The U.S. Department of Homeland Security (DHS) is weighing designating fentanyl as a “weapon of mass destruction” (WMD). The deadly synthetic opioid mainly originates in China and is the top driver of the unprecedented number of fatal drug overdoses in the United States, an internal memo obtained by Task & Purpose revealed this week.

Several experts as well as current and former U.S. officials, including some from DHS, have repeatedly warned that terrorists could potentially weaponize fentanyl — 118 pounds of which is reportedly enough to kill 25 million people.

“A little as two to three milligrams of fentanyl can induce respiratory depression, respiratory arrest, and possibly death. And some fentanyl analogues such as carfentanil are orders of magnitude more potent,” the February 22 memo from James McDonnell, the assistant secretary at DHS for countering weapons of mass destruction, noted.

McDonnell wrote that there is “a general consensus” among national security and military officials “that fentanyl, in certain configurations, has properties that make it a chemical with the potential for mass casualty effects.”

“Within the past couple years, there has been a reinvigorated interest in addressing fentanyl and its analogues as WMD materials due to the ongoing opioid crisis,” he added, referring to the drug overdoses that have killed tens of thousands in recent years.

The Trump administration would deem fentanyl a WMD “when certain criteria” related to the quantity and configuration of the drug “are met,” McDonnell wrote in the document, titled “Use of counter-WMD authorities to combat fentanyl.”

Some configurations are more lethal than others. McDonnell prepared the memo for then-DHS Secretary Kirstjen Nielsen, stressing:

Fentanyl’s high toxicity and increasing availability are attractive to threat actors seeking nonconventional materials for a chemical weapons attack. In July 2018, the FBI Weapons of Mass Destruction Directorate assessed that “…fentanyl is very likely a viable option for a chemical weapon attack by extremists or criminals.”

McDonnell noted that his office could assist DHS in combating fentanyl trafficking by managing and developing new technologies, deploying sensors, and assisting authorities in the field.

He asserted that senior leaders in the U.S. Department of Defense (DOD), such as Navy Adm. Craig Faller, commander of U.S. Southern Command (SOCOM), had “proposed formally designating fentanyl as a WMD material.”

In its latest annual summary of its activities provided to Congress earlier this year, SOUTHCOM expressed concern about the flow of fentanyl into the United States.

American officials believe the synthetic drug primarily originates in China and to a lesser extent Latin America where traffickers are known to get the precursor chemicals from the Asian giant.

SOUTHCOM, which oversees U.S. military activity in most of Latin America and the Caribbean, reported in its annual summary:

In addition to cocaine, traffickers also transport heroin, synthetic opioids like fentanyl, and precursor chemicals from China. While Mexico remains the primary source for heroin smuggled into the U.S. (and China the prime source of fentanyl), the Dominican Republic is emerging as a regional transit point for opioid trafficking into major U.S. cities like Philadelphia, Boston, and Miami.

U.S. Secretary of State Mike Pompeo recently told lawmakers that Chinese Communist Party leader Xi Jinping has failed to keep his promise to Trump that his administration will stop the flow of Chinese fentanyl into the United States.

Task & Purpose acknowledged that DHS and SOUTHCOM did not respond to requests for comment on the memo.

Other DHS officials have warned that in the wrong hands, synthetic opioids such as fentanyl can be an effective weapon capable of killing millions.

Referring to Carfentanil, a deadly synthetic opioid drug believed to be a hundred times more toxic than fentanyl, Peter Ostrovsky, then the assistant special agent in charge of Homeland Security Investigations at the U.S. Immigration and Customs Enforcement (ICE) agency, said in 2016, “Could it be weaponized? Yeah, it could be weaponized.”

“We don’t have any information that’s indicating to us that [carfentanil] will be weaponized. But just let your imagination run wild, and you can see that somebody could use it as a weapon,” he added, according to Global News.

ICE is a component of DHS.

In March 2018, Sen. Tom Cotton (R-AR), echoing other lawmakers, proclaimed fentanyl is “as much a weapon of mass destruction as it is a drug.”

Moreover, Daniel Gerstein, a senior policy researcher at Rand Corp. who served as acting undersecretary in the DHS Science and Technology Directorate during the previous administration, indicated to Bloomberg News this year that fentanyl can be used as “as a tool of terror.”

Josh Bloom, a senior director of chemical and pharmaceutical research at the American Council on Science and Health, added, “If ground-up fentanyl is placed on everyday objects, people could easily put their fingers in their mouths or rub their eyes and have a deadly reaction.”

Fentanyl is “a significant threat to national security,” Michael Morell, a former acting CIA director under former President Barack Obama, wrote in 2017. “It is a weapon of mass destruction.”

Despite the warnings from several independent and government officials, some officials believed designating fentanyl as a WMD is unnecessary.

“This is like declaring ecstasy as a WMD,” a member of the Pentagon’s counter-WMD community, told Task & Purpose on condition of anonymity.

Unlike ecstasy, however, fentanyl is the primary cause of fatal drug overdoses in the United States that in 2017 proved to be more lethal than terrorist attacks across the world during that same period, Breitbart News determined.

According to the latest data from the U.S. Centers for Disease Control and Prevention (CDC), opioids alone, including heroin (15,950) and synthetic drugs like fentanyl (29,418) killed more people (about 49,000) than terrorist attacks (26,400 fatalities) across the globe in 2017.

Overall, overdoses killed an unprecedented 72,287 people in the United States in 2017, prompting the life expectancy rate to drop in the United States.

Trump’s National Security Strategy (NSS) deemed Chinese fentanyl traffickers a top homeland security threat to the United States for killing “tens of thousands of Americans each year.”

President Trump has also declared a public health emergency over the number of fatal drug overdoses and has increased funding to combat the menace.

U.S. authorities believe fentanyl is 50 times stronger than heroin.