Emerging Dangers from Direct Botulinum Access and Use : Journal of Homeland Security and Emergency Management

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Journal of Homeland Security and Emergency Management

Editor-in-Chief: Renda-Tanali, Irmak, D.Sc.

Managing Editor: McGee, Sibel, Ph.D.

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Emerging Dangers from Direct Botulinum Access and Use

Bryan A. Liang1 / Timothy K. Mackey2 / Kimberly Lovett3

1California Western School of Law, University of California, San Diego

2California Western School of Law, University of California, San Diego

3Kaiser Permanente, UCSD School of Medicine

Citation Information: Journal of Homeland Security and Emergency Management. Volume 9, Issue 1, ISSN (Online) 1547-7355, DOI: 10.1515/1547-7355.1973, May 2012

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Botulinum toxin (BTX-A) is the most deadly substance known. Yet it has clinical applications, particularly cosmetic uses. With the latter’s exploding popularity, unauthorized BTX-A is emerging from suspect sources. In combination with the Internet as a virtually unregulated marketplace, BTX-A is available for direct purchase and use. This represents a safety threat against individuals and civil society. Since extant technology and Internet marketing can easily target individual consumers by changing BTX-A concentration and pose risks for society by scaling up production for terrorist purposes, BTX-A availability is a homeland security threat. To address this, BTX-A should be deemed a controlled substance subjecting it to track-and-trace and other requirements. Simultaneously, this categorization would subject it to federal law requiring Drug Enforcement Agency registration and state licensure for sales. This relatively simple step can be a strategy adopted for other high risk materials and an international approach to limit the availability of potentially harmful materials.

Keywords: botulinum toxin; internet pharmacy; bitoterrorism; homeland security; health law; health policy

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