I prepared a public comment and independent evidence review for HHS Docket No. HHS-OASH-2026-0232, concerning the proposed temporary Schedule I placement of 7-hydroxymitragynine, often shortened to 7-OH.

Since then, Pennsylvania has introduced HB 2158, the proposed Synthetic Kratom & 7-Hydroxymitragynine Control Act. Although my report was written for the federal HHS docket, the same evidence is directly relevant here in Pennsylvania.

I want to be clear: I do not believe concentrated 7-OH products should remain unregulated. Some products are high-dose, poorly labeled, irresponsibly marketed, and too easy for young people to access. That is a real public-health problem.

But Schedule I prohibition is not the same thing as smart regulation.

The public record supports immediate federal and state attention. It does not yet prove that broad Schedule I placement is the least harmful or uniquely necessary response. Before Pennsylvania adopts a state-level ban, lawmakers should evaluate enforceable alternatives such as age 21 restrictions, seller and manufacturer licensing, GMP standards, independent testing, accurate labeling, dose and package limits, child-resistant packaging, adverse-event reporting, sales-denominator reporting, recall authority, transition planning, treatment referral, naloxone access, and research protections.

As someone living with degenerative disc disease and ankylosing spondylitis, I also care deeply about the human side of this issue. For too long, drug policy has treated people in pain as collateral damage. Adults who responsibly use plant-derived or kratom-related products for pain, withdrawal avoidance, or harm reduction should not be erased from the discussion.

Patient experience is not a clinical trial. But it is evidence of what people may do when access is abruptly removed.

A sudden Schedule I approach could create foreseeable harms: unmanaged pain, withdrawal, counterfeit-product exposure, illicit substitution, or return to more dangerous substances among some users. The magnitude of those risks is unknown, but they are real enough to deserve policy planning before prohibition becomes the default.

My report argues for a middle path: regulate decisively, protect children and consumers, require testing and transparency, restrict bad actors, preserve research access, and measure outcomes honestly.

The answer is not an unregulated market.

The answer is evidence-based regulation that protects public health without unnecessarily harming people who live with pain.