What Will Scheduling Xylazine Accomplish?
Republican lawmakers want to schedule xylazine. Experts are skeptical that will do much of anything to actually help people struggling with addiction.
Republicans in the House called the government’s response to the overdose crisis "wholly inadequate" in a letter to the DEA asking for xylazine to be scheduled and recognized as “the threat that it is.”
"The effects of xylazine are devastating and include severe necrotic skin ulcerations that often lead to amputation, and severe withdrawal symptoms that leave users trapped in a vicious cycle of addiction," the GOP lawmakers said.
[insert meme: ‘worst person you know making a great point’]
The government appears to be doubling down on the same old supply-side strategy they always do—place substances under stricter control.
Drug scheduling is a long, complicated process. Drugs can be scheduled through legislative, adminstrative, or emergency action, according to a 2021 legal review of the Controlled Substances Act submitted to the 117th Congress. On the legislative side, Congress can put the scheduling of xylazine up for a vote; on the adminstrative side, the DEA and other government agencies (FDA, HHS) must move through a complex and lengthy process; in 2018, the DEA emergency scheduled all fentanyl analogues, though emergency scheduling doesn’t appear to be on the table for xylazine.
So it looks like the adminstrative route involving the DEA, FDA, and HHS is being taken.
First, the DEA must request a scientific and medical evaluation of the substance from the Secretary of HHS, which it appears to have done. Then, the HHS Secretary prepares said evaluation for the FDA’s review. Then the FDA considers the drug’s “potential for abuse and dependence,” as well as the drug’s pharmacological effects and public health risks, along with whether the substance is “an immediate precursor of an existing controlled substance.”
Based on all this, the FDA makes a reccomendation as to whether the substance should be controlled and in which category (1 through 5) it should be placed (1 is the stricest, where marijuana, heroin, etc. all are). The DEA says it is currently moving through this process, and is waiting on the health/drug agencies to provide a scheduling recommendation.
Where is Xylazine Coming From?
Before figuring out what impact any scheduling will have, it’s important to first understand the overall structure of the xylazine supply.
Right now, the xylazine in the drug supply is not manufactured illicitly in Mexico the way fentanyl is. Xylazine is a medical product being diverted directly from the veterinary supply-chain, and from there it’s sold to suppliers who then mix it into fentanyl destined for street sale.
It’s a bit of a mystery right now as to where precisely the leak in the xylazine supply-chain is. How much xylazine can be falling out of the back of the proverbial truck? With the amount of xylazine flowing on the street, there must be a gigantic hole in the xylazine supply. Maybe certain labs or manufacturers of xylazine aren’t really noticing that a bunch of their product isn’t ending up where it’s supposed to be ending up. Theoretically, a stricter xylazine schedule could plug some of these kinds of holes.
But it’s also unclear where exactly in the fentanyl supply-chain the xylazine is being mixed. At least in Philly, journalist Chirstopher Moraff says the xylazine is being mixed into fentanyl closer to the retail-level. “There was a dude going corner to corner selling vet bottles [of xylazine] at $80 a piece the other day,” Moraff said. “Now whether that is being added on top of pre-adulterated fent I can’t say, but my guess is no.”
Zoe Dodd, an organizer with the Toronto Overdose Prevention Society, also thinks xylazine and benzo adulteration is more of a local issue. “If xylazine was coming in the fent, we would have it here in Toronto. But it’s only shown up a couple of times in tests,” Dodd said. “I know locally that people are stepping on the fent by adding benzos. It’s cheap. When I’ve talked to local dealers they said they add it to the cut. They’re doing it themselves. Xylazine seems to be a localized issue.”
If xylazine is indeed being mixed domestically, then tighter controls could have some impact. It’s important to get solid answers to all these questions before being able to really know what a tighter control on xylazine would do.
What Will Scheduling Xylazine Accomplish?
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