Supplemental Reading Week 9 Special Study Critique Policy Warning

Why the “Huestis Kratom Study” Should NOT Be Used to Justify Policy

A critical review of the January 2026 human kratom tolerability trial

Citation Basis

This critique is grounded in the study’s own methods, results, and disclosures. Citations below refer to the published paper itself: Huestis et al., Therapeutic Drug Monitoring (January 2026).

Primary Study Source

The analysis below is based on the full published paper:

Huestis MA et al.
Safety and Tolerability of Single and Multiple Daily Oral Doses of Dried Kratom Leaf Powder in a Randomized Trial in Healthy Volunteers
Therapeutic Drug Monitoring, January 2026

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In January 2026, a study led by Marilyn Huestis et al. was published in Therapeutic Drug Monitoring claiming that a commercial kratom product was “safe and well tolerated” in healthy volunteers. This paper is now being cited by kratom advocates and industry groups to argue against regulation, scheduling, or enforcement.

That use is deeply misleading.

When examined carefully, the study raises significant safety concerns, demonstrates dose-related toxicity signals, and contains material conflicts of interest that demand caution—not policy reliance.

Below is what legislators need to understand.


1. This was NOT a real-world safety study

The study population was highly artificial:

This bears no resemblance to real-world consumers, who frequently:

A study that excludes risk does not prove safety.

2. The study repeatedly triggered liver enzyme elevations

Despite aggressive screening and monitoring, liver toxicity emerged anyway.

Key findings reported in the paper:

This is the point policymakers must not miss:
The absence of severe liver injury was achieved by stopping dosing early—not because the product was benign.

The study acknowledges increased ALT/AST incidence at higher doses and recommends liver monitoring in future studies. That is not reassurance—it is a warning.


3. Serious and alarming adverse events occurred

The paper downplays events that would be unacceptable in most consumer products:

These effects matter for driving, working, supervising children, and public safety.


4. “Well tolerated” masks a high adverse-event burden

Among participants receiving active product:

Calling this “well tolerated” depends entirely on redefining tolerance to mean “participants were stopped before worse injury occurred.”

5. The abuse-potential conclusion is unsupported

The paper claims “no meaningful abuse potential,” yet:

This study cannot answer real-world addiction risk, yet its conclusions are being cited as if it does.


6. Conflicts of interest are not incidental — they are central

This study was:

Disclosed conflicts still matter when:

Industry-funded safety studies should never be treated as regulatory evidence.

7. What legislators are being told vs. what the data actually show

What advocates say

“A large human study proves kratom is safe.”

What the study actually shows


Bottom line for policymakers

This paper does not justify legalization, deregulation, or normalization.

Instead, it supports the opposite conclusions:

Using this study to argue against regulation is scientifically irresponsible and politically dangerous.


Why this study quietly confirms the pharmaceutical reality

If this were a credible candidate for mainstream medicine, you would see a normal pharmaceutical pathway: standardized formulation, reproducible dosing, long-term safety programs, drug–drug interaction studies, abuse-liability testing, and controlled clinical trials under FDA oversight.

That is not what is happening.

Instead, we are watching an industry insist a product is “safe” while:

No serious pharmaceutical manufacturer would try to bring a product to the FDA on this evidence and call it “well tolerated.”
If the best-case scenario still requires medical-style monitoring to prevent harm, it does not belong in convenience stores.

MAHA’s position is simple

When a product requires medical-style monitoring to prevent harm in a controlled trial, it does not belong on gas-station shelves.

Use MAHA’s directory to find your state contacts and take action: State Take Action

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