Ribeiro - Et - Al - DEA Report Critique - 2023

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The DEA report on ayahuasca risks: “Science”

in service of prohibition?

BEATRIZ LABATE1,2†, ANNA O. ERMAKOVA1†,


JORDAN SLOSHOWER3, NICOLE GALVÃO-COELHO4,
Journal of Psychedelic FERNANDA PALHANO-FONTES5,
Studies
HENRIQUE FERNANDES ANTUNES1,
GLAUBER LOURES DE ASSIS1, CLANCY CAVNAR1,
DOI: DRAULIO DE ARAÚJO5 and SIDARTA RIBEIRO5,6p
10.1556/2054.2023.00279
© 2023 The Author(s)
1
Chacruna Institute for Psychedelic Plant Medicines, USA
2
Naropa University, USA
3
Department of Psychiatry, Yale University School of Medicine, West Rock Wellness, New Haven,
CT, USA
4
Department of Physiology and Behavior, Federal University of Rio Grande do Norte, Natal, Brazil
COMMENTARY
5
Brain Institute, Federal University of Rio Grande do Norte, Natal, Brazil
6
Center for Strategic Studies, FIOCRUZ, Rio de Janeiro, Brazil

Received: April 25, 2023 • Accepted: May 3, 2023

ABSTRACT
On February 2023, the Drug Enforcement Administration (DEA) released a document to the legal
team representing the Church of the Eagle and the Condor (“CEC”). This disclosure came two
years after the church, in conjunction with Chacruna Institute, submitted two FOIA requests to the
DEA and the Department of Justice requesting all records pertaining to ayahuasca. This report,
titled “Ayahuasca: Risks to Public Health and Safety,” was issued in July 2020. In the present article,
we challenge a number of claims made in the DEA report and highlight significant factual
omissions, theoretical biases, and misinterpretations of existing data. We will demonstrate that the
DEA report severely downplays the safety profile and therapeutic potential of ayahuasca and
overemphasizes the risks. It also fails to include current research on ayahuasca demonstrating its
potential benefits.

KEYWORDS
ayahuasca, Drug Enforcement Administration, report, critique

INTRODUCTION
Ayahuasca is a traditional Amazonian beverage most commonly prepared by a decoction of
two plants from the Amazon region (McKenna et al., 1984): Psychotria viridis, containing the
psychoactive alkaloid N,N-dimethyltryptamine (DMT), and Banisteriopsis caapi, which

contains reversible monoamine oxidase inhibitors (MAOi), such as harmine, harmaline, and
Shared first authorship. tetrahydroharmine (Riba et al., 2003). Ayahuasca has been used by Indigenous peoples in the
p
Corresponding author. Amazon for centuries (Bianchi 2005; Miller, 2017) and, additionally, is a sacrament in several
E-mail: sidartaribeiro@neuro.ufrn.br ayahuasca religions that originated in Brazil and have spread all over the world. Recently,
ayahuasca (or its main psychoactive component, DMT) has been investigated as a potential
therapeutic for various mental disorders; notably, treatment-resistant depression and
addiction. Early-phase trials are promising, both in terms of safety and efficacy (Nunes et al.,

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2 Journal of Psychedelic Studies

2016; Osório et al., 2015; Palhano-Fontes et al., 2019; original clinical trials indicating antidepressant and anti-in-
Sanches et al., 2016). Nonetheless, DMT remains a Schedule flammatory effects of ayahuasca, as well as that ayahuasca
I substance in the United States. promotes an elevation of a blood biomarker of neuroplasticity
Recently, in the USA, there has been a flurry of (de Almeida et al., 2019; Galvão-Coelho et al., 2020; Leite,
ayahuasca seizures and attempts to criminalize patients, 2023; Osório et al., 2015; Palhano-Fontes et al., 2019).
sitters, and Indigenous shamans involved with ayahuasca Several comprehensive reviews and a global survey on
(see, Council for the protection of Sacred Plants, 2020; ayahuasca’s therapeutic potential indicate consistently
Heffernan, 2021). On February 13, 2023, the DEA released a mounting evidence of potential benefit in psychiatric ill-
single document to the legal team representing the Church nesses, such as depression, anxiety, and substance use dis-
of the Eagle and the Condor (“CEC”). This sole disclosure order (Domínguez-Clavé et al., 2016; Dos Santos, Balthazar,
comes two years after the Church, in conjunction with Bouso, & Hallak, 2016; Hamill, Hallak, Dursun, & Baker,
Chacruna Institute, submitted two FOIA requests to the 2019; Perkins et al., 2022; Sarris et al., 2021); and, poten-
DEA and the Department of Justice requesting all records tially, in other illnesses, such as neurodegenerative disorders
pertaining to ayahuasca—requests that went ignored and and end-of-life distress (Maia, Daldegan-Bueno, Wießner,
unanswered in violation of the Freedom of Information Act. Araujo, & Tófoli, 2023).
This document, titled “Ayahuasca: Risks to Public Health In addition, multiple cross-sectional, case-control, and
and Safety,” was issued in July 2020 (Chacruna Insti- longitudinal studies of ayahuasca in religious or retreat
tute, 2023). settings indicate positive effects of ayahuasca (see review by
In the present article, we challenge a number of claims Maia et al., 2023). Turning a blind eye to so many sound
made in the DEA report, and highlight significant factual studies is highly problematic and anti-scientific. It raises
omissions, theoretical biases, and misinterpretations of suspicion that the author[s] of the report had an a priori
existing data. negative bias, possibly related to a political agenda or ideo-
logical position.

LACK OF SYSTEMATIC REVIEW OF THE MISSING DATA ON THE SAFETY AND


RELEVANT LITERATURE POTENTIAL BENEFITS OF AYAHUASCA FROM
First, the DEA report did not conduct a comprehensive re-
PRE-CLINICAL RESEARCH
view of the literature; rather, it selected studies that exaggerate
dangers and ignored or, at best, made cursory mention of Likewise missing is a large body of pre-clinical evidence
studies that demonstrate safety or positive effects. Notably, of ayahuasca’s therapeutic potential. Rodent and primate
the report has not been updated since it was written in 2020, studies indicate the antidepressant and anti-addictive po-
and does not include several recent pertinent studies in tential of ayahuasca (see reviews by Cameron & Olson, 2018;
humans and in animal models. Given the influence that the Dos Santos, Osório, Crippa, & Hallak, 2016; Ferraz et al.,
DEA report may have on government policy related to 2019; da Silva et al., 2019). Some new evidence indicates that
ayahuasca, it must be dynamic and updated regularly, e.g. ayahuasca seems to have prophylactic action, buffering the
yearly, in much the same way as Investigator’s Brochures, to emergence of depressive-like behaviors and cortisol changes
reflect the most current evidence. in a non-human primate animal model of depression (de
Moreover, there seems to be a kind of circular argument Meiroz Grilo et al., 2022). Moreover, there is evidence that
in the report, wherein being part of the Schedule I list is DMT regulates adult neurogenesis, both in vivo and in vitro
proof in and of itself that these substances are dangerous and (Ly et al., 2018; Morales-Garcia, 2020), as well as modulating
problematic. The Controlled Substance Act (CSA) is evoked immune response (see review by Inserra et al., 2021).
as an authoritative argument that attests to the danger of
ayahuasca to public health. But the CSA needs to be seen as MISSING EVIDENCE FROM EPIDEMIOLOGICAL
a political document that is subject to change and ques-
tioning. The recent discussions about psilocybin, MDMA, STUDIES OF POPULATIONS REGULARLY
and other psychedelics make it clear how it is a document USING AYAHUASCA
that can be updated, and that it cannot in any way be taken
as scientific evidence that ayahuasca causes risks to public The DEA report fails to discuss epidemiological studies
health and safety. suggesting that long-term ayahuasca use is not associated
with psychological and physical impairments but, rather,
improved quality of life and well-being (Barbosa, Mizumoto,
MISSING EVIDENCE FOR SAFETY AND Bogenschutz, & Strassman, 2012; Grob et al., 1996; Kohek
BENEFITS OF AYAHUASCA IN HUMANS et al., 2022; Ona et al., 2019). The level of collective health
and quality of life of certain ayahuasca communities may
A comprehensive assessment of the state of the art in actually be more positive than that of non-ayahuasca-using
ayahuasca research could not have ignored numerous recent social groups living in the same region, as is the case for

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Journal of Psychedelic Studies 3

some Santo Daime communities in the Amazon region health or social harm caused by the use of ayahuasca in the
(Grob et al., 1996; MacRae, 1992). religious communities examined. The report concluded that
Moreover, the report does not consider Indigenous the use of the tea did not have any adverse consequences on
peoples who use ayahuasca as relevant actors whose the social life of its followers; on the contrary, it stated that
traditions and ceremonies need to be considered and ayahuasca is likely to orient them toward the search for social
respected. The report leaves aside all the rich anthropolog- happiness within an orderly and productive context (Federal
ical and sociological literature on the uses of ayahuasca Council of Narcotics CONFEN, 1987, p. 29).
(Anderson et al., 2012; Labate & Araújo, 2004; Labate et al., We must highlight the innovative approach of CONFEN.
2008), and on ayahuasca and health (Labate et al., 2013). Instead of reducing ayahuasca to its chemical compounds
It also ignores all the hundreds of accounts of ayahuasca and focusing solely on their effects, the Brazilian drug agency
benefits present in the oral history of traditional ayahuasca had the cultural and anthropological sensibility to under-
use and, instead, cherry-picks negative anecdotal cases. stand the historical and socio-cultural context of the religious
use of ayahuasca, giving credit to the accumulated knowledge
on the matter and witnessing firsthand the practices of
ayahuasca religions, which began in 1930s (Labate, 2012).
NO MENTION OF THE LEGAL STATUS OF The CONFEN report understood, as is well known in
AYAHUASCA ELSEWHERE IN THE WORLD anthropological studies regarding psychedelic substances,
that these cannot be examined isolated from the context of
The DEA report fails to reflect on the legal status and use, and that the practices of established religious commu-
policies around ayahuasca in South American countries, nor nities play a central role in the use of ayahuasca, making it
on the case of the UDV victory in the US Supreme Court. not only a safe practice but a tradition that is in tune with the
The safety profile of ayahuasca use among the exempted family-centered values most dear to Brazilian society.
groups is not analyzed. In the 2000s, the National Council on Drug Policy (CONAD)
It is important to highlight the Brazilian case. Contrary to reaffirmed the right of ayahuasca groups to practice the religious
the constrained stance of the DEA, the Brazilian government use of ayahuasca, based on the principle of religious freedom and
has shown a much more mindful and comprehensive attitude the constitutional commitment to protect and safeguard Indig-
regarding the use of ayahuasca. Shortly after the ban of enous and Afro-Brazilian traditions. Furthermore, CONAD
ayahuasca by the Brazilian regulatory agency on drugs in sponsored a pioneering initiative of organizing a Multidisci-
1985, the Federal Council of Narcotics (CONFEN) issued a plinary Working Group (MWG) to establish guidelines for the
resolution that established the creation of a working group use of ayahuasca in Brazil. Understanding that this could not be
(WG) to examine the use of ayahuasca in Brazil. The WG was done without acknowledging the accumulated data on the sub-
comprised of members of the council and experts in various ject, CONAD invited a number of scholars from various fields
fields. After two years of intensive research, in which the and representatives of the main Brazilian ayahuasca religions to
members of the WG visited a number of ayahuasca churches be part of the MWG. Together, they published a report in 2006
in the Amazon and in the southeast of Brazil, interviewed that established a number of recommendations for the respon-
their members and leaders, examined their practices, and did sible use of ayahuasca (National Council on Drug Policy
a thorough literature survey, the WG published a Final Report CONAD, 2006). In 2010, the Brazilian government established a
(Federal Council of Narcotics CONFEN, 1987). The report resolution to implement the recommendations of the MGW
stated that ayahuasca religions had moral and ethical stan- report, recognizing the importance of the cultural and religious
dards of behavior similar to the rest of Brazilian society, and value of ayahuasca traditions in the country (National Council on
sometimes even stricter. As for the ceremonies, they Drug Policy CONAD, 2010).
emphasized the role of the religious environment as a whole, The Brazilian case is a successful example of an inclusive
including the role of music and dancing. In addition, they public policy developed through a partnership with promi-
highlighted that, after the ceremonies were over, everyone nent academic specialists in the country and members of
returned to their homes in an orderly fashion. In general, the ayahuasca religions, proving that the religious use of
report described its members as peaceful and happy people, ayahuasca can safely be accommodated in society if there is
highlighting that some of them attributed several positive an open channel for dialogue and collaboration. Hopefully,
changes to the religious use of ayahuasca, such as the the DEA can learn from the Brazilian experience and look
constructive reorganization of family life, a renewed interest for ways to regulate the religious use of ayahuasca in the US.
in the work environment, and the encounter with oneself and
with God (Federal Council of Narcotics CONFEN, 1987 p. 7).
The WG also pointed out that the preparation of FALSE CLAIMS REGARDING AYAHUASCA
ayahuasca is quite difficult and prolonged and performed
within a ritual, meaning that a significant increase in pro-
PREPARATION AND DANGEROUS
duction levels capable of providing a supply for “abuse” and ADMIXTURES
for recreational use would be unlikely. Finally, the WG
stressed that the ritual use of ayahuasca has been documented A central point in the DEA argumentation is the statement
for many decades and that they did not find any evidence of about ayahuasca that “there is no unified or standardized

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4 Journal of Psychedelic Studies

formula for its preparation.” This point appears in the first even serotonin receptor distribution and that “the depen-
paragraph and continues to be stated more than 10 times dence potential of oral DMT and the risk of sustained
throughout the document. psychological disturbance are minimal” (Gable, 2007).
Like all botanical preparations, no two ayahuasca prepa- A more recent review of animal data on ayahuasca/DMT,
rations are exactly the same, and different ayahuasca-using which was not mentioned in the DEA report, indicates that
communities have different methods for preparation. How- ayahuasca is toxicologically safe in ceremonial-comparable
ever, this process among ayahuasca-using communities is far doses (Daldegan-Bueno, Simionato, Favaro, & Maia, 2023).
from random; rather, the traditional uses of ayahuasca are The LD50 in rodents is approximately 30 times higher than
historically built on formulas that follow strict procedures, the therapeutic/ceremonial doses (even taking into account
deep cosmologies, and a know-how that are far from random variability across samples) (Brito-da-Costa, Dias-da-Silva,
and are usually quite rigorous. In fact, ayahuasca is a central Gomes, Dinis-Oliveira, & Madureira-Carvalho, 2020; Simão
part of several Indigenous medical systems, and is frequently et al., 2019).
found among mestizo and urban settings throughout the Another article omitted from the DEA report estimated
globe (Dobkin de Rios, 1972; Luna, 1986). that an extrapolated oral DMT “usual lethal dose” in
The fact that ayahuasca is not a “controllable” synthetic humans would be 2 g, which is about 75 times greater than
compound is not, in and of itself, a risk to public health. The the typical 27 mg DMT dose taken in ayahuasca, and that
traditional use of whole plants as medicines has millennia of the oral ayahuasca “usual effective dose” to “usual lethal
cultural experience, while purified compounds, especially dose” safety ratio of 50 was substantially higher than several
psychoactive ones, have only recently started to be investi- commonly used substances, such as alcohol (10), dextro-
gated (Ribeiro, 2018). By falsely asserting the dangers of methorphan (10), and codeine (20), which demonstrated a
botanical preparations that lack a single method of prepa- favorable safety profile for DMT (Gable, 2004).
ration, the report leads readers to believe that people are A further point that should be highlighted is that the
taking the risk of drinking lethal doses of ayahuasca. The authors of the report equate the use (and associated risks) of
vast anthropological bibliography about the traditional and ayahuasca with that of isolated DMT and beta-carbolines,
urban uses of ayahuasca shows that, in practice, such doses which is a mistake for several reasons. DMT and ayahuasca
are never consumed (Labate, 2004). Additionally, the report have very different pharmacokinetic and pharmacodynamic
overemphasizes the prevalence of admixtures, suggesting profiles and are used via different routes of administration
that substances such as cocaine or plants containing tropane and in different contexts. DMT has a much shorter onset
alkaloids are commonly used in the preparation of time and duration of effects, a higher intensity, and a
ayahuasca, and can therefore cause overdose or toxicity. different phenomenology (James, Keppler, L Robertshaw, &
Kaasik et al. (2021) analyzed 102 samples of brews from Sessa, 2022; Strassman, Qualls, Uhlenhuth, & Kellner, 1994).
ayahuasca-using communities. They found higher and more The synergy between plants containing DMT and plants
variable concentrations of DMT in neoshamanic ayahuasca containing beta-carbolines in the report is reduced to
samples compared to Indigenous samples or samples from “additional risks leading to potential toxic consequences.”
ayahuasca churches. The analysis revealed the average To support this claim, they cite studies that have shown
(minimal – maximal) concentrations (mg L 1) of DMT 764 beta-carboline toxicity, where these substances were isolated
(88–2687), THH 995 (32–3875), harmine 1318 (141–4440), and analyzed alone. Paradoxically, studies indicating that
and harmaline 85 (4–387). In this study, other psychoactive isolated beta-carbolines are neuroprotective and anti-
components, such as moclobemide, psilocin, and yurem- inflammatory were omitted from the report (Katchborian-
amine were only found in analogues of ayahuasca (Peganum Neto et al., 2020; Santos, Moreira, Borges, & Caldas, 2022).
harmala, Mimosa tenuiflora), but not in ayahuasca itself.
Importantly, no ayahuasca analogues were found in any
samples from Brazil or ayahuasca used in Santo Daime
ceremonies in Europe.
CONFLATION OF AYAHUASCA EFFECTS WITH
ADVERSE HEALTH EFFECTS
The DEA report views all subjective and consciousness-altering
PROBLEMATIC COMPARISONS WITH ANIMAL effects of ayahuasca through a negative lens, as if they are all
TOXICOLOGY harmful or undesirable “side effects.” This is in stark contrast to
Indigenous understandings of phenomena such as vomiting,
The DEA report cited an animal toxicology extrapolation which is seen as a cleansing opportunity (purging) (Politi et al.,
model estimating that the LD50 for oral DMT in humans 2022), and ignores emerging scientific evidence that psyche-
would be 8 mg kg 1, which is more than 20 times the dose of delic-induced mystical-type experiences are correlated with
oral DMT (approximately 27 mg) typically consumed from therapeutic benefit (Yaden and Griffiths, 2020). The choice to
ayahuasca (Gable, 2007). However, the report also omitted view all effects of “drug intoxication” as negative follows a long
the researcher’s explanation that “simple extrapolation of demonizing tradition at the core of Prohibition, based on moral
DMT lethality data from mice to humans is obviously un- and religious dogmas that starts by using language with nega-
tenable” due to differences in metabolism, physiology, and tive bias. There is a section called “Adverse Effects of

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Journal of Psychedelic Studies 5

Ayahuasca Reported in the Media.” This kind of reference side effect, the emetic effects of ayahuasca should be regar-
should be viewed with great caution, as these stories are often ded as a safety point, since the emetic dose is similar to the
sensationalist and garbled (Sinclair, 2017). psychoactive one.
It is more informative to look at comprehensive survey Hypertension and tachycardia
data, such as the online Global Ayahuasca Survey, which ran In the DEA report, the authors refer to hypertension
between 2017 and 2019, and collected information about (high blood pressure) and tachycardia (increased heart rate),
“ayahuasca side-effects” in participants (n 5 10,836) from as “cardiotoxicity” (bottom of page 11). For a cardiologist,
more than 50 countries. Acute physical health adverse effects however, cardiotoxicity refers to the occurrence of heart
(primarily vomiting) were reported by 69.9% of the sample, dysfunction as electric or muscle damage, resulting in heart
with only 2.3% reporting the need for subsequent medical toxicity, as occurs sometimes after chemotherapy. Acute
attention. Adverse physical effects were related to older age high blood pressure and tachycardia do not indicate damage
at initial use of ayahuasca, having a physical health condi- to the heart, or “cardiotoxicity.” Elevated blood pressure and
tion, having a previous or family history of psychotic heart rate normally happen transiently in most humans,
symptoms, having a previous substance use disorder diag- including those with no measurable damage to their hearts.
nosis, and taking ayahuasca in a non-supervised context. Gable (2007) analyzed several studies to compare changes in
Adverse mental health effects in the weeks or months heart rate and blood pressure brought on by various psy-
following consumption were reported by 55.9% of the choactive substances and concluded that the hemodynamic
sample; however, around 88% considered such mental effects of ayahuasca appear less hazardous than alcohol.
health effects as part of a positive process of growth or Other adverse effects
integration. Around 12% sought professional support for Chronic ayahuasca users (n 5 22) show no change in
these effects. The occurrence of adverse mental health effects biochemical parameters related to hepatic damage (Mello
was positively correlated with pre-existing anxiety disorders, et al., 2019).
physical health conditions, and the strength of the acute
spiritual experience, and negatively associated with con-
sumption in religious settings (Bouso et al., 2022).
Below we provide necessary nuances to some of the
LACK OF ACCURACY IN NUMBERS OF
“adverse effects” discussed in the report: HOSPITALIZATIONS AND POISONINGS
Hallucinations
The DEA report cites hallucinations as a side-effect of The report cites data from the American Association of
ayahuasca. In fact, they are one of the most sought-after Poison Control Centers (AAPCC) that links exposure to
effects of a psychedelic experience. Altered states of con- ayahuasca to negative health outcomes, including hospital-
sciousness induced by psychedelics, and resulting “mystical” ization. The AAPCC data is based on over 500 cases, some
or “peak” experiences, are reported as some of the most of which mention serious health issues, such as intubation.
meaningful experiences (Griffiths et al., 2011), correlating However, there is no comparison of these cases with the
positively with therapeutic outcomes in depression, anxiety, number of people using ayahuasca, so it is impossible to
and nicotine addiction (Yaden and Griffiths, 2020), attest to the overall prevalence of the problem. Moreover,
including in ayahuasca randomly-controlled trials (RTCs) there were no toxicological exams to confirm the presence of
(Palhano-Fontes et al., 2019). DMT or other active principles of ayahuasca; thus, we do
Hallucinations—particularly visions of autobiographical not know what, if any, substances were actually consumed,
or transpersonal nature, but even more abstract geometric nor do we know the context in which they were consumed.
hallucinations—are thought to catalyze mystical experiences, Hence, these data are entirely unreliable and exclusively
emotional breakthroughs, insights, and experiences of awe based on hearsay. Part of the adverse effects report comes
induced by psychedelics, which are all related to therapeutic from the article “Ayahuasca Exposure: Descriptive Analysis
effectiveness (Aqil & Roseman, 2022). In fact, recent evi- of Calls to US Poison Control Centers from 2005 to 2015.”
dence suggests that the neurophysiological mechanisms While this document describes several adverse effects that
involved with these visions are related to a dream-like state, are possible due to ayahuasca ingestion, the authors also
rather than a pathological hallucination (de Arujo assert that “Case reports of adverse outcomes and human
et al., 2012). deaths may be not from botanical ayahuasca at all”
Vomiting (Callaway et al., 2006).
In shamanic contexts, purging is an essential and Conversely, the data from studies conducted with
intrinsic aspect of ayahuasca’s medicinal value. Although ayahuasca in clinical trials only presented transient and
purging as a healing method is not recognized in Western rapidly resolving side effects, not dissimilar to those of
medicine, new studies on the gut-brain axis may add other classic psychedelics, such as gastrointestinal malaise
knowledge about it in the near future. For instance, it has and vomiting (but see above about the importance of
been suggested that purging has potential benefits for vomiting in traditional and religious contexts), headaches,
gastrointestinal function and microbiota balance, modu- and mild-to-moderate increases in heart rate and blood
lating the gut-brain axis in a positive way (Fotiou et al., 2019; pressure (n 5 108, healthy volunteers and depression
Politi, Tresca, Menghini, & Ferrante, 2022). Rather than a patients in 11 trials). Rarer were reports of anxiety,

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6 Journal of Psychedelic Studies

confusion, emotional distress, depersonalization, and FALSE CONCLUSIONS ABOUT AYAHUASCA’S


dysphoric states, although even those were transient and
resolved on their own or with psychological support
RISK TO PUBLIC HEALTH AND SAFETY
provided during the trial (Rossi et al., 2022).
The DEA report asserts that, “Based upon the existing in-
formation, ayahuasca presents a significant risk to public
health and safety.” We do not dispute that there are po-
LACK OF AWARENESS REGARDING THE tential risks inherent in ayahuasca use, including unknown
SETTING AND INFORMAL FORMS OF CONTROL composition, lack of adequate screening, and lack of psy-
chosocial support leading to untoward experiences, or the
The DEA does not address any of the cultural and social lack of follow-up and integration, which could produce
dimensions of ayahuasca consumption. The dozens of theses psychological harm or lead to calls to poison control.
and dissertations on ayahuasca communities show that they Notwithstanding, the above summary statement is highly
contain complex social and cultural dynamics. The shamans problematic because it asserts that:
and leaders of ayahuasca religions have developed formal a) All ayahuasca use presents a significant risk;
and informal forms of control in order to minimize adverse b) All contexts of ayahuasca use are equally likely to cause
effects and to provide a safe environment for the use of problems;
ayahuasca. In fact, organized ayahuasca-using communities c) Ayahuasca is a risk to public health at large, rather than
employ a number of strategies to mitigate the majority of to a subset of individuals who choose to drink ayahuasca.
significant risks inherent in using ayahuasca. These include
reliable sourcing of ayahuasca, screening potential ceremony Regarding the first two points, the risk of ayahuasca use
participants, and consuming ayahuasca within structured is variable depending on individual user characteristics and,
and supervised settings with experienced leaders and guides as discussed above, the context in which ayahuasca is used.
who can safely support individuals having difficult experi- For instance, ayahuasca use among individuals with histories
ences or in need of (extremely rare) medical attention. Both of psychosis and without social support presents higher
controlled trials as well as prospective data from ayahuasca- risks. Similarly, ayahuasca use in unstructured and unsu-
using communities clearly demonstrate the safety profile of pervised settings is riskier than in controlled environments,
ayahuasca within controlled settings (Barbosa et al., 2012; such as the ceremonial contexts in which the majority of
Chacruna Institute for Psychedelic Plant Medicines & ayahuasca use occurs. These principles are similarly true for
Hoots, 2021; MacRae, 2009; Rossi et al., 2022). nearly all psychoactive compounds, such as alcohol
In this regard, the literature has shown that the ritual use of (e.g., drinking moderate quantities in controlled social
ayahuasca cannot be equated to DMT consumption in a clin- environments vs drinking to excess and driving or drinking
ical setting. As Hartogsohn (2021, p. 14) states, “the effects of by someone with liver disease vs a healthy adult).
ayahuasca are profoundly mediated through complex layers of Regarding the third point, the risks of ayahuasca, both to
intentions, expectations, visual, auditory, and symbolic envi- individual users and to others, are small compared to other
ronments, social and cultural systems, etc. These various substances, and the vast majority of risks inherent to
contextual factors comprise a rich cultural apparatus that serves ayahuasca use are to the users themselves, and not to others
to mitigate harms and facilitate social and personal benefits.” or to the broader communities in which ayahuasca use takes
The importance of the setting and the strict informal and place. This is consistent with a variety of expert groups who
formal means of control established by Indigenous peoples rate psychedelic harms low compared to other medical and
and ayahuasca religions occupy a central role when it comes recreational drugs, while legal alcohol scores are one of the
to experiencing ayahuasca. Epidemiological studies that have highest (van Amsterdam, Nutt, Phillips, & van den Brink,
demonstrated the lack of harm in ayahuasca-using commu- 2015; Bonomo et al., 2019; Nutt, King, & Phillips, 2010).
nities (Barbosa et al., 2012) are proof of effective harm
reduction practices that cannot be ignored nor minimized.
Moreover, the power of traditional and Indigenous knowledge FINAL REMARKS
should not be underestimated, as is clear from the example of
differentiating different ayahuasca vine varieties that elude In this article, we highlight significant and obvious problems
contemporary botanical distinctions (Sheldrake, 2020). By with the DEA report on ayahuasca, such as overt negative
disregarding the current clinical evidence and research in biases, unacceptable omissions, and obsolete mis-
Indigenous and religious communities, and not considering conceptions, while calling attention to recent scientific
the anthropological literature available on the matter, the findings that were either not mentioned or mis-interpreted.
DEA demonstrated a narrow, ethnocentric approach that fails In summary, the DEA report severely downplays the safety
to truly characterize the potential risks related to ayahuasca. profile and therapeutic potential of ayahuasca and over-
We find it highly problematic that the DEA report did not emphasizes the risks. It reduces ayahuasca to DMT and
exhibit the scientific rigor or anthropological sensitivity to falsely equates the risks of one with the other, while simul-
understand the harm reduction practices and benefits of the taneously failing to consider the ways in which context
use of ayahuasca in traditional settings. modulates the risks of use. This is especially harmful when

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Journal of Psychedelic Studies 7

discussing ayahuasca, given centuries of use among Indige- Bouso, J. C., Andión, Ó., Sarris, J. J., Scheidegger, M., Tófoli, L. F.,
nous communities and decades of use in modern religious Opaleye, E. S., Schubert, V., & Perkins, D. (2022). Adverse ef-
contexts. Moreover, the report fails to include current fects of ayahuasca: Results from the global Ayahuasca survey.
research on ayahuasca demonstrating its potential benefits. PLOS Global Public Health, 2(11), e0000438.
Thus, when considering the report as a whole, it seems Brito-da-Costa, A. M., Dias-da-Silva, D., Gomes, N. G.,
clear that it was either written by personnel that lacked the Dinis-Oliveira, R. J., & Madureira-Carvalho, Á. (2020).
proper knowledge and skillsets to produce a comprehensive Toxicokinetics and toxicodynamics of ayahuasca alkaloids
report or was written with a predetermined Prohibitionist- N,N-dimethyltryptamine (DMT), harmine, harmaline and
style political agenda. That being said, we suggest that future tetrahydroharmine: Clinical and forensic impact. Pharmaceu-
policy related to ayahuasca should be informed by evidence- ticals, 13(11), 334.
based science, including social science and humanities Callaway, J. C., Grob, C. S., McKenna, D. J., Nichols, D. E.,
research on the topic (Labate & Cavnar, 2018; Labate et al., Shulgin, A., & Tupper, K. W. (2006). A demand for clarity
2017; Labate & Jungaberle, 2011). Lastly, we advocate for regarding a case report on the ingestion of 5-methoxy-N,N-
inclusion of and respect for Indigenous traditions, which is a dimethyltryptamine (5-MeO-DMT) in an ayahuasca prepara-
challenge for governments, universities, and practitioners. tion. J Anal Toxicol, 30(6), 406.
Since there are no conclusive studies showing that ayahuasca Chacruna Institute (2023, March 1). FOIA brings to light DEA’s
is harmful to public health, we continue to rely on the im- problematic report, “Ayahuasca: Risks to Public Health and
memorial traditional uses and their reports on the safety of Safety. Chacruna. https://chacruna.net/foia-brings-to-light-
ayahuasca, as well as on its key value as a medicine, strongly deas-problematic-report-ayahuasca-risks-to-public-health-and-
supported by a growing number of rigorous clinical studies. safety.
Council for the Protection of Sacred Plants (2020, May 14).
Warning: Increase in recent seizures by homeland security in
the US. Chacruna. https://chacruna.net/warning-increase-in-
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