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and is believed to be the primary naturally occurring kratom constituent the provides the effects"' that consumers report is the basis for their consuming kratom products. The study also complements two other studies that employed well-established models for comparing substances to morphine with respect to physical dependence and withdrawal. Those studies found very low levels of withdrawal"" ""' produced by mitragynine exposure as compared to morphine. This is consistent with surveys and field studies" x 'suggesting that even in heavy long term users of kratom who might experience withdrawal from kratom when they stop using it, the effects are generally far less intense and more readily self -manageable than those produced by abstinence from morphine and other classic addicting opioids. In fact, these studies and other evidence also indicate that many people report using kratom to self -manage opioid addiction, craving, and withdrawal though this is not recognized as an approved safe and effective use by health authorities.."" ""' Dr. Jack Henningfield, an internationally recognized expert in the assessment and regulation of substances with a potential for abuse and addiction who was not involved in the study, stated, "This new study provides important additional scientific evidence that kratom does not warrant regulation as morphine -like opioid (i.e., "narcotic"). Nor should kratom be described as opioid -like with respect to its abuse potential or addictiveness or safety profile based on this study and other research"" x°'"' Dr. Henningfield"' has researched and contributed to the regulatory approaches for many substances and new drugs through his studies with the National Institute on Drug Abuse, Johns Hopkins University, and other research institutions, and provides consulting support through PinneyAssociates on drug regulation as well as kratom science, including advising to the American Kratom Association. Dr. Henningfield further commented: "Abuse potential assessment and substance regulation is strongest when based on a broad range of types of laboratory studies and real world evidence to understand the pharmacological effects, safety and public health risks and benefits, as recommended in FDA's 2017 guidance: Assessment of the Abuse Potential of Drugs.`""' This was the approach by my colleagues and I in our analyses"" of kratom's abuse potential and our regulatory recommendations. It is exciting to see kratom research efforts increasing and using a broad range of techniques such as the animal self - administration, ICSS, and withdrawal models, and studies of potential therapeutic effects, as well as surveys of real world use and effects in the US and other countries such as by Malaysia's Center for Drug Research."" Relevance of COVID-19 and the Opioid Epidemic Dr. Henningfield added: "The COVID-19 pandemic on top of the opioid overdose epidemic adds to the urgency of regulatory approaches to preserve access to kratom by consumers but with product standards to address safety concerns. Kratom was the lifeline away from opioids for many people before the COVID pandemic because for many people formal treatment programs and FDA approved treatment approaches were not accessible, effective or acceptable. The COVID pandemic has been associated with increased opioid overdose deaths and impaired access to formal addiction treatment programs.""' Utah State Senator Curt Bramble, the primary sponsor of the first state legislation to provide for responsible regulation to prevent adulterated kratom products, agreed: "Now is not the time to reduce access to kratom. Now is the time for other states and ideally the Federal government to follow 2 The American Kratom Association is tax-exempt 501-C4 consumer advocacy organization dedicated to protecting and preserving consumer access to safe and unadulterated kratom products.