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.
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 tetrahydroharmine (Riba et al., 2003). Ayahuasca has been used by Indigenous peoples in the Amazon for centuries (Bianchi 2005; Miller, 2017) and, additionally, is a sacrament in several 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., 2016; Osório et al., 2015; Palhano-Fontes et al., 2019; Sanches et al., 2016). Nonetheless, DMT remains a Schedule I substance in the United States.
Recently, in the USA, there has been a flurry of ayahuasca seizures and attempts to criminalize patients, sitters, and Indigenous shamans involved with ayahuasca (see, Council for the protection of Sacred Plants, 2020; Heffernan, 2021). On February 13, 2023, the DEA released a single document to the legal team representing the Church of the Eagle and the Condor (“CEC”). This sole disclosure comes 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—requests that went ignored and unanswered in violation of the Freedom of Information Act. This document, titled “Ayahuasca: Risks to Public Health and Safety,” was issued in July 2020 (Chacruna Institute, 2023).
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.
Lack of systematic review of the relevant literature
First, the DEA report did not conduct a comprehensive review of the literature; rather, it selected studies that exaggerate dangers and ignored or, at best, made cursory mention of studies that demonstrate safety or positive effects. Notably, the report has not been updated since it was written in 2020, and does not include several recent pertinent studies in humans and in animal models. Given the influence that the DEA report may have on government policy related to ayahuasca, it must be dynamic and updated regularly, e.g. yearly, in much the same way as Investigator's Brochures, to reflect the most current evidence.
Moreover, there seems to be a kind of circular argument in the report, wherein being part of the Schedule I list is proof in and of itself that these substances are dangerous and problematic. The Controlled Substance Act (CSA) is evoked as an authoritative argument that attests to the danger of ayahuasca to public health. But the CSA needs to be seen as a political document that is subject to change and questioning. The recent discussions about psilocybin, MDMA, and other psychedelics make it clear how it is a document that can be updated, and that it cannot in any way be taken as scientific evidence that ayahuasca causes risks to public health and safety.
Missing evidence for safety and benefits of ayahuasca in humans
A comprehensive assessment of the state of the art in ayahuasca research could not have ignored numerous recent original clinical trials indicating antidepressant and anti-inflammatory effects of ayahuasca, as well as that ayahuasca promotes an elevation of a blood biomarker of neuroplasticity (de Almeida et al., 2019; Galvão-Coelho et al., 2020; Leite, 2023; Osório et al., 2015; Palhano-Fontes et al., 2019).
Several comprehensive reviews and a global survey on ayahuasca's therapeutic potential indicate consistently mounting evidence of potential benefit in psychiatric illnesses, such as depression, anxiety, and substance use disorder (Domínguez-Clavé et al., 2016; Dos Santos, Balthazar, Bouso, & Hallak, 2016; Hamill, Hallak, Dursun, & Baker, 2019; Perkins et al., 2022; Sarris et al., 2021); and, potentially, in other illnesses, such as neurodegenerative disorders and end-of-life distress (Maia, Daldegan-Bueno, Wießner, Araujo, & Tófoli, 2023).
In addition, multiple cross-sectional, case-control, and longitudinal studies of ayahuasca in religious or retreat settings indicate positive effects of ayahuasca (see review by Maia et al., 2023). Turning a blind eye to so many sound studies is highly problematic and anti-scientific. It raises suspicion that the author[s] of the report had an a priori negative bias, possibly related to a political agenda or ideological position.
Missing data on the safety and potential benefits of ayahuasca from pre-clinical research
Likewise missing is a large body of pre-clinical evidence of ayahuasca's therapeutic potential. Rodent and primate studies indicate the antidepressant and anti-addictive potential of ayahuasca (see reviews by Cameron & Olson, 2018; Dos Santos, Osório, Crippa, & Hallak, 2016; Ferraz et al., 2019; da Silva et al., 2019). Some new evidence indicates that ayahuasca seems to have prophylactic action, buffering the emergence of depressive-like behaviors and cortisol changes in a non-human primate animal model of depression (de Meiroz Grilo et al., 2022). Moreover, there is evidence that DMT regulates adult neurogenesis, both in vivo and in vitro (Ly et al., 2018; Morales-Garcia, 2020), as well as modulating immune response (see review by Inserra et al., 2021).
Missing evidence from epidemiological studies of populations regularly using ayahuasca
The DEA report fails to discuss epidemiological studies 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, Bogenschutz, & Strassman, 2012; Grob et al., 1996; Kohek et al., 2022; Ona et al., 2019). The level of collective health and quality of life of certain ayahuasca communities may actually be more positive than that of non-ayahuasca-using social groups living in the same region, as is the case for some Santo Daime communities in the Amazon region (Grob et al., 1996; MacRae, 1992).
Moreover, the report does not consider Indigenous peoples who use ayahuasca as relevant actors whose traditions and ceremonies need to be considered and respected. The report leaves aside all the rich anthropological and sociological literature on the uses of ayahuasca (Anderson et al., 2012; Labate & Araújo, 2004; Labate et al., 2008), and on ayahuasca and health (Labate et al., 2013). It also ignores all the hundreds of accounts of ayahuasca benefits present in the oral history of traditional ayahuasca use and, instead, cherry-picks negative anecdotal cases.
No mention of the legal status of ayahuasca elsewhere in the world
The DEA report fails to reflect on the legal status and policies around ayahuasca in South American countries, nor on the case of the UDV victory in the US Supreme Court. The safety profile of ayahuasca use among the exempted groups is not analyzed.
It is important to highlight the Brazilian case. Contrary to the constrained stance of the DEA, the Brazilian government has shown a much more mindful and comprehensive attitude regarding the use of ayahuasca. Shortly after the ban of ayahuasca by the Brazilian regulatory agency on drugs in 1985, the Federal Council of Narcotics (CONFEN) issued a resolution that established the creation of a working group (WG) to examine the use of ayahuasca in Brazil. The WG was comprised of members of the council and experts in various fields. After two years of intensive research, in which the members of the WG visited a number of ayahuasca churches in the Amazon and in the southeast of Brazil, interviewed their members and leaders, examined their practices, and did a thorough literature survey, the WG published a Final Report (Federal Council of Narcotics CONFEN, 1987). The report stated that ayahuasca religions had moral and ethical standards of behavior similar to the rest of Brazilian society, and sometimes even stricter. As for the ceremonies, they emphasized the role of the religious environment as a whole, including the role of music and dancing. In addition, they highlighted that, after the ceremonies were over, everyone returned to their homes in an orderly fashion. In general, the report described its members as peaceful and happy people, highlighting that some of them attributed several positive changes to the religious use of ayahuasca, such as the constructive reorganization of family life, a renewed interest 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 ayahuasca is quite difficult and prolonged and performed within a ritual, meaning that a significant increase in production levels capable of providing a supply for “abuse” and for recreational use would be unlikely. Finally, the WG stressed that the ritual use of ayahuasca has been documented for many decades and that they did not find any evidence of health or social harm caused by the use of ayahuasca in the religious communities examined. The report concluded that the use of the tea did not have any adverse consequences on the social life of its followers; on the contrary, it stated that ayahuasca is likely to orient them toward the search for social happiness within an orderly and productive context (Federal Council of Narcotics CONFEN, 1987, p. 29).
We must highlight the innovative approach of CONFEN. Instead of reducing ayahuasca to its chemical compounds and focusing solely on their effects, the Brazilian drug agency had the cultural and anthropological sensibility to understand 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). The CONFEN report understood, as is well known in anthropological studies regarding psychedelic substances, that these cannot be examined isolated from the context of use, and that the practices of established religious communities play a central role in the use of ayahuasca, making it not only a safe practice but a tradition that is in tune with the family-centered values most dear to Brazilian society.
In the 2000s, the National Council on Drug Policy (CONAD) reaffirmed the right of ayahuasca groups to practice the religious use of ayahuasca, based on the principle of religious freedom and the constitutional commitment to protect and safeguard Indigenous and Afro-Brazilian traditions. Furthermore, CONAD sponsored a pioneering initiative of organizing a Multidisciplinary Working Group (MWG) to establish guidelines for the use of ayahuasca in Brazil. Understanding that this could not be done without acknowledging the accumulated data on the subject, CONAD invited a number of scholars from various fields and representatives of the main Brazilian ayahuasca religions to be part of the MWG. Together, they published a report in 2006 that established a number of recommendations for the responsible use of ayahuasca (National Council on Drug Policy CONAD, 2006). In 2010, the Brazilian government established a resolution to implement the recommendations of the MGW report, recognizing the importance of the cultural and religious value of ayahuasca traditions in the country (National Council on Drug Policy CONAD, 2010).
The Brazilian case is a successful example of an inclusive public policy developed through a partnership with prominent academic specialists in the country and members of ayahuasca religions, proving that the religious use of ayahuasca can safely be accommodated in society if there is an open channel for dialogue and collaboration. Hopefully, the DEA can learn from the Brazilian experience and look for ways to regulate the religious use of ayahuasca in the US.
False claims regarding ayahuasca preparation and dangerous admixtures
A central point in the DEA argumentation is the statement about ayahuasca that “there is no unified or standardized formula for its preparation.” This point appears in the first paragraph and continues to be stated more than 10 times throughout the document.
Like all botanical preparations, no two ayahuasca preparations are exactly the same, and different ayahuasca-using communities have different methods for preparation. However, this process among ayahuasca-using communities is far from random; rather, the traditional uses of ayahuasca are historically built on formulas that follow strict procedures, deep cosmologies, and a know-how that are far from random and are usually quite rigorous. In fact, ayahuasca is a central part of several Indigenous medical systems, and is frequently found among mestizo and urban settings throughout the globe (Dobkin de Rios, 1972; Luna, 1986).
The fact that ayahuasca is not a “controllable” synthetic compound is not, in and of itself, a risk to public health. The traditional use of whole plants as medicines has millennia of cultural experience, while purified compounds, especially psychoactive ones, have only recently started to be investigated (Ribeiro, 2018). By falsely asserting the dangers of botanical preparations that lack a single method of preparation, the report leads readers to believe that people are taking the risk of drinking lethal doses of ayahuasca. The vast anthropological bibliography about the traditional and urban uses of ayahuasca shows that, in practice, such doses are never consumed (Labate, 2004). Additionally, the report overemphasizes the prevalence of admixtures, suggesting that substances such as cocaine or plants containing tropane alkaloids are commonly used in the preparation of ayahuasca, and can therefore cause overdose or toxicity.
Kaasik et al. (2021) analyzed 102 samples of brews from ayahuasca-using communities. They found higher and more variable concentrations of DMT in neoshamanic ayahuasca samples compared to Indigenous samples or samples from ayahuasca churches. The analysis revealed the average (minimal – maximal) concentrations (mg L−1) of DMT 764 (88–2687), THH 995 (32–3875), harmine 1318 (141–4440), and harmaline 85 (4–387). In this study, other psychoactive components, such as moclobemide, psilocin, and yuremamine were only found in analogues of ayahuasca (Peganum 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.
Problematic comparisons with animal toxicology
The DEA report cited an animal toxicology extrapolation model estimating that the LD50 for oral DMT in humans would be 8 mg kg−1, which is more than 20 times the dose of oral DMT (approximately 27 mg) typically consumed from ayahuasca (Gable, 2007). However, the report also omitted the researcher's explanation that “simple extrapolation of DMT lethality data from mice to humans is obviously untenable” due to differences in metabolism, physiology, and even serotonin receptor distribution and that “the dependence potential of oral DMT and the risk of sustained psychological disturbance are minimal” (Gable, 2007). A more recent review of animal data on ayahuasca/DMT, which was not mentioned in the DEA report, indicates that ayahuasca is toxicologically safe in ceremonial-comparable doses (Daldegan-Bueno, Simionato, Favaro, & Maia, 2023). The LD50 in rodents is approximately 30 times higher than the therapeutic/ceremonial doses (even taking into account variability across samples) (Brito-da-Costa, Dias-da-Silva, Gomes, Dinis-Oliveira, & Madureira-Carvalho, 2020; Simão et al., 2019).
Another article omitted from the DEA report estimated that an extrapolated oral DMT “usual lethal dose” in humans would be 2 g, which is about 75 times greater than the typical 27 mg DMT dose taken in ayahuasca, and that the oral ayahuasca “usual effective dose” to “usual lethal dose” safety ratio of 50 was substantially higher than several commonly used substances, such as alcohol (10), dextromethorphan (10), and codeine (20), which demonstrated a favorable safety profile for DMT (Gable, 2004).
A further point that should be highlighted is that the authors of the report equate the use (and associated risks) of ayahuasca with that of isolated DMT and beta-carbolines, which is a mistake for several reasons. DMT and ayahuasca have very different pharmacokinetic and pharmacodynamic profiles and are used via different routes of administration and in different contexts. DMT has a much shorter onset time and duration of effects, a higher intensity, and a different phenomenology (James, Keppler, L Robertshaw, & Sessa, 2022; Strassman, Qualls, Uhlenhuth, & Kellner, 1994). The synergy between plants containing DMT and plants containing beta-carbolines in the report is reduced to “additional risks leading to potential toxic consequences.” To support this claim, they cite studies that have shown beta-carboline toxicity, where these substances were isolated and analyzed alone. Paradoxically, studies indicating that isolated beta-carbolines are neuroprotective and anti-inflammatory were omitted from the report (Katchborian-Neto et al., 2020; Santos, Moreira, Borges, & Caldas, 2022).
Conflation of ayahuasca effects with adverse health effects
The DEA report views all subjective and consciousness-altering effects of ayahuasca through a negative lens, as if they are all harmful or undesirable “side effects.” This is in stark contrast to Indigenous understandings of phenomena such as vomiting, which is seen as a cleansing opportunity (purging) (Politi et al., 2022), and ignores emerging scientific evidence that psychedelic-induced mystical-type experiences are correlated with therapeutic benefit (Yaden and Griffiths, 2020). The choice to view all effects of “drug intoxication” as negative follows a long demonizing tradition at the core of Prohibition, based on moral and religious dogmas that starts by using language with negative bias. There is a section called “Adverse Effects of Ayahuasca Reported in the Media.” This kind of reference should be viewed with great caution, as these stories are often sensationalist and garbled (Sinclair, 2017).
It is more informative to look at comprehensive survey data, such as the online Global Ayahuasca Survey, which ran between 2017 and 2019, and collected information about “ayahuasca side-effects” in participants (n = 10,836) from more than 50 countries. Acute physical health adverse effects (primarily vomiting) were reported by 69.9% of the sample, with only 2.3% reporting the need for subsequent medical attention. Adverse physical effects were related to older age at initial use of ayahuasca, having a physical health condition, having a previous or family history of psychotic symptoms, having a previous substance use disorder diagnosis, and taking ayahuasca in a non-supervised context. Adverse mental health effects in the weeks or months following consumption were reported by 55.9% of the sample; however, around 88% considered such mental health effects as part of a positive process of growth or integration. Around 12% sought professional support for these effects. The occurrence of adverse mental health effects was positively correlated with pre-existing anxiety disorders, physical health conditions, and the strength of the acute spiritual experience, and negatively associated with consumption in religious settings (Bouso et al., 2022).
Below we provide necessary nuances to some of the “adverse effects” discussed in the report:
Hallucinations
The DEA report cites hallucinations as a side-effect of ayahuasca. In fact, they are one of the most sought-after effects of a psychedelic experience. Altered states of consciousness induced by psychedelics, and resulting “mystical” or “peak” experiences, are reported as some of the most meaningful experiences (Griffiths et al., 2011), correlating positively with therapeutic outcomes in depression, anxiety, and nicotine addiction (Yaden and Griffiths, 2020), including in ayahuasca randomly-controlled trials (RTCs) (Palhano-Fontes et al., 2019).
Hallucinations—particularly visions of autobiographical or transpersonal nature, but even more abstract geometric hallucinations—are thought to catalyze mystical experiences, emotional breakthroughs, insights, and experiences of awe induced by psychedelics, which are all related to therapeutic effectiveness (Aqil & Roseman, 2022). In fact, recent evidence suggests that the neurophysiological mechanisms involved with these visions are related to a dream-like state, rather than a pathological hallucination (de Arujo et al., 2012).
Vomiting
In shamanic contexts, purging is an essential and intrinsic aspect of ayahuasca's medicinal value. Although purging as a healing method is not recognized in Western medicine, new studies on the gut-brain axis may add knowledge about it in the near future. For instance, it has been suggested that purging has potential benefits for gastrointestinal function and microbiota balance, modulating the gut-brain axis in a positive way (Fotiou et al., 2019; Politi, Tresca, Menghini, & Ferrante, 2022). Rather than a side effect, the emetic effects of ayahuasca should be regarded as a safety point, since the emetic dose is similar to the psychoactive one.
Hypertension and tachycardia
In the DEA report, the authors refer to hypertension (high blood pressure) and tachycardia (increased heart rate), as “cardiotoxicity” (bottom of page 11). For a cardiologist, however, cardiotoxicity refers to the occurrence of heart dysfunction as electric or muscle damage, resulting in heart toxicity, as occurs sometimes after chemotherapy. Acute high blood pressure and tachycardia do not indicate damage to the heart, or “cardiotoxicity.” Elevated blood pressure and heart rate normally happen transiently in most humans, including those with no measurable damage to their hearts. Gable (2007) analyzed several studies to compare changes in heart rate and blood pressure brought on by various psychoactive substances and concluded that the hemodynamic effects of ayahuasca appear less hazardous than alcohol.
Other adverse effects
Chronic ayahuasca users (n = 22) show no change in biochemical parameters related to hepatic damage (Mello et al., 2019).
Lack of accuracy in numbers of hospitalizations and poisonings
The report cites data from the American Association of Poison Control Centers (AAPCC) that links exposure to ayahuasca to negative health outcomes, including hospitalization. The AAPCC data is based on over 500 cases, some of which mention serious health issues, such as intubation. However, there is no comparison of these cases with the number of people using ayahuasca, so it is impossible to attest to the overall prevalence of the problem. Moreover, there were no toxicological exams to confirm the presence of DMT or other active principles of ayahuasca; thus, we do not know what, if any, substances were actually consumed, nor do we know the context in which they were consumed. Hence, these data are entirely unreliable and exclusively based on hearsay. Part of the adverse effects report comes from the article “Ayahuasca Exposure: Descriptive Analysis of Calls to US Poison Control Centers from 2005 to 2015.” While this document describes several adverse effects that are possible due to ayahuasca ingestion, the authors also assert that “Case reports of adverse outcomes and human deaths may be not from botanical ayahuasca at all” (Callaway et al., 2006).
Conversely, the data from studies conducted with ayahuasca in clinical trials only presented transient and rapidly resolving side effects, not dissimilar to those of other classic psychedelics, such as gastrointestinal malaise and vomiting (but see above about the importance of vomiting in traditional and religious contexts), headaches, and mild-to-moderate increases in heart rate and blood pressure (n = 108, healthy volunteers and depression patients in 11 trials). Rarer were reports of anxiety, confusion, emotional distress, depersonalization, and dysphoric states, although even those were transient and resolved on their own or with psychological support provided during the trial (Rossi et al., 2022).
Lack of awareness regarding the setting and informal forms of control
The DEA does not address any of the cultural and social dimensions of ayahuasca consumption. The dozens of theses and dissertations on ayahuasca communities show that they contain complex social and cultural dynamics. The shamans and leaders of ayahuasca religions have developed formal and informal forms of control in order to minimize adverse effects and to provide a safe environment for the use of ayahuasca. In fact, organized ayahuasca-using communities employ a number of strategies to mitigate the majority of significant risks inherent in using ayahuasca. These include reliable sourcing of ayahuasca, screening potential ceremony participants, and consuming ayahuasca within structured and supervised settings with experienced leaders and guides who can safely support individuals having difficult experiences or in need of (extremely rare) medical attention. Both controlled trials as well as prospective data from ayahuasca-using communities clearly demonstrate the safety profile of ayahuasca within controlled settings (Barbosa et al., 2012; Chacruna Institute for Psychedelic Plant Medicines & Hoots, 2021; MacRae, 2009; Rossi et al., 2022).
In this regard, the literature has shown that the ritual use of ayahuasca cannot be equated to DMT consumption in a clinical setting. As Hartogsohn (2021, p. 14) states, “the effects of ayahuasca are profoundly mediated through complex layers of intentions, expectations, visual, auditory, and symbolic environments, social and cultural systems, etc. These various contextual factors comprise a rich cultural apparatus that serves to mitigate harms and facilitate social and personal benefits.”
The importance of the setting and the strict informal and formal means of control established by Indigenous peoples and ayahuasca religions occupy a central role when it comes to experiencing ayahuasca. Epidemiological studies that have demonstrated the lack of harm in ayahuasca-using communities (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 should not be underestimated, as is clear from the example of differentiating different ayahuasca vine varieties that elude contemporary botanical distinctions (Sheldrake, 2020). By disregarding the current clinical evidence and research in Indigenous and religious communities, and not considering the anthropological literature available on the matter, the DEA demonstrated a narrow, ethnocentric approach that fails to truly characterize the potential risks related to ayahuasca. We find it highly problematic that the DEA report did not exhibit the scientific rigor or anthropological sensitivity to understand the harm reduction practices and benefits of the use of ayahuasca in traditional settings.
False conclusions about ayahuasca's risk to public health and safety
The DEA report asserts that, “Based upon the existing information, ayahuasca presents a significant risk to public health and safety.” We do not dispute that there are potential risks inherent in ayahuasca use, including unknown composition, lack of adequate screening, and lack of psychosocial support leading to untoward experiences, or the lack of follow-up and integration, which could produce psychological harm or lead to calls to poison control. Notwithstanding, the above summary statement is highly problematic because it asserts that:
- a)All ayahuasca use presents a significant risk;
- b)All contexts of ayahuasca use are equally likely to cause problems;
- c)Ayahuasca is a risk to public health at large, rather than to a subset of individuals who choose to drink ayahuasca.
Regarding the first two points, the risk of ayahuasca use is variable depending on individual user characteristics and, as discussed above, the context in which ayahuasca is used. For instance, ayahuasca use among individuals with histories of psychosis and without social support presents higher risks. Similarly, ayahuasca use in unstructured and unsupervised settings is riskier than in controlled environments, such as the ceremonial contexts in which the majority of ayahuasca use occurs. These principles are similarly true for nearly all psychoactive compounds, such as alcohol (e.g., drinking moderate quantities in controlled social environments vs drinking to excess and driving or drinking by someone with liver disease vs a healthy adult).
Regarding the third point, the risks of ayahuasca, both to individual users and to others, are small compared to other substances, and the vast majority of risks inherent to ayahuasca use are to the users themselves, and not to others or to the broader communities in which ayahuasca use takes place. This is consistent with a variety of expert groups who rate psychedelic harms low compared to other medical and recreational drugs, while legal alcohol scores are one of the highest (van Amsterdam, Nutt, Phillips, & van den Brink, 2015; Bonomo et al., 2019; Nutt, King, & Phillips, 2010).
Final remarks
In this article, we highlight significant and obvious problems with the DEA report on ayahuasca, such as overt negative biases, unacceptable omissions, and obsolete misconceptions, while calling attention to recent scientific findings that were either not mentioned or mis-interpreted. In summary, the DEA report severely downplays the safety profile and therapeutic potential of ayahuasca and overemphasizes the risks. It reduces ayahuasca to DMT and falsely equates the risks of one with the other, while simultaneously failing to consider the ways in which context modulates the risks of use. This is especially harmful when discussing ayahuasca, given centuries of use among Indigenous communities and decades of use in modern religious contexts. Moreover, the report fails to include current research on ayahuasca demonstrating its potential benefits.
Thus, when considering the report as a whole, it seems clear that it was either written by personnel that lacked the proper knowledge and skillsets to produce a comprehensive report or was written with a predetermined Prohibitionist-style political agenda. That being said, we suggest that future policy related to ayahuasca should be informed by evidence-based science, including social science and humanities research on the topic (Labate & Cavnar, 2018; Labate et al., 2017; Labate & Jungaberle, 2011). Lastly, we advocate for inclusion of and respect for Indigenous traditions, which is a challenge for governments, universities, and practitioners. Since there are no conclusive studies showing that ayahuasca is harmful to public health, we continue to rely on the immemorial traditional uses and their reports on the safety of ayahuasca, as well as on its key value as a medicine, strongly supported by a growing number of rigorous clinical studies.
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