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may be subject to an
enhancement under §3B1.3 (Abuse of Position of Trust or Use of Special Skill). Certain
professionals often occupy essential positions in drug trafficking schemes. These professionals
include doctors, pilots, boat captains, financiers, bankers, attorneys, chemists, accountants, and
others whose special skill, trade, profession, or position may be used to significantly facilitate the
commission of a drug offense.
Note, however, that if an adjustment from subsection (b)(2)(B) applies, do not apply §3B1.3 (Abuse
of Position of Trust or Use of Special Skill).
9. Trafficking in controlled substances, compounds, or mixtures of unusually high purity may warrant
an upward departure, except in the case of PCP, amphetamine, methamphetamine, or oxycodone for
which the guideline itself provides for the consideration of purity (see the footnote to the Drug
Quantity Table). The purity of the controlled substance, particularly in the case of heroin, may be
relevant in the sentencing process because it is probative of the defendant’s role or position in the
chain of distribution. Since controlled substances are often diluted and combined with other
substances as they pass down the chain of distribution, the fact that a defendant is in possession of
unusually pure narcotics may indicate a prominent role in the criminal enterprise and proximity to
the source of the drugs. As large quantities are normally associated with high purities, this factor
is particularly relevant where smaller quantities are involved.
10. The Commission has used the sentences provided in, and equivalences derived from, the statute (21
U.S.C. § 841(b)(1)), as the primary basis for the guideline sentences. The statute, however, provides
direction only for the more common controlled substances, i.e., heroin, cocaine, PCP,
methamphetamine, fentanyl, LSD and marihuana. The Drug Equivalency Tables set forth below
provide conversion factors for other substances, which the Drug Quantity Table refers to as
"equivalents" of these drugs. For example, one gram of a substance containing oxymorphone, a
Schedule I opiate, is to be treated as the equivalent of five kilograms of marihuana in applying the
Drug Quantity Table.
§2D1.1 GUIDELINES MANUAL November 1, 2005
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The Drug Equivalency Tables also provide a means for combining differing controlled
substances to obtain a single offense level. In each case, convert each of the drugs to its
marihuana equivalent, add the quantities, and look up the total in the Drug Quantity Table to
obtain the combined offense level.
For certain types of controlled substances, the marihuana equivalencies in the Drug
Equivalency Tables are "capped" at specified amounts (e.g., the combined equivalent weight
of all Schedule V controlled substances shall not exceed 999 grams of marihuana). Where
there are controlled substances from more than one schedule (e.g., a quantity of a Schedule IV
substance and a quantity of a Schedule V substance), determine the marihuana equivalency for
each schedule separately (subject to the cap, if any, applicable to that schedule). Then add the
marihuana equivalencies to determine the combined marihuana equivalency (subject to the cap,
if any, applicable to the combined amounts).
Note: Because of the statutory equivalences, the ratios in the Drug Equivalency Tables do not
necessarily reflect dosages based on pharmacological equivalents.
Examples:
a. The defendant is convicted of selling 70 grams of a substance containing PCP (Level 22)
and 250 milligrams of a substance containing LSD (Level 18). The PCP converts to
70 kilograms of marihuana; the LSD converts to 25 kilograms of marihuana. The total
is therefore equivalent to 95 kilograms of marihuana, for which the Drug Quantity Table
provides an offense level of 24.
b. The defendant is convicted of selling 500 grams of marihuana (Level 8) and five
kilograms of diazepam (Level 8). The diazepam, a Schedule IV drug, is equivalent to 625
grams of marihuana. The total, 1.125 kilograms of marihuana, has an offense level of
10 in the Drug Quantity Table.
c. The defendant is convicted of selling 80 grams of cocaine (Level 16) and five kilograms
of marihuana (Level 14). The cocaine is equivalent to 16 kilograms of marihuana. The
total is therefore equivalent to 21 kilograms of marihuana, which has an offense level of
18 in the Drug Quantity Table.
d. The defendant is convicted of selling 56,000 units of a Schedule III substance, 100,000
units of a Schedule IV substance, and 200,000 units of a Schedule V substance. The
marihuana equivalency for the Schedule III substance is 56 kilograms of marihuana
(below the cap of 59.99 kilograms of marihuana set forth as the maximum equivalent
weight for Schedule III substances). The marihuana equivalency for the Schedule IV
substance is subject to a cap of 4.99 kilograms of marihuana set forth as the maximum
equivalent weight for Schedule IV substances (without the cap it would have been
6.25 kilograms). The marihuana equivalency for the Schedule V substance is subject to
the cap of 999 grams of marihuana set forth as the maximum equivalent weight for
Schedule V substances (without the cap it would have been 1.25 kilograms). The
combined equivalent weight, determined by adding together the above amounts, is
subject to the cap of 59.99 kilograms of marihuana set forth as the maximum combined
equivalent weight for Schedule III, IV, and V substances. Without the cap, the combined
equivalent weight would have been 61.99 (56 + 4.99 + .999) kilograms.
November 1, 2005 GUIDELINES MANUAL §2D1.1
– 145 –
DRUG EQUIVALENCY TABLES
Schedule I or II Opiates*
1 gm of Heroin = 1 kg of marihuana
1 gm of Alpha-Methylfentanyl = 10 kg of marihuana
1 gm of Dextromoramide = 670 gm of marihuana
1 gm of Dipipanone = 250 gm of marihuana
1 gm of 3-Methylfentanyl = 10 kg of marihuana
1 gm of 1-Methyl-4-phenyl-4-propionoxypiperidine/MPPP = 700 gm of marihuana
1 gm of 1-(2-Phenylethyl)-4-phenyl-4-acetyloxypiperidine/
PEPAP = 700 gm of marihuana
1 gm of Alphaprodine = 100 gm of marihuana
1 gm of Fentanyl (N-phenyl-N-[1-(2-phenylethyl)-4-
piperidinyl] Propanamide) = 2.5 kg of marihuana
1 gm of Hydromorphone/Dihydromorphinone = 2.5 kg of marihuana
1 gm of Levorphanol = 2.5 kg of marihuana
1 gm of Meperidine/Pethidine = 50 gm of marihuana
1 gm of Methadone = 500 gm of marihuana
1 gm of 6-Monoacetylmorphine = 1 kg of marihuana
1 gm of Morphine = 500 gm of marihuana
1 gm of Oxycodone (actual) = 6700 gm of marihuana
1 gm of Oxymorphone = 5 kg of marihuana
1 gm of Racemorphan = 800 gm of marihuana
1 gm of Codeine = 80 gm of marihuana
1 gm of Dextropropoxyphene/Propoxyphene-Bulk = 50 gm of marihuana
1 gm of Ethylmorphine = 165 gm of marihuana
1 gm of Hydrocodone/Dihydrocodeinone = 500 gm of marihuana
1 gm of Mixed Alkaloids of Opium/Papaveretum = 250 gm of marihuana
1 gm of Opium = 50 gm of marihuana
1 gm of Levo-alpha-acetylmethadol (LAAM)= 3 kg of marihuana
*Provided, that the minimum offense level from the Drug Quantity Table for any of these controlled substances
individually, or in combination with another controlled substance, is level 12.
Cocaine and Other Schedule I and II Stimulants (and their immediate precursors)*
1 gm of Cocaine = 200 gm of marihuana
1 gm of N-Ethylamphetamine = 80 gm of marihuana
1 gm of Fenethylline = 40 gm of marihuana
1 gm of Amphetamine = 2 kg of marihuana
1 gm of Amphetamine (Actual) = 20 kg of marihuana
1 gm of Methamphetamine = 2 kg of marihuana
1 gm of Methamphetamine (Actual) = 20 kg of marihuana
1 gm of "Ice" = 20 kg of marihuana
§2D1.1 GUIDELINES MANUAL November 1, 2005
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1 gm of Khat = .01 gm of marihuana
1 gm of 4-Methylaminorex ("Euphoria")= 100 gm of marihuana
1 gm of Methylphenidate (Ritalin)= 100 gm of marihuana
1 gm of Phenmetrazine = 80 gm of marihuana
1 gm Phenylacetone/P2P (when possessed for the purpose
of manufacturing methamphetamine) = 416 gm of marihuana
1 gm Phenylacetone/P2P (in any other case) = 75 gm of marihuana
1 gm of Cocaine Base ("Crack") = 20 kg of marihuana
1 gm of Aminorex = 100 gm of marihuana
1 gm of Methcathinone = 380 gm of marihuana
1 gm of N-N-Dimethylamphetamine = 40 gm of marihuana
*Provided, that the minimum offense level from the Drug Quantity Table for any of these controlled substances
individually, or in combination with another controlled substance, is level 12.
LSD, PCP, and Other Schedule I and II Hallucinogens (and their immediate precursors)*
1 gm of Bufotenine = 70 gm of marihuana
1 gm of D-Lysergic Acid Diethylamide/Lysergide/LSD = 100 kg of marihuana
1 gm of Diethyltryptamine/DET = 80 gm of marihuana
1 gm of Dimethyltryptamine/DMT = 100 gm of marihuana
1 gm of Mescaline = 10 gm of marihuana
1 gm of Mushrooms containing Psilocin and/or
Psilocybin (Dry) = 1 gm of marihuana
1 gm of Mushrooms containing Psilocin and/or
Psilocybin (Wet) = 0.1 gm of marihuana
1 gm of Peyote (Dry) = 0.5 gm of marihuana
1 gm of Peyote (Wet) = 0.05 gm of marihuana
1 gm of Phencyclidine/PCP = 1 kg of marihuana
1 gm of Phencyclidine (actual) /PCP (actual) = 10 kg of marihuana
1 gm of Psilocin = 500 gm of marihuana
1 gm of Psilocybin = 500 gm of marihuana
1 gm of Pyrrolidine Analog of Phencyclidine/PHP = 1 kg of marihuana
1 gm of Thiophene Analog of Phencyclidine/TCP = 1 kg of marihuana
1 gm of 4-Bromo-2,5-Dimethoxyamphetamine/DOB = 2.5 kg of marihuana
1 gm of 2,5-Dimethoxy-4-methylamphetamine/DOM = 1.67 kg of marihuana
1 gm of 3,4-Methylenedioxyamphetamine/MDA = 500 gm of marihuana
1 gm of 3,4-Methylenedioxymethamphetamine/MDMA = 500 gm of marihuana
1 gm of 3,4-Methylenedioxy-N-ethylamphetamine/MDEA= 500 gm of marihuana
1 gm of Paramethoxymethamphetamine/PMA = 500 gm of marihuana
1 gm of 1-Piperidinocyclohexanecarbonitrile/PCC = 680 gm of marihuana
1 gm of N-ethyl-1-phenylcyclohexylamine (PCE) = 1 kg of marihuana
*Provided, that the minimum offense level from the Drug Quantity Table for any of these controlled substances
individually, or in combination with another controlled substance, is level 12.
Schedule I Marihuana
November 1, 2005 GUIDELINES MANUAL §2D1.1
– 147 –
1 gm of Marihuana/Cannabis, granulated, powdered, etc. = 1 gm of marihuana
1 gm of Hashish Oil = 50 gm of marihuana
1 gm of Cannabis Resin or Hashish = 5 gm of marihuana
1 gm of Tetrahydrocannabinol, Organic = 167 gm of marihuana
1 gm of Tetrahydrocannabinol, Synthetic = 167 gm of marihuana
Flunitrazepam **
1 unit of Flunitrazepam = 16 gm of marihuana
**Provided, that the minimum offense level from the Drug Quantity Table for flunitrazepam individually, or in
combination with any Schedule I or II depressants, Schedule III substances, Schedule IV substances, and Schedule V
substances is level 8.
Schedule I or II Depressants (except gamma-hydroxybutyric acid)
1 unit of a Schedule I or II Depressant
(except gamma-hydroxybutyric acid) = 1 gm of marihuana
Gamma-hydroxybutyric Acid
1 ml of gamma-hydroxybutyric acid = 8.8 gm of marihuana
Schedule III Substances***
1 unit of a Schedule III Substance = 1 gm of marihuana
***Provided, that the combined equivalent weight of all Schedule III substances, Schedule IV substances (except
flunitrazepam), and Schedule V substances shall not exceed 59.99 kilograms of marihuana.
Schedule IV Substances (except flunitrazepam)****
1 unit of a Schedule IV Substance
(except Flunitrazepam)= 0.0625 gm of marihuana
****Provided, that the combined equivalent weight of all Schedule IV (except flunitrazepam) and V substances shall not
exceed 4.99 kilograms of marihuana.
Schedule V Substances*****
§2D1.1 GUIDELINES MANUAL November 1, 2005
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1 unit of a Schedule V Substance = 0.00625 gm of marihuana
*****Provided, that the combined equivalent weight of Schedule V substances shall not exceed 999 grams of marihuana.
List I Chemicals (relating to the manufacture of amphetamine or methamphetamine )******
1 gm of Ephedrine = 10 kg of marihuana
1 gm of Phenylpropanolamine = 10 kg of marihuana
1 gm of Pseudoephedrine = 10 kg of marihuana
******Provided, that in a case involving ephedrine, pseudoephedrine, or phenylpropanolamine tablets, use the weight
of the ephedrine, pseudoephedrine, or phenylpropanolamine contained in the tablets, not the weight of the entire tablets,
in calculating the base offense level.
To facilitate conversions to drug equivalencies, the following table is provided:
MEASUREMENT CONVERSION TABLE
1 oz = 28.35 gm
1 lb = 453.6 gm
1 lb = 0.4536 kg
1 gal = 3.785 liters
1 qt = 0.946 liters
1 gm = 1 ml (liquid)
1 liter = 1,000 ml
1 kg = 1,000 gm
1 gm = 1,000 mg
1 grain = 64.8 mg.
11. If the number of doses, pills, or capsules but not the weight of the controlled substance is
known, multiply the number of doses, pills, or capsules by the typical weight per dose in the
table below to estimate the total weight of the controlled substance (e.g., 100 doses of
Mescaline at 500 mg per dose = 50 gms of mescaline). The Typical Weight Per Unit Table,
prepared from information provided by the Drug Enforcement Administration, displays the
typical weight per dose, pill, or capsule for certain controlled substances. Do not use this table
if any more reliable estimate of the total weight is available from case-specific information.
TYPICAL WEIGHT PER UNIT (DOSE, PILL, OR CAPSULE) TABLE
Hallucinogens
MDA 250 mg
MDMA 250 mg
Mescaline 500 mg
PCP* 5 mg
Peyote (dry) 12 gm
November 1, 2005 GUIDELINES MANUAL §2D1.1
– 149 –
Peyote (wet) 120 gm
Psilocin* 10 mg
Psilocybe mushrooms (dry) 5 gm
Psilocybe mushrooms (wet) 50 gm
Psilocybin* 10 mg
2,5-Dimethoxy-4-methylamphetamine (STP, DOM)* 3 mg
Marihuana
1 marihuana cigarette 0.5 gm
Stimulants
Amphetamine* 10 mg
Methamphetamine* 5 mg
Phenmetrazine (Preludin)* 75 mg
*For controlled substances marked with an asterisk, the weight per unit shown is the weight
of the actual controlled substance, and not generally the weight of the mixture or substance
containing the controlled substance. Therefore, use of this table provides a very conservative
estimate of the total weight.
12. Types and quantities of drugs not specified in the count of conviction may be considered in
determining the offense level. See §1B1.3(a)(2) (Relevant Conduct). Where there is no drug
seizure or the amount seized does not reflect the scale of the offense, the court shall
approximate the quantity of the controlled substance. In making this determination, the court
may consider, for example, the price generally obtained for the controlled substance, financial
or other records, similar transactions in controlled substances by the defendant, and the size
or capability of any laboratory involved.
If the offense involved both a substantive drug offense and an attempt or conspiracy (e.g., sale
of five grams of heroin and an attempt to sell an additional ten grams of heroin), the total
quantity involved shall be aggregated to determine the scale of the offense.
In an offense involving an agreement to sell a controlled substance, the agreed-upon quantity
of the controlled substance shall be used to determine the offense level unless the sale is
completed and the amount delivered more accurately reflects the scale of the offense. For
example, a defendant agrees to sell 500 grams of cocaine, the transaction is completed by the
delivery of the controlled substance - actually 480 grams of cocaine, and no further delivery
is scheduled. In this example, the amount delivered more accurately reflects the scale of the
offense. In contrast, in a reverse sting, the agreed-upon quantity of the controlled substance
would more accurately reflect the scale of the offense because the amount actually delivered
is controlled by the government, not by the defendant. If, however, the defendant establishes
that the defendant did not intend to provide or purchase, or was not reasonably capable of
providing or purchasing, the agreed-upon quantity of the controlled substance, the court shall
exclude from the offense level determination the amount of controlled substance that the
defendant establishes that the defendant did not intend to provide or purchase or was not
§2D1.1 GUIDELINES MANUAL November 1, 2005
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reasonably capable of providing or purchasing.
13. Certain pharmaceutical preparations are classified as Schedule III, IV, or V controlled
substances by the Drug Enforcement Administration under 21 C.F.R. § 1308.13-15 even though
they contain a small amount of a Schedule I or II controlled substance. For example, Tylenol
3 is classified as a Schedule III controlled substance even though it contains a small
amount of codeine, a Schedule II opiate. For the purposes of the guidelines, the classification
of the controlled substance under 21 C.F.R. § 1308.13-15 is the appropriate classification.
14. If, in a reverse sting (an operation in which a government agent sells or negotiates to sell a
controlled substance to a defendant), the court finds that the government agent set a price for
the controlled substance that was substantially below the market value of the controlled
substance, thereby leading to the defendant’s purchase of a significantly greater quantity of the
controlled substance than his available re
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