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15
CONCLUSIONS: GUIDELINES FOR
IMPLEMENTING THE USE OF
PSYCHEDELIC MEDICINES
MICHAEL J. WINKELMAN AND THOMAS B. ROBERTS
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The authors of our chapters have tempered their encouraging results from
preliminary studies with reminders that psychedelic medicine has not yet
met the criteria of establishing medical safety and efficacy with DBCS
(double-blind clinical studies) and the full phases of evaluation. To what extent
have psychedelic medicines passed the standards of clinical medicine or bio-
medical science? To what extent are these standards necessary and appropriate?
What uses of psychedelic medicines are justified in terms of the currently avail-
able evidence? And how might one avail themselves of these resources? These
questions are addressed in this chapter.
SCIENTIFIC EVALUATION OF PSYCHEDELIC MEDICINES
1
Where does the field of psychedelic medicine stand with respect to
scientific and clinical evaluation? In order to assess this question of where
the field of psychedelic medicine stands as an established set of treatment
tools with potential for the future, we employ the standard model of
different phases of evaluation, briefly outlined by Frecska (this volume).
This involves:
Phase I studies which are primarily intended to evaluate safety (toxicity),
side effects, and safe dosage range, normally using small groups of healthy
subjects;
Phase II trials which use small groups of strictly selected patients to further
evaluate safety and to determine effectiveness and ideal doses for targeted
illnesses;
Phase III trials which use randomized clinical trials with large groups of
patients, who may have diverse comorbid conditions, to confirm effectiveness,
monitor adverse drug effects and interactions, and compare the effects of the
new substances with commonly used treatments; and
Phase IV trials take treatments that have been shown as effective for a condi-
tion and use additional controlled trials to determine additional information
regarding side effects, safety, long term risks, and benefits, and to perform com-
parisons with other procedures for the same condition.
Because of prohibition over the last 35 years, there have been difficulties
in achieving these phases of evaluation for the psychedelic medicines. Conse-
quently, our approach to assessing the evaluation of these medicines has to be
broader, and at times retrospective (in contrast to the prospective design of the
premarketing trials of the legal drugs) specifically:
Phase I studies relying on patient populations that have the possibility of
showing risks (adverse reactions) where none would exist in normal populations;
and Phase II studies that evaluate outcomes in patient populations, but not always
with the benefit of the double-blind studies. This leaves open the possibility of
placebo effects, but for reasons discussed below, this may be viewed as an
acceptable part of a complementary treatment that relies on set and setting effects
as basic to psychedelic therapeutic processes. We characterize Phase II evidence
as “limited” when lacking certain features such as the benefit of double-blind
controls or having been carried out with nonstandard patient populations.
Table 15.1 summarizes the data that has been presented by the authors of
the chapters here in this volume and Volume II. We suggest that this indicates a
generally well-established safety in studies to be considered here as Phase I.
To the extent that there are Phase II trials, many reflect the practices of the
1960s and consequently have lacked the standards of DBCS expected in today’s
more rigorous methodological climate.
Nonetheless, these less than ideal earlier studies, combined with a variety
of case studies and user reports and epidemiological studies, substantiate that
the broad range of psychedelic medicines are safe and apparently effective
adjuncts for a range of conditions, particularly the addictions (also see Volume
II). However, because of the lack of open research possibilities, we do not have
the full range of studies normally done to evaluate toxicity, nor effective trials
for Phase II and beyond for most of these substances.
While the double-blind clinical trials are limited, other forms of evidence can
be used. As Frecska (this volume) indicates, even when we include the statistics
on abuse as opposed to responsible use, there is evidence of little physical harm
272 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
from psychedelic medicines (Strassman 1984, 1994; Nichols 2004). Other
epidemiological approaches such as the use of cross-sectional (e.g., comparing
uses and nonusers) as well as retrospective (i.e., life history studies of users)
and longitudinal data can help reveal risks—or lack thereof. Such study methods
can be applied to cohorts of psychedelic medicine users and when compared to
appropriate matched control groups or population norms, can provide a basis
for asserting scientific evidence of safety.
As McKenna points out (this volume) with respect to ayahuasca, while
we lack controlled clinical trials, evaluations based on clinical judgments
of experienced practitioners point out that there is substantial evidence that the
psychedelic medicines are effective in the treatment of a range of conditions.
As Alper and Lotsof (Volume II) point out in their assessment of ibogaine, we
can begin to employ more complex, albeit less traditional, forms of validation
through a “triangulation” that combined data derived from animal research, the
numerous medical case studies and personal accounts of those who have received
these substances as treatments, and limited published case series. This would
constitute what we discuss here as “limited” evidence. Other criteria of the
effectiveness of medicines would include clinical judgment based on extensive
experiences (e.g., Grof 1979; also see Volume II chapters by Grof, Merkur,
House, and Walsh and Grob; similar cross-cultural uses and alleged effects (inde-
pendent invention/discovery); patient satisfaction and enhanced ability to engage
activities of daily living and lifestyle; and pharmacological studies indicating
biological mechanisms of action of active ingredients.
Ketamine: An exception to these generally cautious assessments of the
evaluation of these psychedelic medicines is ketamine (see Krupitsky and Kolp,
Volume II), which has received FDA (Food and Drug Administration) approval
for other uses and has been widely employed for the treatment of addictions in
Russia. These applications of ketamine were primarily as a research activity
and were NOT officially registered with the Russian Ministry of Health for
approval as adjunct in the therapeutic treatment of addictions. Nonetheless based
on his assessment of the rules of the FDA, Kolp (pers. comm.) characterizes the
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 273
Table 15.1 Phases of Evaluation of Psychedelic Medicines
Psychedelic Phase 1 Phase II Phase III Phase IV
LSD Yes Limited
2
MDMA
3
Yes Currently
DMT
4
Yes No
Ayahuasca
5
Yes Limited
Psilocybin
6
Yes Yes
Mescaline/peyote
7
Limited Limited De Facto
Ketamine
8
Yes Yes Yes Current
Ibogaine
9
Yes Yes
Marijuana
10
Yes Yes
research of Krupitzky and his colleagues as constituting the completion of Phase
I, Phase II, and Phase III clinical trials in the ketamine psychedelic psychothera-
peutic treatment of alcoholism and opioid dependence. Currently, their research
constitutes the beginning of Phase IV in the United States as Kolp and colleagues
are initiating multicenter, randomized, double-blind studies of the ketamine
psychedelic psychotherapy. Krupitzky and colleagues are similarly at this phase,
currently treating in excess of 1,000 patients with ketamine psychedelic psycho-
therapy (Kolp, pers. comm.; see Krupitsky and Kolp, Volume II). Ketamine
constitutes a special case among the psychedelic medicines since it was already
an FDA-approved drug for more then 35 years ago. The FDA does not requires
the same registration procedures for a new (”off-label”) treatment as it does
for a new drug. Since its initial approval, research has been conducted on
ketamine off-label uses in the treatment of a variety of conditions including
chronic pain disorder, intractable seizure, strokes and heart attacks (Kolp,
pers. comm.).
Are Double-Blind Studies Appropriate Criteria for
Psychedelic Medicines?
The authors of our chapters have tempered their encouraging results from
preliminary studies with reminders that psychedelic medicine has not yet met
the criteria of establishing medical safety and efficacy with DBCS. This “gold
standard” of biomedicine might seem to be the appropriate response from a pro-
fession (and society) that prides itself on the use of science to make decisions
regarding health resources. But is this in fact what happens? Does biomedicine
itself rely on the gold standard of DBCS to determine what treatments we can
receive? Or is the “gold standard” a kind of “double standard,” an ethnocentric
judgment applied more to others’ medicines rather than one’s own?
A variety of studies realized by agencies of the U.S. government have found
that only about 20–30% of commonly used biomedical procedures had actually
been tested with double-blind clinical procedures (see Cassiday 1996; McKee
1988 for references and discussion). Most of biomedicine’s common daily prac-
tices are not substantiated by the strictest criteria of medical science. No DBCS
are carried out on the use of multiple medications simultaneously, a common
aspect of biomedicine that causes drug interaction effects that constitute a major
cause of death in the United States.
The reasons why biomedicine does not rely strictly on DBCS are legion—the
difficulties with control conditions and blinds (e.g., what is involved in a double-
blind procedure for cardiac bypass surgery?); the ethical problems produced by
withholding a potentially effective treatment from someone who needs it in the
interest of a scientific study; and the funding sources and research priorities of
drug companies.
Biomedicine and the other ethnomedical traditions of the world rely on many
forms of evidence to establish some degree of certainty about the efficacy of their
274 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
procedures. What should be the standards held for the use of psychedelic medi-
cines? This depends on the specific medicines, patients, and conditions.
But in spite of limited scientific studies of psychedelic medicines, most have
passed Phase I evaluations as generally safe, providing evidence that supports the
widespread application of psychedelic medicines, reclassified as Schedule II.
The range of conditions for which psychedelic medicines have been used are
limited, but given the wide range of uses found cross-culturally (e.g., see Schultes
and Winkelman 1996; Schultes and Hofmann 1979; Winkelman, Volume II) , they
ought to be evaluated for a wide range of supervised uses for many different con-
ditions including physical diseases and psychosocial and cultural-bound illnesses.
The DBCS must be understood in the context of the effort to separate the
placebo effect from the pharmacological action. These placebo effects are part
of the well-recognized powerful set and setting effects that determine the major
outcomes from use of psychedelic medicines. One of the challenges of psyche-
delic studies is the notorious difficulty in maintaining a double blind in it, as the
powerful effects become quickly apparent to patients and clinicians. Further-
more, the scientific necessity for control of the placebo effect is at odds with
the intent of many applications of psychedelic therapies, where the medicines
are used to amplify the set and setting effects through intention and focus of
attention and interactions with others. The placebo effects of set and setting are
so powerful in the case of psychedelic medicines as to have produced three major
paradigms of the psychedelics’ effects: psychomimetic, psycholytic and psyche-
delic (high dose) (Passie, this volume; Yensen 1985, 1996; Bravo and Grob
1989; Grob and Bravo 1995)
The effects of psychedelic medicines are to a great degree dependent on the
social dynamics and interpersonal relations of the sessions. This makes them
amplifiers of other dynamics and enhancers of other processes. This illustrates
that an important part of the mechanism of psychedelic medicines is the
placebo-psychological effect in a very broad way. Psychedelic medicines seek
to enhance placebo effects, and based on numerous self-reports they do. Control
procedures designed to reduce placebo effects also counter the basic mechanisms
affected by psychedelic medicines. If a basic premise of psychedelic medicine is
to enhance set and setting effects, placebo effects need to be included with the
treatment effect, not separated from it.
This notion of including the placebo may seem alien to medical researches
steeped in the traditions of the DBCS. But such approaches are becoming a stan-
dard in the context of integrative medicine, where the traditional biomedical
treatments are being integrated/combined with the so called alternative medicines
in a complementary fashion. The assessment methods in these approaches com-
pare patients receiving the standard biomedical treatment alone with patients
who receive standard biomedical treatment plus the “alternative/complementary”
treatment. Such additive models are often advocated by supporters of psychedelic
medicines, who see them as adjunctive to aspects of standard psychotherapeutic
care.
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 275
A closing note on the appropriateness of double-blind studies for evaluation
of psychedelic medicines should also consider the notorious difficulty in achiev-
ing this for medications that have such powerful effects. The ability of both
patients and clinicians to break the blind in psychedelic studies is well known.
The powerful effects of these substances make it difficult to come up with an
appropriate control that evokes similar powerful experiences without compro-
mising the uniqueness of the psychedelic medicine (but see Griffiths et al.
Volume II). Consequently, the integrative open-label model may ultimately be
the best model for evaluations of psychedelic medicines, assessing how their
adjunctive use enhances the outcomes ordinarily achieved with standard
biomedical practices. And if this includes in part a placebo effect, we should em-
brace this as a positive outcome to be enhanced with the psychedelic medicines.
USE OF ANALYTIC DESIGNS FROM EPIDEMIOLOGY FOR PSYCHEDELIC
MEDICINE RESEARCH
The methods that epidemiologists use to identify risk factors associated with
specific diseases can be used to assess risks for psychedelic medicine use (see
Frecska, this volume) as well as the possible effectiveness of their use as treat-
ments for specific diseases. Epidemiological methods such as case control and
cohort studies (see Kelsey et al. 1996) can be used to examine at outcomes of psy-
chedelic medicine treatments. For instance, in the case of Sewell and Halpern’s
research (this volume) on the effectiveness of psychedelic medicines in the treat-
ment of cluster headaches, effectiveness can be assessed using methods such as
case control studies. This involves comparisons of those psychedelic medicine
“self-medicators” with a matched group that relied strictly on conventional medi-
cine. Case control studies draw inferences by making comparisons of a target
group (e.g., cluster headache patients who have experienced prolonged remission
from psychedelic medicines) with a matched control group of cluster headache
patients who have not them. Similarly, case control studies can make inferences
about the level of effectiveness of ibogaine treatment of heroin addictions
by making comparisons of the period of sobriety of heroin users who have taken
ibogaine with a control group of heroin addicts in recovery who have not used
ibogaine.
The relative ease of quick comparisons with case control studies can make
them useful for initial screening of the effectiveness of psychedelic medicines in
the treatment of new and intractable diseases or infrequent diseases. While there
are disadvantages to case control methods because of lack of accurate information
on risk factors and confounding variables, and recall bias, if the time sequence for
disease and exposure to psychedelic medicines can be established, there is a better
basis to infer cause and effect relationships. Cross sectional (prevalence) studies
normally assess data from a relatively short period of time. These studies normally
assess exposure and disease at the same time (e.g., hallucinogen use and cluster
headache symptoms), and then assess the prevalence of the cluster headache
276 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
condition in the different groups (psychedelic medicine users vs. nonusers).
In epidemiology, it is routine to use cross-sectional methods to assess existing
cases of disease and compares the rates for groups with and without exposure to
specific factors. Cross-sectional studies are particularly suited for studying dis-
eases that have a slow onset and long duration and are generally not identified
and cared for until they have reached advanced stages. This makes it possible
to see, for instance, if hallucinogen use may be preventive in some disease.
Retrospective (or historical) cohort studies can use medical history interviews to
determine the possible relationship of prior disease of psychedelic medicines to
the manifestations of conditions.
SUMMARY OF PSYCHEDELIC MEDICINE TREATMENT POTENTIALS
Halpern (Volume II) makes the point that considering the limited efficacy of
current treatments for drug addiction, a problem that is evidenced in the high
rates of chronic relapse for these conditions, the use of psychedelic substances
for treatment of drug dependence is an ethical responsibility of the medical field.
Given the much greater safer safety profile of the psychedelics compared to
major addictive drugs (see Frecska, this volume), even repeated use of psyche-
delic medicines as treatments is more ethical than professional maintenance/
treatment programs employing drugs of high abuse or substitutes (e.g., metha-
done treatment or supervised application of heroin
11
) because of their abuse and
overdose potential.
Unfortunately, this option of safer and likely more effective treatment is
generally precluded by the control exercised by administrative law. This makes
it a moral responsibility of politicians to reverse this three and a half decade
prohibition on the use of these valuable medicinal substances.
As Frecska summarizes in his chapter here, we have begun to see the use
in well-controlled Phase II trials of several psychedelics such as ibogaine, mari-
juana, MDMA (3,4 methylenedioxymethamphetamine), and psilocybin.
But because of the great cost of a Phase III studies, there is little hope that we will
see these proceed without some changes in the government funding or industry
approaches that will make these substantial investments. Goldsmith (Volume II)
points to the need for changing the policies of bureaucracies, particularly at the
level of the U.S. Department of Health and Human Services, where the bureauc-
racy resists drug policy and research changes even where permitted by law. This
requires a public relations approach to changing public perceptions, which have
as of yet been a failure for those who favor drug policy reform. Goldsmith out-
lines processes of moving from awareness of issues to a broad enough public
interest to support changes in administrative policies that can lead to ultimately
achieve approval of these medicines as legitimate and mainstream approaches.
He points to a strategy of targeting people who are organizational levers and
administrative decision makers who are key to the introduction to new programs
and policy directions.
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 277
This will require strategic alignments with other interests, and Goldsmith
points out that treatment of central social problems such as addictions is a good
point at which to focus initial energies. Part I of Volume II attests to the wide
range of successful applications of psychedelic medicines to addictions. But to
change the political climate in the United States greater development of educa-
tion and advocacy groups will be necessary. These are the functions of many
organizations, including Drug Policy Foundation, DPA (Drug Policy Alliance),
MAPS (Multidisciplinary Association for Psychedelic Studies), and the CCLE
(Center for Cognitive Liberty and Ethics).
In the following sections we address four major interrelated approaches to
enhancing responsible access to psychedelic medicines through:
• Utilizing currently available psychotherapeutic and religious resources;
• Altering social attitudes through education and the media;
• Changing administrative policies through public policy, judicial, and
legislative approaches; and
• Inventing new approaches through a business or corporate model.
SELF-ADMINISTERED THERAPY
In Volume II, a variety of our authors (e.g., Merkur, Goldsmith, and House)
illustrate that a wide range of clinical knowledge has been developed regarding
the safe and effective use of psychedelic medicines. It should be noted that thera-
peutic recommendations for the use of psychedelic medicine includes the pres-
ence of qualified therapists. While there are uses of psychedelic medicines that
focus on individual self-administration (see Winkelman, Volume II), even those
are generally under the supervision of experienced healers. How does one get
qualified supervision in the current legal context?
Foreign Sources
The general lack of legal access to psychedelic medicine in the United States
suggests foreign treatment sources as a primary means of access. Foreign oppor-
tunities for loosely structured self-directed psychedelic therapy are found within
the mestizo and new age ayahuasca and San Pedro traditions of Peru. More
formal treatment protocols are available for the treatment of various addiction
problems, as discussed in the chapters by Mabit, Krupitsky and Kolp, and Alper
and Lotsof in Volume II.
The loosely self-administered therapeutic applications of ayahuasca mani-
fested in the international “drug tourism” (Dobkin de Rios 1994) provide
many North Americans and Europeans the therapeutic potentials of ayahuasca.
Ayahuasca ceremonies are available in much of South America, particularly the
Amazonian countries. Winkelman (2005) discovered that these people are in
278 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
search of the kinds of powerful personal and spiritual healing provoked by psy-
chedelic medicines. Contrary to the search for hedonistic highs implied by the
characterization as “drug tourists,” their principal motivations are characterized
by seeking spiritual relations and personal spiritual development; various forms
of emotional healing, particularly unresolved traumas; and the development of
personal self-awareness, including some sense of direct contact with a sacred
nature, God, spirits, and plant and natural energies produced by the ayahuasca.
Their motivations for their journeys andtheperceivedbenefits that they report
both point to transpersonal concerns. The principal perceived benefits involve
increased self-awareness, personal insights, access to deeper levels of the self that
enhance personal development, and expressions of the higher self which provided
personal direction in life (Winkelman 2005).
Wasiwaska, a Research Centre for the Study of Psychointegrator Plants,
Visionary Arts, and Consciousness established by Luis Eduardo Luna, exempli-
fies a multifacted organization focused on the provision of private group therapy
with psychedelic medicines. Wasiwaska (the House of the Vine) is a legal Brazil-
ian nonprofit organization located in Floriano´polis, Santa Catarina, in southern
Brazil. This institute also promotes a variety of research projects on ayahuasca.
Domestic Adaptations to Prohibition
Eventually, there may also be several other approaches available to those
remaining in controlled areas through various forms of self-medication as
an adaptation of shamanism. These self-medication approaches may be both
solitary or interpersonal “recreational consumption,” or could potentially occur
in professional settings that are integrated into a semi-structured group thera-
peutic setting with ritual activities and processing. Psychotherapists might be
protected in an occasional practice where clients self-administer psychedelics
in a group retreat setting (see relevant discussion in Boire, this volume). Thera-
pists could probably find protection by disclaimers and the provision of other
natural altered state of consciousness induction practices as part of spiritual
healing practices (e.g., see Winkelman’s chapter on shamanic guidelines
in Volume II). Therapist could obtain greater protection from persecution by
providing “psychedelic retreats” managed by therapists and in which each
client brought their own preselected particular psychedelic medicine.
Some other psychedelic treatments may not require the group dynamics to
the same degrees, such as with the cluster headaches. As Boire discusses, such
people who find themselves driven to self-medicate with psychedelics might be
legally protected through documenting their medical needs and frustration with
conventional medicines.
It is imperative that we apply psychedelic medicines to the treatment of some
of the most ravaging social diseases of our times, the addictions to alcohol,
tobacco, and opiates and their synthetic derivatives. The generally acknowledge
success rate in the addictions treatment industry does not appear to be much
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 279
different from the spontaneous remission rate. And while Alcoholic Anonymous
and its derivative organizations do provide some degree of treatment success, it is
obviously not a successful venue for most addicts.
The range of psychedelic addiction treatments is truly impressive, as we
will see in the chapters of Part II, Volume II. Peyote, ibogaine, ayahuasca, LSD
(lysergic acid diethylamide), and ketamine are among the psychedelic medicines
for which we have substantial evidence of their effectiveness in addictions
medicine.
Religious Therapies
The existing legal frameworks discussed by Fenney (this volume), and
Groisman and de Rios’ (this volume) discussion of the cultural contexts of the
Brazilian Ayahuasca religions and the U.S. Supreme Court justices decisions,
establish some broad parameters within which religious formation, conversion,
and evangelism might extend the therapeutic applications of psychedelics as sac-
raments and entheogens. The ability to establish new U.S.-based local churches
of the Brazilian Ayahuasca churches may be protected in the current judicial
climate. Brazilian Ayahuasca religions coming to the United States are a likely
possibility. In fact, they are here now. Existing American religious groups
(e.g., Unitarian Universalists) could conceivably engage in ecumenical outreach
to ayahuasca churches, inviting them to the United States to share their
sacraments and expand religious/pastoral counseling through using psychedelic
medicines as entheogens.
The broader range of spiritual applications are indicated by authors in
Volume II, particularly the chapters by Grof, Walsh, and Grob, Marsden and
Lukoff, Winkelman, and who point to the transpersonal uses of these medicines.
The potential applications of these substances as entheogens are among the most
widely established in human history, although their place in modern medicine
has yet to be determined. Yet the work of Griffith et al.’s (Volume II) illustrates
that these spiritual applications are reliably induced by psychedelic medicines,
pointing to a relatively unexplored aspects of human well-being that are
addressed by psychedelic medicines.
EDUCATION AND IMPROVING PUBLIC KNOWLEDGE
Education about the actual effects and potentials of psychedelic medicines
and other drugs is a crucial aspect of increasing the use of these resources, backed
by the knowledge of the parameters of their safe use and efficacious effects.
A variety of policy organizations (see next section) have attempted to change
the opportunities regarding drugs through an education approach that focuses
on affecting public health policy. Their focus is to educate society, legislators,
and administrators regarding regulation of drugs based in science, compassion,
280 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
and activities that enhance health and protect human rights. Education is a central
tool in addressing the misinformation, fears, and prejudices that contribute to the
legal and administrative attitudes that waste resources in punitive activities and
prohibition efforts that produce more problems than they solve. Many problems
of addiction are caused by the drug war and oppressive judicial and administra-
tive measures rather than the drugs. Through education we can best hope to
advance drug policies that reduce harms of drug misuse as well as drug
prohibition. The kinds of evidence our authors provide in these two volumes are
a contribution to similar efforts. Two other educational venues merit special
notice—schools and the media.
Schools
When things in my (Roberts) honors seminar “Foundations of Psychedelic
Studies” start to drag a bit, I have found a topic that always enlivens the discus-
sion—the DARE drug education program. Spiced by snickers, guffaws, and roll-
ing eyes, the discussion heats up, and almost everyone in my class has a “horror
story” about this futile program. Why is drug education in failing health, and
how can it be revived? Truth is a powerful serum, but drug education programs
are about “Keeping kids off drugs” not about telling the truth, the whole truth,
and nothing but the truth.
Unfortunately, the biased and slanted information that my students report
represents the general state of drug education and public knowledge, both formal
education in schools and informal education in the news media. We hope these
two volumes will be a segment of the whole truth. And, of course, we are present-
ing up-to-date ideas on some medical aspects of psychedelic drugs, while a full
picture would be vast and include not only psychedelic drugs but also other
psychoactive drugs, and it would stretch beyond medicine to the arts, sciences,
religion, and elsewhere.
One reason our culture has such a difficult time thinking clearly about drugs is
that our system of ideas is adapting only slowly to recognize that there are benefits
of using other mindbody states (states of consciousness) in addition to our
ordinary awake state (Roberts 2006). When the psychedelic 60s erupted decades
ago, an interest in mindbody practices such as meditation, yoga, or breathing
exercises were largely misinterpreted and mistrusted. Now churches teach media-
tion, park districts and schools offer yoga classes, and health professionals teach
relaxation exercises; over the decades, our culture is becoming educated about
the benefits of mindbody psychotechnologies and coming gradually to accept
them. Also, during this time the number of prescribable, psychoactive medicines
has—ahem—mushroomed. Culturally, we still have much to learn from some
premodern societies about other mindbody states, ways to access them, and how
to use them (Winkelman, this volume and Volume II).
From a scientific perspective, presenting partial information as if it were the
whole story is little different from lying. Everything one says may be true, but if a
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 281
biased selection of the information misrepresents the whole evidence, this is
likely to lead to a misleading conclusion. This is the way lawyers work, not scien-
tists: lawyers start with the conclusion and marshal evidence to support it. Along
the way, they disregard conflicting information. (It may be no odd occurrence
that most politicians, who set drug policy and fund drug education, are lawyers.)
Scientists, on the other hand, will include all the information and ask: “What con-
clusions does this evidence require us to make?” Most drug education programs
work in the lawyerly way: they start with the conclusion that all drug use is
bad, then they collect the information that supports their prejudged conclusion.
This has a tragic downside: judging from my sample of college juniors, when
we present biased information about drugs, students come to recognize this and
throw out the realistic cautions because of the exaggerated fears. If anything they
are taught is wrong or misleading, the baby of realistic warnings gets thrown out
with the dirty waters of lies and exaggerations.
News Media as Educators
On a wider social scale, our educators are the news media, and with some
notable exceptions, they are little better than DARE.
A DOZEN HANDY GUIDELINES FOR REPORTING ON DRUG RESEARCH
In 1997, a group of leading scientists, law enforcement specialists, and health
policy experts proposed a 14-point Principles for Practical Drug Policies (Feder-
ation of American Scientists). Among the 14 policies they recommend as “a
middle way” was a drug policy based on scientific evidence, civility toward those
with different solutions, and honesty about facts, proposals, and motives. How
might a responsible news media write fact-based news stories and educate people
on psychedelics and other psychoactive drugs? The following questions will help
reporters clarify drug issues, and readers judge the content of the stories they read.
When they receive information about drug studies or talk to officials, they
can ask the following questions.
Was the drug used actually the same as the drug reported on? During the
early press reports of MDMA (Ecstasy, X, and the rave drug), the press reported
results of MDA (methylenedioxyamphetamine) research as MDMA research.
Even a very slight change in a molecule can greatly change its biological and
psychological effects.
Was the route of administration the usual route? The effects of a drug vary
greatly according to the four S’s — whether it is smoked, swallowed, snorted,
or shot. For example, when a drug is swallowed, a great many biological events
take place in the stomach and liver before the drug is generally circulated in the
blood stream. Injections, which are usually used in animals, bypass this process.
When a drug is smoked, some chemical structures are broken, and new chemicals
can be formed.
282 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
Was the research in vitro (test tube) or in vivo (in living organisms)? Sub-
stances induce a cascade of biological events in living organisms, but this number
is drastically diminished in a test tube. Some side effects (both desirable and
undesirable) are missed in the test tube, and some effects that appear in the test
tube would not occur in a living body, or would occur at a much diminished
degree.
Was the dosage typical of common usage? It makes little sense to claim a
drug has an affect if the dosage was extremely high or low. When a researcher
reports that the dosage was, say, “x milligrams per kilogram of body weight,”
reporters and readers or TV viewers should ask, “What is the typical concentra-
tion in a typical user?” Researchers should compare the experimental dose with
the typical use. It is helpful to think of street use in terms of a normal curve,
which range from very low to very high doses, but with the majority in the
middle. Where do the problems derive? From “normal” doses or the high
extremes?
Was the research done on people or other animals? Reports of behavioral
change by psychoactive drugs in animals are minimally generalizable to humans.
Biological activity such as attachment at receptor sites is more applicable. The
lack of generalizability is especially true for drugs which are taken primarily
for their effect on thinking and emotions. What does it mean to say that a drug
effects cognitive processes of a rat or gives a sense of well-being to a monkey?
Was an alleged drug actually the drug taken? This is especially a problem
with “street drugs.” A dealer who is out of a certain drug may substitute another,
and the purchaser may attribute his/her experience to the wrong drug. This is also
a problem with dosage and contamination. Information based on street drugs and
research based on pure laboratory samples may or may not apply to each other.
How typical is an expert’s report of a drug’s effects on humans? Doctors,
police officers, and mental health professionals are likely to see people who have
had bad effects of drugs. Although their sample is skewed toward reporting ill
effects, it probably is useful in answering the question, “What are the possible
dangers of this drug?” Their experience is not accurate in answering, “What is
atypical effect of this drug?” Asking most drug specialists about drugs is like ask-
ing a divorce lawyer about marriage.
Does “drug-related” mean “drug money related”? Most “drug related
violence” does not come from using drugs but comes from fighting over
the money associated with drugs—to obtain the money to buy drugs, fighting
over the profits, intergang competition, debts, etc. Drug trafficking is a lucrative,
tax-free business that is engaged in for profit.
What are the “set” and “setting?” In human subjects, major effects of
psychoactive drugs result from the person’s “set” (expectations, mood, and frame
of mind) and “setting” (location). In psychoactive drugs, set and setting are
primary influences. This applies less to drugs which are taken for somatic, bodily
purposes; thus, when medical doctors think about the effect of a psychoactive
drug, they may not recognize the primacy of its set and setting.
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 283
Why do people do this drug? Whenever a large number of people do some-
thing, it is worth assuming there are many reasons, and most people probably
have a mixture of reasons. A way to test the expertise of an alleged “expert” is
to probe to see if he or she recognizes multiple reasons why people like drugs.
It is worth asking, “What benefits do people who use this drug think (rightly
or wrongly) they are obtaining?” The more complex the answer, the greater the
likelihood you have a well-informed “expert.”
Talk to people who have actually taken the drug. The news stories I read
seem to rely on third parties telling why they think people do the drug being
reported on. “Peer pressure” and “to escape reality” are probably true some of
the time, but if we want to write policies to affect people’s behaviors, can we
do so without knowing why they do those behaviors? Most people voluntarily
take drugs because—rightly or wrongly—they think they benefit from doing so.
What are these alleged benefits?
Why are you telling me this? Reporters and editors are taught to be skeptical,
always to have the questions “Why are you telling me this?” and “What will you
gain if I report this?” in the back of their minds. But for some reason, they naively
switch off these questions for drug stories. They know that other governmental
press releases, news conferences, and interviews are provided in order to get
an agency’s message across, and an implicit or explicit background theme for
many such news events is we need more funding. Since the funding of drug war
agencies depends on their ability to scare people about drugs, the bigger the
scare, the greater the funding.
Unfortunately, much drug reporting is naive, divisive, sensationalistic,
and simplistic. Reporters can educate the public and increase the accuracy
of their stories by exercising the common skills of reportorial skepticism, and
readers can understand drug news stories better by asking questions based on
common sense.
PUBLIC HEALTH POLICY, JUDICIAL, AND LEGISLATIVE
APPROACHES
There is a surprising large number of organizations supporting reform in
drug policies and rational approaches based on both rational evidence and human
caring.
Drug Policy Alliance
12
The DPA (see www.drugpolicy.org) points out that it is the state legislatures
which have traditionally been at the forefront of policy change on drug laws.
Local context provides “laboratories” for experimenting with new ideas and
potential solutions. This isexemplifiedindrugpolicyreformonissuessuchas
drug sentencing, medical marijuana use, overdose prevention and treatment
284 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
programs, and the expansion of drug treatment services. The “Drug Policy
Reform: the State of the States, 1996-2002” (DPA, www.drugpolicy.org) summa-
rizes many of these developments promoted by local voters and state govern-
ments who have enacted more than 150 significant drug policy reforms
during the last decade. While the DPA’s focus on education has focused on mari-
juana and other commonly used illicit drugs, it has provided a context within
which to discuss alternatives to current drug policies and treatment alternatives
to incarceration.
For example, the DPA organized voters in Oakland, CA, to support Medical
Marijuana use through a ballot measure that established a framework for decrimi-
nalizing marijuana and making it the local police’s lowest enforcement priority,
instead focusing their resources to address violent crime. Although local ordinan-
ces have allowed for local use of some substances such as marijuana, there
has been a constant battle with the federal authorities who feel that they are not
limited by state initiatives.
A significant feature of the policy advocacy has been a focus on harm reduc-
tion strategies that attempt to reduce problems, particularly those associated with
enforcement. The ideas of reducing harms can be expanded to appreciating
potential benefits where substances have proven medicinal uses, maximizing
potential benefits of psychedelic medicines through their judicious use. These
possibilities for the broader use of psychedelic medicines have not yet been a
significant focusing of the referendum process, the milder marijuana typically
being the focus of the referendum process. Nonetheless the role of the DPA
and similar activist organizations in supporting the development of legislative
and referendum work at the state levels leaves open the possibility of legislated
treatment programs in the same way that we have seen legislated needle
exchange and methadone programs.
A significant feature of this multifaceted approach has been to include a con-
tinued and expanded resistant to the War on Drugs. The immense expenditure
focused on the arrest, prosecution and incarceration of tens of thousands of
persons each year for crimes associated with the possession and use of illegal
drugs has led to an erosion of many constitutional rights. The War on Drugs is
a war on public health that has been resisted by public health organizations
such as the American Public Health Association, as well as other professional
organizations such the American Society of Addiction Medicine, the National
Association of Alcoholism and Drug Abuse Counselors, and the American
College of Obstetricians and Gynecologists.
Center for Cognitive Liberty and Ethics
13
Combined education and legal approaches have been emphasized by
the CCLE (www.cognitiveliberty.org) as well. The CCLE is a network of
scholars that address issues in the intersection of law and policy issues as they
pertain to cognitive freedoms to use psychedelic medicines and other drugs.
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 285
Their educational and policy approach has addressed policies necessary to
preserve the ethics of the freedom of thought regarding these substances.
The clinical applications of psychedelic medicines clearly move the con-
cerns beyond the context of purely medical use and into the improvement and
enhancement of cognitive abilities. They emphasize the importance of protecting
personal freedoms involving the exploration of the capabilities of our own minds
as a direct right as long as it does not directly harm others. There are many forms
of resistance to the governments’ efforts to limit and criminally prohibit forms of
consciousness and cognitive enhancement. The CCLE has emphasized the
importance of social impact litigation as a process for broadly advancing the
potential to exercise our cognitive liberties, and has filed legal briefs on the topic
of cognitive liberty in federal court. But central to their efforts is raising aware-
ness of the emerging issues of cognitive liberty through outreach and education
campaigns designed to provide people with the information necessary so that
they can empower themselves to participate meaningfully in public discourse
and affect relevant democratic processes.
Multidisciplinary Association for Psychedelic
Studies
14
The combined public education, research, and policy efforts necessary to
change the political climate limiting the use of psychedelic medicines are
exemplified in MAPS (see www.maps.org). MAPS is a membership-based non-
profit research and educational organization founded in response to increasing
governmental control exemplified in the classification of MDMA as a Schedule
1 drug by the DEA (Drug Enforcement Administration). MAPS exemplifies the
private sector organizations that take a multifaceted approach to changing the
political climate through education, organization of local political efforts,
lawsuits, and research funding. Its scope of activities range from a research
mission engaged in sponsoring scientific researchers to spearheading efforts to
obtain governmental approval for research projects, engaging in fund raising
activities, and conducting and reporting on psychedelic research to make neces-
sary information available to legislators, administrators, and the voting public.
MAPS programs exemplify the need to address these issues of personal con-
sciousness and cognitive freedom, embodied in the conflicts of the politically and
ideologically driven War on Drugs with personal and scientific freedoms. This
negation of science has led to gross social problems, embodied in economic, civil,
and social problems from drug enforcement rather than drug use. MAPS has
played a significant role in pointing to the source of these conflictive societal
dynamics in the deep-seated cultural traditions, and the collective and individual
ambivalence about spiritual experiences. MAPS seeks to achieve a balance
between adequate control of powerful psychedelic medicines and the rights of
scientific researchers, clinicians, patients, and people with a nonmedical interest
in the applications of these in spiritual, recreational, and creative contexts.
286 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
Through the funding of research, MAPS contributes to the development of
beneficial applications of psychedelic medicines in psychotherapeutic practices
and physiological research, as well as treatment of pain and addictions
and exploration of spirituality, creativity research, shamanic healing, psychic
abilities, and a range of research projects on brain physiology. It supports a range
of projects (e.g., see chapters in this volume, such as Abrams’). Because of
funding provided by organizations like MAPS, research teams are able to
operate in other countries where restrictions are less onerous (e.g., Canada,
Israel, Russia, and Switzerland).
The Federal government’s administrative apparatus has proven to be
a major impediment to research, imposing a range of administrative barriers
that preclude access to needed medicines or approvals for studies (e.g., see
Strassman 2001). MAPS has sponsored lawsuits against DEA for their refusal
to issue the required permits for growing facilities, access to drugs and approvals
for applications, a venue that will be increasingly necessary to fight against
the arbitrary bureaucratic impediments to legitimate research and treatment
[also see Doblin’s (2001) doctoral dissertation “Regulation of the Medical
Use of Psychedelics and Marijuana”].
The need to act at the level of the election of sympathetic federal officials—
including the president—is emphasized in the MAPS statement that “there
will probably be no privately-funded medical marijuana research effort ever
started until a more reasonable President is in office.” Other venues of action
for overcoming administrative and judicial impediments could include a
campaign of pressure through letters of support from members of Congress to
influence the DEA Administrator to make favorable recommendations. In the
face of federal level opposition to research, the development of state-level
reforms becomes even more significant.
But organizations such as MAPS depend on public support, which is
limited and insufficient for the range of research projects currently awaiting
support. MAPS uses private donations and other forms of fund raising to
acquire resources to fund research for scientists to design studies, seek funding,
and obtain necessary institutional and governmental approval for studies
into the risks and benefits of psychedelic medicines. A specific focus of
MAPS’ mission has been to sponsor scientific research necessary to seek
FDA-approval for the use of psychedelics and marijuana as prescription
medicines. This also requires a public education approach to provide
correct and honest information about the risks and benefits of psychedelic
medicines.
MAPS educational mission is complemented in its operation as a nonprofit
pharmaceutical company with the priority of researching the potential of
MDMA (Ecstasy) and marijuana as FDA-approved prescription medicines.
The formidable expenses normally involved are illustrated in the MAPS estimate
of a $5 million cost for the five years of research necessary to meet FDA
criteria for the safety and efficacy of a single psychedelic medicine for just
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 287
one clinical indication. These costs make the idea of a business model—a corpo-
rate approach—an almost necessary avenue for exploration and development in
the current political climate.
A CORPORATE SOLUTION
How might we use psychedelics most advantageously and at the same
time limit their risks? As these two volumes of this book and especially this chap-
ter and the concluding chapter of Volume II show, the diversity of psychedelics’
possible uses leads to a diversity of ways to embed them in existing institutions
and possibly new ones. In these concluding chapters, we regard only a few
of them.
When I (Roberts) first considered a corporate answer to how to develop
psychedelics safely and efficiently, I thought about writing an essay proposing
such a company, but my thoughts kept leapfrogging from ordinary sentences
and paragraphs to imagining what a prospectus for such a company would look
like. How could these ideas make sense to Wall Street types? How might the City
act? Rather than write a straightforward narrative essay and hope that some day
the essay would inspire a startup company, my mind jumped immediately to a
prospectus-as-essay.
Like science fiction, this part of our concluding chapter is business fiction.
Scifi ideas often presage actual events and inventions. Similarly, this attempt at
bizfi may foretell the future too. Here are selected ideas from that longer, fictional
prospectus.
PRELIMINARY PROSPECTUS
Community Psychedelic Centers International, Inc.
Incorporated in the State of Delaware
An offering of 10,000,000 shares of common stock at $20 each
SUMMARY Community Psychedelic Centers International, Inc., (“CPC or
“the company”) anticipates offering 10,000,000 shares of common stock on or
about (date forthcoming). This will be the initial public offer for the company
and may represent special risks. The company expects to provide two types of
services: (1) psychedelic-assisted psychotherapy and (2) and psychedelic-
assisted professional development (See “The Company’s Business” below). With
the proceeds of this offering, the company expects to establish therapeutic centers
and professional development centers. The therapeutic centers will consist of
(1) free-standing, self-contained centers for referral patients and (2) on-grounds,
in-house centers located at existing major mental health hospitals and centers.
The Professional Development Centers will provide service for clients who wish
288 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
to enhance religious experience, creativity, personal growth, academic and
scholarly research, and similar non-therapeutic purposes.
The company believes it has already identified several potential drug candidates
as investigational new drugs, and furthermore, that while additional studies
may be required to firmly establish their safety and efficacy, preliminary studies
support both their safety and efficacy.
The company will receive approximately 85% of the proceeds of this offering.
The underwriters will receive approximately 1% for underwriting and miscella-
neous fees, and approximately 14% will go to the individuals who comprised
CPC Partners and are now the current stockholders.
Underwritten by
Hofmann & NiewKranium, Inc.
Member of the Zurich, New York, and Amsterdam Stock Exchanges
HANDPRIK & TWIST, inc.
Member of the Sausalito, La Honda, and Montauk Stock Exchanges
The Company
The CPC (Community Psychedelic Centers) Partnership was formed with
20 partners. This partnership organized CPC International, Inc. and incorporated
it in the state of Delaware. CPC has applied to the FDA to commence clinical tri-
als of several drugs which CPC believes offer advantages as adjuncts to psycho-
therapy. CPC also believes these drugs as used within the confines of the
proposed sessions are effective methods of increasing professional development
including, but not limited to, creativity and problem solving, providing insights
of value to academic and scientific researchers, enhancing primary religious
experience, stimulating artistic works, and exploring and developing the human
mind. No assurance can be given that the candidate drugs will prove effective,
and if they are, no assurance can be given that the FDA will approve their uses
as anticipated by CPC.
CPC believes that these drugs should not be prescribed to patients in such a
way that the patients can buy them and self-administer them, but that their proper
use requires the presence of fully trained professionals. Patients may not take
these substances home with them. An analogy might be anesthetics, which are
administered only by properly prepared professionals.
TRADING SYMBOL
CPC International has applied to the NASDAQ (National Association of
Securities Dealers Automated Quotation system) to trade CPC stock under the
symbol LSDD.
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 289
CHARITABLE ALLOTMENT
An unusual feature of this offering is the “charitable allotment.” Purchasers
of these shares at the underwriting are required to donate half their purchases to
a charity recognized as such by the U.S. Internal Revenue Service or by appropri-
ate state, local, or national laws in the jurisdictions where purchasers reside.
For example, if someone buys 200 shares, he or she must donate 100 shares to a
recognized charity. These shares are fully registered and identical to all other
units. CPC’s tax consultants believe that such gifts may qualify as a charitable
donation for Federal Income Tax purposes, but the Internal Revenue Service has
not made a determination on this issue.
CHARITABLE CHOICE—PSYCHEDELIC FOUNDATION
Investors may select any charity or charities of their choice, such as a church,
university, museum, community organization, or other legally recognized
eleemosynary institution. CPC partners has established Psychedelic Foundation,
Inc. to receive these and other donations if investor-donors so desire. Psychedelic
Foundations is entirely separate from CPC, and its charter allows it to fund a wide
variety of health-related, educational, religious, scientific, civic, and other pro
bono projects. This includes, but is not limited to, paying fees for treatment and
services for people who cannot afford to pay for CPC’s services. Although CPC
Partners hopes investors will contribute their charitable allotment so as to further
psychedelic research, either through Psychedelic Foundation or through organiza-
tions such as the MAPS, the Albert Hofmann Foundation, or the Heffter Research
Institute, the underwriters will not give preference because of the charity which is
to receive the donor shares.
Services
Unlike pharmaceutical companies, whose business is the manufacture and
sale of pharmaceuticals, CPC’s primary business will not consist of drug sales
but will consist of the service of providing professionally guided psychedelic
“sessions.” CPC may derive income from the manufacture and sale of its drugs,
but this is expected to be incidental to the company’s main business. The com-
pany’s primary service will include screening and preparation for the sessions,
conducting the session, and follow-up.
The company’s structure consists of two divisions, the Psychedelic Therapy
Division and the Psychedelic Professional Development Division. The company
calls prospective purchasers of the services of the Psychedelic Therapy Division
“patients” and calls prospective purchasers of the services of the Psychedelic
Professional Development Division “clients.”
Depending on regulatory and other matters, the two divisions and their
centers may be located in the same state or in different states and in the same
nation or in different nations. They may also be housed together or separately.
290 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
SESSIONS
Both therapeutic services and professional development services will consist
of four phases: (1) screening, (2) preparation, (3) the session, and (4) post-session
follow-up. Because these differ according to the nature of the patients and clients
and the nature of the desired outcomes, the details of the procedures are only
summarized here and are more fully described in Manual of Procedures for
Psychedelic Sessions, which is incorporated herein by reference.
Screening consists of physical and psychological examinations to determine
whether the applicant, clients, and patients are physically hardy enough to with-
stand possible stressful emotional and psychosomatic stress. Preparation consists
of determining the client’s/patient’s personal preferences of setting and explain-
ing to the client/patient the kinds of experiences he or she is likely to experience
during the session, the activities which may occur (such as listening to music),
and so forth. It will include establishing rapport with the guide or guides who will
attend the patient/client during the session day. A typical session will take a full
day. The client/patient will be accompanied throughout the session by at least
one professional.
After a session, which may last 12 hours or more, clients and patients may
stay overnight at the center or may be accompanied to their homes. In the case
of patients who are residents at mental health treatment facilities, they will be
returned to the custody of their institutions either the same day or they may stay
overnight and return the next day. During the follow up, the session and its effects
will be evaluated. In the case of patients, this activity will include consulting
and/or reporting to the patient’s doctor and/or therapist. In the case of clients,
the client, as well as the sessions guide, will typically evaluate the outcome.
Owing to the nature of psychedelic sessions, the follow-up evaluations may
include unanticipated results as well as the intended ones.
THERAPY DIVISION
Psychedelic Therapy Centers will provide services only to clients who are
referred by mental health professionals who are certified or licensed in the juris-
dictions where the centers are located. In the United States, these will vary from
state to state. Internationally, these will vary from country to country. Officially
recognized competent authorities are likely to include, but not be limited to,
psychiatrists, clinical psychologists, and others similarly licensed or certified.
At the present, CPC believes its proposed therapeutic services have been
shown by preliminary studies to be safe and efficacious for the following indica-
tions: alcoholism, drug addiction, post-traumatic stress disorder, lost memory
recovery, depression, autism, and selected neurotic and psychotic diagnoses
recognized in the Diagnostic and Statistical Manual - IV. Regulatory approval
will require additional studies to establish these claims.
As experience with these drugs and CPC’s method of running sessions
increases, CPC believes that other indications will emerge. Among these is the
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 291
possibility that intense, overwhelming self-transcendent experiences may boost
the immune system. CPC believes that to date existing studies suggest this may
be the case, but that such evidence is not strong, and that additional studies may
or may not confirm these leads.
Psychedelic Therapy Center’s current plans call for some of its centers to
be located in-house or on the grounds of existing mental health facilities
such as state mental hospitals, private residential treatment centers, and similar
locations. Other centers will be located as free-standing centers. CPC envisions
free-standing centers located so as to serve the needs of several mental health
facilities and professionals in an area.
CPC believes that psychedelic sessions also have value in the training
of mental health professionals and will provide both preservice and in-service
education for these groups. CPC plans to apply to appropriate governmental
agencies and/or educational accrediting agencies for permission to offer Contin-
uing Education Units, “CEU’s.” In some cases, these CEU’s may be offered
in conjunction with educational institutions such as medical schools, nursing
schools, institutions of higher education, professional societies, and others. While
CPC believes enough referrals will occur to make the Psychedelic Therapy
Centers profitable, no assurance can be given that this will be the case.
PROFESSIONAL DEVELOPMENT DIVISION
Psychedelic Professional Development Centers will provide services
for professional and vocational development in business, religion, education,
scholarship, science, law, mental health, the arts, and related fields. Instead of
being undertaken for the purpose of curing an existing mental health condition,
sessions will be undertaken to work in these fields. CPC believes this division’s
proposed services have been shown to be safe and efficacious, but it makes
no assurance that regulatory agencies will interpret the existing studies this
way. A major barrier to regulatory approval is the assumption that psychoactive
substances have appropriate use only in medicine and psychotherapy. CPC
may have to undertake, or cause to be undertaken, additional studies to
provide evidence of the usefulness of psychedelic sessions for nonmedical
purposes.
Because the proposed activities of the PPDC are not medical or psychothera-
peutic, it is not clear which governmental agencies, if any, have jurisdiction over
these issues. This unresolved regulatory issue is especially acute for the religious,
artistic, and educational uses because these areas have traditionally been outside
U.S. government control. Pending the resolution of this issue, CPC may establish
its first Professional Development Centers outside the United States.
Clients of the Professional Development Division must be certified as at
low risk of aversive consequences from their sessions, and like the patients of
the Psychedelic Therapy Centers, they will undergo screening, preparation, the
session itself, and post-session follow-up.
292 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
Some Psychedelic Professional Develop Centers may be associated within
one specific institution such as a major university, research facility, church,
or monastery; others may serve consortia of institutions; and others may be
associated with, or sponsored by, professional organizations.
DRUG DISCOVERY AND CANDIDATE DRUGS
While most pharmaceutical companies and drug discovery companies spend
many years and much effort identifying new drug candidates, CPC believes it has
already identified potentially successful investigational new drug candidates,
including LSD, DPT (dipropyltryptamine), DMT (dimethyltryptamine), MDA,
MDMA, psilocybin, ayahuasca, and mescaline. Other compounds may be added
from time to time.
DRUG TESTING AND APPROVAL
Because appropriate Federal agencies in the United States and in
selected foreign countries have already granted some of these drugs the status
of Investigational New Drugs, CPC believes its applications for approvals as
treatments will move expeditiously if additional scientific and medical studies
are successful.
Investment Questions
How likely is this busfi idea to presage such a company and an initial public
offering of its stock? Are there people who would invest in it? The chapters
in these two volumes indicate a wide variety of possible medical and psycho-
therapeutic applications, and the concluding chapter of Volume II describes
nonmedical applications from creative problems solving and scientific insights
to education and spiritual development. Many people already know of psyche-
delics’ positive uses, making them potential investors. Some potential investors
have experienced psychedelic drugs themselves and believe they have benefited
from them; others know people who have experienced psychedelic drugs and
believe they have benefited from them; still others are familiar with the scientific
and medical findings in pilot and preliminary studies.
PSYCHEDELICALLY INFORMED
Is there enough financial interest to organize such a company and offer its
stock to the public? According to the 2002 National Survey on Drug Use and
Health, 24,500,000 Americans have ever used LSD. The 2002 National Survey
of Drug Use and Health estimates that 34,300,000 Americans have ever used
some form of hallucinogens, with that number climbing every year. Here are
another 10,000,000 people with some percentage wanting to invest in LSDD
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 293
stock. If even 1% of the LSD number was likely investors that would be 245,000
people; of course, the actual number may be larger or smaller.
To start conservatively and consider only retirement accounts in the United
States—IRA, 401(k), 403(b), and similar accounts—for only 1% of the former
LSD users and assumed investments of $5,000 per person:
245,000 ×$5,000 = $1,225,000,000
Presumably, some investors would want to invest more than $5,000 per
person.
LARGER RESERVOIRS OF MONEY
Individually controlled retirement funds are only a small slice of the overall
equity investment pie, and other sources of funds exist. Mutual funds, banks,
insurance companies, pension plans, and similar financial fiduciaries are bigger
pools of funds. Could these numbers be doubled or more than doubled when we
consider foreign investors? There are some very wealthy individuals and venture
capitalists who realize the business potentials of psychedelics and know a good
speculation when they see one. It is widely rumored that among the Silicon
Valley multimillionaires and billionaires, there are many who use psychedelics
or have used them in the past.
DUE DILIGENCE
But would professional investors want to take the risk of investing their
clients’ funds in LSDD? Exercising fiduciary responsibility requires them to
carefully and thoroughly investigate possible investments for both their risks
and for possible rewards. To do this for CPC, these financial intermediaries
(people who handle other peoples’ money) would have to acquaint themselves
with the research such as the chapters in these two volumes and similar sources.
While they probably wouldn’t read the psychedelic research on their own, exer-
cising “due diligence,” as it’s called, would inform them about psychedelics’
potentials. An ironic side-benefit from a psychedelic stock offering is educating
large and powerful groups about psychedelics’ benefits. This benefit is not to be
underestimated.
Another byproduct benefit of a psychedelic stock offering is that CPC would
need medical and scientific research done. Just as happens with pharmaceutical
and healthcare companies now, some of the funds raised would flow to univer-
sities and medical research institutes. Additionally, owners of LSDD could
develop into a supporting constituency for supporting both CPC, specifically,
and psychedelic research, in general. The charities that received their pro bono
charitable allotments—churches, schools, universities, museums, hospitals, civic
organizations, and so forth—would share an interest in psychedelics, learning
294 PSYCHEDELIC MEDICINE: SOCIAL, CLINICAL, AND LEGAL PERSPECTIVES
about them and supporting further research. Again, the effect of this should not be
underestimated.
In a broader framework, the chapters in these two volumes are about much
more than curing specific illnesses; their implications go far beyond the field
of medicine and healthcare. As this concluding chapter of this volume and
its companion concluding chapter of Volume II propose, used carefully,
psychedelics’ benefits can extend to education, the arts, and religion (Roberts
2001, 2006) as well as medicine. As this section of the chapter shows, the
business community can benefit from psychedelics and hasten these benefits for
society.
CONCLUSIONS
The conclusions and recommendations we have considered here and the drug
policy groups we have listed are only some of the ways and means of strengthen-
ing drug policy and appropriate medicinal applications. The Internet web sites we
have given provide many links to other ways. We recommend you explore them
and the chapters of Volume II where many other aspects of the applications of
psychedelic medicines are explored.
NOTES
Thanks to our contributors for making these conclusions more apparent through
their research and the reports provided here. These assessments of the therapeutic poten-
tials need to be considered in light of the recommendations made in the previous chapters,
especially Passie, Frecska and Greer, and Tolbert.
1. Thanks to Ede Frecska for his assistance in constructing this section, and the
information provided by our contributors, especially Krupitsky and Kolp.
2. For Phase I, see Farber et al. (1998); Phase II for “limited” evidence, see
Grof (1975; 1979); Halpern, Volume II.
3. We characterize Phase II evidence as “limited” when lacking the benefit of
double-blind controls but strongly suggested from less rigorous forms of validation such
as animal research, medical case studies, and personal accounts and case series.
4. MDMA has undergone several studies constituting Phase I trials, both in the
United States and Europe, with hundreds of participants evaluated in controlled studies.
For MDMA Phase I studies, see De la Torre et al. (2000); Grob et al. (1996); Liechti
et al. (2000); Vollenweider et al. (1999); Gamma et al. (2000); Gouzoulis-Mayfrank and
Daumann (2006); also see Mithoefer (2003); for current Phase II studies see Mithoefer,
this volume.
5. For Phase I studies of DMT, see Strassman (2001).
6. For Phase I studies of Ayahuasca, see Grob et al. (1996); Callaway et al. (1999);
for limited Phase II evidence, see McKenna, this volume, Mabit, Volume II.
7. For Phase I and II evaluations of psilocybin, see Moreno and Delgado, Grob, this
volume; Volume II.
GUIDELINES FOR IMPLEMENTING THE USE OF PSYCHEDELIC MEDICINES 295
8. For Phase II evaluations, we have case studies of Peyote Church members
(see Halpern 2004; Halpern et al. 2005 for reviews); for evidence of Phase III–approved
therapeutic use, we have the practice of the Indian Health Service, a branch of the
U.S. federal government, approving use of peyote for treatment of alcoholism among
Native Americans (see Calabrese, Volume II).
9. Ketamine is already classified as a Schedule III drug, with approved uses. Phase I,
Phase II, and Phase III clinical trials in the ketamine psychedelic psychotherapeutic treat-
ment of alcoholism and opioid dependence have been carried out, and currently there is
research that constitutes the beginning of Phase IV (see Kolp and Krupitsky, Volume II;
Krupitsky et al. 2002).
10. The FDA approved clinical trial of ibogaine which were not, however, completed
as NIDA withheld funding for the planned and approved Phase I and II protocols and sub-
sequently ended its ibogaine evaluation project in 1995. Nonetheless, the continuing use of
ibogaine for addictions treatment in the United States and around the world constitutes a
“vast uncontrolled experiment,” which when combined with the other kinds of studies
(case reports, preclinical toxicological evaluation, and initial Phase I trials of safety phar-
macokinetic; paraphrase from Alper and Lotosf, Volume II), provides a substantial body of
evidence constituting preclinical proof of concept (See Alper et al. 1999; Alper 2001;
Mash et al. 1998, 2001; Alper and Lotosf, Volume II).
11. See Abrams, this volume. To keep up with the latest developments in medical
marijuana, we recommend the groups listed in the concluding chapter of Volume 1 plus
the following: www.mpp.org, (Marijuana Policy Project) http://www.gwpharm.com/
research_pipeline.asp (G. W. Pharmaceuticals). If you search PubMed or other standard
scientific resources, try searching <cannabinoid>. — The Editors.
12. Material in this section liberally adopted from www.drugpolicy.org.
13. Material in this section liberally adopted from www.cognitiveliberty.org.
14. Material in this section liberally adopted from www.maps.org.
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