I am also the chair of the International Drug Policy Consortium.
I have a few comments on the operation of the system of re-scheduling of substances. In a time of constantly diversifying drug market, and rapidly developing science on risks and patterns of use of substance and their impacts, the process of scheduling decision is even more important. It’s about assessing risk of restricting medical use and non-medical use.
The UN system has its own process for making this decision but so do member states. There are 3 principles to this process: raising concerns around a particular substance, the process of assessing risk and science, and decision on whether to ban – at national and international level.
At the UN level, the process of assessing risk and science is done by WHO, the decision is made by this forum and implemented by the INCB.
We have to admit that the system s not working as strongly as needed, primarily because of resource use. The resource committee on dependence does not have resources to respond to rapidly to changing situations, with so many new substances, and not been able to constantly review substances already scheduled.
There is fundamental problem with the operation of the science process. The role of the INCB is unclear, sometimes it raises concerns and tends to take a role in expressing opinions on science and evaluation which can bring it into conflict with WHO advice. This leads to difficulties for member states, who have to consider where technical advice is coming from. The temptation is then to engage in scheduling decisions through other mechanisms.
It is clear to us that the difficult process relates to a lot of issues on the scheduling decision, eg. with the coca leaf, which leads to member states going through other political processes. Sometimes member states disagree with recommendations from the WHO but the mechanisms for resolving these conflicts are weak.
We ask you to give attention to structural processes for making scheduling decisions, which requires a resolution of the resource questions. The era of trying to get by with a low resourced scientific process is no longer sustainable.