Ask Dr. Shulgin Online

ARCHIVE:  July 12, 2002

Salvinorin A and the Analogue Act

Dear Dr. Shulgin:

At the DEA webpage it states that Salvia divinorum and Salvinorin A may be subject to control under the Analogue statutes because of its functional pharmacological similarities to other CI hallucinogens like THC. How could this possibly be true? It seems to me that there is very little pharmacological or chemical similarity between Salvia divinorum and THC.

-- Peter

I had to call up that web page because I simply didn't believe you had quoted it correctly. But you had! I recommend that the reader call up this site just to see how many misstatements and blatant errors can be crammed into a two page article. Here are some examples.

"There are at least two types of terpenoids differentiated by the presence or absence of nitrogen." Terpenes are hydrocarbons that may contain oxygen but which never contain nitrogen.

"The nitrogen-containing terpenoids are called 'thujones'." Thujone is a compound, not a group of compounds, and does not contain nitrogen.

"The grouping of 'thujones' includes Salvia Divinorum [sic], Absinth [sic] (wormwood), and tetrahydrocannabinols (THC)."

Salvia divinorum is a plant, not a compound. Absinthe and Wormwood are names for the same plant, Artemisia absinthium, and the first name has also been given to a drink made from the plant. Neither is a compound although a principal compound in the drink is thujone. Tetrahydrocannabinol is THC and is indeed a compound but it does not have a nitrogen atom and has a structure very different from thujone.

"Salvia Divinorum, Salvinorin A and Divinorin A are not listed in the Controlled Substances Act." Absolutely correct.

"If sold for human consumption, Salvia may be subject to control under the Analogue statutes because of its functional pharmacological similarities to other CI hallucinogens like THC."

According to the Controlled Substance Analogue Enforcement Act, if a substance is substantially similar in structure, or in action, to a Schedule I or II controlled substance, then it can be treated as a Schedule I controlled substance. There are several points that would have to be settled by some law court. Is a plant a substance? Can a plant be "substantially similar" to a compound? And what is the "function" that is implicit in the phrase that suggests that Salvia (the plant) has "functional pharmacological similarities" to THC (the compound)?

I believe it would be an uphill battle for the prosecution.

-- Dr. Shulgin

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