Agency
Department of Health Professions
 
Board
Board of Pharmacy
 
chapter
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
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6/4/24  11:52 am
Commenter: Concerned Citizen

Support for amending 18VAC110-20-322 to include mitragynine and 7-hydroxymytragynine
 

I am not a proponent of the continued availability of this drug. The kratom industry is, in every sense of the word "predatory". Lives are continually being negatively impacted from the open sale of kratom products in the American market without proper warning, education, labeling, and consumption directions. Furthermore, it seems at this point the manufacturers are not interested in providing said education, and are relying on the fundamental ignorance of their consumers, and attempts at legal disclaimers regarding kratom to further sales without retribution. It is my opinion that the current marketing regulations do not appropriately cover the risks involved with a plant containing atypically structured opioid compounds. The "dietary supplement" category for kratom is entirely improper, and it should be addressed for what it is, an addictive botanical drug. The current state 'Kratom Consumer Protection Acts' leave large enough holes to drive a dump-truck full of high-powered and even metabolite based products through. 

While kratom may be a safer alternative to street opioids, it is in no way proper to expose the entire US population to these compounds. Essentially by suggesting these chemicals stay on the market, we suggest they are entirely safe for every man and woman in America. This simply isn't true as evidenced not only by the copious amounts of adverse event reports as reported by FAERS, but also by the outcries of over 50,000 individuals online regarding their attempts to stop taking kratom based products, being locked into a physical addiction.

Per the Smith et al. 2022 study on Assessment of Kratom Use Disorder and Withdrawal, 47.3% of respondents met the criteria for Kratom Use Disorder. This is, in no way, acceptable for a product to be on the open American market with this sort of addiction potential, and absolutely no warnings, all the while (in some circumstances) being sold as a "health tonic" targeted towards vulnerable individuals (https://www.classaction.org/media/torres-v-botanic-tonics-llc-et-al.pdf)

Smith, Kirsten E., Kelly E. Dunn, Jeffrey M. Rogers, Albert Garcia-Romeu, Justin C. Strickland, and David H. Epstein. 2022. “Assessment of Kratom Use Disorder and Withdrawal among an Online Convenience Sample of US Adults.” Journal of Addiction Medicine 16 (6): 666–70. https://doi.org/10.1097/ADM.0000000000000986.

CommentID: 224053