DEA/OD/ODE page 1 of 39 December 2013

Quinolin-8-yl 1-pentyl-1H-indole-3-carboxylate (PB-22; QUPIC),

quinolin-8-yl 1-(5-fluoropentyl)-1H-indole-3-carboxylate (5-fluoro-PB-22; 5F-PB-22), N-

(1-amino-3-methyl-1-oxobutan-2-yl)-1-(4-fluorobenzyl)-1H-indazole-3-carboxamide

(AB-FUBINACA) and N-(1-amino-3,3-dimethyl-1-oxobutan-2-yl)-1-pentyl-1H-indazole3-carboxamide (ADB-PINACA)

Background Information and Evaluation of ‘Three Factor Analysis’ (Factors 4, 5, and 6)

for Temporary Scheduling

Drug and Chemical Evaluation Section, Office of Diversion Control, Drug Enforcement 

Administration, Washington, DC 20537

December 2013

Introduction

Since 2009, there has been a marked increase in law enforcement encounters of

synthetic cannabinoids in the United States. These substances are being encountered 

on the designer drug market, laced on plant material and being abused for their 

psychoactive properties. Both law enforcement and public health reports demonstrate

a sustained abuse of synthetic cannabinoids and this abuse is having a negative impact 

on communities. Clinical reports demonstrate that the abuse of synthetic cannabinoid 

designer drug products can result in toxicity (Gunderson et al., 2012; Hermanns-Clausen 

et al., 2013; Fantegrossi et al., 2013; Konstrand et al., 2013). 

Synthetic cannabinoids are a large family of compounds that are functionally 

(biologically) similar to THC, the main active ingredient in marijuana. Synthetic 

cannabinoids, however, are not organic but are chemicals created in a laboratory. Two 

of the synthetic cannabinoids currently controlled (CP-47,497 and cannabicyclohexanol) 

were first synthesized in the early 1980’s for research purposes in the investigation of 

the cannabinoid system. JWH-018, JWH-073, and JWH-200 (all controlled under the 

Synthetic Drug Abuse Prevention Act of 2012) were synthesized in the mid-1990s and 

studied to further advance the understanding of drug-receptor interactions regarding 

the cannabinoid system. Synthesized as research tools, no other known legitimate uses 

have been identified for these five synthetic cannabinoids.
DEA/OD/ODE page 2 of 39 December 2013

According to forensic laboratory reports, the initial appearance of synthetic 

cannabinoids in herbal incense products in the United States occurred in November 

2008 when U.S. Customs and Border Protection (CBP) first encountered products using 

brand names such as “Spice.” Prior to appearing on the U.S. market, synthetic 

cannabinoids were marketed in herbal incense products in several European countries. 

After experiencing numerous health-related incidents, some European countries banned 

these products/chemicals. According to CBP, a number of the synthetic cannabinoids 

appeared to originate from foreign sources.

Detailed chemical analyses by DEA and other agencies have found synthetic 

cannabinoids applied on plant material in herbal incense products marketed to the 

general public. Product analyses have found variations in both the type of synthetic 

cannabinoid and the amount of the substance found on the plant material.

The vast majority of cannabinoids are manufactured in Asia by foreign chemists 

who are not bound by any manufacturing requirements or quality control standards. 

The bulk products are smuggled into the United States typically as misbranded imports. 

These chemicals are generally found in powder form or are dissolved in solvents, such as 

acetone, before being applied to the plant material comprising the “herbal incense” 

products. After local distributors apply the drug to the leafy material, they package it 

for retail distribution, ignoring any control mechanisms to prevent contamination or to 

ensure a consistent, uniform concentration of drug in each package. According to 

Internet discussion boards and law enforcement encounters, spraying or mixing the 

synthetic cannabinoids on plant material provides a vehicle for the most common route 

of administration- smoking (using a pipe, a water pipe, or rolling the drug-spiked plant 

material in cigarette papers). They are sold under hundreds of different brand names, 

including “Spice,” “K2,” “Blaze,” “Red X Dawn,” “Paradise,” “Demon,” “Black Magic,” 

“Spike,” “Mr. Nice Guy,” “Ninja,” “Zohai,” “Dream,” “Genie,” “Sence,” “Smoke,” 

“Skunk,” “Serenity,” “Yucatan,” “Fire,” and “Crazy Clown.”

Law enforcement personnel have encountered dosage form and packaging 

operations in residential neighborhoods, garages, and warehouses. Throughout this 

process, there is no concern for preventing contamination of the product, consistent 

dosage, or the adverse health consequences that may occur from ingesting the drug. As 

proposed in scientific literature, the risk of adverse health effects is further increased by 

the fact that similar products vary in the composition and concentration of synthetic 

cannabinoids applied on the plant material. 
DEA/OD/ODE page 3 of 39 December 2013

The designer drug products laced with synthetic cannabinoids are often being 

sold under the guise of ‘herbal incense’, ‘potpourri’, etc. under various product names 

and routinely labeled ‘not for human consumption’. Additionally, these products are 

marketed as a ‘legal high’ or ‘legal alternative to marijuana’ and are readily available 

over the Internet, in head shops, or sold in convenience stores. There is an incorrect 

assumption that these products are safe (Fattore and Fratta, 2011; McGuinness and 

Newell, 2012) and further, that mislabeling of these products as ‘not for human 

consumption’ is a legal defense against prosecution. Research has shown that even 

after various synthetic cannabinoids are subjected to control measures, producers of 

these products attempt to circumvent the law, thus making intervention measures 

particularly challenging (Cottencin et al., 2013).

These substances have no accepted medical use in the U.S. and have been 

reported to produce adverse health effects in humans while having a negative effect on 

communities. Acute and chronic abuse of synthetic cannabinoids in general have been 

linked to adverse health effects including signs of addiction and withdrawal 

(Zimmermann et al., 2009; Muller et al., 2010), numerous reports of emergency room 

admissions resulting from their abuse (Forrester et al., 2011; Hermanns-Clausen et al., 

2013, SAMHSA, 2012) and death (Patton et al., 2013; Law Enforcement/Toxicology 

correspondence). Psychiatric case reports have been reported in the scientific literature 

detailing the harms of synthetic cannabinoid abuse and psychoses (Oluwabusi et 

al.,2012; Peglow et al., 2012: Thomas et al., 2012).

The European Monitoring Center for Drugs and Drug Addiction (EMCDDA) 

published 84 reports regarding synthetic cannabinoids from January through May 2013, 

up from 30 reports in 2012 and 9 in 2009 (Cottencin et al., 2013; EMCDDA, 2013). 

In 2011 and again in 2013, DEA emergency scheduled a variety of synthetic 

cannabinoids including JWH-018, JWH-073, JWH-200, CP-47,497, and CP-47,497 C8 

(temporarily scheduled on March 1, 2011 at 76 FR 11075, and later placed in schedule I 

by Section 1152 of Food and Drug Administration Safety and Innovation Act (FDASIA), 

Pub. L. 112-144, on July 9, 2012) and UR-144, XLR11 and AKB-48 (temporarily scheduled 

on May 16, 2013 at 78 FR 28735) to protect the public health and safety. Section 1152 

of the FDASIA amended the Controlled Substances Act (CSA) by placing cannabimimetic 

agents and 26 specific substances (including 15 synthetic cannabinoids, 2 synthetic 

cathinones, and 9 phenethylamines of the 2C-series) in schedule I. UR-144, XLR11, and 

AKB48 were not included among the 15 specific named synthetic cannabinoids, did not 

fall under the definition of cannabimimetic agents under FDASIA, and were emergency 

scheduled on May 16, 2013. Although seizures of JWH-018, JWH-073, JWH-200, CP-
DEA/OD/ODE page 4 of 39 December 2013

47,497, and CP-47,497 C8 showed a decline shortly after these drugs were scheduled,

new synthetic cannabinoids began to emerge on the designer drug market. This new 

generation of synthetic cannabinoids, including UR-144, XLR11, and AKB48 quickly 

became the new drugs of choice in the synthetic marketplace, reaching total seizure 

levels higher than JWH-018, JWH-073, JWH-200, CP-47,497, and CP-47,497 C8 

combined. More recently law enforcement has been encountering another generation 

of synthetic cannabinoids including quinolin-8-yl 1-pentyl-1H-indole-3-carboxylate (PB22; QUPIC), quinolin-8-yl 1-(5-fluoropentyl)-1H-indole-3-carboxylate (5-Fluoro-PB-22; 

5F-PB-22), N-(1-amino-3-methyl-1-oxobutan-2-yl)-1-(4-fluorobenzyl)-1H-indazole-3-

carboxamide (AB-FUBINACA) and N-(1-amino-3,3-dimethyl-1-oxobutan-2-yl)-1-pentyl1H-indazole-3-carboxamide (ADB-PINACA). 

PB-22 and 5F-PB-22 are synthetic cannabinoids (Figure 1) that have 

pharmacological effects similar to the schedule I hallucinogen delta-9-

tetrahydrocannabinol (Δ9-THC). PB-22 and 5F-PB-22 were not reported in the scientific 

literature prior to their appearance on the illicit drug market. A report from March 2013 

identified PB-22 as a component of dried plant material obtained via the internet 

between July 2012 and January 2013 in Japan (Uchiyama et al., 2013). According to the 

System to Retrieve Information from Drug Evidence (STRIDE1) data, there are 189

reports for PB-22 and 155 reports for 5F-PB-22 from January 1 through November 30, 

2013 (Query date: December 18, 2013). During the same time period, the National 

Forensic Laboratory Information System (NFLIS2) registered 2,150 reports containing 

these synthetic cannabinoids (PB-22 – 1,092 reports; 5F-PB-22 –1,058 reports) in 29

states (Query date: December 18, 2013). In addition, five deaths have been reported 

involving the use of 5F-PB-22 (see factor 6).

AB-FUBINACA is also a synthetic cannabinoid (Figure 1) that has pharmacological 

effects similar to the schedule I hallucinogen delta-9-tetrahydrocannabinol (Δ9-THC). 

First appearing in a 2009 patent filed by the pharmaceutical manufacturer Pfizer 

(Buchler et al., 2009), AB-FUBINACA was most recently reported in the scientific 

literature as a component of so-called “herbal products” purchased via the Internet in 

July 2012 (Uchiyama et al., 2012). According to STRIDE data, there are 42 reports 

involving AB-FUBINACA and 458 reports in NFLIS from January 1 through November 30, 

2013 (Query date: December 18, 2013).

 

1

STRIDE is a database of drug exhibits sent to DEA laboratories for analysis. Exhibits from the database 

are from the DEA, other federal agencies, and low enforcement agencies. 

2 NFLIS is a national drug forensic laboratory reporting system that systematically collects results from 

drug chemistry analyses conducted by state and local forensic laboratories across the country.
DEA/OD/ODE page 5 of 39 December 2013

ADB-PINACA was first encountered in the United States following reports of 

serious adverse events in Georgia on August 23, 2013. Reports of ADB-PINACA were not 

found in the scientific literature prior to its emergence on the designer drug market. 

The Georgia Bureau of Investigation (GBI) reported on September 12, 2013 that ADBPINACA, was detected in “herbal incense” products sold under the brand name “Crazy 

Clown.” It was later confirmed by the Centers for Disease Control and Prevention (CDC) 

as the substance responsible for severe adverse events in at least 22 persons who 

consumed the product (CDC, 2013b). In addition, On August 30, 2013, the Colorado

Department of Public Health and Environment (CDPHE) was notified by several hospitals 

of an increase in the number of patients visiting their emergency departments (EDs) 

with altered mental status after using synthetic marijuana (Appendix 2). On September 

8, CDPHE, with the assistance of CDC, began an epidemiologic investigation whereby 

221 cases of severe illness due to ingestion of a synthetic cannabinoid were identified

(CDC, 2013c). Those that presented at emergency rooms in the Denver, Colorado area

around September 1, 2013 had symptoms similar to those found in the August 

2013Georgia incident. Laboratory analysis of samples from the Colorado incident 

confirmed that the substance abused in the “herbal incense” products was ADB-PINACA.

With no legitimate medical use and limited safety or toxicological information, 

these substances (PB-22, 5F-PB-22, AB-FUBINACA and ADB-PINACA) have emerged on 

the designer drug market and are being abused for their psychoactive properties. 

PB-22, 5F-PB-22, AB-FUBINACA and ADB-PINACA were also not included among the 15 

specific named synthetic cannabinoids under FDASIA, and do not fall under the 

definition of cannabimimetic agents as provided. To protect the public health and 

safety, the Drug Enforcement Administration (DEA) intends to temporarily place PB-22,

5F-PB-22, AB-FUBINACA, and ADB-PINACA in schedule I of the CSA. With respect to 

finding an imminent hazard to the public safety, DEA has considered the factors 

required under the CSA for the temporary scheduling of PB-22, 5F-PB-22, AB-FUBINACA

and ADB-PINACA. 21 U.S.C. 811(h)(3) and 811(c)(4)-(6).
DEA/OD/ODE page 6 of 39 December 2013

Figure 1. Chemical Structures

PB-22 and 5F-PB-22 belong to the aminoalkylindole structural class where 

previous studies have focused primarily on varying the indole nitrogen (1-position) and 

3-position substituents. PB-22 and 5F-PB-22, similar to JWH-018 and AM-2201

respectively, are substances representative of the aminoalkylindole structural class. 

Aminoalkylindoles are known to exhibit typical cannabinoid pharmacology in vivo

(D’Ambra et al., 1992; Compton et al., 1992). For example, 5F-PB-22 is structurally 

related to AM-2201 and it differs by having 8-quinolinyloxyl replacing the naphthalene 

group of AM-2201. The indole core became a framework for continued investigations 

with the early work by Sterling-Winthrop that led to pravadoline and WIN-55212-2 

(D’Ambra et al., 1992). Several other research groups expanded this investigation of 

structure activity relationships pertaining to this structural class, most notably the 

laboratories of Huffman and co-workers and Makriyannis and co-workers (Huffman, 

2009; Makriyannis and Liu, 2003). The scientific and patent literature details the further 

modification of the aminoalkylindole structural class with specific substitutions at the 3-

position of the indole core structure to incorporate aromatic and non-aromatic ring 

systems. 

AB-FUBINACA is classified as a pentyl indazole and has been reported in the 

literature as a cannabinoid agonist (Buchler et al., 2009; Uchiyama et al., 2013). 

AB-FUBINACA shares structural features with the schedule I substance AKB48. Both ABFUBINACA and AKB48 are based on the same indazole core structure where the 1- and 

3-positions of the indazole ring system are substituted. The 1-position of AB-FUBINACA 

is substituted with a para-fluorobenzyl group. The 3-position of AB-FUBINACA, like 

AKB48, is substituted with an amide linker. In AB-FUBINACA the nitrogen atom (N) of 
DEA/OD/ODE page 7 of 39 December 2013

this linker is further substituted with an acyclic alkyl amide, named 1-amino-3-methyl-1-

oxobutan-2-yl.

ADB-PINACA is classified as a pentyl indazole and was first reported online by the 

GBI following analysis of an herbal incense product called “Crazy Clown” in September 

of 2013. Consumption of ADB-PINACA resulted in multiple emergency room visits in 

Georgia and Colorado. ADB-PINACA shares structural features with the schedule I 

substance AKB48 (schedule I). There have been no published reports regarding its 

pharmacological properties.

Synthetic Cannabinoids

Quinolin-8-yl 1-pentyl-1H-indole-3-carboxylate (PB-22; QUPIC)

Studies evaluating the pharmacological effects of PB-22 in humans and laboratory 

animals have not been reported in the scientific literature. A study conducted by contract 

researchers of the National Institute on Drug Abuse (NIDA) and indicated that PB-22 binds 

to and acts as an agonist at the CB1 receptor (NIDA, 2013a; NIDA, 2013b). PB-22, and JWH018, a schedule I substance, are both based on the same indole core structure where the 1-

position of the indole ring system is substituted with an alkyl group in both structures. 

This alkyl group for both PB-22 and JWH-018 is a five carbon unit chain, known as a pentyl 

group. Both PB-22 and JWH-018 are substituted at the 3-position with a carbonyl linker to a 

fused aromatic ring system. In PB-22 there is an additional oxygen atom between the 

carbonyl group and the fused ring system. In both substances, the fused aromatic ring 

systems are based on ten atoms connected to each other in the same manner. 

In PB-22 one of these ten atoms is a nitrogen atom whereas in JWH-018, the ring system is 

carbon-based. Both fused rings in PB-22 and JWH-018 are aromatic, being of the same 

chemical classification.

Quinolin-8-yl 1-(5-fluoropentyl)-1H-indole-3-carboxylate (5F-PB-22)

Studies evaluating the pharmacological effects of 5F-PB-22 in humans and 

laboratory animals have not been reported in the scientific literature. A study 

conducted by contract researchers of NIDA indicated that 5F-PB-22 binds to and acts as

an agonist at the CB1 receptor (NIDA, 2013c; NIDA, 2013d). 5F-PB-22 is structurally 

similar to the schedule I substance AM2201. Both 5F-PB-22 and AM-2201 are based on 

the same indole core structure where the 1-position of the indole ring system is 

substituted with the same fluoroalkyl group in both structures. This fluoroalkyl group 
DEA/OD/ODE page 8 of 39 December 2013

for both 5F-PB-22 and AM-2201 is a five carbon unit chain, known as a pentyl group with 

a fluorine atom present on the terminal carbon atom. Both 5F-PB-22 and AM-2201 are 

substituted at the 3-position with a carbonyl linker to a fused aromatic ring system. 

In 5F-PB-22 there is an additional oxygen atom between the carbonyl group and the 

fused ring system. In both substances, the fused aromatic ring systems are based on ten 

atoms connected to each other in the same manner. In 5F-PB-22 one of these ten 

atoms is a nitrogen atom whereas in AM-2201, the ring system is carbon-based. 

Both fused rings in 5F-PB-22 and AM-2201 are aromatic, being of the same chemical 

classification.

N-(1-amino-3-methyl-1-oxobutan-2-yl)-1-(4-fluorobenzyl)-1H-indazole-3-carboxamide

(AB-FUBINACA).

AB-FUBINACA shares structural features with schedule I substances such as 

AKB48. Both AB-FUBINACA and AKB48 are based on the same indazole core structure 

where the 1- and 3-positions of the indazole ring system are substituted. The 1-position 

of AB-FUBINACA is substituted with a para-fluorobenzyl group. The 3-position of ABFUBINACA, like AKB48, is substituted with an amide linker. In AB-FUBINACA the 

nitrogen atom (N) of this linker is further substituted with an acyclic alkyl amide, named 

1-amino-3-methyl-1-oxobutan-2-yl. A patent submitted by Pfizer in 2009 demonstrates 

that AB-FUBINACA has a high affinity and functions as an agonist to the CB1 receptor

(Buchler et al., 2009). A study conducted by contract researchers NIDA indicated that 

AB-FUBINACA also binds to and is an agonist at the CB1 receptor (NIDA, 2013e; NIDA, 

2013f).

N-(1-amino-3,3-dimethyl-1-oxobutan-2-yl)-1-pentyl-1H-indazole-3-carboxamide (ADBPINACA)

ADB-PINACA shares structural features with the schedule I substance AKB48.

ADB-PINACA and AKB48 are based on the indazole core structure and are substituted on 

the 1- and 3- positions of their core indazole ring system. Structurally, ABD-PINACA and 

AKB48 are the same with one exception. AKB48 has an adamantly group attached 

through an amide linkage to its indazole core. The only difference between AKB48 and 

ADP-PINACA is that the adamantly group is replaced with a 1-amino-3,3-dimethyl-1-

oxobutan-2-yl group (ADB) to form ADP-PINACA.
DEA/OD/ODE page 9 of 39 December 2013

In vitro

Binding at CB1 Function at CB1

PB-22 Ki – 0.73 nMaEC50 – 2.47 nMb

5F-PB-22 Ki – 0.27 nMcEC50 – 0.95 nMd

AB-FUBINACA Ki – 0.9 nMe

Ki – 0.79 nMf

EC50 – 23.2 nMe

EC50 – 3.0 nMg

ADB-PINACA n/a n/a

a

NIDA, 2013a

b

NIDA, 2013b

c

NIDA, 2013c

d

NIDA, 2013d

e

Buchler et al., 2009

f

NIDA, 2013e

g

NIDA, 2013f

n/a – not available

Table 1. In vitro binding data for PB-22, 5F-PB-22, AB-FUBINACA and ADB-PINACA

Factor 4. Its history and current pattern of abuse 

Synthetic cannabinoids were first reported in the U.S. in a November 2008 

encounter, where a shipment of ‘Spice’ was seized and analyzed by U.S. Customs and 

Border Protection in Dayton, Ohio. Around the same time, in December 2008, JWH-018 and 

cannabicyclohexanol were identified by German forensic laboratories (EMCDDA, 2009). It

has been stated that there is a belief that these substances existed and were abused some 

time prior to their identification (Psychonaut Web Mapping Research Group, 2009).

Since the initial identification of JWH-018 (November 2008), many additional 

synthetic cannabinoids have been found applied on plant material and encountered as 

designer drug products (Auwarter et al., 2009; DEA, 2009). The popularity of these 

cannabimimetic substances and their associated products appears to have increased since 

January 2010 in the U.S. based on seizure exhibits and media reports. This trend appears to 

mirror those experienced in Europe since 2008 (EMCDDA, 2009). Synthetic cannabinoids 

are being encountered in most regions of the U.S. with the substances found as adulterants 

on plant material or being abused alone as self-reported on Internet discussion boards 

(Atwood et al., 2010). 

Data gathered from published studies, supplemented by discussions on Internet 

discussion websites and personal communications demonstrate that these products are 

being abused mainly by smoking for their psychoactive properties. The adulterated 

products are marketed as ‘legal’ alternatives to marijuana. This characterization and their 
DEA/OD/ODE page 10 of 39 December 2013

reputation as potent herbal intoxicants has been suggested to contribute to their 

popularity (Lindigkeit et al., 2009). These substances alone or laced on plant material have 

the potential to be more harmful than cannabis due to their method of manufacture and 

the potency of the substances. Several synthetic cannabinoids have been shown to display 

higher potency in vitro and in vivo when compared to Δ9-THC (Compton et al., 1992; Wiley 

et al., 1998; Weibelhaus et al., 2012). Smoking mixtures of these substances abused for 

the purpose of achieving intoxication have resulted in numerous emergency room visits 

and calls to poison control centers. Abuse of these synthetic cannabinoids and their 

products has been characterized with both acute and long term public health and safety 

issues. Distinct pharmacological properties and metabolism of synthetic cannabinoids 

have been suggested to contribute to the observed toxicity associated with the abuse of 

synthetic cannabinoids (Fantegrossi et al., 2013). Numerous states, local jurisdictions, and 

the international community have also controlled these substances.

Synthetic cannabinoids have been developed over the last 30 years as tools for

investigating the cannabinoid system (Weissman et al., 1982; Huffman et al., 1996; 

Huffman et al., 1999). The majority of the substances encountered on the illicit market 

have not been tested beyond preliminary pre-clinical laboratory screens before clandestine 

operators applied them on plant material (Lewin et al., 2013). It is extremely concerning 

that these substances have been identified as adulterants in numerous retail products 

(Auwarter et al., 2009, EMCDDA, 2009, Lindigkeit et al., 2009, Dresen et al., 2010, Hudson 

et al., 2010, Uchiyama et al., 2010, Uchiyama, 2012a, Uchiyama et al., 2012b) and are 

marketed directly to adolescents (ONDCP, 2011). JWH-018 was the first synthetic 

cannabinoid to be identified as a product adulterant in Germany in 2008. This substance 

was initially synthesized as a research tool to investigate the cannabinoid system (Huffman, 

1994; Wiley et al., 1998). Since then, numerous other synthetic cannabinoids have been 

identified as product adulterants and law enforcement has seized bulk amounts of these 

substances. The first synthetic cannabinoids identified as being abused included JWH-018, 

JWH-200, JWH-073, CP-47,497, and CP-47,497 C8 homologue, followed shortly thereafter 

by new generations of synthetic cannabinoids including drugs such as AM2201 and JWH200, and eventually UR-144, XLR11, and AKB48. Since the emergence of PB-22, 5F-PB-22 

and AB-FUBINACA, NFLIS has detailed 2,150 reports from forensic laboratories identifying 

PB-22 and 5F-PB-22, 458 reports involving AB-FUBINACA and 9 reports involving ADBPINACA in drug related reports for a period from January 1 through November 30, 2013. In 

addition, STRIDE has 189 reports involving PB-22, 155 reports involving 5F-PB-22 and 42

reports involving AB-FUBINACA during the same time period.
DEA/OD/ODE page 11 of 39 December 2013

These synthetic cannabinoid products are marketed directly to adolescents and 

youth which appear to be the primary abusers of synthetic cannabinoids and synthetic 

cannabinoid-containing products. This is supported by law enforcement encounters and 

reports from emergency rooms (SAMHSA, 20123; Fattore and Fratta, 2011; Vandrey et al., 

2012); however, all age groups have been reported by media as abusing these substances 

and related products. For patients between the ages of 12-29, 75% of emergency 

department visits in 2010 involved synthetic cannabinoids. In addition, the majority (59%) 

of emergency department visits of patients aged 12 to 29 did not involve any other 

substance. Of the remaining 41% of individuals, the most frequently abused substance in 

combination with synthetic cannabinoids was marijuana (17%), pharmaceuticals (17%) and 

alcohol (13%) (SAMHSA, 2012). Individuals, including minors, are purchasing synthetic 

cannabinoids from Internet websites, gas stations, convenience stores, and head shops. 

These substances and laced products are commonly marketed as ‘legal highs’ with a 

disclaimer of ‘not for human consumption’. As detailed in reports, law enforcement and 

public health officials are encountering the abuse of these substances (CDC, 2013a, 2013b, 

2013c; NFLIS, 2013; STRIDE, 2013).

Numerous herbal incense products have been found to contain one or more 

synthetic cannabinoid(s) (PB-22, 5F-PB-22, AB-FUBINACA, and/or ADB-PINACA) laced on 

plant material (Appendix 2). There is no known explanation for the addition of these 

synthetic cannabinoids to plant material being marketed as herbal incense, other than 

for their psychoactive properties (Lindigkeit et al., 2009). The psychoactive properties 

are directly linked to the synthetic cannabinoids laced on the plant material sold as 

retail products (Auwarter et al., 2009, EMCDDA, 2009, Atwood et al., 2010). To lace the 

plant material, the synthetic cannabinoids are generally dissolved in a solvent and 

sprayed on the plant material or the plant material is soaked in a solution of the 

dissolved substance (Vardakou et al., 2010, Wells and Ott, 2011). Two research articles 

propose that the packaging is professional and inconspicuous (unlabeled), targeting 

young people, possibly eager to use cannabis, but who are afraid of the judicial 

consequences and/or association with illicit drugs (Lindigkeit et al., 2009, Schifano, 

2009). The appeal of these highly dangerous substances to adolescents and young 

adults is particularly concerning (Oluwabasi et al., 2012; Durand et al., 2013).

Dresen and colleagues (Dresen et al., 2010) found that synthetic cannabinoids

are being abused by individuals in drug treatment centers with a positive rate of 63.3% 

 

3

SAMHSA (the Substance Abuse and Mental Health Services Administration) is a branch of the U.S. 

Department of Health and Human Services. It is charged with improving the quality and availability of 

prevention, treatment, and rehabilitative services in order to reduce illness, death, disability, and cost to 

society resulting from substance abuse and mental illnesses.
DEA/OD/ODE page 12 of 39 December 2013

in forensic psychiatric centers based on their sampling. U.S. Drug Courts4have 

communicated concerns related to the abuse of synthetic cannabinoids and a response 

rate of greater than 30% by juveniles subject to routine drug screens from a sampling 

(information communicated to DEA). According to recent testimony given by the 

Deputy Director of the Office of National Drug Control Policy (ONDCP) to the U.S. Senate 

Caucus on International Narcotics Control (September 25, 2013), current drug testing 

misses significant populations of synthetic cannabinoid users. In an example described 

in his testimony, a study found that in a sample of men 30 years old or younger within 

the District of Columbia parole and probation system, 39 percent of those who cleanly 

passed a traditional drug screen tested positive for synthetic cannabinoids5. The study 

continued that between one-quarter and one-third of young men who were tested in 

the Washington, D.C. criminal justice system had positive test results for synthetic 

cannabinoids, regardless of whether they had failed or passed a traditional drug screen6. 

In addition to the characterized psychoses, drivers with driving impairment have been 

encountered with confirmed presence of synthetic cannabinoid in their systems (Yeakel 

and Logan, 2013).

The Monitoring the Future (MTF)7Report for 2012 detailed that while synthetic 

cannabinoid use has remained level in 12th graders at 11.3%, “the fact that its 

prevalence rate has remained high despite federal and state efforts to reduce its use is 

troublesome” (Johnston et al., 2013). For the first time, synthetic cannabinoid use in 8th

and 10th graders was measured, with annual prevalence rates being 4.4% and 8.8% 

respectively. The Monitoring the Future Report for 2013 detailed that there has been a 

recent decline in the use of synthetic cannabinoids, decreasing from 11.3% in 2012 to 

7.9% in 2013 (Johnston et al., 2014).

Summary

Recently, law enforcement has been encountering PB-22, 5F-PB-22, and ABFUBINACA in increasing numbers. There have also been reports of abuse of ADB-

 

4 Drug courts were developed to achieve a reduction in recidivism and substance abuse among nonviolent, 

substance abusing offenders by increasing their likelihood for successful rehabilitation through early, 

continuous, and intense judicially supervised treatment, mandatory periodic drug testing, and the use of 

appropriate sanctions and other rehabilitation services. Drug courts analyze specimens from participants 

for new and existing drugs of abuse.

5 Office of National Drug Control Policy. Community Drug Early Warning System: The CDEWS Pilot 

Project, 13.September 13, 2013.

6

Id. p. vi.

7 MTF is a national survey conducted by the Institute for Social Research at the University of Michigan 

under a grant from the NIDA that tracks drug use trends among American adolescents in the 8th, 10th, and 

12th grades.
DEA/OD/ODE page 13 of 39 December 2013

PINACA in Georgia and Colorado. Synthetic cannabinoids and their associated products 

are available over the Internet or found to be sold in gas stations, convenience stores, 

and tobacco and head shops. PB-22, 5F-PB-22, AB-FUBINACA and ADB-PINACA, similar 

to the previously scheduled synthetic cannabinoids (DEA, 2012; DEA, 2013), have been 

seized alone and/or spiked on products that are marketed as herbal incense and 

promoted as legal alternatives to marijuana. 

Factor 5. The scope, duration, and significance of abuse

Recently, increased exposure incidents have been documented by poison control 

centers in the U.S. as the abuse of synthetic cannabinoids has been associated with both 

acute and long-term public health and safety concerns. From January through 

November 2013, according to STRIDE, there were 189 reports involving PB-22, 155 

reports involving 5F-PB-22, and 42 reports involving AB-FUBINACA. (Queried on 

December 18, 2013) From January through November 2013, NFLIS registered 1,092 

reports containing PB-22 in 29 states (Arkansas, Arizona, Colorado, Connecticut, Florida, 

Georgia, Hawaii, Iowa, Kansas, Kentucky, Louisiana, Maryland, Minnesota, Missouri, 

North Dakota, Nebraska, New Hampshire, New Jersey, New Mexico, Ohio, Oklahoma, 

Oregon, Pennsylvania, South Carolina, Texas, Utah, Virginia, Wisconsin and Wyoming) 

1,058 reports containing 5F-PB-22 in 25 states (Arkansas, Arizona, Colorado, Florida, 

Georgia, Iowa, Indiana, Kansas, Louisiana, Minnesota, Missouri, North Dakota, New 

Jersey, New Mexico, Nevada, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, 

Texas, Utah, Virginia, Wisconsin and Wyoming), 458 reports containing AB-FUBINACA in 

17 states (Arizona, Colorado, Florida, Georgia, Iowa, Indiana, Kansas, Louisiana, 

Minnesota, Missouri, North Dakota, New Jersey, Nevada, Ohio, Oklahoma, Pennsylvania 

and Texas) and 9 reports containing ADB-PINACA in one state (Colorado) (Queried on 

December 18, 2013). No reports in NFLIS or STRIDE were identified for PB-22 or 5F-PB22 prior to February 2013. No reports in NFLIS or STRIDE were identified for ABFUBINACA prior to June 2013.

ADB-PINACA was first encountered in the United States following reports of 

serious adverse events in Georgia and Colorado on August 23, 2013. Reports of ADBPINACA were not found in the scientific literature prior to its emergence on the designer 

drug market. The Georgia Bureau of Investigation (GBI) reported on September 12, 2013 

that ADB-PINACA, was detected in “herbal incense” products sold under the brand 

name “Crazy Clown.” It was later confirmed by the Centers for Disease Control and 

Prevention (CDC) as the substance responsible for severe adverse events in at least 22 

persons who consumed the product (CDC, 2013b). In addition, On August 30, 2013, the 

Colorado Department of Public Health and Environment (CDPHE) was notified by several 
DEA/OD/ODE page 14 of 39 December 2013

hospitals of an increase in the number of patients visiting their emergency departments 

(EDs) with altered mental status after using synthetic marijuana (Appendix 2). On 

September 8, CDPHE, with the assistance of CDC, began an epidemiologic investigation 

whereby 221 cases of severe illness due to ingestion of a synthetic cannabinoid were 

identified (CDC, 2013c). Those that presented at emergency rooms in the Denver, 

Colorado area around September 1, 2013 had symptoms similar to those found in the 

August 2013 Georgia incident. Laboratory analysis of samples from the Colorado 

incident confirmed that the substance abused in the “herbal incense” products was 

ADB-PINACA. 

The American Association of Poison Control Centers (AAPCC) reported receiving 

in excess of 5,200 exposure calls in 2012 corresponding to products purportedly applied

with synthetic cannabinoids, although the data provided does not generally include

biological sample testing that would confirm which cannabinoids the user was exposed 

to.

8

 In addition, the AAPCC has reported over 2,436 calls regarding synthetic 

cannabinoids through November of 2013. A majority of exposure incidents in both 2012 

and 2013 resulted in individuals seeking medical attention at health care facilities. 

Chronic abuse of synthetic cannabinoids has been linked to signs of addiction and 

withdrawal similar to that experienced with cannabis abuse (Zimmermann et al., 2009, 

Muller et al., 2010, Vardakou et al., 2010). Additionally, tolerance to these drugs may 

develop fairly rapidly with larger doses being required to achieve the desired effect 

(EMCDDA, 2009). In 2010, the Substance Abuse and Mental Health Services 

Administration (SAMHSA) reported 11,406 emergency department visits involving a 

synthetic cannabinoid product. In 2011, SAMHSA reported the number of emergency 

department visits involving a synthetic cannabinoid product had increased 2.5 times to 

28,531 (SAMHSA, 2013) (Figure 2).

Synthetic cannabinoids and the associated products are sold over the Internet and 

found to be abused by diverse populations. Since synthetic cannabinoids were never 

intended for human consumption, minimal information exists as to the health implications 

 

8 The content of this report does not necessarily reflect the opinions or conclusions of the American 

Association of Poison Control Centers. The American Association of Poison Control Centers (AAPCC; 

http://www.aapcc.org maintains the national database of information logged by the country’s 57 Poison 

Control Centers (PCCs). Case records in this database are from self-reported calls: they reflect only 

information provided when the public or healthcare professionals report an actual or potential exposure to a 

substance (e.g. an ingestion, inhalation, or topical exposure, etc.), or request information/educational 

materials. Exposures do not necessarily represent a poisoning or overdose. The AAPCC is not able to 

completely verify the accuracy of every report made to member centers. Additional exposures may go 

unreported to PCCs and data referenced from the AAPCC should not be construed to represent the 

complete incidence of national exposures to any substance(s).
DEA/OD/ODE page 15 of 39 December 2013

resulting from exposure to these substances (Griffiths et al., 2010, Vardakou et al., 2010). 

The scientific literature and reports received by DEA suggest that tolerance and 

dependence to synthetic cannabinoids may develop (Zimmermann et al., 2009). 

In addition, the chronic abuse of products laced with synthetic cannabinoids has been 

linked to addiction and withdrawal (Vardakou et al., 2010).

The increased abuse of these synthetic cannabinoids in the U.S. is supported by an 

increasing number of encounters by law enforcement. There has been a significant increase 

in availability, trafficking and abuse of PB-22, 5F-PB-22, AB-FUBINACA and ADB-PINACA 

throughout the U.S. since January of 2013, evident from the increasing number of 

encounters reported by forensic laboratories (NFLIS data). In addition, laboratory 

confirmations of novel cannabinoids such as ADB-PINACA have resulted in serious illness 

and adverse effects following consumption in Georgia and Colorado. Due to the previous 

temporary scheduling actions of various synthetic cannabinoids (emergency scheduling of 

JWH-018, JWH-200, JWH-073, CP-47,497, and CP-47,497 C8 homologue, March 1, 2011; 

FDASIA, July 9, 2012 – permanent scheduling of JWH-018, JWH-200, JWH-073, CP-47,497,

and CP-47,497 C8 homologue in addition to others; emergency scheduling of UR-144, 

XLR11 and AKB48, May 16, 2013), law enforcement has been encountering new synthetic 

cannabinoids including PB-22, 5F-PB-22, AB-FUBINACA, and ADB-PINACA.

Figure 2. Emergency department visits involving synthetic cannabinoids (SAMHSA, 

2013). Synthetic cannabinoid data were not collected prior to 2010.

0

5000

10000

15000

20000

25000

30000

2010 2011

Emergency Department Visits Involving 

Synthetic Cannabinoids*
DEA/OD/ODE page 16 of 39 December 2013

*Estimates of ED visits are based on a representative sample of non-Federal, general, short-stay hospitals 

with 24-hour EDs in the U.S.

Summary

The abuse of synthetic cannabinoids is characterized in the scientific literature 

and by law enforcement encounters with reported adverse health effects. Numerous 

calls have been received by poison control centers regarding the abuse of products 

potentially laced with synthetic cannabinoids that have resulted in visits to emergency 

departments. Following legislative control by FDASIA in July of 2012 and the emergency 

scheduling of UR-144, XLR11, and AKB48 in May of 2013, law enforcement has begun

encountering novel synthetic cannabinoids including PB-22, 5F-PB-22, AB-FUBINACA,

and ADB-PINACA.

Factor 6. What, if any, risk there is to the public health

Law enforcement, military, and public health officials have reported exposure 

incidents that demonstrate the dangers associated with abuse of synthetic cannabinoids 

to both the individual abusers and other affected individuals since these substances 

were never intended for human use. Warnings regarding the dangers associated with 

abuse of synthetic cannabinoids and their products have been issued by numerous state 

public health departments and poison control centers and private organizations. 

Detailed product analyses describe variations in the amount and synthetic cannabinoid 

laced on the plant material even within samplings of the same product 

(Hudson et al., 2010). These unknowns present a significant risk or danger to the 

abusing individuals (Auwarter et al., 2009, Hudson et al., 2010). Wells and Ott stated 

concern regarding the possibility of serotonin syndrome related to synthetic 

cannabinoids of the indole structural class due to the similarity to serotonin (Wells and 

Ott, 2011). Some of the common clinical effects reported in emergency rooms in 

response to the abuse of synthetic cannabinoids include vomiting, anxiety, agitation, 

irritability, seizures, hallucinations, tachycardia, elevated blood pressure, and loss of 

consciousness (Forrester et al., 2011; Cohen et al., 2012; Harris and Brown, 2013; 

Hermanns-Clausen et al., 2013; Zawilska and Wojcieszak, 2013) (see reports from state 

health departments and poison centers including AAPCC, Appendix 1). A 12-month 

study conducted in 2012 demonstrated that out of 950 self-reported users, 2.4% 

reported having a medical emergency requiring treatment resulting from a combination 

of panic, anxiety, paranoia, and breathing difficulties (Winstock and Barratt, 2013). Data 

from this study also demonstrated that recent users who reported seeking emergency 

treatment were significantly younger than those who did not report seeking treatment
DEA/OD/ODE page 17 of 39 December 2013

(Winstock and Barratt, 2013). These data correspond to figures reported by SAMSHA, 

which demonstrates that youth, specifically those aged 12 to 17 years old, comprise a 

large percentage of users requiring emergency medical attention (Figure 3.)

Figure 3. Age-related emergency department visits involving synthetic cannabinoids and 

marijuana (SAMHSA, 2012). 

By sharing pharmacological similarities with the schedule I substances (Δ

9

-THC and 

JWH-018), synthetic cannabinoids pose a risk to the abuser (Weissman et al., 1982, 

Compton et al., 1992; Wiley et al., 1998), and the chronic abuse of products laced with 

synthetic cannabinoids has been linked to addiction and withdrawal (Vardakou et al., 

2010). Similar products have been found to vary in the amount and type of synthetic 

cannabinoid laced on the plant material, which could be one explanation for the numerous 

emergency department admissions that have been connected to these substances 

0

5

10

15

20

25

30

35

Aged 12-17 Aged 18-20 Aged 21-24 Aged 25-29

Synthetic Cannabinoids

Marrijuana

Age Related Synthetic Cannabinoid and 

Marijuana -Related Emergency Department (ED) 

Visits - 2010
DEA/OD/ODE page 18 of 39 December 2013

(Vardakou et al., 2010; Vearrier and Osterhoudt, 2010; Schneir et al., 2011; Fattore and 

Fratta, 2011). Health warnings have been issued by numerous state public health 

departments (Appendix 1) and poison control centers describing adverse health effects 

associated with smoking (inhaling) these products including agitation, vomiting, 

tachycardia, elevated blood pressure, seizures, hallucinations and non-responsiveness.

The earliest reported detection of PB-22 was via Finnish Customs (Tulli) in Helsinki 

who intercepted a consignment of 54 kilograms en route from China to Russia on October 

27, 2012. Finland notified the European Monitoring Centre for Drugs and Drug Addiction 

(EMCDDA) on November 20, 20129. From January through November 2013, U.S. Customs 

and Border Protection (CBP) reported the following seizures with most shipments 

originating in China and intended for destinations within the United States: PB-22 – 25 

seizures involving 69.6 kg; 5F-PB-22 – 23 seizures involving 32.9 kg; and AB-FUBINACA – 9 

seizures involving 16.1 kg. (Appendix 2)10. DEA has reported multiple encounters of large 

quantities of PB-22, 5F-PB-22, and/or AB-FUBINACA that have been confirmed by forensic 

laboratories (STRIDE). In addition, a report sent to DEA from the Mansfield Division of 

Police Forensic Science Laboratory in Mansfield, Ohio has confirmed the presence of PB-22 

(17 cases) or 5F-PB-22 (6 cases) from January through May of 201311. This report included 

incident/investigative public narratives that included physical symptoms and observations 

of users. Excerpts from these reports with laboratory confirmation of either PB-22 or 5FPB-22 are detailed below.

PB-22

1) Subject was unable to stand, and when trying to stand, he kept falling down. 

Subject was lethargic and could not speak clearly. Subject transported to medical 

facility. 

5F-PB-22

1) After smoking “spice” all day, subject began vomiting and having convulsions. 

Subject was unconscious when law enforcement arrived, was not responding but 

was breathing. Subject would be comatose one minute and then would become 

violent the next. Medics restrained the subject’s legs and were working on 

restraining the subject’s arms when the subject appeared to start hallucinating. 

The subject began screaming and tried to get off of the stretcher several times. 

 

9 Correspondence from EMCDDA to the Drug and Chemical Control (ODEC) Unit of DEA 02/01/2013

10 Correspondence from CBP to ODEC, DEA

11 Correspondence from Mansfield Division of Police Forensic Science Laboratory to ODEC, DEA 

06/13/2013
DEA/OD/ODE page 19 of 39 December 2013

The subject began to scream that “he had to shoot him to save his cousin”. 

The subject appeared to be looking into the corner of the ceiling. Subject referred to 

medical facility.

Since abusers obtain these drugs through unknown sources, purity of these drugs is 

uncertain, thus posing significant adverse health risk to these users (EMCDDA, 2009, Dresen 

et al., 2010). From July through November 2013, five deaths have been reported involving 

5F-PB-22. A 17 year old male’s cause of death was listed by the medical examiner as “5F-PB22 intoxication”12

. Autopsy findings of an 18 year old male reported as a fatal cardiac 

arrhythmia and/or fatal seizure in association with 5F-PB-22 use13. In addition, a toxicology 

laboratory is currently gathering additional information for three separate postmortem 

toxicological investigations in which 5F-PB-22 has been identified in blood and 

quantitatively measured14. As mentioned above, there are reported instances of 

emergency department admissions in association with the abuse of PB-22 and 5F-PB-22. 

There is no accepted medical use of these substances in the U.S.

In late August of 2013, local law enforcement in Brunswick, Georgia reported that 22

users presented to emergency departments with sever adverse reactions after the 

consumption of a synthetic product called “Crazy Clown”. Adverse effects included the 

inability to stand, foaming at the mouth, violence towards police and paramedics and 

memory lapse. The substance responsible for these effects was later identified by the GBI 

as ADB-PINACA. Days later in early September 2013, over 200 patients presented to 

emergency departments in Colorado after have adverse reactions to a synthetic product 

labeled as “Black Mamba” (Appendix 2). Adverse effects included having no gag reflex, 

inability to breathe on their own, hallucinations and psychotic episodes as described by 

nurses and attending physicians. The substance in these episodes was also identified as 

ADB-PINACA. 

The CSA (21 U.S.C. 811(h)(4) requires the Deputy Administrator to notify the 

Secretary of the Department of Health and Human Services (HHS) of his intention to 

temporarily place a substance into Schedule I of the CSA.15 The Deputy Administrator 

transmitted notice of his intent to place PB-22, 5F-PB-22, AB-FUBINACA, and ADB-PINACA in 

schedule I on a temporary basis to the Assistant Secretary by letter dated November 7, 

 

12 Correspondence from Law Enforcement to ODEC, DEA , 09/10/2013

13 Correspondence from Law Enforcement to ODEC, DEA, 11/12/2013

14 Correspondence from Private Toxicology Laboratory to ODEC, DEA, 11/18/2013

15 The Secretary of HHS has delegated to the Assistant Secretary for HHS the authority to make domestic 

drug scheduling recommendations. As set forth in a memorandum of understanding entered into by HHS, 

the FDA, and NIDA, FDA acts as the lead agency within HHS in carrying out the Secretary’s scheduling 

responsibilities under the CSA, with the concurrence of NIDA. 50 FR 9518.
DEA/OD/ODE page 20 of 39 December 2013

2013. The Assistant Secretary responded to this notice by letter dated XX-XX-XXXX 

(received by DEA on XX-XX-XXXX), and advised that based on review by the Food and Drug 

Administration (FDA), there are currently no investigational new drug applications or 

approved new drug applications for PB-22, 5F-PB-22, AB-FUBINACA, or ADB-PINACA. The 

Assistant Secretary also stated that HHS has no objection to the temporary placement of 

PB-22, 5F-PB-22, AB-FUBINACA, or ADB-PINACA into schedule I of the CSA. DEA has taken 

into consideration the Assistant Secretary’s comments. As PB-22, 5F-PB-22, AB-FUBINACA, 

or ADB-PINACA are not currently listed in any schedule under the CSA, and as no 

exemptions or approvals are in effect for PB-22, 5F-PB-22, AB-FUBINACA, or ADB-PINACA 

under Section 505 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355), DEA believes 

that the conditions of 21 U.S.C. 811(h)(1) have been satisfied. Any additional comments 

submitted by the Assistant Secretary in response to this notification shall also be taken into 

consideration before a final order is published. 21 U.S.C. 811(h)(4).

Conclusion of 3-Factor Analysis

After a careful review of the scientific literature, Factors 4, 5, and 6, NFLIS, STRIDE, 

and other law enforcement data and sources of information, it is evident that PB-22, 5FPB-22, AB-FUBINACA and ADB-PINACA are trafficked and abused and pose an imminent 

hazard to public safety. 

DEA has considered the three criteria for placing a substance into schedule I of the 

CSA (21 U.S.C. 812). The data available and reviewed for PB-22, 5F-PB-22, AB-FUBINACA 

and ADB-PINACA indicated that these substances, including their salts, isomers, and salts 

of isomers, pose an imminent hazard to public safety and health, have high potential for 

abuse, have no currently accepted medical use in treatment in the U.S., and lack accepted 

safety for use under medical supervision.
DEA/OD/ODE page 21 of 39 December 2013

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DEA/OD/ODE page 26 of 39 December 2013

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DEA/OD/ODE page 28 of 39 December 2013

Appendix 1

Public Health

1. The Substance Abuse and Mental Health Services Administration (SAMHSA) 

reported that in 2010, an estimated 11,406 emergency department visits 

involved a synthetic cannabinoid product.

2. SAMHSA reported that in 2011, an estimated 28,531 emergency department 

visits involved a synthetic cannabinoid product, a 2.5 times increase over the 

2010 estimated visits.

3. Monitoring the Future study results for 2012 (released 12/19/2012) state 

that for the second year of reporting, use of synthetic marijuana amongst 

12th graders held level at 11.3%. Study authors stated that while a leveling 

was encouraging, the high prevalence rate despite federal and state efforts 

to reduce its use was troublesome.

4. Monitoring the Future study results for 2013 (released 12/18/2013) state 

that use of synthetic marijuana amongst 12th graders fell from 11.3% in 2012 

to 7.9% in 2013.

5. Health effects from the drug can be life-threatening and can include:

a. Severe agitation and anxiety.

b. Fast, racing heartbeat and higher blood pressure.

c. Nausea and vomiting.

d. Muscle spasms, seizures, and tremors.

e. Intense hallucinations and psychotic episodes.

f. Suicidal and other harmful thoughts and/or actions.

g. http://www.aapcc.org/alerts/synthetic-marijuana/

6. ...these substances are among the worst they have ever seen. People high on 

these drugs can get very agitated and violent, exhibit psychosis and severe 

behavior changes, and have harmed themselves and others. Some have been 

admitted to psychiatric hospitals and have experience continued neurological 

and psychological effects. (News Release – American Association of Poison 

Control Centers: AAPCC Issues Statement on the Synthetic Drug Abuse 

Prevention Act, July 11, 2012)

Poison Control Centers

1. March 24 AAPCC Press Release. As of March 24, 2010, 112 exposure calls 

had been received since 2009 regarding synthetic cannabinoids and 

associated products, including 59 exposure calls since March 1, 2010, 

according to the National Poison Data System (NPDS).

2. July 23, 2010 AAPCC Press Release. As of July 23, 2010, 761 exposure calls 

had been received regarding synthetic cannabinoids and associated products 

according to NPDS.
DEA/OD/ODE page 29 of 39 December 2013

3. August 20, 2010 AAPCC Press Release. As of August 20, 2010, 1,057 

exposure calls had been received regarding synthetic cannabinoids and 

associated products according to NPDS.

4. September 27, 2010 AAPCC Press Release. As of September 27, 2010, 1,503 

exposure calls had been received regarding synthetic cannabinoids and 

associated products according to NPDS.

5. November 3, 2010 AAPCC Press Release. As of November 3, 2010, 1,966 

exposure calls have been received by poison centers regarding products 

purported to contain synthetic cannabinoids according to NPDS. Calls have 

been received in 48 states and the District of Columbia.

6. November 22, 2010 AAPCC Press Release. As of November 22, 2010, poison 

centers have reported 2,304 exposure calls regarding products purported to 

contain synthetic cannabinoids according to NPDS. Poison centers have 

received exposure calls in 49 states and the District of Columbia.

7. December 21, 2010 AAPCC Press Release. As of December 21, 2010, U.S. 

poison centers have reported receiving more than 2,500 exposure calls this 

year alone. As of December 21, 2010, poison centers have reported 2,752 

exposure calls about the products according to NPDS.

8. January 18, 2011 AAPCC Press Release. As of January 18, 2011, U.S. poison 

centers have received more than 3,000 exposure calls regarding products 

purported to contain synthetic cannabinoids. In 2010, poison centers 

reported 2,867 exposure calls. As of January 18, 2011, U.S. poison centers 

have reported 217 exposure calls for 2011.

9. February 3, 2011, AAPCC Press Release. As of February 3, 2011, U.S. poison 

centers have reported 385 exposure calls for 2011.

10. February 10, 2011, AAPCC Press Release. Synthetic marijuana products have 

spurred more than 3,000 exposure calls to U.S. poison centers since 2010.

11. February 24, 2011, AAPCC Press Release. As of February 24, 2011, U.S. 

poison centers have reported 706 exposure calls for 2011. The total number 

of calls since 2010 is more than 3,500 exposure calls. 

12. April 20, 2011, AAPCC Press Release. Synthetic marijuana products have 

spurred more than 4,500 exposure calls to U.S. poison control centers since 

2010.

13. July 11, 2012, AAPCC Press Release. In 2010, poison centers nationwide 

responded to about 3,200 exposure calls related to synthetic marijuana and 

bath salts. In 2011, the number jumped to more than 13,000. Sixty percent of 

these cases involved patients 25 and younger.
DEA/OD/ODE page 30 of 39 December 2013

14. November 28, 2011, AAPCC Press Release. Poison center data provides vital 

information leading to DEA ban of synthetic drugs.

15. February 16, 2012, AAPCC Press Release. American Association of Poison 

Control Centers joins the Office of National Drug Control Policy Working 

Group in addressing the dangers of synthetic drugs.

16. May 31, 2012, AAPCC Press Release. The AAPCC commends the U.S. Senate 

for passing a ban of synthetic drugs in SB 3187 and call on the U.S. House of 

Representatives to include the language in the final version of the bill.

17. July 11, 2012, AAPCC Press Release. AAPCC comment the nation’s policy 

makers on passage into the law the Synthetic Drug Abuse Prevention Act of 

2012.

18. From January 1, 2012 through December 31, 2012, poison centers 

nationwide have received 5,200 exposure calls regarding exposure to 

synthetic cannabinoids.

19. From January 1, 2013 through November, 2013, poison centers nationwide 

have received 2,436 exposure calls regarding exposure to synthetic 

cannabinoids.

Relevant Positions/Statements by Organizations

A. National Drug Court Institute, Drug Court Practitioner Fact Sheet, Spice, K2 and 

the Problem of Synthetic Cannabinoids, October 2010, vol. 5, no. 1. 

(www.ndci.org)

B. MetroKids, ‘Spice’ Health Warning Issued, April 2010 (www.metrokids.com)

C. Indiana Prevention Resource Center, Indiana University Bloomington, K2/Spice: A 

Fake Drug Carrying a Real Potential for Harm, undated, (www.drugs.indiana.edu)

D. Prevention First, Fake Marijuana Called Spice or K2 Can Cause Serious Harm to 

Teens, April 13, 2010 (www.prevention.org)

E. Saint Louis University, SLU Toxicologist Warning to Parents: Look for Signs of K2, 

March 3, 2010 (www.slu.edu/x35328.xml)

F. Community of Anti-Drug Coalitions of America, Researchers Warn About 

Dangers of Synthetic Marijuana, March 18, 2010 (www.cadca.org)
DEA/OD/ODE page 31 of 39 December 2013

Table 3. NFLIS – State and Local Forensic Laboratory Reports (Queried on December 18, 2013)

2010 2011 2012 2013 Total

Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4†

 JWH-018; JWH073;

 JWH-200; CP47,497

 CP-47,497 C8 

homologue

138 413 670 1196 1515 997 661 542 425 354 226 144 102 80 44 1 7,509

UR-144; XLR11;

AKB48 1* 0 0 0 0 0 0 50 569 3,271 6,174 4,928 5,940 5,598 2,577 398 29,505

PB-22

0 0 0 0 0 0 0 0 0 0 0 0 220 434 383 55 1,092

5F-PB-22

0 0 0 0 0 0 0 0 0 0 0 0 102 419 472 65 1,058

AB-FUBINACA

0 0 0 0 0 0 0 0 0 0 0 0 0 22 308 128 458

ADB-PINACA

0 0 0 0 0 0 0 0 0 0 0 0 0 0 7 7 9

*Encounter confirmed in March 2012; † = data are incomplete for fourth quarter 2013, still being reported
DEA/OD/ODE page 32 of 39 December 2013

Table 4. STRIDE Records (January through November* (Queried on December 18, 

2013):

NUMBER OF RECORDS

PB-22 189

5F-PB-22 155

AB-FUBINACA 42

ADB-PINACA 0

* No reports identified in STRIDE regarding PB-22 or 5F-PB-22 prior to February 2013. No 

reports of AB-FUBINACA prior to June 2013.
DEA/OD/ODE page 33 of 39 December 2013

Appendix 2

Table 5. Reports from ADB-PINACA overdoses (August – September 2013)*

Location Substance Identified Packet Label Remarks

Denver, CO ADB-PINACA

Crazy Clown 

Pineapple 

Express

None

Denver, CO ADB-PINACA Crazy Clown

Two males passed 

out in a vehicle; both 

became extremely 

ill; driver placed on 

life support

Denver, CO ADB-PINACA

AM-HI-C; Atomic 

Bomb; Black 

Mamba

Single vehicle 

accident, driver 

passed out while 

driving and collided 

with a tree

Denver, CO ADB-PINACA Dead Man 

Walking

User became ill after 

using substance and 

required 

hospitalization

Denver, CO ADB-PINACA Unknown

User was found 

slumped over the 

wheel of a vehicle in 

the middle of an 

intersection

Denver, CO ADB-PINACA Mamba

Male and female 

user found passed 

out in backyard; 

female vomited over 

herself; male 

became combative 

and required 

restraints

Denver, CO ADB-PINACA Mamba

User had minimal 

vitals upon EMS 

arrival; required use 

of a respirator at 

hospital; user 

collapsed following 

single puff from a 

rolled cigarette of 

“Mamba”
DEA/OD/ODE page 34 of 39 December 2013

Denver, CO ADB-PINACA Mamba

Two juveniles 

required 

hospitalization after 

smoking mamba; 

one juvenile found 

stumbling down the 

street

* Communication from Aurora Police Department to DEA (12/18/2013)

Table 6. Reports from Customs and Border Protection Laboratory (January –

November 2013)

Date of 

Detention

Identified 

Substance(s) Detained at

Originated 

from Destination

TOTAL 

WEIGHT

1/29/2013 PB-22

FedEx 

Anchorage, AK China

Fort 

Lauderdale, FL 15 kg

1/29/2013 PB-22

FedEx 

Anchorage, AK China

Fort 

Lauderdale, FL 15 kg

2/8/2013 PB-22

San Francisco 

Intl Mail China Richardson, TX 2 kg

2/13/2013 PB-22

San Francisco 

Intl Mail China San Dimas, CA 2 kg

2/28/2013 PB-22

San Francisco 

Intl Mail China

Newman Lake, 

WA

300 

grams

2/28/2013 PB-22

San Francisco 

Intl Mail China

Newman Lake, 

WA

300 

grams

2/28/2013 PB-22

San Francisco 

Intl Mail China Arlington, TX

100 

grams

3/6/2013 PB-22

San Francisco 

Intl Mail China Tulsa, OK 2 kg

3/13/2013 PB-22

FedEx 

Anchorage, AK China

South 

Charleston, 

WV 3.5 kg

3/22/2013 5-fluoro-PB-22

FedEx 

Anchorage, AK China Columbia, MO 3.5 kg

4/4/2013 PB-22

San Francisco 

Intl Mail China Phoenix, AZ

200 

grams
DEA/OD/ODE page 35 of 39 December 2013

4/4/2013 PB-22

San Francisco 

Intl Mail China Temecula, CA 2 kg

4/4/2013 PB-22

San Francisco 

Intl Mail China Columbia, MO 2 kg

4/4/2013 PB-22

San Francisco 

Intl Mail China Columbia, MO 2 kg

4/4/2013 PB-22

San Francisco 

Intl Mail China Walnut, CA 2 kg

4/12/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China Phoenix, AZ unknown

4/19/2013 PB-22

San Francisco 

Intl Mail China Sprints, LA

100 

grams

5/6/2013 PB-22

San Francisco 

Intl Mail China Decatur, IL

100 

grams

5/16/2013 PB-22

San Francisco 

Intl Mail China

Las Cruces, 

NM 1 gram

5/18/2013 5-fluoro-PB-22

San Francisco 

Intl Mail Hong Kong Las Vegas, NV

500 

grams

5/31/2013 5-fluoro-PB-22

FedEx 

Anchorage, AK China

Las Cruces, 

NM 1 kg

6/13/2013 PB-22

San Francisco 

Intl Mail China

Coeur D'Alene, 

ID

500 

grams

6/13/2013 PB-22

San Francisco 

Intl Mail China Baytown, TX 1 kg

6/25/2013 PB-22

San Francisco 

Intl Mail Hong Kong

Salt Lake City, 

UT 5 kg

6/25/2013 PB-22

San Francisco 

Intl Mail China Houston, TX 2 kg

6/25/2013 PB-22

San Francisco 

Intl Mail China

Chatsworth, 

CA 1 kg

6/25/2013 PB-22

San Francisco 

Intl Mail China Katy, TX 3 kg

6/27/2013 5-fluoro-PB-22

FedEx 

Anchorage, AK China Las Vegas, NV 3 kg

6/29/2013 5-fluoro-PB-22

FedEx 

Anchorage, AK China Puerto Rico 2.8 kg

7/5/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China Pahrump, NV 1 kg
DEA/OD/ODE page 36 of 39 December 2013

7/5/2013 PB-22

San Francisco 

Intl Mail China Tacoma, WA 3 kg

7/8/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China Las Vegas, NV 2 kg

7/8/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China Las Vegas, NV 2 kg

7/10/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China Anchorage, AK 1 kg

7/17/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China

Las Cruces, 

NM

300 

grams

7/17/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China

Independence, 

LA

700 

grams

7/17/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China

Independence, 

LA

700 

grams

7/17/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China

Independence, 

LA 2.5 kg

8/8/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China Houston, TX 3 kg

8/15/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China Ogden, UT

500 

grams

8/22/2013 PB-22

San Francisco 

Intl Mail China Elizabeth, NJ 5.5 kg

9/4/2013 5-fluoro-PB-22

FedEx 

Anchorage, AK China Tulsa, OK 2.3 kg

9/5/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China

Baton Rouge, 

LA 50 grams

10/3/2013 5-fluoro-PB-22

San Francisco 

Intl Mail unknown unknown 1.3 kg

10/9/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China

Bremerton, 

WA 2 kg

10/9/2013 AB-FUBINACA

San Francisco 

Intl Mail China Houston, TX 5 kg

10/24/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China Casper, WY

800 

grams

10/24/2013 5-fluoro-PB-22

San Francisco 

Intl Mail China

Bremerton, 

WA 2 kg

10/24/2013 AB-FUBINACA

San Francisco 

Intl Mail China Houston, TX 4 kg
DEA/OD/ODE page 37 of 39 December 2013

10/24/2013 AB-FUBINACA

San Francisco 

Intl Mail China Anderson, SC 10 grams

10/31/2013 AB-FUBINACA

San Francisco 

Intl Mail China Austin, TX 5 grams

11/7/2013 AB-FUBINACA

San Francisco 

Intl Mail China Metairie, LA

100 

grams

11/7/2013 AB-FUBINACA

San Francisco 

Intl Mail China

Canyon 

Country, CA 2 kg

11/7/2013 AB-FUBINACA

San Francisco 

Intl Mail China

Canoga Park, 

CA 3 kg

11/7/2013 AB-FUBINACA

San Francisco 

Intl Mail China

Canyon 

Country, CA 2 kg

11/7/2013 AB-FUBINACA

San Francisco 

Intl Mail China Mchenny, IL 5 grams

Table 7. DEA Sample Laboratory Results

Date Label Flavor/

Characteristic

Confirmed 

Substance

Lab Notes

5/2/2013 Dr. Feelgood Kush PB-22

South 

Central

2g packet, mad 

scientist holding 

green bottle

5/2/2013 Dr. Feelgood

Chronic 

Hypnotic PB-22

South 

Central

2g packet, mad 

scientist holding 

green bottle

6/6/2013

Scorpion 

King PB-22 Northeast

Plastic vial, 

picture of 

scorpion

6/6/2013

Newer 

Diesel PB-22 Northeast

Plastic vial, gold 

crown

6/6/2013 Black PB-22 Northeast

Plastic vial, 

scary eyes on 

label

6/6/2013 Dead Man PB-22 Northeast Plastic vial

6/6/2013 Aloha PB-22 Northeast Plastic vial

6/6/2013 El diablo PB-22 Northeast Plastic vial

6/10/2013 Caution PB-22 Northeast

3g, Orange 

packet, 

biohazard 

symbol

6/10/2013 California PB-22 Northeast Packet, green 
DEA/OD/ODE page 38 of 39 December 2013

Dreams and white 

marijuana leaf 

on front

6/10/2013 Kush PB-22, XLR11 Northeast

11g, green 

sparkle writing, 

black packet

6/14/2013 Demon Child Kush

PB-22, 5FPB-22 Western2g packet, skull 

on front

6/14/2013 Red Eye Jack PB-22 Western

3g, Jack (from 

playing cards) 

on front with 

red eye

6/14/2013 Demon Child Blueberry Thrill

PB-22, 5FPB-22 Western5g packet, skull 

on front

6/14/2013 Biohazard Original PB-22 Western

2g packet, 

brown 

background, 

biohazard 

symbol on front

6/14/2013

Game 

Master Original PB-22, XLR11 Western

1g packet, Man 

with numbers 

coming from 

head, blue 

background

6/17/2013 OMG Next Gen PB-22 Northeast

4g packet, 

dwarf, 

psychedelic 

colors

8/26/2013 Wonderland Kush

PB-22, 5FPB-22 Western

2g packet, red

mushrooms 

growing over a 

dock and pond

8/26/2013 Joker

Chronic 

Hypnotic 5F-PB-22 Western

5g black packet, 

evil clown face 

on front, 

aromatic 

therapy

8/26/2013 Vato Locos Melon Mamba

PB-22, 5FPB-22 Western

2g black packet, 

three guys in 

suits (green, 

purple, red), 

also comes in 

larger packet

8/26/2013

Hysteria 

Black

Melon Mamba; 

Strawberry

PB-22, 5FPB-22 Western

2g black packet, 

XXX, red 

triangle pattern

8/26/2013 WTF PB-22 Western 1.5 and 2.5 g 
DEA/OD/ODE page 39 of 39 December 2013

black packet, 

Fidel Castro 

w/no toilet 

paper on front

8/26/2013 El Diablo PB-22 Western

Small plastic 

vial, black lid, 

red and black 

label

8/26/2013 Fallen Angel

Kush; Chronic

Hypnotic

PB-22, 5FPB-22 Western

5g black packet, 

woman on fire 

on front

8/26/2013

Devils 

Advocate Kush

PB-22, 5FPB-22 Western

5g black packet, 

skull with horns, 

fire behind

8/26/2013

Black 

Mamba PB-22 Western

Clear plastic 

vial with black 

lid, red sticker 

on top