Xylazine can complicate overdoses and overdose response, and often leads to difficult-to-treat soft tissue wounds among people who inject drugs.iv However, because xylazine is not typically used by or to treat humans, the scientific and medical communities have much to learn about this substance in order to understand the most effective ways to help people who take xylazine. [...] The eight-factor analysis conducted by the Department of Health and Human Services (HHS) as part of our typical drug scheduling process is a key step in gathering this initial knowledge.v The process ensures a scientific evaluation of a given drug’s true potential for misuse (a key criterion for scheduling decisions) and pharmacological effects, among other things. [...] Faced with stigma and the threat of law enforcement interactions, individuals are more likely to use alone and less likely to practice harm reduction or call for emergency services.xi In addition, while prohibition of individual substances may reduce their production and distribution, it has been shown to lead to an increasingly potent and opaque drug supply over time, a process often referred to. [...] Nearly 9 of 10 individuals at the lowest levels of the drug distribution chain report using drugs, and almost half meet the criteria for a SUD.xiii Because scheduling substances is not an effective way to stop or even substantially slow overdoses, and overcriminalization comes with additional risks to people who use drugs, there is no benefit to moving forward without thorough scientific evaluatio. [...] Furthermore, once a drug is placed on the CSA, “down-scheduling,” though not unheard of, is a slow and potentially arduous process that can further delay scientific research (as is evidenced by the process of moving cannabis from Schedule I to Schedule III).xv Policy Solutions We share Congress’ concerns about the spread of xylazine (and other, emerging adulterants) in the illicit drug supply and.
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