DEA Period of Public Commenting - My Comment - 11/30/2016

Before I submitted my comment, I took the time to research what I could. I typed up my comment in MLA format, complete with double-spacing and references. I made sure to make it the best I could!



[Spaethon]
Age **
November 30, 2016

Please Save Lives and Improve Quality of Life by Keeping Kratom Legal

       I commend the Drug Enforcement Agency’s decision to accept a short period of professional and public comment regarding the legality of Kratom. This herbal supplement has greatly improved the lives of millions across the country and implementing a ban on Kratom will worsen the existing opioid epidemic. An estimated 69% of users stated that they will seek opioid medication as an alternative if Kratom becomes illegal [1]. 29 million people cannot afford health insurance and a single hospital visit can cost tens of thousands of dollars or more [2]. Acute and chronic illnesses have destroyed the finances of so many citizens. Although I do not believe that Kratom should be a substitute for medical care, people can use Kratom to manage diagnosed chronic symptoms that otherwise forces them into ongoing expensive doctor visits.

       I am a 32 year-old male and have been a daily consumer of Kratom for 5 years. I am deeply grateful for those pain-free years. My experience with Kratom has been nothing short of life-changing. I have a history of a herniated disc in my lower back as well as left-sided kidney problems including multiple surgeries and kidney stones. I spent two years being prescribed Hydrocodone and Oxycodone by my physician. I consumed these medications on a daily basis and every 3-6 months my physician decided to increase my dosage. My primary reason for the pursuit of a natural alternative to opioids was because these drugs caused me to feel trapped, dependent, depressed, and hopeless. I also learned that these medications are derived from the same source as heroin and can be equally addictive and potentially deadly. My doctor failed to explain the history and risks associated with prescription opioids. Even if I was informed, there is no better alternative in prescription pain management except for Kratom.

       Kratom provides me with a significantly reduced level of pain, which allows me to live a normal happy life. My health insurance provider and I are not forced to spend significant sums of money to see a physician on a monthly basis for the purpose of receiving pain medications. To further hinder patients experiencing chronic pain, the CDC has released new opioid prescribing guidelines in March, 2016 which recommends physicians to scale back on prescribing pain medications [3]. With regard to people in chronic pain, physicians provide very few effective alternatives to opioid medication. I have tried chiropractic care, over-the-counter pain medication, topical creams, back support devices, stretches, and exercises and none of these methods came close to the relief provided by Kratom. My use of Kratom has not altered my daily life in any way. I have worked full-time, I help support my wife and daughter, and I currently maintain a 3.15 GPA in college with the help of Kratom. This natural remedy has never hindered my ability to function normally. In fact, Kratom has allowed me to have a better quality of life by suppressing my chronic pain. Although Kratom elevates my mood, I have never felt a “high” through the use of this herbal supplement. Claims have alleged that Kratom is both habit-forming and increases tolerance over time. If I stop taking Kratom, I experience mild symptoms very similar to quitting a caffeine regiment. For the past 5 years I have taken the exact same dose with no need to increase.

       I discovered that people around the world benefit from Kratom. I also found that Kratom is grown, harvested, processed, and sold in a 100% natural state. There are no chemical alterations or synthesized processes in the production of Kratom, unlike prescribed and illicit opioids. Kratom is not a member of the opioid family but instead falls directly into the coffee family. It is known that Kratom binds to opioid receptors in the brain, but this is not been extensively studied. A natural substance is not classified as an opioid just because it contains elements that bind to opioid receptors. For example, here are some items used in our daily lives that contain opioid compounds: dark chocolate contains an antioxidant, epicatechin, that binds to the δ-opioid receptors; the oil cafestrol in coffee is known to produce morphine-like activity, spinach contains the opioid peptides rubiscolins-5 and rubiscolins-6; an opioid peptide known as gluten exorphin is found in wheat; and an opioid peptide called casomorphin is found in cow’s milk. Just because Kratom contains a compound that is known to bind with certain opioid receptors doesn’t automatically require it to be labeled as a dangerous opioid substance. Otherwise chocolate, coffee, spinach, wheat, and milk must also be labeled as opioids. [4]

       The Drug Enforcement Agency reports that Kratom is “an imminent threat to public safety”, but a ban on Kratom will only further support this claim. The continued legalization of Kratom will only prove the opposite. Thousands have successfully substituted prescription narcotics with Kratom and banning this natural supplement will force people back into prescription narcotic regiments, thus worsening the opioid epidemic. This will inevitably increase the rate of prescription overdoses. Since the cost of healthcare is unaffordable to millions, a ban on Kratom will prevent many from acquiring medication to aid their suffering, which will drive up heroin use nationwide.

       The media has been reporting that Kratom is the salvation to opioid and alcohol dependency withdrawal, which is true for many. But the majority of Kratom users take the herbal remedy to alleviate their chronic pain, anxiety, Post-Traumatic Stress Disorder, and depression. A study was conducted by the Pain News Network organization and, although this is not a formal scientific study, all 6,150 participants are current and/or past Kratom users. These participants in the survey have no logical motive for dishonesty because Kratom is not currently a scheduled substance and this survey was conducted prior to the DEA’s announcement of intent to ban Kratom. Based on the results of these participants, 51% use Kratom as a treatment for chronic or acute pain (spine or back pain, fibromyalgia, migraine or headache, rheumatoid arthritis, osteoarthritis, lupus and other autoimmune diseases, inflammatory bowel disease, and other conditions). Over 90% of people found Kratom to be “very effective” in treating their medical ailments and 98% of people found Kratom to be a non-dangerous substance. In contrast, only 1.62% use Kratom recreationally. 75% of people report that Kratom did not make them feel “high”, 22.58% state that Kratom made them feel “a little high”, and 2.4% claim that Kratom made them feel “high.” An overwhelming 98.19% of people want the federal government to keep Kratom available as a supplement without a prescription. 95.45% of people surveyed believe that making Kratom illegal will be harmful to society while a mere 3.55% believe that banning Kratom will be helpful to society. [1]

       The majority of Kratom users take the natural remedy to treat pain and anxiety and in 2014 alone, pain-relieving opioids and anxiety-alleviating benzodiazepines have led to 37,412 deaths [5]. No evidence has supported Kratom as the sole contributor to any deaths globally. In light of the opioid epidemic and the overwhelming population without health insurance, the DEA should be advocating for the use of Kratom as a natural replacement to opioid and benzodiazepine medication rather than attempting to ban it. It has been reported that Obamacare rates will drastically increase next year, forcing many recipients to drop their coverage [6]. With the healthcare industry putting a significant financial strain on the American population, Kratom can provide a much-needed solution for millions of these people. Not only can Kratom save people from ongoing expensive doctor visits to refill narcotic prescriptions, but this can simultaneously grow the economy through healthcare cost savings while also saving thousands of lives from opioids and benzodiazepine overdoses annually.

       To satisfy the people, organizations, agencies, and administrations who see Kratom as a threat despite the evidence supporting the contrary, laws can be implemented to restrict the purchase of Kratom to individuals 18-21 and older. Since the vast majority of Kratom is purchased through online vendors, steps can be implemented that require age verification before purchase. This verification process is already in practice with the online E-cigarette market. Laws can also prevent drug paraphernalia merchants from marketing Kratom as a “legal high” since less than 2% claim to use Kratom for recreational purposes [1].

       In conclusion, the benefits of Kratom significantly outweigh its risks. Countless citizens can use Kratom as a successful alternative to dangerously addictive opioids and benzodiazepines. Current Kratom users can continue benefiting from its effects without seeking addictive prescription narcotics as an alternative. The opioid epidemic is only getting worse and Kratom is a profound solution that combats this plague in our society. Very few use Kratom recreationally and no deaths have been directly linked to Kratom. We deserve the right and freedom to choose a completely natural alternative to prescription narcotics and other man-made substances. Thank you very much for allowing me to submit my comments and I truly hope you consider the lives of American citizens who greatly benefit from this natural supplement.

References:
[1] – https://www.painnewsnetwork.org/kratom-survey/
[2] – http://www.thefiscaltimes.com/2016/05/10/Even-Obamacare-29-Million-People-Are-Uninsured-Here-s-Why
[3] - http://www.cdc.gov/drugoverdose/prescribing/providers.html
[4] – http://www.greenmedinfo.com/blog/do-hidden-opiates-our-food-explain-food-addictions1
[5] – https://www.drugabuse.gov/related-topics/trends-statistics/overdose-death-rates
[6] – http://www.nytimes.com/2016/10/26/upshot/rising-obamacare-rates-what-you-need-to-know.html?_r=0