Establishing baseline criteria for the mitigation of the illegitimate sale of health-related products using the DNS

ABSTRACT

There is no unified framework or accepted set of recommendations concerning the sale of health-related products online, which negatively impacts the most vulnerable populations. We propose the DNS as an avenue for advancing solutions via the broader DNS community, outside ICANN’s remit. The existing mechanisms available to curb malicious action are inconsistent due to a combination of jurisdictional conflicts and a lack of guidelines, and the establishment of baseline criteria would lay the groundwork for regulation and the creation of relevant Trusted Notifiers. The current status quo hinders legitimate online pharmacies while facilitating illegitimate operations. Our scope is limited to legal medicines, focusing on medicines requiring a medical prescription. Making use of the DNS in this manner may be a blunt tool, but it is effective if used in a measured manner to stop threats to human safety. We conclude by proposing that there are recommendations that can be transposed to the online world to help assess actor legitimacy, with the following initial criteria: requirement of a valid prescription; requirement of a licensed pharmacist on staff; clear indication of the country in which the pharmacy is based; and limited dispensing of controlled substances.

KEYWORDS:

• DNS
• DNS abuse
• global health policy
• internet governance
• trusted notifiers

Acknowledgements

This research would not have been possible without the support of the DNS Research Federation, which graciously provided partial funding for this effort. I thank my mentor Ron Andruff for helping me understand the urgency of tackling public health challenges and motivating me to develop solutions. I thank Christiane T. da Silva for being my invaluable co-researcher in several of the papers that led to this study. Finally, I thank the efforts of the GNSO Council’s DNS Abuse Small Team, who worked tirelessly with the community to propose ways to make the Internet a safer place for end users.

Disclosure statement

No potential conflict of interest was reported by the author(s).

Correction Statement

This article has been corrected with minor changes. These changes do not impact the academic content of the article.

Notes

1 Their main functions are: the registration and licensing of products; inspection and licensing for manufacturers and distributors; post-marketing surveillance; the regulation of statements for commercial promotion of products; and the authorisation of clinical trials (Pan American Health Organization 2020).

2 Brazil, China, Mexico, South Africa, India and Nigeria.

3 The USA has its own complex set of regulations for the sale of medicines online centring around its National Association of Boards of Pharmacy (NABP) and the Verified Internet Pharmacy Practice Sites (VIPPS) programme. The NABP is also the operator of the ‘.pharmacy’ generic Top-Level Domain (gTLD). While some of the literature assumes these elements to be a key part of the debate, this research opts to focus instead on a more global perspective.

4 As a complement to that, it has also been estimated that 96% of the world’s preventable deaths (‘amenable mortality’) occur in LMICs (Alkire et al. 2018). The causes of these losses are often correlated with diseases that are preventable and treatable – such as diseases affecting the circulatory and respiratory systems (OECD 2022).

5 Generic Names Supporting Organization.

6 Contracted Party House: those who have direct contractual relationships with the ICANN organisation.

7 Substandard: which fail to meet quality standards, specifications or both; falsified: that deliberately or fraudulently misrepresent their identity, composition or source; unregistered: which are not approved by the national or regional regulatory authority of the market in which they are being sold (Rojas-Cortés 2020).

8 For example, DNS filtering is a different technique that can be employed at the ISP or organisational level, but that is not particularly effective in stopping actors on a global scale.

9 Goncharov (2015) offers the following countries as examples of territories where bulletproof hosts are concentrated: Bolivia, China, Iran, Panama, Lebanon, Luxembourg, Netherlands, Russia, Switzerland and Ukraine.

10 The author is aware of at least one smaller-scale health-related TN in operation as of 2023.

11 Nonadherence is particularly high among the elderly, with practices such as the improper rationing of doses, unfortunately, being commonplace (Briesacher, Gurwitz, and Soumerai 2007; Kleinsinger 2018).

12 OTC substance abuse has been overlooked in spite of it also representing a serious threat to the lives of patients, with medicines such as aspirin, cough syrups, sleep aids, laxatives and antihistamines leading to hospitalisations with alarming frequency (Lessenger and Feinberg 2008; Sansgiry et al. 2016).

Additional information

Funding

This work was supported by DNS Research Federation.