Last month, SSDP Science Policy Committee Co-founder Dr. Elijah Ullman traveled to Vienna, Austria to represent SSDP at the 68th Session of the UN Commission on Narcotic Drugs and to deliver an official statement strongly urging international lawmakers to prevent poorly planned drug scheduling regulations from halting vital scientific research. For reference, Dr. Ullman’s testimony has been included in full below.
Item 5b 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
I thank the Chair for the Opportunity to speak to this esteemed body on behalf of students for sensible drug policy.
My name is Dr. Elijah Zorro Ullman. I study the actions of drugs at the molecular and cellular level as a research scientist.
Schedule I status for a drug impedes research
The most restrictive classification for drugs, Schedule I impedes scientific research, a term titled “Research Harms”. Research harms refers to the added costs to a researcher or institution, whether in time or financial. 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 onerous federal, possible state bodies, and university regulatory bodies. Numerous review articles and government bodies have discussed these barriers to research and their impact on scientific breakthroughs.
“Abuse Liability” definition is narrow
Drug controls must have scheduling determinations rooted in robust current data 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 many control agencies that any use of a psychotropic drug outside purely medical contexts constitutes abuse. This narrow view is not the consensus of the scientific community at large.
This body should keep this context in mind. Isolated reports of the consumption of a drug not currently scheduled are insufficient to warrant Schedule I status. Blanket structure based similarity is inappropriate. This body is considering Nitazenes which have never even been evaluated! Laboratory study of its effects is needed.Small chemical changes can even eliminate all activity of a drug and this is useful for researchers as well.
This body must continuously reevaluate drug controls as new data emerges.
Psychedelics for example have been shown effective in preclinical and clinical trials to treat depression, pain, anxiety, and ptsd.
Recommendations
1) The UN Mandated in Article 4 Section 2b of the 1971 Convention, to in summary, assess the ‘degree of seriousness of the public health and social problem and degree of usefulness of the substance in medical therapy…” when considering a drug for scheduling. To assess medical utility, scientists need easy access to study the drug. We encourage the INCB to ease restrictions into studying drugs to satisfy this component of the Convention and support member States in their ability to conduct research.
2) We ask member states to Amend the 1971 single Convention, to align registration requirements for researching Schedule I drugs with that of Schedule II.
Thank you
Elijah Zorro Ullman, PhD
On behalf of Students for Sensible Drug Policy (SSDP)
