Thread by @MasonMarksMD

1/ #Oregon Health Authority publishes latest draft #psilocybin rules to implement Measure 109. Some early thoughts: First, the rules allow for a variation of #microdosing. Clients could consume up to 5mg and potentially leave a center after 1 hour.

oregon.gov/oha/PH/PREVENT…

2/ Under the draft rules, the minimum length of administration sessions would vary based on the dose of #psilocybin received. Clients consuming 5 - 10mg could potentially leave after 2 hours, and 15 - 25mg would require a minimum stay of 4 hours.

3/ The facilitator to client ratios will also change depending on the doses of #psilocybin received, ranging from a potential 8 clients to each facilitator for doses of 5 - 10mg to no more than 1 client for every facilitator for doses between 40 - 50mg.

4/ Basing the facilitator to client ratios on the dose receives seems a bit arbitrary because people will likely react very differently to different doses. Under #Oregon's draft #psilocybin rules, the maximum dose during a single administration session is 50mg.

5/ Under #Oregon's draft #psilocybin rules, the maximum serving size (for packaging purposes) is 25mg. Manufacturers could offer products in smaller doses such as 1, 5, or 10mg to suit different clients' needs, including those who wish to #microdose.

6/ #Psilocybin facilitator candidates in #Oregon must achieve a score of 75 percent on an online licensing exam offered by @OHAOregon. According to draft rules, candidates can repeat the exam after waiting 48 hours.

7/ As recommended by #Oregon #Psilocybin Advisory Board & Health #Equity committee, applicants for all license types must include a Social Equity Plan with their applications. However, @OHAOregon is unlikely to scrutinize them or penalize applicants for poorly drafted plans.

8/ #Oregon #psilocybin license fees will be as follows (according to draft rules): $10,000 for manufacturers, service centers, and laboratories. $2,000 for facilitators. The fees are reduced by 50% for non-profit entities.

9/ #Oregon's draft #psilocybin rules smartly limit facilitators' scope of practice. There has been confusion over the nature of Measure 109's regulated system. But the rules state facilitators cannot diagnose or treat disease nor exercise privileges of other licensed professions.

10/ Limiting facilitator scope of practice reflects Measure 109's non-medical purpose, which I wrote about for @Charcuna. If facilitators diagnose or treat health conditions, they risk their medical licenses and put Oregon's #psilocybin services at risk.

chacruna.net/oregon-legaliz…

11/ One slightly concerning part of #Oregon's draft #psilocybin rules involves when facilitators must contact emergency responders. Facilitators must immediately call police if clients ignore their transportation plan, putting themselves in danger.

12/ Though well intentioned, this rule could lead to tense and dangerous confrontations between #psilocybin clients and police. Police responding to #mentalhealth emergencies often lack adequate training and sometimes kill the people they were called to help.

13/ #Oregon's draft #psilocybin rules do a reasonable job protecting client #privacy. They prohibit video recording during administration sessions and require consent to share client's identifiable info. But there's still room for improvement.

14/ #OHAOregon did a great job implementing many of the #psilocybin board's recommendations including those regarding facilitator conduct, social equity plans, and clients' rights.

15/ One aspect of #psilocybin rules untouched by the Oregon Advisory Board was sanctions for facilitators. @OHAOregon proposes a tiered violation structure with category I - IV violations resulting in different penalties depending on the number accrued per 2-year period.

@OHAOregon 16/ @OHAOregon has taken a middle path when it comes to #psilocyin client screening. Some had suggested a more detailed and invasive medical questionnaire, but the draft rules envision a system that promotes safety while respecting significant client autonomy.