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Vincent Joralemon

2 papers in the library

Papers

Regulating Psilocybin as Food, Not Drugs

Julia Etkin, Vincent Joralemon

Psilocybin, currently a Schedule I controlled substance with no accepted medical use and high abuse potential, is actually among the safest psychoactive compounds by comparative-harm metrics—far safer than alcohol and tobacco, which are exempt from the Controlled Substances Act and regulated as adult-use commodities. This essay argues that psilocybin should be regulated under food law, specifically the dietary-supplement framework of the Dietary Supplement Health and Education Act of 1994, rather than drug law.

The FDA Backdoor to MDMA Rescheduling

SSRN Electronic Journal Vincent Joralemon

The Drug Enforcement Administration (DEA) classifies MDMA as a Schedule I controlled substance, the most restrictive category under the Controlled Substances Act. However, Lykos Therapeutics (formerly MAPS PBC) has submitted a New Drug Application for MDMA-assisted therapy for PTSD. If the FDA approves this drug, it would provide the 'accepted medical use' that Schedule I drugs are statutorily denied, triggering a rescheduling process. Based on precedents like XYWAV and cannabis-derived medications, the DEA would likely reschedule only the specific FDA-approved drug product—likely to be marketed as RENSANSE—to Schedule II or III, while raw MDMA remains on Schedule I. This mechanism offers a model for incrementally relaxing federal restrictions on psychedelic substances and expanding research access.