Publisher’s Note: We appreciate the splendid reaction you have made to our posts. Your comments are viewed by regulators, the press and Congressional staff. We apologize for not responding to the questions you raised in your comments or the questions you raised in the submissions to CRE via the contact link on this website. Rest assured a member of our staff reads all submissions and the comments are placed in a database which we use for our advocacy operations. That said, we simply do not have the resources to be as responsive to your requests as your have been to ours.
CRE continues to read and benefit from the hundreds of comments we received. One reoccurring theme is that HHS had its fingers in the DEA decision to ban kratom.
CRE has not been able to verify these statements but CRE has asked DEA to release the letter it sent to HHS requesting its views on a range of topics. CRE has not been provided with the said letter.
Of particular interest to CRE was whether DEA informed HHS of the fact that a black market would emerge as a result of imposing a ban on kratom. Another question that arises from a detailed review of the record is the nature, if any, of discussions between HHS and DEA before DEA sent a formal request to HHS.
Much of the aforementioned discussions are considered “deliberative” and necessary for the proper functioning of the federal government. We agree.
However whether such deliberations are shielded from an interrogatory or subpoena will be determined by a federal judge in the event DEA is challenged under the Administrative Procedure Act for failing to provide the public with the opportunity to comment on the ban it imposed by an administrative action.
Next the atrocities associated with a black market.