Aaron advises clients on compliance with U.S. and international regulations addressing industrial uses of chemicals that have the potential for diversion for misuse as illegal drugs or as precursors in the illicit manufacture of such drugs.  Examples of his work in this area are provided below. 

Controlled Substances Disposal

For a waste services company, Aaron worked to develop a nationwide program for collection and disposal of unused pharmaceuticals, helping to ensure that it would be consistent with applicable controlled substance rules of the Drug Enforcement Administration (DEA), as well as regulations governing transport of hazardous materials and disposal of hazardous wastes.

Precursor Safeguards

Aaron counsels a variety of manufacturers, importers, and users of chemical products that contain controlled substance precursors (e.g., GBL and MEK) on the potential regulation of such products under U.S. and international rules for ensuring that such chemicals are not diverted to the production of narcotics or psychotropic substances. He has helped clients develop and implement plans for reporting apparent non-compliance to government authorities and correcting the problems in ways that limited any business disruptions.

International Advocacy

For a major high-tech trade association, Aaron helped develop a successful strategy to ensure that the UN Commission on Narcotic Drugs (CND) did not adopt a World Health Organization (WHO) recommendation to list two chemicals that are widely used in industrial applications under Schedule I of the Psychotropic Substances Convention, which would have severely limited or even prohibited continued production and use of the chemicals.