Comment on FR Doc # 2012-25509

Document ID: DEA-2012-0006-0009
Document Type: Public Submission
Agency: Drug Enforcement Administration
Received Date: October 31 2012, at 12:52 PM Eastern Daylight Time
Date Posted: November 2 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: October 17 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: December 17 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 1jw-81ps-8yjp
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I think the main issue in determining drug scheduling classifications, especially when trying to differentiate between schedule I and schedule II drugs, is to look at the purpose, use, and effect of the drug. Since Schedule I and II drugs generally have very similar chemical potency (i.e. Heroine is a schedule I while Morphine is a schedule II) the main difference is the way in which the drugs are used and for what purpose. Both heroine and morphine give pain relief and euphoric feelings, similar to those seen with Methylone, and all three drugs have the potential for abuse. However, the distinguishing factor is that unlike heroine, morphine has many legitimate clinical/medical uses while heroine is solely used as a recreational drug and is not considered legitimate for medical use. Therefore, in determining the scheduling of methylone, it is important to determine the potential medical applicability. Whereas it was designed and patented by Jacob Peyton and Alexander Shulgin in 1996 as an antidepressant, now it is generally used for recreational purposes and is treated very similarly to heroin. Based on the fact that there are many more regulated and effective drugs already on the market for depression, the fact that methylone is being used primarily illegally rather than clinically, leads me to believe that placing it in the same class as heroine, i.e. Schedule I, is proper.

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