Meeting Public Comments

Charles White [Kratom Consumer Advisory Council]

What Iowa is struggling with is similar to that of other states and municipalities across the United States. It is a tricky situation because it comes with tradeoffs. I have presented about the current landscape in the kratom derived product market to the National Association of State Controlled Substance Agents and more recently to the Addiction Policy Forum where I show the stark differences between natural leaf kratom (used since the 1800s) and newer isolated, concentrated 7OH products (only available since 2024). This is the link to the 35 min Addiction Policy Forum talk I did in December. https://www.addictionpolicy.org/post/webinarunderstanding7ohsciencerisksandrealworldimpactIn a nutshell, natural leaf kratom is not a riskfree substance, but it is predominantly used by people to substitute for other substances of abuse or to treat intractable pain issues not sufficiently treated with prescription options. It is not FDA approved for these indications, but it is an accessible option for people without access to healthcare, those with highdeductible plans who cannot afford to access care, and for those who failed the FDA approved options. The available evidence suggests that people engage in less risky behaviors and are better able to care for themselves and fulfill societal obligations when using kratom vs. using illicit opioids. Natural leaf kratom does not have the same risk of respiratory depression, a cause of tens of thousands of deaths annually from prescription and illicit opioids. They also seem to function better on kratom than when suffering from alcohol use disorder. Isolated, concentrated 7OH products function with a potency of traditional opioids and have an in vitro and animal pharmacologic profile very different than the mitragynine in natural leaf kratom or leaf kratom itself. That is why the FDA and the Department of Health and Human Services specifically state that 7OH products should be scheduled/banned but natural leaf kratom should not. The FDA is currently actively studying natural leaf kratom with a recently released tolerability study with doses up to 4 times the standard dose used by consumers. No severe negative effects were seen. This doesn't mean there is no risk, just that preliminary assessments are positive. Given the balance between potential benefits and risks, the Kratom Consumer Advisory Council, which I lead, have suggested a 7OH ban but instead offer several regulations for natural leaf kratom to reduce its negative impact on children and communities while still allowing access for vulnerable people. This aligns with the determinations not only of the FDA, Department of Health and Human Services, the DEA, and the WHO, but also many major researchers in the kratom space. For more on me, please see my bio on: https://globalkratomcoalition.org/kcacboardmembersTo see our KCAC position statements: https://globalkratomcoalition.org/kcacpositionstatements

Wendy Chamberlain [Kratom Danger Awareness, Inc]

Chair and Members of the Committee,My name is Wendy Chamberlain. I am the founder of Kratom Danger Awareness and a mother who lost her only child to mitragynine toxicity, the primary alkaloid in kratom.My son was healthy and had no other substances in his system.Kratom is not an herbal supplement. It is a psychoactive substance that acts on opioid receptors and is sold without FDA approval, medical dosing standards, or adequate consumer warnings. Families like mine only learn the truth after tragedy.In 2024, national mortality data shows that approximately 2% of unintentional overdose deaths tested positive for mitragynine. That translates to thousands of deaths, not an isolated issue. These are not anecdotes they are documented toxicology findings.Regulation has also failed. Utah, a state often cited as a model for kratom regulation, is now moving away from its consumer protection framework after rising harms and enforcement failures. Potency has increased, products remain mislabeled, and new synthetic derivatives continue to emerge faster than laws can keep up.Iowa has an opportunity to act before more families are harmed. I urge you to prioritize public health and public safety over industry assurances and support decisive action on kratom.Thank you for your time and consideration.

Dan Gibbs

My son Austin passed away Dec 6, 2023 solely fromMitragynine intoxication. Toxicology and autopsy reports showed no other illicit or prescription drugs in his system. Cause of death was respiratory depression. Used since the 1800s is not a safety argumentHistorical use does not equal safety, especially when:Use patterns, doses, and formulations are radically different todayProducts are commercially concentrated, standardized for potency, and marketed for daily useBy that logic, laudanum and cocaine tonics would still be acceptable. Regulators do not rely on age of use they rely on modern morbidity and mortality.People function better on kratom is anecdote, not evidenceClaims that users:Engage in less risky behaviorFunction betterFulfill societal obligationsare selfreported narratives, not controlled outcome data.There are:No randomized trials showing kratom improves employment, health, or mortalityNo longitudinal data proving reduced overdose riskNo populationlevel evidence showing kratom lowers opioid death ratesAnecdote is not publichealth evidence.The harmreduction substitute argument backfiresAdvocates repeatedly say kratom:Replaces morphineReplaces oxycodoneReplaces heroinTreats intractable painThat admission undermines their own safety claim.A substance capable of replacing opioids is, by definition:OpioidactiveDependenceformingCapable of respiratory depression under realworld conditionsYou cannot argue:Its strong enough to replace opioidsandIt doesnt carry opioid risksThose claims cannot coexist.No respiratory depression is falseMitragynine and 7hydroxymitragynine:Act at the opioid receptorProduce opioidtype respiratory depressionHave been implicated in fatal outcomes, including cases without fentanylA lower risk claim is not the same as no risk and public health policy is not built on marketing language.Deaths disprove theory.The 7OH carveout is scientifically incoherentThe claim that only isolated 7OH is dangerous ignores basic biology:7OH originates from the kratom plantIt is present in leaf in variable amountsIt is produced endogenously when mitragynine is metabolized in the liverYou cannot have 7OH without kratom.Banning derivatives while protecting leaf does not eliminate exposure it just hides it behind metabolism.The FDA has NOT endorsed natural leaf kratom.This is one of the most misleading arguments from the KCAC and the AKA and is simply not true. The FDA study was not a safety study, not an approval, and not evidence that kratom is safe.The Food and Drug Administration:Has not approved kratom for any useHas repeatedly warned against its consumptionHas stated kratom products are unlawfully marketedHas cited serious safety concerns, including addiction and deathA tolerability study is not:A safety determinationA chronicuse studyA mortality assessmentAn approvalPhase1 tolerability publichealth safety.DEA, HHS, and WHO have NOT endorsed leaf kratomNeither the Drug Enforcement Administration, HHS, nor the World Health Organization has declared natural leaf kratom safe.In fact:WHO has stated more data is neededDEA has cited abuse and safety concernsHHS has flagged kratom for ongoing risk evaluationSaying these agencies align with KCACs position is misrepresentation by omission.Access for vulnerable people is not a safety justificationLack of healthcare access does not justify:Allowing an unapproved, opioidactive substanceSold without dosing standardsWith variable potencyWith known fatalitiesPublic health does not substitute unregulated drugs for healthcare gaps.Regulation has failed everywhere its been triedAge limits, labels, and testing:Do not stop online salesDo not prevent concentrationDo not control dose escalationDo not prevent dependenceDo not stop deathsThis is exactly how synthetic cannabinoids, designer opioids, and bath salts escaped early regulation.Real deaths outweigh speculative benefitsMedical examiners deal in outcomes, not theories.When:People dieToxicology shows mitragynine aloneFamilies lose childrenThat evidence outweighs advocacyfunded narratives about functioning better.

Stacey Reilly

I just want to say that my 21 yearold son took kratom, thinking it was safe. I found him dead in his bed from mitrogynine toxicity on February 5, 2021. There was nothing else in his system except a normal dosage of his medication. Therefore it was determined that he died from Kratom. He only took the leaf variety. This poison needs to be banned!!

Susan Cave [Kratom Danger Awareness]

My son, William Cave died from a combination of raw kratom and his antidepressants. There are no non bias studies that conclude a lethal dose of mitragynine, how it interacts with other drugs, effects of long term chronic use, how it might effect someone with underlying health conditions. My hopes and my prayer is kratom will be banned/scheduled,NONBIAS studies to prove kratoms medical efficiency and then prescribed under doctors order and understand doctor supervision. REGULATING kratom won't work and will not ensure public safety

Alyssa Putnam

Kratom needs to be banned. Too many people have been harmed or lost their lives because of it, and the risks are not taken seriously enough. This issue hits far too close to home for mekratom took my cousin, Randy Wilson, this past July. No family should have to go through that kind of pain. Until stronger action is taken, more lives will continue to be lost. Awareness and prevention matter, and banning kratom could save lives.

Phyllis Bowers

If a total ban on the substance saves just one life, then thats what needs to be done. ASAP.Kratom is a drug that offers no benefit to anyone, only heartache. Time for it to go.

Holly Trouville

I lost my 25 yr old son to Mitragynine toxicity Feb 2024. He had no opioids in his system and his sole cause of death was that and no secondary. It was ruled an accident. Kratom, in its entirety is deadly. There are so many lawsuits popping up daily and people getting addicted or dying. I implore you to please ban Kratom so another parent doesnt have to feel the pain of losing a child. Especially a loss from something marketed as natural.