PREPARED STATEMENT OF LEE I. DOGOLOFF, ASSOCIATE DIRECTOR, DOMESTIC POLICY STAFF, THE WHITE HOUSE

Mr. Chairman, and members of the Committee, I welcome the opportunity to be here today to discuss Federal activities regarding Phencyclidine, or PCP. We have been concerned about the rising levels of PCP marketing and use for some time, particularly as it could provide a model for the marketing of other cheap, easily made, synthetic drugs.

The issue of PCP was raised last fall in our regular bi-weekly meeting with the heads of the agencies most directly involved in drug abuse prevention and control. The principals group includes the Senior Advisors and Coordinator for International Narcotics Matters to the Secretary of State, the Director of NIDA, the Administrator of DEA, the Commissioner of Customs and the Commandant of the Coast Guard. We established the PCP Action Coordinating Committee under the principals group to develop and coordinate the Federal response to PCP.

The PCP phenomenon presents some unique problems and a Federal response must be carefully calibrated.

PCP is an easily manufactured psychoactive drug, which can induce bizarre behavior, disorientation, and, with chronic use, persistent cognitive and memory problems and psychosis. Some researchers believe that adverse consequences are inevitable with persistent use. PCP can cause death, both directly by overdose, and indirectly through violent behavior and accidents, particularly drowning. PCP-reported deaths have nearly doubled in the past year, as has use in the 12-17 year old age group, which has risen to 5.8 percent. Use by the 18-25 age group has increased by 50 percent to 13.9 percent of the population. These facts are disturbing. Dr. Dorynne Czechowicz from NIDA will give you more details of PCP's pharmacological effects, and current use patterns. Given all of the reports of the negative consequences of PCP use, we have been baffled by the continued high levels of use. In trying to understand why use persists and is widespread, we have learned that although users universally report some negative aspects of use, a number report positive aspects as well. The extreme negative effects do not occur with every use, and are unpredictable. This is a very dangerous situation, in which a young person could use PCP or see his friends use it, with some degree of satisfaction, and only minor negative consequences. He could then be lulled into believing that the drug was not dangerous and disbelieve reports of its extremely negative consequences, only to be affected severely himself at some unknown and unforeseeable future date. Therefore all of us must do all we can to inform the public accurately of these dangers, discourage use and reduce availability.

Through the PCP Action Coordinating Committee, we have been working with the NIDA to implement sensible, comprehensive Federal responses which they will describe to you in some detail, including assessment of the problem, the preparation of educational materials and treatment and prevention programs. PCP also presents a challenge to law enforcement efforts. It is easily manufactured, and its sale can yield enormous profits: about $24,000 on an investment of $500-$1500. On the recommendation of the Coordinating Committee, several actions have been taken.

PCP was moved from Schedule III to Schedule II of the Controlled Substances Act on February 24, 1978. Two of the precursors of PCP, 1-phenylcyclohexylamine and PCC, have also been rescheduled into Schedule II. DEA and HEW are currently investigating several precursors and analogues of PCP.

In addition, the Drug Enforcement Administration is working with chemical manufacturers and distributors to closely scrutinize any unusual orders or purchases of the chemicals and equipment needed to manufacture PCP. This technique is already proving effective in identifying and developing cases involving illicit PCP production.

This voluntary program has contributed significantly to increasing illicit lab seizures, drug removals and arrests.

We also want to ensure that traffickers in PCP get adequate sentences when they are apprehended, and have suggested that the Department of Justice consider means of educating judges as to the dangers of PCP, with the view to ensuring that appropriate sentences are meted out to traffickers.

We have been monitoring the PCP situation closely in the last year. It is available throughout the country, but use is particularly high in New York. I

would like to take a minute to outline what is happening in New York, both to illustrate the complexity of the problem, and to point out what may be disturbing future trends.

New York State has recently completed a secondary school survey, covering the 7th-12th grades, and recorded a PCP use level that is more than twice the national average. Fourteen percent of the respondents reported using PCP at least once, 9 percent used since September 1977, 5 percent in the 30 days prior to the survey, and 1 percent 10 times in the 30 days preceding the survey. Nearly half of the users began their use in 1977/1978, so this is a recent upward trend. These levels of use are alarming.

However, we are told by the prevention and treatment experts in New York that this is not strictly a PCP-use situation. Ninety-nine percent of the young people who used PCP also used other drugs-mainly alcohol and marijuana, but 39 percent reported cocaine.

We are therefore dealing with polydrug users, with a high acceptance of drug use. It could easily prove counterproductive to highlight PCP. Our recommended approach to prevention is non-drug specific; rather we try to develop alternatives to drug use as a way of achieving certain individual and social goals. However, at the same time as avoiding undue publicity, school, health and other officials and parents must be made aware of the characteristics of PCP use, and told what to do if intervention becomes necessary.

New York City has reported a disturbing occurrence-PCP is apparently becoming an acceptable drug to the hard core heroin users. PCP trafficking is increasing in areas where heroin trafficking used to be high and the NYC reports that some of their top 100 heroin violators have switched to dealing in PCP. They use the same brand name distribution system as they used for heroin, and it is sold in glassine envelopes in $5 and $10 bags. Heroin addict clientele appear to be buying PCP as a supplement or substitute for heroin. This is a new phenomenon and will need to be monitored closely. Not only may such use have serious treatment implications, but it is of great concern that sophisticated trafficking organizations are getting into the sale of PCP.

We will be following these developments in the coming months, in order to tailor an appropriate Federal response.

PREPARED STATEMENT OF PETER B. BENSINGER, ADMINISTRATOR, DRUG
ENFORCEMENT ADMINISTRATION, U.S. DEPARTMENT OF JUSTICE

Chairman Wolff; distinguished members of the Select Committee: I appreciate this opportunity to appear before you this morning to relate the Drug Enforcement Administration's perception of the phencyclidine (PCP) situation.

Known by many different names, PCP also masquerades in a variety of forms: it can be found as a powder, tablet, "rock" crystal, in leaf mixtures, and combined with other drugs. Of course, the effects of PCP will vary depending on the amount taken, the method by which it was administered, and the individual who is taking it. Obviously, not all users of phencyclidine have the same reactions with the same intensity. Aside from PCP's well-publicized ability to spark behavioral aberrations, this drug is capable of inducing severe physiological conditions. The simple documented fact is that a massive overdose of PCP can kill. Many PCP users have also died from accidents caused by the strange behavior this drug produces in them.

When PCP first surfaced as a "street drug" in 1967, it was usually misrepresented as THC, the principal psychoactive ingredient in marihuana, or as LSD. By the mid-1970's though, PCP had, in its own right, become a drug of choice. Since then, the abuse of PCP has escalated and continues to rise at alarming rates. The National Institute on Drug Abuse estimates that over seven million people in the United States, primarily young people, have used PCP.

Virtually, the entire illicit supply of PCP is manufactured in clandestine laboratories. This synthesis process is not particularly difficult and can be done by individuals who have only modest technical training. These laboratory operations vary in size and scope from a small quantity of chemicals and a few pieces of glassware in the possession of two juveniles, to a large facility with the production capabilities of a commercial scale which include barrels of chemicals, sophisticated industrial equipment and major distribution networks. Although

there is considerable diversity among the clandestine labs, most that we in DEA encounter have several elements in common:

(1) Rudimentary equipment and facilities.-The workplace typically consists of a kitchen, bathroom, or basement in a residential dwelling, although we have encountered operations housed in industrial buildings. The equipment normally consists of a reaction vessel-frequently a trash can-stirrers, ovens, vacuum filtering equipment, kitchen utensils and a few items of glassware. Little or no safety equipment exists.

(2) Small size of operation.-Typically, the scale of the operation is on the order of a few pounds per batch.

(3) Lack of cleanliness.-The operations employ no quality control and are thus usually dirty. Furthermore, the material they produce is usually not purified to any extent so that reaction by-products and intermediates are usually incorporated into the final product.

Of course, the size and production capability of the operations vary greatly, but the following example will illustrate how a small investment in a lab cạn yield enormous profit.

One kilogram (2.2 pounds) of phencyclidine can be produced with a total outlay of $500 to $1,500. Of this amount, $80 to $150 is required for consumable chemicals. The balance is for equipment which is reusable. At PCP's wholesale price of $700 an ounce, the operator can expect a $24,000 return on his investment of $500 to $1,500.

Because of growing abuse of PCP, in August 1977, I directed the agency to include PCP among the dangerous drugs receiving priority attention and also directed that appropriate measures be taken to reschedule PCP.

The following month a meeting was held to discuss the special problems encountered in investigating clandestine labs and methods available for improving operations. One such operation, which had been conducted for several years by DEA and its predecessor agencies, is the Precursor Liaison Program. The careful monitoring of unusual or suspicious orders for precursors-chemical intermediaries used in the manufacture of a controlled substance-is an important investigative tool. This program is based on liaison with and voluntary cooperation by the chemical industry. DEA field coordinators establish contact with the firms and identify to them the chemicals in which we are interested. The firm is requested to give added scrutiny to purchases of the identified chemicals and to notify the local DEA office in the event of an unusual order. As a result of this September meeting, specific agents in each field office were assigned the responsibility for the Precursor Liaison Program, and the precursors for PCP were made a high priority.

From an enforcement viewpoint, the results of the stepped-up program are encouraging. Several significant points worth noting are:

(1) The number of PCP laboratory seizures during 1977 was 42 per cent higher than the combined totals of the previous two years.

(2) The number of dosage units removed in conjunction with the laboratory seizures was 209 per cent higher.

(3) Total DEA and DEA Task Force removals during 1977 nearly equaled the combined total of the two previous years.

(4) Total DEA and DEA Task Force arrests for PCP were 60 per cent above arrests reported for 1975 and 39 per cent above those reported in 1976. Simply, the numbers of individuals arrested for PCP has nearly doubled.

One such Task Force has been established in our own community. Funded through DEA's Task Force program, the Washington District Office PCP Task Force has been fully operative since January 1, 1978. The area State police departments, county police units, and Metropolitan Police Department, as well as DEA, have officers detailed to this group.

In the 6 months that this Task Force has been operative, they have arrested 20 defendants, seized 8 operating labs of various sizes, 39 firearms, vehicles, and a large amount of PCP and PCC crystal worth in excess of $1.5 million on the street. These labs were all directed towards supplying the Washington, D.C. metropolitan area with PCP. I am pleased to note the success of this interagency endeavor and commend their efforts to you.

The Office of Enforcement is now directing a new program-Special Action Office/PCP to focus exclusively on combating the escalating abuse and manufacture of PCP nationwide. SAO/PCP is an expanded enforcement effort directed toward decreasing the availability of PCP in the United States through the

location and seizure of the source clandestine labs and prosecution of the highest level violators. SAO/PCP draws upon every area of expertise within DEA and also requires the utilization of State and local enforcement agencies. The initial phase of SAO/PCP began June 1, 1978 and will run until October 1, 1978. In order to be able to evaluate the impact of SAO/PCP, the program coordinators developed quantitative criteria based on previous quarters' arrest, lab seizure and drug removal statistics by which to measure their progress. In this fashion, as SAO/PCP is in operation, monthly statistics can be measured against projected figures. It was projected that at the conclusion of this 4-month phase of SAO/PCP: 17 clandestine labs would be seized; 5.1 million dosage units would be removed; 118 significant violators would be arrested.

SAO/PCP, in its first month, has exceeded the anticipated level of enforcement activity: 8 labs were seized (7 operative, 1 inactive); 130,750 dosage units removed via purchase; 2,206,860 dosage units were removed via seizure; 26 individuals have been arrested.

At the same time that the DEA operational and support elements were giving the PCP program added attention, DEA also moved to more tightly control the manufacturing and trafficking of this drug by rescheduling PCP from Schedule III to Schedule II of the Controlled Substances Act.

According to this law, DEA could not place PCP in Schedule I because that Schedule is reserved for drugs and substances without currently accepted medical use in treatment in this country; and PCP does have a legitimate use in veterinary medicine. This rescheduling was effective on February 24, 1978. With PCP on Schedule II, DEA has more control of the storage and distribution of PCP through tighter security and inventory regulations. The rescheduling of PCP will serve as a signal to judges, prosecutors and juries that PCP is a drug of considerable danger and high abuse potential. Significantly, at least 40 State schedules will follow the Federal Government's rescheduling lead.

Following the control of PCP in Schedule II, immediate steps were taken to thwart further clandestine manufacturing. On May 17, 1978, two of the immediate precursors of PCP, phenylcyclohexylamine and PCC (piperidinocyclohexanecarbonitrile), were placed in Schedule II of the Controlled Substances Act. This is the first time that DEA moved to control an immediate precursor. These two precursors would generally be found only in illicit laboratories, since either is a step in the manufacture of PCP from raw material to finished product. In the past, the clandestine lab operators synthesized the manufacture of PCP to a point just short of the actual drug, thus avoiding legal grounds for prosecution for producing PCP. After making certain that they were not under surveillance, the chemists would then complete their work. Control of these substances now allows enforcement action against operators prior to their obtaining the final "marketable" product, PCP.

An analog is a chemical related to a parent chemical that varies only in the substitution of one or more parts of the molecule. The qualitative effects of these variants usually remain essentially the same as that of the parent chemical.

DEA has been aware of the abuse of PCP analogs for about three years. One of the first to appear on the street was TCP (thiophene). Because TCP was manufactured solely by street chemists for abuse purposes, DEA moved to place this analog on Schedule I.

Currently, DEA is pursuing the inclusion of two other analogs, PCE and PHP on Schedule I. From what information is available, PCE and PHP seem to pose the same public health problems as PCP. DEA has taken the initial steps to control these analogs by supplying data to the Food and Drug Administration (FDA) for their medical and scientific evaluation. At present, we are awaiting their scheduling recommendations.

Until these analogs are scheduled as part of the Controlled Substances Act, it is not a Federal offense to manufacture, possess, or distribute these analogs. In fact, we are seeing a surge of these clandestine laboratory cases. From one reported PHP case in 1974, there were 14 reported cases in 1977. I am afraid that the following scenario will become all too familiar to us:

In mid-June 1978, the Michigan State Police assisted by the DEA Detroit Regional Office seized a PCE laboratory, one-half pound of PCE powder, 50,000 dosage units of PCE, several pounds of suspect PCE and an operational 20 stage pill press. Documents seized indicated that the organization planned in tableting 15 million dosage units of PCE in the next month.

In this instance, the defendants can be prosecuted at the State level. Michigan is one of the states that has taken regulatory or legislative action to control PCP analogs.

Although our stepped up enforcement efforts have resulted in a dramatic increase in the number of clandestine laboratory seizures and arrests of violators, our efforts are minimized by the sentencing constraints in present legislation. Therefore, the Drug Enforcement Administration believes that legislation providing for increased criminal penalties for the unauthorized manufacture or distribution or possession of PCP with intent to distribute would be beneficial to the enforcement of the Controlled Substances Act, as would increased penalties for all Schedule II substances. PCP is a non-narcotic in Schedule II, and as such, the maximum sentence is five years imprisonment as well as a fine. Preliminary data indicate that a significant number of PCP violators are being released upon conviction with suspended sentences and probation. And, in fact, the average length of Federal prison sentences imposed in 1977, decreased substantially in PCP cases from the previous year. In 1976, the average length of Federal prison sentences for a PCP defendant was 35.3 months; the following year the average length was only 24.9 months. I believe that the sentencing structure for PCP violators should reflect the emphasis we are placing on the PCP abuse problem.

The following example all too clearly reflects the present sentencing climate: As a result of information voluntarily provided by chemical companies located on the East Coast who are participating in our precursor liaison program, DEA initiated surveillance of chemicals air-freighted to Los Angeles. Approximately 80 agents of our Los Angeles office, as well as agents who were temporarily brought in from our San Diego and San Francisco offices, and about 50 Deputy Sheriffs of the Los Angeles County Sheriff's Office, conducted this surveillance. Based on this two-week effort, 17 search warrants were executed on December 17, 1977. The following seizures were effected: 104.5 pounds of PCP, 869 pounds of PCC (the immediate precursor to PCP), 11 tons of chemicals used in the manufacture of methaqualone, a multi-station tableting press and various laboratory equipment. The seizure was the largest PCP seizure effected to date.

Five defendants were charged with felony counts of conspiracy to manufacture, possession with intent to distribute and aiding and abetting. Two of the defendants cooperated with Federal prosecutors and received probationary sentences. Bearing in mind the seriousness of this case, the United States Attorney in Los Angeles assigned two senior Assistant United States Attorneys to prosecute the three remaining defendants. After a two-week trial, all three were found guilty.

In the case I just cited, only one defendant received a sentence of incarceration and that was for only three years. The other two defendants received probationary sentences.

The concern with the PCP problem demonstrated by the Congress is encouraging. Thank you, Chairman Wolff, for your interest and support in this matter. I look forward to working with the Select Committee on this significant drug problem.

PREPARED STATEMENT OF DORYNNE CZECHOWICZ, M.D., SPECIAL ASSISTANT FOR MEDICAL AND SCIENTIFIC AFFAIRS, NATIONAL INSTITUTE ON DRUG ABUSE

Mr. Chairman and Members of the Committee, I thank you for the opportunity to appear today to discuss phencyclidine (PCP) and the response of the National Institute on Drug Abuse to the increased use of the drug over the last few years and the subsequent rise in the numbers of persons seeking care in our nation's drug abuse treatment centers and hospital emergency rooms because of their PCP use.

THE EXTENT OF PHENCYCLIDINE USE

PCP is now estimated to have been tried by more than 7 million people in the United States and was associated with at least 100 deaths and over 4,000 emergency room visits in 1977. However, it is difficult to specifically determine just how widely PCP is used. The drug is often sold as another substance, is known by a large number of street names, and varies widely in its physical appearance.