Opinion: The DEA Draws a Firestorm of Criticism – April 18, 2018 – by Richard A Lawhern, Ph.D.
DEA has proposed rule changes which will allow them to force reductions on production of opioid pain relievers for any scheduled drug which they believe to be “diverted.”
They seem utterly uncaring that quotas have already been reduced for the past five years without noticeable positive effect.
This is typical of the drug-war: when a policy is not showing positive results, instead of trying something different, they double-down on the ineffective policy.
Overdose-related deaths continue to skyrocket due to street drugs. Like its predecessor in the 1980s, that drug war has already been lost.
DEA is compounding their nonsense by shortening the public comment period to a mere two weeks. But it’s not working.
The DEA docket on controlled substance quotas is receiving significant numbers of comments (over 650 in the first week).
[However, ] they only partly respond to what DEA is doing. For those of us who haven’t yet filed comments, the “message” needs to be more focused.
They want to roll back production allowances on any scheduled drugs that they believe to be diverted to abusers.
This is almost unbelievably vague:
- if the DEA “thinks/believes” (or even wants to believe)
- that a scheduled drug is being diverted (from patients? Or pharmacies, or shipping facilities, or distribution centers, or manufacturers?),
they will allow less of it to be manufactured.
But they haven’t offered details on how they propose to determine diversion.
This seems ridiculous. They are proposing an action (reduce quotas) based on a factor (amount of specific drug diverted) that has not been measured (and may not even be measurable).
Dr. Lawhern suggests
…our message should be more specific:
- DEA has no reliable way to determine whether or how much any controlled substance is diverted to non-medical use.
- Hospitals are experiencing shortages of scheduled drugs (see DEA Quotas Cause Opioid Shortage in Hospitals) and patients are being endangered because of past unjustified restrictions on production.
- Restrictions on medical supply are ineffective and unjustified.
- Even the National Institutes on Drug Abuse acknowledge that actively managed pain patients are almost never involved in opioid overdose-related death. In the few cases where they are, it may be as a consequence of under-treatment of pain and depression, forcing the patient to seek relief in street markets.
- DEA has already damaged or destroyed countless lives by creating a hostile regulatory environment, driving doctors out of pain practice and forcing the discharge or coerced tapering of patients into agony.
- DEA proposed rule making on production quotas should be withdrawn. It is entirely based on misunderstandings of addiction, counter-productive and inhumane.
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Author: Richard “Red” Lawhern Ph.D. is Co-Founder and Corresponding Secretary of the Alliance for the Treatment of Intractable Pain