June 4, 2019                                                                                       

Honorable Lindsey Graham, Chairman

on the Judiciary


Dirksen Senate Office Building
Washington, D.C. 20515

Honorable Dianne Feinstein, Ranking Member

on the Judiciary


Dirksen Senate Office Building
Washington, D.C. 20515

RE: Hearing on “The Countdown: Fentanyl
Analogues & the Expiring Emergency Scheduling Order

Chairman Graham & Ranking Member Feinstein:

The R Street Institute is a nonprofit,
nonpartisan, public policy research organization based out of
Washington, D.C. We strive to promote free markets and effective government
policies in many areas, including harm reduction and public health.

My interest in and efforts to promote
reasonable policy relating to drug abuse are based on my scientific expertise
in neural mechanisms of addiction, as well as my keen understanding of sound
public policy and its ability to positively influence society.

When considering amendments to the
Controlled Substances Act, including rescheduling or de-scheduling drugs or
drug analogs, we ask that consideration be given to the consequences associated
with these actions.

We appreciate that synthetic opioids, such
as fentanyl and certain derivatives, have contributed to the opioid overdose
crisis that the United States is currently experiencing. However, we submit
that keeping fentanyl analogs as Schedule I drugs and extending the emergency
scheduling order will not curb the number of opioid overdose deaths. Instead:

Given current regulations surrounding the use and potential
use of scheduled drugs, we believe that reclassifying fentanyl analogs as
Schedule II drugs would be more appropriate.

Thank you for your time and consideration.

Respectfully submitted,

Dr. Carrie Wade, Director of Harm Reduction Policy

R Street Institute

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