UK Research Use of Controlled Drugs exemption update
Government response to ACMD report on research exemption provided a mixed bag. Although they agree in principle to lowering barriers for research, the key proposal to define "research organisations" was seen as not practical
Without legally defining what research organisations are and what research is covered, its unclear whether the other recommendations could be implemented in a meaningful manner. For example how would chemical suppliers know what research an customer was doing? What research would be allowed?, could anyone claim to be doing research?
The UK government have issued a letter to the Advisory Council on the Misuse of Drugs (ACMD) concerning the ACMD’s report of 30 July 2021 entitled “Considerations of barriers to research Part 1: Synthetic cannabinoid receptor agonists (SCRA)”
That report had made the following recommendations;
Recommendation 1 - To ensure that proposed changes only apply to legitimate research, the ACMD recommends that the Home Office defines the term ‘research organisation’.
Recommendation 2 - The ACMD recommends that the 2001 Regulations should be amended to permit such ‘research organisations’ to produce / possess / supply / offer to supply a 100mg de minimis limit for compounds caught under the synthetic cannabinoid generic definition of the Misuse of Drugs Act 1971 (MDA) and the 2001 Regulation.
Recommendation 3 - The ACMD recommends that the 2001 Regulations should also be amended to permit ‘research organisations’ defined in recommendation 1 to import / export up to 100mg of synthetic cannabinoids, except those that come under international control.
The government have responded to these recommendations as follows, “The government agrees with the aims identified by the ACMD of enabling greater access with fewer regulatory burdens for legitimate research purposes whilst ensuring that the legislation and licensing system continues to tackle harm, diversion and misuse. We accept in principle the need to amend the legislative framework to achieve these aims. However, we consider that it is not practical to set out a wide-ranging definition of “research organisation” in the manner proposed. We also intend that any reforms should, if possible, encompass Schedule 1 drugs in general, rather than undertaking reform for SCRAs in isolation, subject to an assessment of the risks and any mitigations.”
The government have now formally commissioned the ACMD to look at the wider barriers to research, also known as Part 2, to consider application to all controlled drugs. They ask for advice of the ACMD on how best to reduce regulatory burdens on:
schedule 1 controlled drugs in general, which may also include SCRAs and, in particular, psychedelic drugs including psilocybin; and all stages of the research process, including clinical trials, building on your 2017 advice.
Its good to see these discussion happening, but its important to note nothing has changed in law with regards to controlled drugs for research, they are still controlled as such and it will likely take many years for any changes (if any) to be made.
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