Dear Members of the Virginia Board of Pharmacy,

I strongly advocate for the immediate classification of kratom as a Schedule I controlled substance in Virginia. This recommendation is based on substantial evidence highlighting kratom's severe health risks, potential for abuse, and the alarming rise in related fatalities and medical incidents.

1. Significant Increase in Mortality Rates:
Recent data from the Centers for Disease Control and Prevention (CDC) report an alarming surge in deaths associated with kratom, totaling over 900 fatalities nationwide in 2022, with Virginia accounting for 53 of these. This stark statistic alone underscores the urgent need for regulatory action to address this growing public health crisis.

2. Public Health Incidents:
In 2017, a salmonella outbreak linked to contaminated kratom products affected nearly 200 individuals across 41 states, exposing serious lapses in product safety and quality control. Further investigations by the FDA revealed that for 26 recalled kratom products, critical information regarding their origins and manufacturing could not be verified, highlighting significant safety and regulatory discrepancies within the industry.

3. Escalating Poison Control Calls:
The increasing frequency of calls to poison control centers concerning kratom exposure further emphasizes its danger. In 2022, U.S. poison centers received over 1,000 reports involving kratom, many of which involved severe toxicity and life-threatening conditions, underscoring its substantial risk to public health.

4. FDA Findings on Adverse Events and Mortality Risk:
According to the FDA Adverse Events Reporting System (FAERS) from January 2004 to September 2021, there were 489 reports involving kratom, with death and withdrawal symptoms being the most frequently reported events. A pivotal FDA study revealed that kratom is 63 times more likely to result in death than other over-the-counter supplements, clearly illustrating its inherent danger.

5. Aggressive and Misleading Advocacy by the American Kratom Association:
The American Kratom Association (AKA) has engaged in deceptive and aggressive tactics to thwart regulatory measures, including a vast letter-writing campaign/email campaign designed to intimidate and manipulate public opinion. This organization’s conduct reveals a stark and dangerous disregard for consumer safety, blatantly prioritizing industry interests over the well-being of the public.

6. Necessity for Stringent Regulation and the Protection of Our Youth:
Given its high potential for abuse, lack of any recognized medical benefits, and substantial evidence of serious health risks, it is clear that kratom meets the criteria for classification as a Schedule I substance. This classification is essential to combat the misleading packaging that often appears child-friendly, posing an even greater risk to our youth. The time to act is now, to prevent further exploitation of regulatory loopholes and to safeguard the health and safety of Virginians, particularly our children.

I urge the Virginia Board of Pharmacy to take immediate and decisive action by classifying kratom as a Schedule I controlled substance. Implementing strict controls is crucial to preventing further tragedies and ensuring the health and safety of our community.

Thank you for considering this critical public health issue. I look forward to your prompt action in addressing this urgent matter.

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