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PPCPs as Environmental Pollutants Commentary on Illicit Drugs in the Environment

Christian G. Daughton
Chief, Environmental Chemistry Branch, ESD/NERL, Office of Research and Development, Environmental Protection Agency, Las Vegas, NV 89119, USA; e-mail: daughton.christian@epa.gov; 702-798-2207; fax 702-798-2142.
23 October 2001

[Please note that the materials presented below represent the
personal and professional views and opinions of Dr. Christian Daughton.
They do not necessarily reflect those of the U.S. Environmental Protection Agency.]


This discussion further elaborates and extends upon the ideas first presented in the book chapter "Illicit Drugs in Municipal Sewage: Proposed New Non-Intrusive Tool to Heighten Public Awareness of Societal Use of Illicit/Abused Drugs and Their Potential for Ecological Consequences," C.G. Daughton, in Pharmaceuticals and Personal Care Products in the Environment: Scientific and Regulatory Issues, Daughton, C.G. and Jones-Lepp, T. (eds.), Symposium Series 791; American Chemical Society: Washington, D.C., 2001, pp. 348-364 (Chapter 20). [Chapter 20 text]

Illicit (illegal) drugs purportedly have a broad range of profound effects on our society. Their use by multitudes of individuals has untold adverse impacts on human health, their purchase funds the inner-workings of criminal elements, the inability to personally finance addictive habits breeds wide-ranging criminal acts, and their consumption and disposal by untold numbers of users and manufacturers/traffickers leads to environmental consequences that have yet to be fully defined. A more recently recognized dimension of the purchase of both illicit drugs and "drugs of abuse" involves the purchasers' inadvertent support to terrorist organizations because of the substantial income received by terrorist-connected trafficking (which occurs on both the black market and via the open market, as provided by the countless "pharmacies" accessible via the world wide web, e.g., see: "Drugs Online Face Scrutiny," Chem. Eng. News 2001 79 [40], 51-55).

While the wide scope of consequences of the extensive chain of events in illicit drug manufacture and use are fairly well understood, all attempts over the decades to eliminate either the sources or the demand for illicit drugs have proved singularly unsuccessful. Any new approach that has a rational basis deserves consideration. But no sector of our nation's political, social, or scientific communities has succeeded in formulating a new and meaningful proposal that has had any potential for fighting the "war on drugs." Now that the war on drugs can also be directly linked to what is projected to be a very long "war on terrorism" (as a result of the events of 11 September 2001), the need for all potentially viable means of fighting both wars at once would prove extraordinarily valuable.

The original American Chemical Society (ACS) book chapter conceptualized the first approach to have been proposed in decades for educating and informing the public as to the significance of the consumption of illicit drugs and drugs-of-abuse by individual end-users. By doing so, the hope would be to increase public awareness of the major consequences of drug consumption that have received comparatively little exposure, namely: the possibilities for adverse environmental effects, and contributing indirectly to the financial support for international terrorist organizations. Indeed, with regard to the latter, keeping the public "actively engaged" in a long "war on terrorism" is a major sociopolitical concern. The proposed monitoring approach could help in this regard.

While controversial, the book chapter presents a seminal, pioneering approach to improving public education, raising public awareness, and prompting a useful national dialog regarding an emotionally charged debate. The paper offers a rare, creative application of a physical science to address a social issue. The concept presented by the paper grew from the body of work pioneered on the multi-dimensioned, emerging environmental issue of pharmaceutical and personal care products (PPCPs) as environmental pollutants. This background information will not be given here, other than to state that PPCPs (which include illicit drugs) can enter the environment following their use by multitudes of individuals and subsequent excretion/disposal to (and incomplete removal by) sewage treatment systems. Residues of PPCPs in treated sewage effluent (or directly discharged raw sewage) then enter the environment.

Since the time that the "War on Drugs" officially began in the late 1960s (as a more formalized expansion of the pre-existing U.S. policy on controlling certain pharmacologically active substances some 80 years ago), there has been a dramatic lack of objective, hard data around which to base any meaningful discourse. Consequently, this national debate has degenerated into an emotional exchange of rhetoric and vague science, as witnessed by the constant barrage of countless stories on radio, TV, and the printed media.

From the many aspects and issues surrounding the licit pharmaceutical substances as environmental pollutants, this book chapter formulated a unique proposal to use environmental monitoring as a means of collecting definitive data that can directly reflect the collective use of illicit drugs at the community scale. The proposal avoids all the controversy normally associated with invasion of individual privacy, which is a major problem with current data-gathering approaches. The proposed approach guarantees protection of individual privacy (a major problem that biases the long-used paper-survey approaches) while at the same time provides data on collective use of drugs at the community level (strictly defined by the service area of a sewage treatment facility). This approach has the potential to offer meaningful real-time consumption/use data for furtherance of a rational national debate on this emotionally charged issue.

This approach also provides new means to reduce the cost of conventional drug monitoring programs in specific populations. For example, for certain confined communities (such as naval ships and prisons) that have active drug-monitoring programs, testing of community sewage could serve to (1) screen for overall negatives obviating the need for more expensive individual testing at that time, and (2) detect the emergence of new trends in illicit/abused drug use or the excursions of concentrations above trigger values, both necessitating individual testing, but with the added advantage that it would be known in advance that the timing would be optimal for positive detection. In both cases, conventional drug testing programs would be made more effective.

The proposed monitoring approach would also provide environmental scientists key information on potential, bioactive environmental pollutants, and as such would forge a direct linkage between the previously separated realms of human and ecological health. It is also of interest that this work impacts directly the disciplines of social science (and psychology), an area in which ORD and the Agency have been weak with respect to development of science.

The previous Director (General Barry R. McCaffrey) of the White House's Office of National Drug Control Policy (ONDCP) testified before the Senate Judiciary Committee (February 27, 1996) that he saw five aspects of drug control: treatment, prevention, education, enforcement, and interdiction. The approach proposed in this book chapter would greatly enhance the existing efforts with the third aspect (education) and it would also have great potential to aid three of the other aspects (prevention, enforcement, and interdiction). The newly proposed idea promotes a public health approach to the drug problem with a consequent de-emphasis on criminal justice -- a very current desire that many groups are beginning to embrace but for which no ideas up to now have been available to implement.

The chapter is the first publication to address any topic related to illicit drugs in the environment. It breaks new ground in applying the current body of knowledge (on the occurrence of therapeutic drugs in the environment) by opening a window onto what has long been an aspect of society that has proved difficult to accurately assess -- the magnitude and extent of the use of illicit drugs. The chapter pioneers a conceptual research and monitoring proposal that has high potential for helping to accomplish two major goals simultaneously.

First, the proposal is the first creative, innovative approach to be advanced in decades for addressing one the nation's more perplexing social issues -- the seemingly pervasive use of illicit drugs. Second, the proposal would at the same time serve to acquire environmental data (which, up to now, no one has yet contemplated collecting) for a number of highly bioactive classes of potential pollutants. The unique, never-before considered approach would provide objective, scientific data regarding community-wide drug use and manufacturing. The resulting monitoring data would have multiple uses, including:

(i) collection of aquatic occurrence data for a number of highly bioactive chemical classes for which no prior data exist,

(ii) public education and outreach regarding environmental science,

(iii) increasing the accuracy of public knowledge regarding community-wide illicit drug use,

(iv) fostering a science-based social discourse on society's use of illicit drugs,

(v) improving public awareness of how citizens inadvertently support the advancement of terrorism via illegal financial transactions.

The proposed monitoring approach addresses a major human health issue as well as a potential aquatic toxicity issue. The proposal creates a rare linkage between a physical science (environmental analytical chemistry) and social science (determining societal behavior and promoting social discourse) with the main objective being to foster a more meaningful national debate on the long-festering and perplexing issue of illicit drug use and to what degree it pervades and affects our society.

One of the two major objectives of the original proposal was to offer the first truly innovative approach and totally new dimension to the decades-old (and largely unsuccessful) national quest for understanding the overall issue of illicit drug use as well as informing the public on the perceived widespread use and the many purported consequences of illicit/recreational drugs. The second major objective was to advance society's understanding of the intimate, immediate, and inseparable connection between humans and their environment - by documenting the environmental consequences from the personal use of a large class of highly bioactive chemicals usually kept from the immediate view of society at large.

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A New Dimension: Terrorism: The Taliban had even proposed capitalizing on the prospects of increasing opium production as a means of furthering terrorism (see story "Taliban reaps drug profits" by Jerry Seper, The Washington Times, 4 October 2001, accessible at: http://nucnews.net/nucnews/2001nn/0110nn/011004nn.htm#330 Taliban reaps drug profits). Exit EPA Disclaimer

The linkage between drugs and terrorist organizations is widely recognized. See the following links as examples:

Drugs & Terror
http://www.theantidrug.com/drugs_terror/index.html Exit EPA Disclaimer {Important Note: There is much confusion on the web regarding the public service web site "theAntiDrug.com". "TheAntiDrug.com" can be easily confused with the similar URLs "theAntiDrug.org" and "AntiDrug.org", neither of which has any relation to "theAntiDrug.com"}

See the links provided at: "Drugs & Terror: Understanding the Link"
http://www.theantidrug.com/drugs_terror/understanding.html Exit EPA Disclaimer

The United Nations Office for Drug Control and Crime Prevention (ODCCP)
http://www.undcp.org/ Exit EPA Disclaimer

The U.S. government has formally declared that all entities aiding terrorists in any way will be considered as enemies to those countries that do not support terrorism. Financial support to terrorists is included in this stance. A logical (and possibly useful) and natural extension of this stance is that all parties involved in the cultivation, manufacture, trafficking, sale, purchase, or use of illicit drugs could therefore be considered as actively or indirectly aiding terrorist activities. The original proposal for monitoring illicit drug use on a community-wide basis therefore takes on a new dimension by presenting an additional means for combating terrorism.

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Potential Tool for Addressing Inter-Related Multiple National Priorities: A potentially powerful means is now available to accomplish several national priorities, each of which addresses what at first might otherwise seem to be unrelated purposes but which are now intimately intertwined:

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(1) Improving the public's understanding of and appreciation for environmental science. This can be accomplished by documenting the occurrence of high-visibility chemicals (i.e., illicit drugs) in our water supplies and thereby showing the intimate, immediate, and inseparable connection between humans and their environment - through the individual's personal use of chemicals. This work also furthers people's understanding of basic environmental processes (the water cycle is but one of many examples) and the fate and effects of pollutants.

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(2) Advancing the national debate on drug use. By making available to the public for the first time, real-time hard data on the usage of illicit drugs, progress could perhaps be made via a more rational national discussion on the pervasiveness of drugs in society and the purported adverse effects of illicit drugs on a wide spectrum of societal concerns and issues. Implementation of the monitoring proposal on either limited local levels, nationwide, or internationally could provide a radically innovative approach and totally new dimension to the decades-old quest of understanding the overall issue of illicit drug use as well as informing the public on the perceived widespread use, and the many purported consequences, of illicit/recreational drugs. Importantly, a monitoring network would also supply an early-warning capability (currently lacking) where patterns of newly emerging illicit drugs (e.g., "designer" drugs) could be detected. Such a network would also be able to better establish, in near-real time, regional usage patterns and trends (declines and accelerations) in usage of particular drugs so as to better tailor preventative and treatment programs.

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(3) Educating the public on the direct ties between drug use and the "war on terrorism." Personal usage of illicit drugs is the ultimate "symptom" and objective of drug cultivation, manufacture, and trafficking. As such, those involved in any aspect of the drug trade are directly (albeit perhaps inadvertently) aiding the advance of terrorism by way of financial support. This fact provides an additional means of educating the public against illicit drug use, one that does not have to rely on the extremely complex and sometimes convoluted arguments that are traditionally advanced regarding adverse health effects and economic effects (e.g., via increased crime). To a certain extent, fighting terrorism and the age-old "war on drugs" could become one and the same.

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(4) Helping to keep the public focused on the "war on terrorism." A major, ongoing concern for America is whether the public will maintain interest in what will undoubtedly prove to be a very long, protracted effort in fighting terrorism -- a war comprising many largely invisible battles that will garner little interest on the part of the public.

Historically, it is recognized that a durable national focus proves critical to maintaining cohesive national action and resolve. A nationwide monitoring network that reports real-time illicit drug usage at the community level could give the public a continually updated view of success/failure in support of the educational efforts showing that drug use benefits terrorism.

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