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Commenting on the DEA's Tryptamine Scheduling Proposal

On September 23, the DEA proposed placing five tryptamines in Schedule I: 4-OH-DiPT, 5-MeO-AMT, 5-MeO-MiPT, 5-MeO-DET, and DiPT. Scheduling is a formal rulemaking “on the record,” and a final rule is reviewed for substantial evidence. So I read the notice for what it concedes:

  • The evidence is pooled across five substances. For 4-OH-DiPT it is one multi-substance poison-center case. For DiPT it is two.
  • The DEA says diversion “is not applicable” and that dependence liability cannot be determined.
  • Human effects rest on “anecdotal reports usually on internet forums.”
  • The finding that people use these substances without medical advice is assumed because the substances are unapproved, which is circular.
  • The small-business analysis divides by entire industries, and its own footnote says 0.02% where the text says 0.18%.

The comments are due October 23 at regulations.gov under docket DEA1715. You don’t need standing or evidence to file.

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