The DEA is moving to ban two invaluable psychedelic research chemicals, DOI and DOC. Students and researchers with Students for Sensible Drug Policy are fighting back.

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When the Drug Enforcement Administration (DEA) moved in April 2022 to move two psychedelic research chemicals that have been used safely for decades onto Schedule I of the Controlled Substances Act (CSA), it encountered immediate pushback from the research and drug reform communities. Opponents of the move argued that it would effectively block research with the chemicals, that the chemicals were not widely abused, and that they were key to valuable areas of research on the brain.

Leading the charge was the Science Policy Committee of Students for Sensible Drug Policy (SSDP), which demanded a hearing on the proposed move. After months of negotiations with the DEA, the agency announced in August 2022 that it was withdrawing the proposal. But that apparent victory was only temporary. Perhaps hoping no one would notice amidst the holiday cheer, just two days before last Christmas, the DEA again proposed scheduling the two chemicals. And now, SSDP has rejoined the fray.

The two compounds in question are 2,5-Dimethoxy-4-iodoamphetamine (DOI) and 2,5-Dimethoxy-4-chloroamphetamine (DOC), essential pre-clinical psychiatry and neurobiology research chemicals. Their unscheduled status has made them key tools for researchers studying serotonin receptors. DOI in particular has been a cornerstone in neuroscience research due to its high selectivity for the 5-HT2A serotonin receptor, a critical component in understanding and potentially enhancing the therapeutic effects of psychedelics. DOI's use in the lab ushered in a new era of psychiatric drug discovery since it was used to map the localization of an important serotonin receptor in the brain critical in learning, memory, and psychiatric disease. Over 80 percent of the antidepressant drugs on the market affect the serotonin system.

DOI has been cited in more than 900 research articles in the past two decades, contributing significantly to the understanding of complex neural mechanisms and offering potential pathways for breakthrough treatments. Recent studies utilizing DOI have shown encouraging results in managing pain and reducing opioid cravings, offering a beacon of hope in the ongoing opioid crisis.

Less than two weeks after the DEA renewed its quest to schedule DOC and DOI, SSDP struck back, filing a request for a hearing challenging this move on behalf of more than 20 graduate students, post-docs, staff scientists, and professors who have been actively involved in research using DOC and DOI. SSDP again cited the lack of substantive evidence and the negative impact on research. At the same time, Robert Rush, a Denver-based attorney representing three independent researchers, also filed a petition to challenge the scheduling. SSDP is now working hand-in-hand with Rush, who is spearheading the legal strategy for the case.

Last week, SSDP took another step in the process, filing a prehearing statement in the DEA Administrative Court yesterday that challenges the DEA's attempt to add the research chemicals to Schedule I of the Controlled Substances Act, which defines Schedule I drugs as those with a high potential for abuse, no currently accepted medical use in treatment in the United States, and a lack of accepted safety for use under medical supervision.

"DOI and DOC are important research chemicals with basically no evidence of abuse. We are excited to fight on behalf of SSDP scientists so that they can continue the critical work they are doing with these substances," said Brett Phelps, Esq, an SSDP alum and legal counsel for the youth-driven drug policy nonprofit.

"DOI has been the most widely used compound to study the role of the serotonin 2 receptor of the last several decades. The serotonin 2 receptor is widely accepted as the primary target of psychedelic drugs -- which have seen incredible press coverage as possible treatments for depression -- but is also critically involved in learning, memory, and mood. The DEA's proposed rulemaking to place DOI in Schedule I of the Controlled Substance Act defies scientific study and will make it more difficult for researchers to work on the serotonin 2 receptor," said Elijah Ullman, a PhD Candidate in Molecular and Systems Pharmacology at Emory University who serves as the chair of SSDP's Science Policy Committee.

"There is a plethora of evidence demonstrating that DOI does not have significant potential for abuse yet the DEA continues on an anti-scientific tirade of ignoring facts," says Ullman.

"The DEA's attempt to classify DOI, a compound of great significance to both psychedelic and fundamental serotonin research, as a Schedule I substance exemplifies an administrative agency overstepping its bounds," said Rush. "The government admits DOI is not being diverted for use outside of scientific research yet insists on placing this substance in such a restricted class that it will disrupt virtually all current research. In light of recent Supreme Court decisions, we look forward to aggressively fighting to stop this injustice."

Given recent Supreme Court decisions questioning the extent of administrative power of federal agencies, the effort to block DOC and DOI from being added to the CSA could set important precedents.

"DOI and DOC could lead to significant breakthroughs in treating some of today's most challenging health issues, but this is not just about keeping two chemical compounds available for research; it's about preserving the integrity of scientific inquiry, advancing medical treatment, and ultimately, impacting lives positively," said SSDP Executive Director Kat Murti. "The DEA's current path is a disservice to science, health, and the principles of justice and compassion. Let's stand together to advocate for sensible drug policy and ensure that potential treatments can reach those in need without undue government interference."

Will the DEA be forced to back off once again? Stay tuned.