Ohio Board of Pharmacy:

It has come to my attention that the Ohio Board of Pharmacy is recommending a ban on kratom (mitragyna speciosa). I am a Columbus, Ohio, resident who consumes kratom on a daily basis. I have read the proposal for classification, and it is apparent that the board is basing this recommendation on alarmingly false and misconstrued information.

Regarding the first criteria, "potential for abuse," the fact that compounds in kratom have similar structure to opioid analgesics and bind to mu-opioid receptors does not intrinsically indicate abuse potential. There are many commonly consumed substances that have opiate-like activity in the body. Some examples include compounds in dairy products (beta-casomorphine-7), and Imodium, a common over-the-counter anti-diarrheal medication. I doubt anyone would argue that milk and Imodium have any potential for abuse.

The evidence of "pharmacological effects" described are not, in my opinion, scientific. The terms "cocaine-like" and "morphine-like" used by the European Monitoring Centre for Drugs and Drug Addiction could be used to describe a variety of substances that most people consume on a daily basis. Coffee could certainly be described as having "cocain-like" effects. (Interestingly, kratom is a relative of the coffee plant, so perhaps it isn't surprising that both plants can give one energy.) Exercise can have a "morphine-like" effect. These are not scientific terms. The dose of 10-25 grams described as "large" would be more aptly described as "extremely uncommon." It is commonly echoed in forums, such as the reddit group, /r/kratom, that "less is more" when it comes to dosage. The more kratom one consumes at once, the more likely it is that you will simply become sick. This is exactly what is described by the EMCDDA. Note that this is not described as a deadly or dangerous reaction. I believe most people would agree that if you ingest too much of even the most benign things, you will experience effects such as "sweating, dizziness, and nausea." Concerning the animal studies and their reference to 7-hydroxymitragynine, there is one important piece of information left out. 7-hydroxymitragynine occurs negligibly in the kratom leaf. In his presentation titled Kratom (Mitragyna Speciosa) as a Potential Therapy for Opioid Dependence at the Ethnopharmacologic Search for Psychoactive Drugs II in Buckinghamshire, England, Dr. Christopher McCurdy goes into great depth about the results of kratom studies on animal models done by the University of Mississippi and by others. These studies confirmed that when isolated, mitragynine, the main active compound in kratom, does not produce withdrawal signs or respiratory depression. Even when the mice were given pure, unadulterated kratom leaf containing the typical amount of 7-hydroxymitragynine, withdrawal and addiction signs were not observed. It was only isolated 7-hydroxymitragynine administered in much larger doses than would be present in natural kratom leaf that produced typical signs of addiction, withdrawal, and respiratory depression. If the board would propose a ban on 7-hydroxymitragynine extracts or products with artificially increased concentrations of 7-hydroxymitragynine, I would find this acceptable. I strongly support standards and chemical analyses for kratom vendors, and the American Kratom Association has recently proposed creating such standards to protect kratom consumers.

The third criteria is based upon the FDA's Public Health Assessment. This assessment has been refuted by many doctors and scientists. Nine scientists have signed a letter to the DEA stating that the FDA has used "bad science." This letter states, "We believe strongly that the current body of credible research on the actual effects of kratom demonstrates that it is not dangerously addictive, nor is it similar to 'narcotics like opioids' with respect to 'addiction' and 'death.' Equally important, four surveys indicate that kratom is presently serving as a lifeline away from strong, often dangerous opioids for many of the several million Americans who use kratom." This last sentence should be a wake-up call to the board, as Ohio is one of the most opioid-addicted states in the country.

In the fourth criteria, it is stated that kratom can lead to death. This is simply untrue. No deaths in which kratom has been found in the deceased systems can be without a doubt contributed to kratom. In every single case cited by the FDA, other drugs or underlying medical conditions have been present that are known to cause death or serious adverse effects. Even if one were to ignore the facts and insist that each of these deaths were caused by kratom, the double-digit number of deaths claimed by the FDA is monumentally less than that of Tylenol-induced deaths per year in the United States.

One of the most shockingly false claims presented by the board in the proposal is found under criteria five where it is claimed that, "the most common route of administration for kratom was intravenous injection." I don't believe it takes much scientific literacy or explanation to understand that one cannot shoot dried plant powder through a needle. If there was some physical way to get dried plant matter directly into a vein, the shooter would certainly die of a blood clot or need to be rushed to the hospital immediately to avoid this. This claim is absolutely laughable, and was most likely made by heroin users participating in a survey who have never heard of kratom for the sole purpose of collecting the participation money. Perhaps this fact might shock the board, but drug addicts lie to get money for drugs. The most common form of kratom consumption is oral consumption. I would argue that this is actually the only form of consumption. There is no need for a survey to determine this. I encourage the board members to visit any forum about kratom and conduct their own research into what they see as the most common method of consumption. The rest of criteria five does nothing but describe the fact that a legal product is being purchased and imported. This should not be cause for concern, and it is certainly not a sign of abuse.

Concerning the risk to public health, all the evidence needed seems to be located in this very description. Kratom products that have been adulterated with other illegal drugs are causing deaths. Kratom taken in combination with other deadly substances causes death. Krypton, the product cited from Sweden, was laced with o-desmethyltramadol. This is not kratom. These things should not be in kratom. No one in the kratom community wants this adulteration. To reiterate, the American Kratom Society is adamant about creating a quality control system for vendors to prevent anything like this from happening. To put the blame on kratom is as nonsensical as blaming candy for containing razor blades on Halloween; no one wants this, and candy isn't the problem. Also discussed in this section is the recent salmonella recall. I am at a loss as to how this is grounds for a ban, as no one has suggested banning spinach, peanut butter, lettuce, or any of the other products that are periodically recalled for salmonella contamination.

Regarding criteria seven, I will refer you back to the studies discussed by Dr. Christopher McCurdy. I will also give you my own personal experience regarding dependence. I take kratom twice a day because it gives me more energy and helps me to feel less anxious. I currently take 2 grams in the morning and 2 grams in the afternoon mixed with orange juice. I have been taking kratom for two years. When I began to take kratom, I was taking around 4 grams at a time. I did this for about 6 months. I then cut my dose down to 2 grams at a time with absolutely no withdrawal effects whatsoever. I have maintained this dose ever since. Some days, I forget to take kratom. I do not experience withdrawal or cravings on these days. I have not had to increase my dose to keep up with a building tolerance. I also have a full-time job, I do not believe there is any evidence that kratom is having an adverse effect on my life or well-being.

In conclusion, the "evidence" presented in this recommendation for a ban is greatly flawed, and reflects poorly on the capacity of the Ohio Board of Pharmacy to make informed decisions for Ohio. I strongly urge the board to withdraw this recommendation.

Thank you