Kratom_CSA Factor 7

Factor 8: Whether Kratom is an Immediate Precursor of a Substance Already Controlled

The next and last factor in the study, Factor 8 includes whether kratom is an immediate precursor of a substance already controlled, as well as the conclusion.

This is something we need to keep in mind, kratom is NOT morphinans by origin or molecular structure.

Neither kratom nor any of the constituents in kratom or its alkaloids are controlled substances or are precursors of a controlled substance. They are not a morphinans by origin or molecular structure, and the science to date indicates that they differ significantly in from prototypic opioids of abuse with respect to abuse potential and safety.

In conclusion to this very extensive study is painfully obvious. That is, the DEA/FDA is attempting to vilify kratom when in reality, it’s a godsend to many dealing with pain, anxiety, depression, and other disorders. With that said, the missing link here is evidence and study.

We recommend further study of kratom and its alkaloids and further consideration of public health benefits and risks of its historical and current use before any regulatory actions are taken to restrict its availability.

Kratom’s overall low potential for abuse and risk to public health and its extensive history of safe use, including findings from recent surveys in the US, suggest a strong benefit to risk profile that is within the range of current dietary supplements and many over-the-counter products However, if some extract of kratom, or single entity was used to develop a drug, that product and its active substance(s) would need to be thoroughly evaluated for abuse potential according to FDA’s 2017 Guidance and determined, consistent with the CSA, if the product should be placed in the CSA and if so, which schedule would be most appropriate.


8 Factor Analysis performed by Dr. Henningfield

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