Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Pharmacy
 
chapter
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
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6/5/24  11:06 pm
Commenter: Ed

Scheduling Means More Harm
 

Designating kratom leaf powder Schedule I will not save lives nor prevent addiction. It would deprive persons with chronic illnesses a safe means to manage pain and fatigue. Continued scientific study of the compounds found in Mitragyna Speciosa is needed. The leaves of this tree have been used by humans in Southeast Asia for centuries, and the social fabric has not frayed. Kratom gives farm laborers the stamina to work long days. Its anti-spasmodic effects have been harnessed. It's used to treat diarrhea as folk medicine in rural areas afflicted by dysentery. And kratom has been used historically to attenuate the misery of opium withdrawal. In short, it's a marvelous herbal, offering relief to persons everywhere, especially those outside of mainstream medicine.

Scheduling kratom would take these benefits away for our citizens. Many rely upon it to relieve chronic pain, and others, as a means to cease the use of deadly narcotics like Fentanyl. Why would we want to wall off kratom behind a Schedule I wall while the Fentanyl crisis rages on? I am aware of many cases where harm reduction was achieved by the use of kratom.

Many of us seek to create a sensible regulatory scheme. The placement of this herbal into Schedule I defies the purpose of this catagory. In fact, kratom doesn't meet the criteria for Schedule I. For one thing, the FDA has not yet settled the matter of kratom's potential dangers. An escalatory dosing regimen on 40 study participants did not show serious adverse events. For another, Schedule I is limited to those compounds thought to have no legitimate medical use. It's totally premature to declare that the compounds in Mitragyna Speciosa have no value to mainstream medicine. The path to amazing new drugs may run through kratom. There's so much research yet to be done. Placing kratom in Schedule I forecloses opportunities for scientific gain.

Please deny the petition as written. Instead, work with the kratom community to develop sensible and nuanced regulations. For example, protocols to assure purity and standardized dosing are much needed. Kindly consider the Federal Kratom Consumer Protection Act (KPCA), introduced by Sen. Mike Lee in 2023 (S.3039).

CommentID: 225658