I commented on HHS-OASH-2026-0232-0001, the Request for Information regarding the proposed 7-hydroxymitragynine (7-OH) scheduling threshold.
Comment Tracking Number: mry-8nrd-tg5g
I am submitting this comment in response to the Request for Information regarding the proposed 7-hydroxymitragynine (7-OH) scheduling threshold (Docket HHS-OASH-2026-0232).
First, on the imminent-hazard finding itself: temporary scheduling under 21 U.S.C. 811(h)(1) is meant to address genuinely urgent threats that cannot wait for ordinary scheduling procedure. I would ask OASH to specify the comparative risk data—overdose rate, dependence liability, and ER visits per capita of users—that establishes 7-OH at the proposed threshold as more hazardous than legal, widely available substances such as alcohol, which carries well-documented acute toxicity and tens of thousands of attributable deaths annually without triggering emergency scheduling. Absent that comparative showing, it is difficult to evaluate whether the proposed threshold reflects an evidentiary emergency finding or a policy preference.
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