Charles P. Rosenberg Administrator (Acting) Drug Enforcement Administration Lincoln Place-West 700 Army Navy Drive Arlington, VA 22202 Re: Kratom Dear Mr. Rosenberg:
Having worked as a regulatory official in five1 Presidential Administrations, I understand that regulatory policy is not and should not be determined via plebiscite; however, in the instance of Kratom, when 100,000 2members of the public express outrage with a regulatory decision, it deserves a second look. Consequently CRE, in its role as a nationally3 recognized regulatory watchdog, is going to investigate this matter. In addition CRE has received hundreds of letters—not form letters—from concerned citizens which we have posted on the Kratom Policy Forum 4 on this page. We realize the time involved in reading a regulatory docket. It is for this reason we compiled these first hand stories for easy viewing by policymakers; no need to visit a website, then input docket numbers and take other actions. All is needed is a simple click on the aforementioned link.
The Resolution of Interagency Conflicts Is Within the Jurisdiction of OMB The Office of Information and Regulatory Affairs (OIRA) has been described as the cockpit of the regulatory state. It is an organization that has a statutory mandate to manage and oversee the flow of regulatory actions taken by federal agencies. In the discharge of these duties OIRA is often involved in one-on-one discussions with agency personnel to resolve potential conflicts with OMB personnel. However in this instance, the DEA action to ban Kratom, the conflict is considerably wider in scope. In this instance there is a sharp disagreement among a number of federal agencies. Consequently if there were ever a time for an OMB intervention this is it.
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Edited by cristinew, 12 September 2016 - 09:47 AM.