AKA letter to CDC on Kratom reads like déjà vu when compared to claims made about prescription opiates

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By R Carter

A recent letter from the American Kratom Association (AKA) in response to a report issued by the CDC on Kratom being detected by medical examiners and coroners, reads like déjà vu when comparing it point by point to claims made by the chronic pain community about the role of prescription opiates in the drug overdose crisis, the need for more research, details on drug sources and a separation of concerns between treatment for chronic pain and opioid use disorder.

Before getting into the details let me make my position clear. I have no doubt that prescription opiates have played a role in what’s called the opiate crisis. Where I part from government agencies and public health officials are on these points which I have written on repeatedly.

Likewise, each of the following points has a corresponding and nearly identical point taken verbatim from the AKA letter in the link above.

  • Media outlets have badly misstated the data on the role of prescription opiates in reported deaths. This is evidenced by attention-grabbing headlines such as “Odds of dying from accidental opioid overdose in the US surpass those of dying in car accident”; “Prescription Drugs Including Opioids Responsible for Most Overdose Deaths”; and “Fatal opioid overdoses are on the rise, and most involve prescription drugs”..
    • Unfortunately, media outlets have badly misstated the data on kratom’s role in the reported deaths. This is evidenced by attention-grabbing headlines such as “Herbal drug kratom linked to almost 100 overdose deaths CDC says”; “More deaths have been associated with kratom than previously known”; and “CDC Study Shows Kratom-Linked Overdose Deaths”. [Americans Are Dying From Kratom Overdoses: CDC]
  • Documentation of postmortem toxicology testing protocols is needed to more accurately clarify the extent to which prescription opiates contribute to fatal overdoses.
    • Documentation of postmortem toxicology testing protocols is needed to further clarify the extent to which kratom contributes to fatal overdoses
  • More precise toxicology screening is needed on all controlled substances  to accurately identify the role counterfeit prescription opiates have in overdose deaths, including the sources from where they come.
    • .A proper understanding of the type and number of substances detected in the postmortem toxicology screens of decedents would allow for the identification of substances that actually cause a death and, importantly, exclude substances that do not. The CDC report showed that in death cases where kratom was found in a toxicology screen, fentanyl and fentanyl analogs were listed as the “cause of death for 65.1% of kratom-positive decedents and 56.0% of kratom-involved decedents.” Heroin was the second most frequent substance listed as the cause of death in kratom positive decedents at 32.9%; benzodiazepines at 22.4%; prescription opioids at 19.7%; and cocaine at 18.4%.
  • CDC data does not report whether overdose victims use prescription opiates prescribed by doctors or whether these drugs come from illegally prepared sources which are adulterated with more potent drugs such a Fentanyl and its analogs.
    • The CDC data does not report whether the decedents ingested pure, unadulterated kratom in conjunction with dangerous substances or used an adulterated kratom product.
  • Lax guidelines for medical examiners and coroners are incorrectly reporting prescription opiates as the cause of death. The lack of a consistent postmortem testing protocols to accurately pinpoint the extent prescription opiates contribute to a death has exacerbated the grossly inaccurate and overstated numbers used in the public narrative on the potential dangers of opiates. There is a critical need for the publication of standards for postmortem toxicology testing to avoid inaccurate findings by medical examiners and coroners, such as prescription opiates allegedly being the cause of death and comprehensively identify substances that are not detected in routine testing for drugs of abuse.
    • Medical examiners and coroners are incorrectly reporting kratom-involved deaths as deaths caused by kratom. The lack of a consistent postmortem testing protocol to accurately pinpoint the extent kratom contributes to a death has exacerbated the grossly inaccurate and overstated FDA public narrative on the potential dangers of kratom. There is a critical need for the publication of standards for postmortem toxicology testing to avoid inaccurate findings by medical examiners and coroners, such as kratom allegedly being the cause of death and comprehensively identify substances that are not detected in routine testing for drugs of abuse.
  • All controlled substances are included in the CDC Wonder Reporting System, including those that did and did not substantially contribute to death, resulting in reporting which inflates estimates erroneously applied to prescription opiates.
    • Non-opioid substances are included in the State Unintentional Drug Overdose Reporting System (SUDORS), but the system records all substances testing positive on postmortem toxicology testing (including those that did and did not contribute to death).
  • The CDC’s repeated public statements based on these reports are inflating risks associated with prescription opiates used in treating chronic pain which contributes to inaccurate and, in some cases, clearly incorrect hypotheses now treated as facts that have served to materially mislead coroners, medical examiners, and other public policy makers about the alleged dangers of prescription opiates used in treating chronic pain.
    • FDA’s repeated public statements inflating risks associated with kratom use has contributed to inaccurate and, in some cases, clearly incorrect hypotheses now treated as facts that have served to materially mislead coroners, medical examiners, and other public policy makers about the alleged dangers of kratom use.
  • Clearly, if illegal and counterfeit prescription opiates are adulterated with substances like fentanyl, cocaine and heroin, as reported by the National Institute of Drug Abuse (NIDA), they can and do lead to overdose deaths. Those deaths would surely result if any other controlled substance were adulterated with these substances. The only reason we do not see CDC reports on them is that coroners and medical examiners are not compelled to perform toxicology examinations which would identify trace elements unique to these adulterated counterfeits.
    • Clearly, if kratom is adulterated with substances like fentanyl, heroin, benzodiazepines, cocaine, and other prescription opioids as set forth in the CDC report, adulteration can lead to overdose deaths. Those deaths would result if any other common consumer product (coffee, soft drinks, daily vitamins, or health foods) were adulterated with these substances. The only reason we do not see CDC reports on “coffee-involved”, “diet coke-involved”, or “vitamin-involved” deaths related to drug overdoses is that coroners and medical examiners accept the scientific consensus on the amounts of caffeine and vitamins that are toxic and the effects of those toxicities.
  • It is also clear from the data that polydrug users regularly consume many substances concurrently, and it is only because prescription opiates have recently (last ten years) been added to the toxicology screens that they are implicated more than other substances also used by those suffering from addictions.
    • It is also clear from the data that polydrug users regularly consume many substances concurrently, and it is only because kratom has been added to the toxicology screens that it is implicated more than other substances also used by those suffering from addictions.
  • Production quotas placed on the supply of opiates for acute and chronic pain, as well as extreme caps and limits placed on prescribing for chronic pain, will force pain patients to consider more dangerous options, including dangerous and potentially deadly illegal opioids, adulterated with unknown amounts and types of other drugs.
    • A ban on kratom would force current kratom users to consider more dangerous options, including dangerously addictive and potentially deadly opioids or equally deadly adulterated kratom products that are freely available on the Internet.
  • Postmortem toxicology testing protocols must be standardized to provide completely accurate and actionable reports on the contribution of all controlled substances, including prescription opiates, which contribute to overdose deaths.
    • Postmortem toxicology testing protocols must be standardized to provide accurate and actionable reports on the contribution of substances, including kratom, to a [overdose] death.

In the points made by AKA, you can nearly replace kratom with prescription opiates and the same arguments apply. Given these nearly identical arguments, those made by the chronic pain community with those made by AKA, it becomes far more difficult to trust what our public health officials and government agencies are saying with regards to the cause and effect of prescription opiates. It would seem these old and now warn out arguments, distortions of facts and misleading rhetoric, are revealing the ideological and political roots from which they’ve come. Our elected official should open their eyes to let common sense lead them to a more rational and balanced approach regarding policy, one which is based in solid facts rather than half truths.

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