, it hosted an international working group on the issue, and the INCB notified competent authorities throughout the world to be aware of the problem. This organization also acts as a central collection point for data regarding ephedrine and pseudoephedrine shipments, which it disseminates worldwide on a timely basis via electronic mail. This support from the INCB has been a significant factor in the outstanding cooperation OD has received from the countries mentioned above.
Needs for the Future
It is evident that battling the diversion of precursors for the illicit production of methamphetamine (and methcathinone) is a difficult and complex task both on the domestic front and internationally. The concerted international effort to curtail and prevent ephedrine and pseudoephedrine diversion have impacted the traffickers' activity. A 25 kg. barrel of ephedrine, selling in the legitimate market for an average of about $1,800, which traffickers were able to procure for $45,000 in mid-1995, reportedly sells in January 1996 for $60,000-$80,000. But as described above, each time legal or regulatory measures have been implemented both federally and by states, traffickers and clandestine lab operators have reacted by seeking alternatives. Success in working with the international community to shut down the unlimited source of ephedrine supply to traffickers has resulted in the massive domestic diversion of pseudoephedrine. OD is aware of several mail order distributors located on the East Coast and in the Midwest that are currently dealing almost exclusively in exempt pseudoephedrine tablets and combination ephedrine tablets, who are shipping massive quantities of the tablets on a weekly basis to recipients on the West Coast. Recently, over-the-counter pseudoephedrine products, containing 30-120 mg. pseudoephedrine and which are currently exempt from the chemical provisions of the Controlled Substances Act, have begun turning up in clandestine laboratory seizures around the country.
On October 31, 1995, DEA published a notice of proposed rulemaking (NPRM) in the Federal Register which proposed the removal of the drug exemption for certain over-the-counter pseudoephedrine products. The NPRM would require registration and record keeping and reporting requirements for business entities at the manufacturer and distributor level. The retail level, such as pharmacies, truck stops and mini-marts, would be exempt from registration for the sale of small quantities for individual medical use. DEA is working closely with the pharmaceutical industry in order to arrive at a solution which does not have negative impact on the availability of pseudoephedrine for legitimate use.
A vital domestic aspect of this drug effort is the need for resources sufficient to fully implement the DCDCA. This law, as described above, will allow DEA to investigate all distributors of ephedrine so that registration may be denied to rogue companies, effectively putting them out of business. DEA was not provided resources for the purpose of implementing this legislation. At present, the Office of Diversion Control does not, therefore, have the resources to conduct in a timely fashion all of the investigations which will be needed as a result of the registration process.
1. Mike Sager, "The Ice Age," Rolling Stone, 8 February 1990, 53-116.
2. Cho, Arthur K., "Ice: A New Dosage Form of an Old Drug," Science, 10 August 1990, 249:631-634.
3. Drug Enforcement Administration, Office of Diversion Control, Drug and Chemical Evaluation Section. 30 March 1995. The Licit and Illicit Utilization of Pseudoephedrine: A Background Paper. Internal DEA document. Washington, D.C.
4. Drug Enforcement Administration, Intelligence Division. March 1995. Mexican Methamphetamine Traffickers: A Growing Domestic Threat. Washington, D.C. (DEA-95026).
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