Comment on FR Doc # 2012-04982

Following a number of other countries that have banned similar synthetic substances, the DEA is trying to make illegal such substances within the U.S. However, a flat out ban on synthetic cannabinoids only creates a black-market for those substances. For example, in New Zealand, the government banned the sale of Benzylpiperazine (“BZP”). Following the ban, reports show a massive increase in the consumption of BZP. Instead of a flat ban on synthetic cannabinoids, like JWH-018, the DEA should consider alternative methods in controlling its use. When making its determination on whether a substance should be classified as a Scheduled drug, the DEA looks (in part) for the drug's potential for abuse. In determining a drug's potential for abuse, the DEA relies on four factors. The first factor, “whether there is evidence that individuals are taking the substance in amounts sufficient to create a hazard to their health or to the safety of other individuals or to the community,” is easily cured by placing certain regulations on synthetic cannabinoids, rather than banning it. The first method to cure the potential for harm is to place a regulation on all producers of synthetic cannabinoids that mandates each substance to come with an ingredients label. This allows consumers to understand what they are buying and the potential affects such products will have. Secondly, the DEA can create a regulation that producers of synthetic cannabinoids only sell it in certain dosages. This lessens the potential risk of overdose. Third, only allow synthetic cannabinoids in a pill form. This reduces the negative effects that smoking such substances may have on an individual. [Please see the attached document for the remaining portion of this comment]