Meeting Public Comments

Dr. Michele Ross [Addiction Scientist - 7-HOPE Alliance]

I am writing to strongly oppose any proposal to ban kratom, mitragynine or 7hydroxymitragynine (7OH).I am an addiction neuroscientist who has studied chronic pain and alternative medicines including kratom for over 17 years. I am the author of Kratom Is Medicine, and serve as the Chief Scientific Advisor to the nonprofit 7HOPE Alliance. I work with kratom consumers across the United States, including California.Kratom is used by at least 20 million people nationwide with over 15 years of mainstream use in the United States. The primary use of kratom is chronic pain relief and the secondary use is recovery from opioid use disorder (OUD). If you ban all kratom products including kratom leaf, kratom extracts, and kratom alkaloids, you will cause real harm to these consumers, including forced withdrawal and potentially even overdoses and deaths as kratom users seek far more dangerous illicit opioids to deal with their chronic pain or addiction issues. The primary active alkaloids in kratom, mitragynine and 7hydroxymitragynine (7OH), are atypical opioids both in chemical structure and because they both function as G proteinbiased partial mu opioid agonists, meaning they can never activate the opioid receptor to the same magnitude as a traditional opioid like fentanyl, morphine, or oxycodone that are full mu opioid agonists. This translates to minimal euphoria and even dysphoria at higher doses of kratom or 7OH, little activation of the betaarrestin pathway that causes respiratory depression, and low likelihood of overdose and death when taken alone. Compare this to traditional opioid drugs with very real risk of addiction, overdose and death. Kratom and kratom alkaloid products are the safer option with established therapeutic use.Kratom simply isnt a crisis that merits a ban. In 2023, the National Poison Data System (NPDS) reported only 25 kratom exposure cases in Iowa out of a total of 23,529 exposure cases. 3,442 exposure cases were for analgesics including traditional opioid painkillers, showing how kratom is relatively safer than traditional painkillers.Neither kratom nor 7OH is a recreational drug of abuse nor is it a drug that teens are using. The average age of both traditional kratom users and alkaloid products such as 7OH is over 40. Teens are not using kratom products, as the Monitoring The Future (MTF) survey data collected by the federal government shows less than 1% of high school students have experimented with it. On the other hand, 11% of teens have used delta8THC vapes. The argument that kratom or 7OH needs to be banned to protect the children simply isnt valid here, and instead warrants regulations such as agegating to 21+ and child resistant packaging.Finally, I urge Iowa to follow science, not fear and to ignore the misleading attacks you may hear from certain kratom industry groups specifically on 7OH. These individuals are being misinformed by industry members seeking market control, not consumer safety, and they do not represent the experiences of the hundreds of thousands of Iowa residents who rely on kratom and use 7OH responsibly every day.Instead of banning the sale of kratom and kratom alkaloids including 7OH via HSB 508, I urge Iowa policymakers to support reasonable regulation, quality standards, and transparent labeling approaches that protect consumers while preserving access to an important natural alternative.Please follow the science, not fear, and do not ban the sale of kratom or 7OH kratom alkaloid products. I am available for any questions you may have.

Misty Brown

Dear Members of the Committee,I am writing to clarify an important scientific distinction between traditional wholeleaf kratom and the products now being sold as "7hydroxymitragynine" (7OH).Wholeleaf kratom is the dried leaf of Mitragyna speciosa. Its primary alkaloid, mitragynine, is what produces kratom's effects. When consumed, the human body converts only a very small fraction of mitragynine into 7OH, typically well under 1%, through normal liver metabolism. This process is slow and selflimiting.By contrast, today's 7OH products are not naturally occurring kratom preparations. They contain laboratoryisolated or chemically converted 7hydroxymitragynine in concentrations far beyond what the body could ever produce from kratom leaf. At these levels, 7OH behaves much more like a traditional opioid, with significantly higher risk.Conflating these highpotency 7OH products with the kratom plant itself leads to inaccurate risk assessments and poor public health policy. Regulating or restricting 7OH does not require banning wholeleaf kratom, which has helped many adults avoid far more dangerous substances.I urge the Committee to consider this distinction when evaluating policy and enforcement decisions.Heres my testimonyFrom 2008 to 2019, I lived in the grip of FDAapproved pain pills, benzos, and muscle relaxers prescribed for my degenerative disc disease. For 11 years, chronic pain management fueled my addiction. What started as a dependency slowly slid into a destructive cycle of misuse and despair.In April 2019, I was dismissed from pain management after failing a required pill count. I was 11 pills short, and my usual drug dealers didnt have the pink oxy 10s I needed. Cut off from prescriptions, I turned to the streets in desperation and eventually slipped into cocaine use while searching for another doctor.Then, in June 2019, while suffering through cocaine withdrawal, I stumbled upon the documentary A Leaf of Faith. That single moment changed the course of my life. The very next day, I began my journey with wholeleaf Kratom, not synthetic 7OH, by walking into a smoke shop. The Kratom was in a glass case, locked up and i was carded when purchased. Kratom quieted the relentless cravings, the constant voice whispering, one more pill, one more snort, one more escape. For the first time in over a decade, I felt peace. Kratom gave me the space and clarity to confront the deeper reasons behind my addiction and to rebuild my life from the ground up.I have not returned to pain management in over six and a half years. Today, I am a thriving mother, a proud firsttime grandmother, a functioning member of society, and a taxpaying citizen. Most importantly, Im no longer a burden to my children. Im an example of hope and healing.I will forever be grateful that I found safe, labtested, wholeleaf Kratom. Now, I share my story, knowledge, and the science behind it to help others facing addiction, chronic pain, anxiety, and depression.Yours truly,Misty BrownKratom Consumer, Advocate & Activist est. 2019

Jennifer Gillis

Dear Members of the Committee, I'd like to share the impact kratom has had in my life. After waking up one day in 2005, paralyzed from my neck down, I was eventually diagnosed with Transverse Myelitis, and became a chronic pain patient. For years, I was able to manage my chronic pain with prescription medications, but eventually with more DEA cutbacks and new regulations over the years those were no longer an option for me. I was left to endure living in pain every single second of every single day just like so many other chronic pain patients in the same position. Luckily I discovered whole leaf kratom powder in May of 2019. I've been consuming it responsibly for 6 years and it has granted me a second chance at life! I no longer suffer every day, I can get out of bed and be a mom! I can go to school functions run errands, go to the store, and just live life without suffering. Though I regained mobility I still face many physical limitations, however I'm no longer confined by constant pain. Kratom gave me my life back. My story is just one of many chronic pain patients that have been able to manage their pain with kratom. There is a big difference between natural wholeleaf kratom VS the semisynthetic 7OH products being marketed as kratom. Ive been encouraged to see even the FDA has stepped in, not only to educate the public on this distinction, but also to warn about the risks of 7OH. Theyve made it clear their concern is with 7OH products, NOT with whole leaf kratom.Im asking you to support regulation instead of prohibition and keep natural, wholeleaf kratom legal. We need clear safety standards such as age restrictions, mandatory lab testing, accurate labeling, and limits on 7hydroxymitragynine (7OH). These are the kinds of measures that protect public health while preserving the freedom of choice for responsible adults.Thank you so much for your time and letting me use my voice to represent the many others in the chronic pain community.Sincerely, Jennifer Gillis

SUSAN EPPARD

My 22 year old son Matthew Eller died from whole leaf Kratom Powder (the least potent form of Kratom available in the United States). Kratom caused him to have a seizure, go into cardiac arrest and die. His toxicology showed he died from the TOXIC effects of Mitragynine an alkaloid found only in Kratom. He had no prescription drugs, no street drugs nor alcohol in his system when he died, and his autopsy showed he had no underlying health conditions. Its important to note my son didnt die from 7OH/7hydroxymitragynine.

Joshua Tumlin

I have been dealing with chronic pain since 2008, when I injured my lower back.I eventually had surgery in my lower back that was highly recommended to me by my doctors.This only made it worse.For 10 years I was prescribed two strong opioid medications, medications much, much stronger than Kratom tea, along with other CNS suppressants that carry harsher side effects. They also have led to many, many more deaths than Kratom.Kratom has greatly improved my quality of life.A total ban will do much more harm than good.More than 50x the number of those that have died(3 confirmed cases of users who took obscene amounts of the powdered plant) from Kratom have died instead from OTC medications like benedryl.