Rethinking Drug Scheduling: SSDP Speaks at the United Nations
Better Drug Control Policies Through Expediting Scientific Research
On February 25, 2025, Students for Sensible Drug Policy (SSDP), a non-governmental organization in consultative status with the Economic and Social Council (ECOSOC) since 2011, submitted a written statement to the 68th Session of the UN Commission on Narcotic Drugs (CND). Prepared by Dr. Elijah Zorro Ullman, former Chair of SSDP’s Science Policy Committee, the statement highlights how overly restrictive drug scheduling undermines research and calls for needed reforms to advance public health and scientific understanding.
Currently, Schedule I classifications create significant barriers for researchers, delaying or discouraging critical studies on substances that could have therapeutic benefits. The U.S. Drug Enforcement Administration’s narrow definition of “abuse potential” also fails to reflect modern science, limiting opportunities for evidence-based policymaking.
SSDP’s recommendations to the UN and U.S. include:
- Reducing barriers to research;
- Updating definitions in drug scheduling law;
- Allowing class-wide research approvals; and
- Increasing funding for innovative studies.
By adopting these reforms, governments can create drug control systems that are more flexible, evidence-driven, and supportive of public health.
Read the Statement Below:
Item 5a of the Agenda, Implementation of the international drug control treaties, Changes in the scope of control of substances
Title: Better Drug Control Policies Through Expediting Scientific Research
The Controlled Substances Act, or CSA, in the United States (U.S.) and the United Nations (U.N.) Single Convention on Narcotics were designed not merely as mechanisms for restricting drug abuse but as nuanced frameworks for balancing public safety against the imperative of scientific progress. Rather than viewing the CSA as a beginning or an end, it is better conceived as an evolving regulatory tool intended by the U.S. Congress to embody sufficient flexibility to adapt to changes in knowledge as science and research evolve.
The U.S. Drug Enforcement Administration (DEA) should make scheduling determinations rooted in robust current evidence that reflect the broader societal and scientific context. The agency does not seek non-governmental expert scientific consultation before administrative rulemaking that proposes adding a drug to a particular schedule. As such, the agency’s view of the definition of terms such as “abuse potential” is out of step with the modern consensus of other agencies, such as the National Institutes on Drug Abuse (NIDA) .
In the U.S., the purpose of the Controlled Substances Act is to regulate certain drugs that are deemed to possess the potential of abuse or dependence. Unfortunately, the law also restricts access to scientific research at the university level and harms public understanding of the drug’s features—including potential for abuse or dependence. We will offer suggestions that the U.S. and U.N. should follow to promote scientific research and further understand the pharmacology and impacts of said drugs.
Schedule I status for a drug impedes research
Overly restrictive drug scheduling impedes scientific research, a term titled “Research Harms”. Research harms refers to the added costs to a researcher or institution, whether temporal or monetary, as well as added barriers to knowledge dissemination to the greater communities, both scientific and general. Some examples of such barriers include: physical modifications to research laboratories to accommodate safe requirements to house Schedule I drugs and a year – or longer – approval process for Schedule I compounds that require review by the DEA, Food and Drug Administration (FDA), possible state regulatory bodies, and university regulatory bodies. Any modifications to the proposal require authorization by the DEA and FDA. Numerous review articles have discussed these barriers to research and their impact on scientific breakthroughs, such as Nutt et al., (2013); National Academy of Sciences (2017); Howard et al., (2021); Henningfield et al., (2022); Barnett et al., (2025) and in a report authored by the Advisory Council on the Misuse of Drugs “ACMD” to the United Kingdom Minister of State for Crime, Policing and Fire in 2023.
The House Appropriations Committee requested NIDA to provide a brief report on the research barriers resulting from the classification of drugs and compounds as Schedule I substances . In a report titled “Barriers to Research with Schedule I Substances” , the former director of the National Institutes of Health states, “Barriers that have been reported by [NIDA]-funded researchers…may delay or discourage research on such substances…Researchers have reported that obtaining a new registration can take more than a year, that modifying a registration can also be time-consuming, and that differing interpretations of the Schedule I registration requirements among local DEA field offices, research institutions, as well as distinct federal and state registration requirements, greatly complicate the process. These challenges can impede critical research on Schedule I substances and deter or prevent scientists from pursuing such work.” Pg. 1-3. The U.S. Biden-Harris Administration made efforts to streamline the registration process for Schedule I drugs, in line with Schedule II compounds, expanding research into Schedule I substances. Nora Volkow, the Director of NIDA, testified to Congress about the difficulties for researchers studying Schedule I substances . Former Assistant Secretary of the Department of Health and Human Services, Brett Giroir, wrote in 2018 in his professional capacity that a proposed schedule I placement for kratom constituents mitragynine and 7-hydroxymitragynine should be withdrawn due to the underdeveloped scientific understanding of its active compounds and his “…concern[s] about the impact of scheduling kratom on our ability to conduct research…”
U.S. DEA “abuse liability” definition is narrow
The Drug Enforcement Administration (DEA) must have scheduling determinations rooted in robust current evidence and reflect the broader societal and scientific context. Key to scheduling is a determination of a drug’s “abuse potential”. It is the longstanding view of the DEA that any use of a psychoactive drug outside purely medical contexts constitutes abuse.
As the CSA was being written, the House Subcommittee on Public Health and Welfare of the House Committee on Interstate and Foreign Commerce held eleven days of hearings in 1970. The House report makes the following important observations:
The Committee made clear that it “…did not intend that potential for abuse be determined on the basis of ‘isolated or occasional non-therapeutic purposes.’ The Committee felt that there must exist ‘a substantial potential for the occurrence of significant diversions from legitimate channels, significant use by individuals contrary to professional advice, or substantial capability of creating hazards to the health of the user or the safety of the community’ ….”
As such, “abuse potential”, as referenced in the DEA’s 8 Factor Analysis for drug scheduling, must contextualize any reports of law enforcement encounters of a drug or confirmed urinary analysis for a drug within the broad scope of drug-seeking behavior. Any agency concerned with drug scheduling – including the United Nations – should keep this context in mind. Isolated reports of the ingestion of a drug not currently scheduled are insufficient to warrant Schedule I status.
As noted by the DEA in their Jan. 6, 2025 filing to a DEA Administrative Law Judge regarding the proposed placement of 2,5-dimethoxy-4-chloroamphetamine (DOC) and 2,5-dimethoxy-4-iodoamphetamine (DOI) in the CSA, “The subjective effects of hallucinogens drive their abuse which can lead to a variety of adverse health effects, such as paranoia, agitation, depression, and violent outbursts toward self and others. Intoxication and deaths associated with the abuse of hallucinogens have been reported”. This description of hallucinogens is incomplete and misleading, as it does not describe the numerous potential positive health effects of this classification, as discussed in a multitude of reviews. These positive health impacts include potential utility in the treatment of post-traumatic stress disorder, depression, anxiety, smoking cessation, and inflammation. None of the 37 pages of their post-trial brief to the “ALJ” discusses this research, nor does the initial report on DOC and DOI from the U.S. Department of Health and Human Services “HHS”.
Recommendations for the U.S. and U.N.
1) The DEA asks the following question in the 8 Factor Analysis as Factor 6, “What, if any, Risk there is to the Public Health?” This question should be amended to include or require consideration of, “What, if any, harms would the scheduling of a drug pose to public health? And how do these harms compare; is the drug’s harm to the public health significantly greater than the harm to research?”
2) In line with the Biden-Harris Administration’s previous goals and recommendation by the U.K. ACMD, Schedule I drugs, for scientific research, should only be subject to the registration requirements of Schedule II drugs. OR;
3) Drug class-wide registration be established such that a researcher who wishes to study e.g. hallucinogenic compounds can purchase any compound within a specific class without requiring that an amendment to the Schedule I registration be submitted if a researcher wishes to study any one of the compounds in a class. This action will promote greater flexibility in researchers’ experimental design.
4) Increase funding for unexpected lines of research from Schedule I drugs. Ibogaine, a Schedule I drug, has demonstrated some efficacy in the treatment of addiction broadly but is a Schedule I narcotic due to alleged abuse potential. Recent work has established that non-psychoactive analogs of Ibogaine can be created with notable pre-clinical efficacy in the reduction of alcohol and heroin-seeking behavior. By funding novel, unexpected lines of research such as this, there may be a reduction in trafficking and the use of ibogaine for self-experimentation.
5) Change “…drugs with no currently accepted medical use…” to insert “or scientific” between medical and use to the definition of Schedule I drugs.
Elijah Zorro Ullman, PhD
Students for Sensible Drug Policy (SSDP)
+1 (310)-803-7789
ezu321@gmail.com
