Under the Controlled Substances Act, drugs are classified into legal, regulatory categories by the Drug Enforcement Administration. This is known as “drug scheduling”, and it’s generally guided by a drug’s potential for abuse, and its medical value – and then the idea of classwide scheduling came along. In 2018, in a misaligned approach to addressing the overdose crisis, President Trump used classwide scheduling to classify all fentanyl-related substances (FRS) as Schedule I controlled substances. This means that any substance that was structurally similar enough to fentanyl became subject to harsh criminal penalties, regardless of its effects on the body. President Biden, despite apologizing for his tough-on-crime past and promising real criminal justice reform, is advocating to make this Trump-era decision permanent, and it's now up to Congress to decide. In February of 2022, the House voted to extend the policy yet again through March 11, and it’s unclear how long the extensions will continue – the longer they do, the more harm they bring. DPA’s Maritza Perez invited FRS expert and criminal defense attorney Patricia Richman to the podcast to explain more about what classwide scheduling means, and why we are fighting against it.
For more information on fentanyl and related substances, visit https://drugpolicy.org/drug-facts/synthetic-opioids-fentanyl.
Special thanks to DPA’s Communications intern Matthew Gonzalez for his help on this episode.
Welcome to Drugs and Stuff, a podcast from the Drug Policy Alliance.
Gabriella Miyares (0:09)
Hello, and welcome to Drugs and Stuff. I'm your host, Gabriella Miyares. As a listener to a podcast all about drug policy, you're likely familiar with the concept of drug scheduling, where drugs are classified into legal regulatory categories by the Drug Enforcement Administration under the Controlled Substances Act. Scheduling is generally guided by a drug's potential for abuse and its medical value. This system already has many issues. But in the last few years, a newly proposed approach to scheduling has brought many more. This unprecedented approach, called classwide scheduling, has come up with the increase of fentanyl and fentanyl related substances, or FRS, in the drug supply. My colleague, Maritza Perez, invited FRS expert and criminal defense attorney Patricia Richman onto the podcast to explain more about what classified scheduling means and why we are fighting against it.
Maritza Perez (1:14)
Hi, everyone, my name is Maritza Perez. I'm the Director of the Office of National Affairs at the Drug Policy Alliance. Our office lobbies Congress and the administration on drug policy issues. For the last few years we've been fighting against an unprecedented approach to drug scheduling, called classwide scheduling. In 2018, President Trump classified all fentanyl related substances, FRS, as schedule one controlled substances, triggering a harsh crackdown on low level offenses in a wrongheaded approach to addressing the overdose crisis. President Biden, despite apologizing for his tough on crime past and promising real criminal justice reform, is advocating to make this Trump-era decision permanent. It's now up to Congress to decide. To discuss this policy at length, I've invited resident FRS expert Patricia Richman of the Federal Defenders to join us. Patricia, can you please introduce yourself to our audience?
Patricia Richman (2:05)
Hi Maritza. Thanks so much for having me in today. I work with the Federal Public and Community Defenders where I help respond to issues related to policy and legislation. Prior to taking this role at the Defenders, I was a public defender in Baltimore, Maryland and Greenbelt, Maryland, and had been working as a criminal defense attorney for about 10 years.
Maritza Perez (2:27)
Great. To kick off the conversation today, I thought it would be helpful for our audience just to understand the basics on fentanyl and penalties. So let's start really broadly: what is fentanyl?
Patricia Richman (2:38)
So fentanyl is a synthetic opioid -- that means it's not something that found naturally, it's something that is produced in a lab -- and it provides pain relief. It was first synthesized in 1960. And it is 50 to 100 times more potent than morphine. It's a really important analgesic with significant medical benefits. Unfortunately, with those benefits comes a high potential for abuse. So fentanyl is on schedule two of the Controlled Substances drug schedule, which means it has a medical benefit. But that also means that if you use it illicitly, or distribute it illicitly, meaning without a prescription, it carries pretty stiff penalties.
Maritza Perez (3:21)
And how is fentanyl related to fentanyl analogues? And you know we also hear about fentanyl related substances. What is the difference between all of these -- fentanyl, fentanyl analogues, versus fentanyl related substances?
Patricia Richman (3:34)
I'm not a chemist or pharmacologist, but I will do my best. Because fentanyl is produced in a lab, it has a certain chemical structure. And we know that that exact chemical structure of fentanyl has an exact effect on the human brain. You can change certain aspects of that structure. And it will look very similar to fentanyl. And most broadly, that's what an analogue is. It's something that's just structurally similar to fentanyl. So if you looked at the drawing of that chemical structure on paper, next to one another, they'd look really similar. More narrowly, and as defined in the Controlled Substances Act, a fentanyl analogue means something that not only has a similar structure, or build, as fentanyl, but also acts similarly in the brain. So it's like a relative, a cousin, of fentanyl. Fentanyl related substances are a subset of fentanyl analogues that have certain structural changes to them. What we don't know about fentanyl related substances is whether they all act the same way, have the same pharmacological effect, as fentanyl.
Maritza Perez (4:38)
Is there such thing as a fentanyl analogue that isn't dangerous?
Patricia Richman (4:42)
Yeah, so drugs can act a lot of different ways in the human brain, right? Opioids in particular, can attach to something called the mu receptor in the brain, and they can activate it, and that's an agonist effect. It causes a high, it causes certain respiratory effects. That's the way that fentanyl acts in the brain. And that's the way that some fentanyl analogues, that have been found and already scheduled on schedule one, act in the brain. But sometimes a substance can be structurally similar to fentanyl, but act in a completely different way in the brain. It can even act as an antagonist and I like to think of that as like a football -- you know, defense person, I don't know football words -- but you know, getting in there and blocking the effects and pushing it off of the mu receptor and stopping the reaction it's causing. And so naloxone is a common example of an antagonist. It's an antidote. And often, substances like Naloxone that are antagonists, antidotes, look really structurally similar to other substances that act as agonists, that cause that high. And then finally, there's a whole world of substances that might structurally look like fentanyl, but don't have any sort of psychoactive effect. So for example, if you were to look at a diagram of an over the counter diarrhea remedy called Imodium, look at the drawing of it, and you were to compare it to fentanyl, they would look very structurally similar. But Imodium, when taken as prescribed, doesn't have that agonist effect. It doesn't enter the brain. It's not psychoactive.
Maritza Perez (6:24)
What exactly is the issue with the classwide scheduling of fentanyl related substances? What does it mean?
Patricia Richman (6:29)
The concern with classwide scheduling is that it's looking only at structure. And it's looking at that structure to make a decision to place 1000s of substances -- potentially more, we don't know for sure, under schedule one. And with that placement comes really harsh penalties. But when you look only to structure, you're not confirming that things are actually harmful, that they have that potential for abuse, which has traditionally been a requirement to place a substance on schedule one, to make it subject to the really harsh criminal penalties that exist under law. So it's going to have a huge overcriminalizing effect. There was a recent hearing in the House, where the FDA testified that even though they've only looked at 25 of these fentanyl related substances so far, they've already found some that don't have the same effects as fentanyl, pharmacologically. And one that even might be an antidote. But if you were found in possession of one of those substances right now, a trace amount of that substance, and 10 grams of a substance? You'd be facing the five year mandatory minimum. Even though scientists have concluded that it doesn't have those harmful pharmacological effects or potential for abuse. And that's really concerning when we think about the individual lives at stake in criminal prosecution.
Maritza Perez (7:56)
So this is something that we've heard a lot in conversations with various lawmakers. But this question of aren't the penalties associated with a classwide placement of FRS necessary to curb the use of drugs and mitigate the overdose epidemic?
Patricia Richman (8:11)
When Congress first decided to put in place harsh mandatory minimum penalties, harsh penalties in response to drug use, that was in the 1980s. And it was an experimental move. That hadn't been tried before, there wasn't evidence about whether it would work or whether it wouldn't work. The difference between the 80s and now is that we have decades of evidence showing that incarceration, arrest, and penalties don't reduce use. They don't reduce supply. And when we look at the trend of incarceration in our country, we can map it right against the rise of overdose deaths. They've both gone up. So if incarceration worked to stop use and abuse, we would know it by now. We've had a long time engaging in this experiment, and it's failed.
Maritza Perez (9:05)
Another question that we often get, doesn't it make sense for FRS to have stronger penalties since we know less about them than regular fentanyl?
Patricia Richman (9:12)
It's a good question. But the problem is, is that knowing less about them means that we're criminalizing things that aren't harmful. And people think that this might be a theoretical concern -- when we don't know specifically about substances, that authorizes prosecutors to charge them in ways that have devastating effects. And with no ability to really defend against that charge, like I said, one of those non harmful substances that the FDA official testified about. That's a schedule one substance, it's illegal. There's not a defense, even though it's not harmful, because of this blanket approach. Another thing that I'd like to emphasize is that fentanyl analogues, to the extent they're harmful, are already illegal. That's because the Department of Justice, the Attorney General has the ability to quickly control substances. So a lot of fentanyl analogues, have been individually identified and moved on schedule one over the past few years. And those are the bulk of prosecutions. That has nothing to do with fentanyl related substances. The other thing that the -- the other tool that the department has, is to be able to use something called the Controlled Substances Analogue Act. So if they have a case involving a new substance that hasn't cropped up before, they can still prosecute someone for it. Now, they have heavier burdens to carry in that prosecution, because it's not a substance that's been scheduled or vetted. And that's appropriate. So really, this expansive approach is purely about overcriminalization.
Maritza Perez (10:59)
Something else we hear in these meetings with lawmakers is, you know, doesn't a classwide placement of FRS end this constant game of Whack a Mole, where new analogues are being invented to skirt existing laws. So in other words, if we're doing this classwide approach, doesn't it stop like these new analogues from popping up?
Patricia Richman (11:17)
This Whack a Mole argument is one that law enforcement officials have been making to Congress since the 80s. If you go back and review the Congressional Record, you will see that they've used this claim -- that they need more control authority, that they need stricter penalties, in order to end a Whack a Mole or creation of new synthetic drugs. And every time it doesn't work, right, they come back and they say, well, we just need more control authority, we need more tools. But it doesn't work. And just like we know that penalties don't curb use. We know that domestic criminalization of substances isn't really going to change how somebody is acting outside this country. Right? How they're producing and making drugs. And to the extent it does, we see that that creates an effect where even more dangerous, novel substances are created. So this case, you know, in this case, you can look to synthetic opioids. So we now see more innovations and synthetic opioids that are being created and introduced to the market that are not fentanyl related substances. There's something entirely new, and they're dangerous. They're having harmful effects. So you're just sort of changing the terms of the discussion, making it broader and making the stakes much higher. Until we turn away from this idea that control and criminalization is a tool, we're never going to stop engaging in -- we're never going to stop the creation and distribution of new and harmful substances.
Maritza Perez (13:03)
Next, I wanted to dig into some of the dangers of criminalization. Some people are saying that the permanent scheduling of FRS is reminiscent of the crack cocaine versus powder cocaine penalties that we saw back in the 80s and 90s. Why is that comparison being made now on this issue?
Patricia Richman (13:21)
In the 80s and 90s, we saw a great deal of inflammatory rhetoric that was used in the press, that was used by lawmakers, in how they discussed crack cocaine. And we see now that, since 2015, fentanyl and fentanyl analogues are becoming the new substance where that rhetoric is really being ratcheted up. And so, when you look at the 80s and 90s, those discussions, they led Congress to really hastily adopt these non-evidence backed mandatory minimum penalties. And those policies have just devastated our country. What's really remarkable about that discussion is that was based on crack being somehow more harmful, more pernicious than powder cocaine. But the scientific foundation for those claims didn't bear out. When you look now at the way that fentanyl and fentanyl analogues are being discussed. The nuances between the different kinds of fentanyl analogues, the fact that the science shows that not all fentanyl analogues are the same. Aren't nuances that the discussion focuses on. Instead, lawmakers are urging a radical response to fentanyl analogues. It's not science based. And I think that's the clearest parallel. And by radical response I mean, this idea of placing a whole class of substances onto schedule one. You know, our modern form of drug control, which was created in 1970, rests on a foundation of shared control between law enforcement and our public health and science authorities. So Congress originally said, Look, we think that law enforcement should have something to say about drug control. But we want to make sure that scientists, medicine, public health officials are confirming those choices. They're making sure that they're valid. And that's been the way we've proceeded since. No matter what controls have been granted, to the Department of Justice to the attorney general, there's been that backstop, that check of medical and scientific evaluation. Class control removes that backstop. It makes it so the only question is whether this chemical structure is found in the substance. And then no public health or scientific study is done to examine whether that prediction about how that drug is going to act actually is borne out.
Maritza Perez (16:11)
So speaking of the crack cocaine comparison, how do the racial disparities in federal prosecutions compare to what we saw in the 80s and 90s?
Patricia Richman (16:21)
Well, we're seeing significant racial disparities in these prosecutions with people of color compromising almost 75% of those sentenced in fentanyl cases in 2019. That held true for fentanyl analogues, for which 68% of those sentenced were people of color. Anecdotally, I think of certain jurisdictions. There's a law enforcement program called Stop Opioid Surge that was launched under the Trump administration. And that strategy was to prosecute every readily provable offense that involved any fentanyl or fentanyl analogue. States prosecute the vast majority of controlled substances offenses. But sometimes, federal authorities can pick up state based charges, and prosecute them. And a lot of the time, the reason they do that is because the penalties in the federal system are so much harsher. In Stop Opioid Surge, SOS, jurisdictions, they're moving up every state prosecution with fentanyl or fentanyl analogues into the federal system, no matter the scale. So there have been claims made by folks in the Department of Justice that this tool will be used to focus on quote unquote, kingpins, or drug traffickers. And that's not the case. One example that I was given by a colleague working on those cases was that there was an SOS jurisdiction, over 90% white. And I asked my colleague, well, what do your clients look like? Are you seeing charges against people who are white, who that are originating from that county? And he said, No, every single one of my cases has been against a person of color. And the data bears that out. And that goes to this greater tendency for our public discourse around drug misuse, to treat people of color as criminal and to treat people who are not as victims. So this trend of enforcement falling the back of communities of color with all the attendant destructive effects, is continuing in the prosecutions for these substances.
Maritza Perez (18:41)
So in September of last year, the Biden administration decided to weigh in on this issue, and they released an interagency proposal, a recommendation to Congress. I wanted to talk to you about about that proposal specifically. First, what are the recommendations that the Biden-Harris administration released?
Patricia Richman (19:00)
So the Biden-Harris administration, you know, I will say that they did try to respond to some of these concerns. And so the Biden-Harris proposal would make this classwide control permanent, right? It does adopt this sort of unprecedented break, and then it tries to sort of fix all the harms that are going to fall out from that. The first fix is to do a quantity based carveout from mandatory minimums for fentanyl related substances. As I mentioned, any detectable amount of a fentanyl analog and 10 grams of a substance triggers a 5 year mandatory minimum, a detectable amount 10 grams up to a 10 year mandatory minimum. So they create a carveout for that. They also provide a mechanism for, which they've referred to in some places as a "safety valve", for correcting sentences imposed for substances that are later shown to not properly be categorized, categorized on schedule one. The other important part of the proposal are a number of research reforms for scheduling substances. One thing that I'm focused on in my work, or my work focuses almost exclusively on the criminal legal effects of classwide scheduling. There are a huge range of implications for the research community, and their access to and ability to explore and study substances that are related to fentanyl, which may well include really powerful antidotes, may include pain relief, maybe less of an addictive property, it's really important to have researcher access to these substances. So the Biden proposal recognizes that and tries to mitigate the harm of the overclassification by making some schedule one reforms. They also create a GAO study to sort of look at the question of whether prosecution reduces the supply of fentanyl related substances, whether prosecution stops overdose deaths, I'm speaking generally. But that is sort of the last aspect of it.
Maritza Perez (21:34)
Thanks for that overview. How does the Biden proposal fall short?
Patricia Richman (21:38)
The harm from this overcriminalization is one that it's really impossible to undo. I am skeptical that there will be a reliable way to identify substances which are incorrectly scheduled. And the mechanism that the Biden proposal would create to do that is not effective. More broadly, the idea that we will tolerate the deprivation of a person's liberty for a substance that we're not sure is actually illegal, and then hope that the moonshot of descheduling or rescheduling helps us find that person? Really is at odds with core notion of fairness and liberty in our country. I think of a case of a man named Todd Coleman. Mr. Coleman was charged for selling small quantities of cocaine on three different occasions. None of those quantities, if they'd just been cocaine, would have triggered any mandatory minimum. But the third sale included trace amounts of fentanyl analogues. And the prosecutor used that to enhance the sentence to a 10 year mandatory minimum. We were really lucky, in Mr. Coleman's case, to discover that the substance involved in that case, the fentanyl analogue in that case, was not pharmacologically active. And we were lucky to have a mechanism to try to reduce the sentence there. And fortunately, his sentence was reduced to three and a half years. That was all sheer luck. And I am confident that there are folks out there who will not have -- who will not have the same relief. For a person whose entire case, for instance, is predicated on fentanyl related substance, we can anticipate that that person will be detained from the moment their case is charged, they may even be sentenced. There's research showing that two or three days of incarceration is sufficient to completely disrupt a person's life, to shatter their ties with their family, to lose custody of a child to lose a job to lose a home to lose a vehicle. And we're -- we're okay with the possibility that that's going to happen to people who are prosecuted for substances that don't have a pharmacological effect. The technical way that the Biden proposal goes about trying to fix the sentences is also really broad. It doesn't require that a court vacate a sentence that is imposed for a substance that is not pharmacologically active, it says okay, if you want to, you can. And it doesn't even require that the attorney general or the Department of Justice notify people when substances are descheduled or rescheduled. So it's putting it on the shoulders of defense attorneys, or for the people who have been convicted, to discover this fact. And that's really, I think, an unrealistic expectation. So all of these twists and turns, all of these complicated fixes in order to make this policy, this flawed policy of overcriminalization work, why? And I've told people before, I, I would understand this discussion to be more difficult if we sat down, and you said, look, we've got 30 years of hard evidence that when we increase prosecution, when we increase sentences, then that saves lives. And that decreases drug supply. I would understand the difficulty of that debate more, I think I might still land in the same place I am now. But I would understand it. That this conversation is occurring against the backdrop of decades of evidence that that will not be the case, that drug use will continue, that supply will rise, that overdose death will continue -- makes it really difficult for me to understand why this trade off is being made, why we're accepting this cost. And I think that it's unprecedented, and that it's going to have an incredibly harmful effect, not just for these substances, but for the role of public health and science in drug control.
Maritza Perez (26:35)
Does the Biden proposal couple the criminalization approach with funding for substance use treatment and recovery or greater access to harm reduction services?
Patricia Richman (26:48)
No, it does not. And, you know, I would just add that there's considerable evidence that strategies of criminalization and prosecution actually reduces people's outreach for help. If somebody is at the site of an overdose, they might run away, rather than dialing 911 because of the risk of criminal prosecution. So not only is there no funding, with this proposal, for substance use treatment and recovery, it's going to exacerbate the stigma that drives folks away from seeking help, from seeking treatment.
Maritza Perez (27:32)
I wanted to go back to this point around mandatory minimums and the Biden proposal because I think it's an important one to make. But won't Biden's plan to exclude FRS for mandatory minimums actually reduce mass incarceration rate?
Patricia Richman (27:45)
So I want to start by saying, you know, the positive, which I do think it's really significant to have a proposal around drug control that specifically says no mandatory minimums. I view that as progress. But I don't think that this mandatory minimum carveout is sufficient to actually reduce mass incarceration rates for a couple of reasons. Number one, the sentences recommended by the sentencing guidelines, which are a group of policies every judge has to consider in federal court before they impose a sentence, treat fentanyl analogues very harshly and recommend very long sentences. Second, the administration still retains the tools under its proposal to seek mandatory minimums in the vast majority of fentanyl analogue prosecution. As I mentioned, individually scheduled fentanyl analogues comprise the vast majority of the department's prosecutions. And this proposal doesn't change the ability for the administration to seek and obtain mandatory minimums, but also overcriminalizes the number of substances that people can be sentenced for. So it increases the bases for which people can be prosecuted, which will not reduce mass incarceration. To the contrary, it will continue to fuel it.
Maritza Perez (29:18)
And I know you touched on this, but I just wanted to tease it out a little bit more. Biden's proposal establishes a process by which FRS with low potential for abuse, or no pharmacological effects, can be rescheduled, and those convicted for an offense involving such FRS can have their sentences reduced. Doesn't that address the problem that we talked about earlier? Remedy potential sentencing disparities and make the situation significantly different from the crack versus powder problem?
Patricia Richman (29:48)
No, for a number of different reasons. First, I just don't think there's a remedy for the deprivation of a person's liberty for -- on the basis of a prosecution for a substance that's not harmful. Second, the process that the proposal establishes, doesn't actually require for the public health agencies to look at the substances. So it creates, or purports to create, an expedited way to remove substances at HHS's request. But it never says the HHS or FDA have to actually study or look at these substances. So who's going to do that? Importantly, Biden's proposal only expedites descheduling and rescheduling, for requests that come from HHS, but requests that come from individuals go through the same Administrative Procedure Act steps. And those requests take years, may take a really long time. So by the time you've gone through all of that, and you've established that the substance has been rescheduled, and descheduled, then you need to initiate the next step of that process, which is seeking resentencing or a vacatur of the original charge. And that's going to be a legally complicated motion, which may be contested by the US Attorney's Office, which relies, at least in the Biden proposal, completely on the judge's discretion. And so you're still rolling the dice, to know whether and how much relief that person will get. So none of this is a sure thing. And it's incredibly complex and difficult.
Maritza Perez (31:36)
Next, I wanted to pivot to some things that Congress can be doing, and also wanted to hear what's on the horizon for this issue. So first, I want to hear your take on what can be done about fentanyl related overdose deaths and the overdose epidemic overall.
Patricia Richman (31:51)
We know that there has been 5,000% increase in fentanyl analogue prosecutions, since I believe 2015. And we know that during that time, fentanyl analogue use has spread throughout the country more, we know that we've seen an escalation in overdose deaths. So for mine, see, I can tell you what plainly won't work, which is criminalization and incarceration. I think that groups like yours, and the other public health experts, some of whom have offered their testimony to the House have a range of different solutions. And what those all have in common is that they embrace the fact that, that answers to this might require multiple steps, they might be complicated, they may not have the satisfaction that a quick fix, like saying you're going to lock somebody up, will have. But if we invested our resources into those solutions, if we invested the money that was flowing towards prosecution, if we invested just the money that the Trump administration and the Biden administration have put into trying to get this policy into effect, into public health based solutions? We could start to turn that tide. We need to -- we need to accept the clear evidence that the approaches we've been using are a failure. I think I'd turn that question back to you. My expertise is in the world of criminal defense and not in public health. So I'm interested actually, in your thoughts on that question.
Maritza Perez (33:39)
Yeah, well, I appreciate the question. The Drug Policy Alliance supports public health responses not just to the overdose epidemic, but to drug activity when necessary. I think first, it's important to point out that not all drug use is problematic and requires access to treatment and harm reduction services or health services broadly. But sometimes people who use drugs do need those services. To really address the overdose epidemic, we know what we need. The science is there. We need overdose prevention centers. We need Naloxone to reverse the effects of an overdose and save lives. We need to make sure that people have access to things like fentanyl test strips so they can test their drugs before they consume them. We need good samaritan laws so people won't be afraid to call the police should somebody be experiencing an overdose. So these are just some strategies. There's a whole host of things that Congress could be embracing right now. But again, they're all public health strategies, harm reduction strategies, meeting people where they're at. So what's the role of Congress in all of this?
Patricia Richman (34:39)
Classwide scheduling of fentanyl related substances has been extended several times since 2020. And it expires yet again on February 18. So we will soon see what next steps Congress wants to take, whether they are ready to address this problem for what it is, which is a complex public health crisis, or whether they will continue to kick this problem down the road.
Maritza Perez (35:14)
Right, and I'll just add that the position of the Drug Policy Alliance is that this policy needs to expire, and as Patricia said, that we really should be embracing a public health response to the overdose epidemic, one that will truly save lives. Well, thanks for your time today, Patricia, this was great.
Patricia Richman (35:30)
Gabriella Miyares (35:36)
Thanks again to Patricia and Maritza, for that incredible overview of a really important and timely issue; clearly showing how crucial it is to focus on public health approaches, and not continue the harms of criminalization. If you'd like to learn more about fentanyl and its analogues, visit our website drugpolicy.org. We have a Drug Facts section with a page answering many common questions around fentanyl and similar drugs. Thanks again for listening, and stay tuned for future podcasts.
Drugs and Stuff is brought to you by the Drug Policy Alliance. If you like what you hear in the podcast, do us a favor and rate the show on iTunes. Give it five stars and a nice review. Also, we'd love to hear from you. Tweet us @drugsnstuffDPA. Use the hashtag #drugsandstuff and check out our website, drugpolicy.org, to see the other work we do, sign up for our emails, and donate. Special thanks to our producer Katharine Heller and to the hardworking staff of the Drug Policy Alliance for all of their work. Thanks for listening.