This blog post examine how List 1 and List 2 chemicals goes beyond simple named substances, also controlling similar chemicals.
Historically Controlled Drug precursors, also known as List 1 and list 2 regulated chemicals in the USA were controlled by naming defined, discrete chemicals. This typically covered fairly common chemicals such as acetone or sulfuric acid, which can be used to manufacture controlled drugs.
More recent years has also seen more specific building blocks and intermediates being included.
However with this the game of “whack a mole” then begins, as the illicit drug trade then switches to other very similar building blocks which then needs to be regulated as DEA List 1 or list 2 regulated chemical to allow authorities to track, identify and disrupt illicit usage.
May 2020 saw the DEA take a new approach to this, introducing chemical family / generic statement controls aimed at defining and controlling all related chemicals to the named DEA List 1 or list 2 regulated chemical, initially for N-phenylpiperidin-4-amine type chemicals
Then in May 2023 piperidone type chemicals were targeting by a chemical class type control as a DEA List 1 chemical.
These types of control have been used for many years to control actual narcotic/psychoactive substances (notably Cannabinoids and Opioids in the USA), but are new to the world of controlled drug precursors.
Most recently, in November 2023 the description of N-phenylpiperidin-4-amine was updated to further expand it to cover all halides.
"N-phenylpiperidin-4-amine, its amides, carbamates, halides and salts are designated as List I chemicals under the United States of America Controlled Substances Act (CSA).”
Visually in chemical notation, this looks like
As you can see it can cover 10,000s of possible chemicals based on N-phenylpiperidin-4-amine, all which are now regulated with reporting and licencing requirements.
This chemical family / generic statement control followed on from an earlier one for 4-piperidone
4-piperidone, its acetals, its amides, its carbamates, its salts and salts of its acetals, its amides, and its carbamates, and any combination thereof, are designated as list I chemicals under the United States of America Controlled Substances Act (CSA).
Visually in chemical notation, this looks like
It’s important to be able to correctly identify if your organization is using, storing, shipping or selling these controlled drug precursor and all other listed ones. The DEA can impose significant fines or prosecute companies and individuals who do not properly report and store these or hold the appropriate licenses.
Controlled Substances Squared, part of compliance hub, allows you to quickly and easily identify all your chemicals that are DEA List 1 and list 2 chemicals, e.g drug precursors, allowing you to ensure maximum compliance.
Its algorithms and database of controlled drugs and precursors are updated weekly to ensure you are always compliant.
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