Comment on FR Doc # 2012-25509

There is no doubt that if, as reported in the Federal Register, methylone and synthetic cathinones cause health problems similar to that of MDMA, methamphetamines, and amphetamines, the drug poses a serious health risk to individuals taking the drug. However, adding this drug to the CSA may not be the best way to combat the rising use. First, the use of the drug seems to be relatively low: STRIDE Reports 220 cases three-and-one-half years. Furthermore, poison control centers and law enforcement tend to report synthetic cathinone exposures rather than methylone exposure. The frequency of poison control calls and other reports must be questioned because the DEA assumes that methylone is a problem: "[a]lthough methylone may not be specifically identified during exposure calls or identified by toxicology testing by AAPCC, it is likely that some of these retail products described by the callers contained methylone, based on the identification of methylone in approximately 26% of all synthetic cathinones." 77 Fed. Reg 63766, 63768 (Oct. 17, 2012). Thus, it seems that cathinones are the real problem. Second, my concern is not about the outlawing of methylone itself, but the unintended consequences of once again expanding the reach of the CSA. The United States continues to fight the "War on Drugs" without much decrease in distribution and sales of illegal substances. People of all ages and walks of life continue to become addicted and the justice system continues to put persons with addictions into jails and prisons for non-violent offenses like possession, without providing the proper treatment that could reduce recidivism in drug crimes. The CSA should have to prove its effectiveness in the "War on Drugs" before we continue to expand it parameters and thereby increase jail and prison populations that have notoriously underfunded treatment programs.