Why We Must Treat Fentanyl as a Chemical Threat — and What Strategic Action Looks Like

For years, fentanyl has been framed almost exclusively as a public health and law-enforcement crisis. That framing is necessary—but no longer sufficient. Illicit fentanyl is not only devastating families and communities; it also presents a national and global security risk that defense, preparedness, and international legal frameworks are only beginning to confront.

A recent interview with a former Department of Defense weapons-of-mass-destruction (WMD) official warned that terrorist groups could one day attempt to aerosolize fentanyl or its analogues, exploiting their extreme potency to cause mass casualties (Just the News). This concern is not speculative. In 2002, Russian security forces used an aerosolized fentanyl-based incapacitating agent during the Moscow theater hostage crisis, resulting in the deaths of approximately 130 hostages. That incident remains a stark reminder of what is technically possible when pharmaceutical-grade compounds are repurposed for hostile use.

What has changed since then is scale, access, and intent. Illicit fentanyl and its precursors are now widely available through global criminal supply chains, inexpensive to manufacture, and potent enough that minuscule quantities can overwhelm emergency response systems. In the hands of asymmetric actors, these characteristics create a dual-use chemical threat that bridges public health, national security, and chemical weapons preparedness.

A Growing Consensus Across Security and Health Communities

This concern is not isolated. A 2019 National Defense University study urged Western governments to modernize chemical weapons and arms-control frameworks to address pharmaceutical-grade compounds like fentanyl, citing their central nervous system effects, extreme potency, and availability (NDU Press). The report warned that existing treaties were not designed with modern synthetic opioids in mind, leaving dangerous legal and policy gaps.

In the United States, this evolving threat perception has already begun to influence policy. The executive branch has designated illicit fentanyl and its precursors as Weapons of Mass Destruction, reframing the issue as more than a narcotics challenge. The designation reflects concern that fentanyl could be weaponized for concentrated, large-scale terror attacks, triggering a whole-of-government response (The White House).

While the issue is controversial, the underlying security concern is real. Fentanyl’s lethality at micro-doses, combined with ease of synthesis and transport, gives it a threat profile that increasingly resembles a chemical weapon when malicious intent is present.

The Role of DoD Nuclear, Chemical, and Biological (NCB) Programs and Policy

Within the Department of Defense, Nuclear, Chemical, and Biological (NCB) programs and policy provide the strategic framework for identifying, assessing, and mitigating threats posed by weapons of mass destruction, including emerging chemical risks. As concerns grow over the potential misuse of highly potent synthetic opioids, NCB policy plays a critical role in evaluating dual-use pharmaceutical compounds through a WMD lens, ensuring they are appropriately considered in deterrence, preparedness, and consequence-management planning. NCB programs integrate threat intelligence, doctrine development, and capability requirements across the Services, enabling coordination between chemical defense, medical countermeasures, detection technologies, and force protection. In the context of fentanyl and related compounds, NCB policy can guide the incorporation of opioid-based threat scenarios into CWMD planning, exercises, and interagency coordination, ensuring DoD remains prepared for non-traditional chemical threats while supporting civilian response partners and international norm-setting efforts.

What Policymakers Must Do Next

Addressing this challenge requires a proactive, layered strategy—one that strengthens deterrence and preparedness without undermining legitimate medical use or addiction treatment.

1. Formal Threat Recognition in Preparedness Frameworks

Agencies such as the Department of Health and Human Services—particularly the Administration for Strategic Preparedness and Response (ASPR)—should formally recognize weaponized synthetic opioids as chemical threat agents for preparedness planning. This step does not restrict medicine; it aligns emergency response, consequence management, and interagency coordination with modern threat realities.

2. Expand Medical Countermeasure (MCM) Investment

The Biomedical Advanced Research and Development Authority (BARDA) should prioritize countermeasures designed for mass-exposure scenarios, not just individual overdoses. This includes:

• Longer-acting and higher-capacity opioid antagonists

• Rapid-deployment formulations for first responders

• Combination therapies for ultra-potent synthetic opioids

• Field-ready diagnostics to distinguish opioid exposure from other chemical agents

• Preparedness at scale is a form of deterrence.

3. Modernize Defense and CWMD Doctrine

The Department of Defense must integrate opioid-based threat scenarios into Chemical Weapons and Materials of Mass Destruction (CWMD) planning, training, and exercises. A pharmaceutical origin should not exempt a substance from chemical defense consideration when intent and scale mirror those of chemical warfare tactics.

4. Invest in Emerging Detection and Deterrence Technologies

• Protecting populations requires more than supply-chain interdiction. Emerging technologies already offer promising capabilities:

• Advanced chemical sensors capable of detecting ultra-low-dose aerosolized toxicants

• AI-enabled environmental monitoring systems to flag anomalous exposure patterns

• Wearable and point-of-care diagnostics for first responders

• Integrated data platforms linking public health surveillance with security intelligence

• Sustained investment in detection, diagnostics, and rapid response is essential to staying ahead of evolving threats.

5. Engage Congress Strategically

While new legislation may not be strictly required, Congress plays a critical role through oversight, appropriations, and report language. Hearings and funding priorities can reinforce interagency coordination and long-term preparedness without politicizing the issue or disrupting legitimate medical practice.

6. Lead International Norms and Treaty Clarification

Finally, the United States should lead at the Organization for the Prohibition of Chemical Weapons (OPCW) to clarify that intentional weaponization of pharmaceutical-grade agents falls within chemical weapons prohibitions. Closing these gray zones strengthens global norms and reduces the risk of misuse by state and non-state actors alike.

Balancing Security and Health

None of this should stigmatize legitimate medical uses of fentanyl, which remains essential for anesthesia, trauma care, and palliative medicine. The distinction must be clear: it is not the substance, but the intent and scale of use, that define the threat.

Our policy frameworks must evolve as rapidly as the threat environment. Treating fentanyl solely as a criminal or supply-chain problem leaves dangerous gaps. Treating it as a potential chemical threat—while preserving medical access—reflects the level of sophistication required to protect both our people and the world.

Preparedness is not panic. It is prudent.