November 28, 2016
The American Herbalists Guild (AHG) is a non-profit, educational, member-based association of herbal practitioners founded to represent the goals and voices of herbalists specializing in the medicinal use of plants. We currently represent over 2000 practitioners, educators, students, and others who utilize herbalism is a safe, effective, and therapeutic fashion. The AHG’s primary goal is to promote a high level of professionalism and education in the study and practice of therapeutic herbalism, whether based on modern biomedical, traditional, or other approaches.
The AHG would like to publicly as well as directly to the DEA state our opposition to the classification of mitragynine and 7-hydroxymitragynine as Schedule I substances according to the Controlled Substances Act (CSA) – a regulatory move that would effectively ban the plant kratom (Mitragyna speciosa) which contains these constituents.
The AHG considers such a step to be unjustified. As noted by AHPA and others, there is no precedent for the DEA to use its emergency authority in this manner for a naturally occurring substance such as a plant. As documented elsewhere (Yearsley, McGuffin and Young) the serious adverse health effects including deaths that have been in some cases potentially attributed to kratom are more likely due to adulteration and/or concomitant use of hazardous and toxic substances.
Schedule I classification would also be highly counterproductive in terms of gaining additional scientific knowledge about kratom and its potential uses, as well any potential safety concerns, in that such a legal classification would overly restrict further scientific research into not only its safety but also its therapeutic value.
The AHG urges the DEA to permanently set aside the potential classification of kratom as a Schedule I drug as inappropriate, given all we know of its uses and safety based on both science and tradition. We believe that it is vital that plants with a long tradition of therapeutic use such as kratom remain accessible to the public.
Citations and Additional Resources
AHG Encourages the Public to Submit Comments to the DEA by December 1, 2016 at this link.
Michael McGuffin, Anthony Young, American Herbal Products Association, Letter submitted to DEA, September 30, 2016
Connor Yearsley, Kratom: Medicine or Menace? HerbalGram. Issue:112 p46-59, 2016; American Botanical Council (must be logged in to access)