Submission to Health Canada on a proposal to control the derivatives and analogues of 4-piperidone and its salts under the Controlled Drugs and Substances Act

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On October 28, 2023, Health Canada solicited comments and published a Notice of Intent proposing to amend item 27 of Schedule VI to the Controlled Drugs and Substances Act (CDSA) and item 28 of the Schedule to the Precursor Control Regulations by expanding the existing listings of the fentanyl precursor 4-piperidone and its salts to include its derivatives and analogues under the CDSA.

The Canadian Drug Policy Coalition made a submission that considered the existing legal framework, lessons from previous and ongoing scheduling of substances, and concerns about the health and societal risks created by the existing regulatory environment. The submission noted that the persistent and growing scheduling of substances and pre-cursors does not achieve the intended outcome of reducing the use of substances and has unintended negative consequences, especially for people who use drugs, and encouraged a more fulsome discussion of the models and options available to regulate all substances, drawing on lessons learned from other public health policy issues.