Proposed Rules for Oregon Measure 109 Psilocybin Centers

Here are my comments in response to:

https://www.oregon.gov/oha/PH/PREVENTIONWELLNESS/Pages/Psilocybin-Administrative-Rules.aspx –

I later found a copy of section 3070 Practicum Training: https://casetext.com/regulation/oregon-administrative-code/chapter-333-oregon-health-authority-public-health-division/division-333-psilocybin/section-333-333-3070-psilocybin-facilitator-practicum-requirements – d/k if it’s open for comments.

Proposed Rules and the November 2022 Public Comment Period 

We want to hear from you! Below is a copy of the proposed rules for the November public comment period. We invite you to provide comments on the proposed rules during the public comment period that runs from November 1, 2022 to November 21, 2022 (closing at 5:00 P.M. Pacific Time). 

During the public comment period, you can provide your comments in writing and by e-mailing: publichealth.rules@odhsoha.oregon.gov

email title:

Comments on Proposed Rules for 109

Hello,

Find “Comment:” below, about administrative rules to implement ORS chapter 475A, the Oregon Psilocybin Services Act.

I wish to comment on section 3070 (training practicum), but the 333-333 Proposed Rules Nov 2022 pdf skips that section number.

At bottom is the link to my Requirements for Guides page, based on the cubensis initiation image/scene from the Canterbury psalter illuminated manuscript. Row 1 of 3 shows practicum, facilitator, testing, cubensis administration session, and cubensis banquet administration:

This is public feedback about the proposed rules during the November 2022 public feedback period per webpage:

https://www.oregon.gov/oha/PH/PREVENTIONWELLNESS/Pages/Psilocybin-Administrative-Rules.aspx

and per the Proposed Rules document:

https://www.oregon.gov/oha/PH/PREVENTIONWELLNESS/Documents/333-333-PROPOSED-Rules.pdf

333-333-1010

Definitions

Comment:

Add term “group administration session”.  I thought it meant a classroom filling out paperwork together prior to the private preparation session.

Add term “administration session”.

Add term “training practicum”, where is document section 3070 about it?  Skipped in Nov 2022 pdf proposed rules.

(37) “Lead educator” means a person affiliated with a training program who is responsible for tracking the progress of students throughout the program.

Comment:

“Students” = clients, or facilitators? Specify which.  Per (74), facilitators.

The lead educator (facilitator) of initiation candidates (clients) is depicted in the Canterbury psalter image row 1 left, bearded; second figure from left, also shown in row 1 right, at the cubensis banquet table with funnel hat, encouraging the maiden.  

(74) “Training program” means a program that has been approved to offer training to psilocybin facilitators as described in ORS 475A.380.

(75) “Training program applicant” means a program that has applied to offer training to psilocybin facilitators as described in ORS 475A.380.

Comment: 

My main concern is to deliver my “Requirements for Guides” webpage, to connect it to document section 475A.380.

https://www.oregonlegislature.gov/bills_laws/ors/ors475A.html

475A.380  Minimum standards of education and training for psilocybin service facilitators; rules

Comment:

This section is my main concern per my Requirements for Guides webpage. 

      475A.375 Powers and duties relating to psilocybin service facilitators. The Oregon Health Authority shall:

      (1) Determine the qualifications, training, education and fitness of applicants for licenses to facilitate psilocybin services, giving particular consideration to:

      (a) Facilitation skills that are affirming, non-judgmental, and non-directive;

Comment:  

A facilitator must know the standard established suggestion that to restore stable self control, submit control; submit to trans-personal, greater, overpowering control, if the client experiences the highly predictable, classic psilocybin experience of being a helpless puppet externally controlled.

      (b) Support skills for clients during an administration session, including specialized skills for:

      (A) Client safety; and

Comment:

The main problem for client safety (with high dose) is the threat of loss of control, while transforming the mental model of control. The standard, known, established solution is to submit control and acknowledge multi-level control.  This is the main “specialized skill” required for an adequate and authentic facilitator: the ability to move from control seizure back to stable control, by acknowledging limited personal control. 

      (B) Clients who may have a mental health condition;

      (c) The environment in which psilocybin services should occur; and

      (d) Social and cultural considerations.

Comment:

World religion concurs that the solution to control seizure panic attack spiritual emergency is to acknowledge limited personal control. Control stability thereby is restored. 

      (2) Formulate a code of professional conduct for psilocybin service facilitators, giving particular consideration to a code of ethics;

      (3) Establish standards of practice and professional responsibility for individuals licensed by the authority to facilitate psilocybin services;

Comment:

It would be irresponsible, the ultimate classic hubris, and one would be a basically unequipped facilitator, if a facilitator is not able to instruct a client of the standard way to restore control stability in the peak state: submit control; acknowledge limited personal control.  

Lacking that specialized skill would be to lack the most basic, fundamental, relevant authority. 

This specific knowledge is the very essence of authority in the psilocybin domain of experiencing. 

      (4) Select licensing examinations for licenses to facilitate psilocybin services;

Comment:

A facilitator must be examined to see if they are able to restore a client’s control stability during a peak state spiritual emergency, solving control seizure.

      (5) Provide for waivers of examinations as appropriate; and

      (6) Appoint representatives to conduct or supervise examinations of applicants for licenses to facilitate psilocybin services. [2021 c.1 §40]

475A.380 Minimum standards of education and training for psilocybin service facilitators; rules. 

     (1) The Oregon Health Authority shall adopt by rule minimum standards of education and training requirements for psilocybin service facilitators.

Comment: 

Those minimum standards must include the topic of loss of control and transformation of the mental model of personal control per the well-established principle of “submission” (ie. submit to a greater, uncontrollable higher source of control-thoughts). 

The established solution to the classic psychedelic peak climactic problem of control instability and panic or spiritual emergency is commonly called “submit control”.  

A facilitator absolutely must understand this dynamic and solution, or else they are fundamentally unqualified. 

See my “Requirements for Guides” webpage explaining the Canterbury psalter initiation image.  

      (2) The authority shall approve courses for psilocybin service facilitators. To obtain approval of a course, the provider of a course must submit an outline of instruction to the office and the Department of Education. The outline must include the approved courses, total hours of instruction, hours of lectures in theory and the hours of instruction in application of practical skills. [2021 c.1 §41]

Comment: 

Courses must cover panic attack, control seizure, spiritual emergency, and the standard solution of submitting, to align with the higher, ultimate source of control.  

Peak classic ego death as described in religious mythology, explained in direct detail by the Egodeath theory, must be expected and thoroughly prepared for, in the course materials, given that control seizure is a peak-state classic effect of psilocybin.

475A.345 Preparation session.

    (1) Before a client participates in an administration session, the client must attend a preparation session with a psilocybin service facilitator.

Comment:

I agree with preliminary educating and preparing the initiate or client.  This section should mention or differentiate “practicum training” (especially since section 3070 about latter is not found).

Comment:/Objection:

What is covered in the client preparation session?  Do Rules now intend to specify this, or out of scope?  

The Canterbury psalter cubensis initiation image depicts youths being trained and tested specifically about how to restore control stability by affirming a non-branching world model, which is equivalent to the standard solution of “submit control”. 

Do the Rules require course materials that instruct trainers?  I believe so and that should be required. 

Comment:/Objection:

Do the Rules require course materials that instruct clients?  I believe not, but that should be required. 

Comment:/Unclear:

Do the Rules require course materials that instruct trainers on how to instruct clients?  I believe so, and that should be required. 

Comment:/Objection: 

Is a single training or preparation meeting with the client sufficient?  

The rules should require that the client receive and read adequate peak-state training material, including about panic attack, spiritual emergency, and above all, restoring stable control by the standard classic advice of “submit”.  

I would definitely advise and require initiates (clients) to read about control seizure, “the shadow”, the “submit control” solution, prior to the preparation session.  

The Rules should cover this educating the client and not imply that a preparation session is sufficient.  

The course materials are underspecified in document 475A, perhaps deliberately.  

My recommendations and Requirements (webpage url) concern the content of the course training materials, which is apparently not specified in the Rules. 

333-333-2015

Allowable Species

Comment:

I agree with selecting Cubensis in particular.  

This avoids wood lover’s paralysis.  

This agrees with the cubensis initiation scene in the Canterbury psalter illuminated manuscript. 

I agree with using a natural extract, though I am open to synthetic psilocybin.  

Maybe the Marsh Chapel Good Friday Experiment and Roland Griffiths’ 2008 experiment used synthetic psilocybin – if so, that is a curious disconnect with the interest in natural extracts. 

333-333-2310

Packaging and Serving Size

Comment:

The banqueting scene in the cubensis initiation image in the Canterbury psalter suggests that the maiden’s dose is one bowl of cubensis and the youth’s dose is two bowls of cubensis, because his hands are touching two bowls. 

333-333-4470

Practicum Site

(1) Any service center may function as a practicum site under OAR 333-333-3070.

Comment:

Where is section OAR 333-333-3070?  Skipped by this pdf.  Define “practicum site”.

(2) A service center that functions as practicum site must notify the Authority that practicum will be offered at their location and identify any training program affiliated with the practicum prior to practicum taking place at their location.

Comment:

Define “practicum training”; where is section 3070?

The lesser mysteries trained initiates prior to ingesting the sacred meal/sacrament.  Row 1 left in the Canterbury psalter cubensis initiation image depicts preliminary education and testing of initiation candidates (regarding understanding non-branching of possibilities and thus understanding limited personal control, to endure psilocybin-induced control seizure & restoration of stability).  

(3) A service center that functions as a practicum site must comply with all applicable requirements of these rules, including but not limited to OAR 333-333-5200.

Statutory/Other Authority: ORS 475A.235, ORS 475A.305

Statutes/Other Implemented: ORS 475A.235, ORS 475A.305

333-333-5000

Preparation Session Requirements 

(1) A facilitator must complete a preparation session with every client who will participate in an administration session at least twenty-four hours but no more than 90 days prior to the commencement of the client’s first administration session with the facilitator. If different facilitators will conduct a client’s preparation, administration sessions or integration session, the client must provide written consent as described in subsection (7)(g) of this rule. A client must have an opportunity to approve and meet any facilitator who will provide psilocybin services prior to receiving services from that facilitator.

Comment: 

Rules should mention reading materials for clients to read before the preparation session, alerting to loss of control, or transformation of the experience of wielding control, when using high dose. 

(2) Preparation sessions required under this rule must be conducted privately with each individual client to allow clients to share personal information.

(3) For every client who will participate in an administration session, a facilitator must receive a completed client information form as described in OAR 333-333-5050.

(4) For every client who will participate in an administration session, a facilitator must complete a transportation plan as described in OAR 333-333-5150 in coordination with the client. The transportation plan may not approve a client to operate a motor vehicle, bicycle, or other form of self-operated transportation immediately following the administration session.

Comment:

Agree with explicitly covering transportation. 

(5) For every client who will participate in an administration session, a facilitator must coordinate with the client to complete a client safety plan as described in OAR 333-333-5080. 

Comment:

Client safety plan in 5080 = client-specific risks, which is out of scope of my Requirements for Guides that’s part of the Egodeath theory. 

(6) A facilitator must provide a client with the following during or prior to a preparation session and review each document with the client during a preparation session:

(a) Informed consent document as described in OAR 333-333-5040.

(b) Client Bill of Rights as described in OAR 333-333-4520.

Comment:

Regarding materials/documents given to client before or prior to prep session, do Rules specify content of such, such as informing client that high dose can cause control loss (/transformation) seizure?  

That ultimate peak-state problem is solved by claiming limited personal control, ie “submitting control”.  

(f) Applicable sections of the service center emergency plan required by OAR 845-025-4460.

Comment:

Document 4460 is not found at same webpage.  Emergency plan a la Stan Grof spiritual emergency needs to cover ego death loss of control seizure panic attack & submitting limited personal control to restore (transformed) control stability.  

(7) In addition to the documents required by sections (3)(4)(5) and (6) of this rule, a facilitator must obtain prior written consent from a client during a preparation session for the following activities and circumstances:

(a) Participation in a group administration session, including the opportunity to meet other clients and facilitators participating in the group session as described in OAR 333-333-5020.

(b) Use of supportive touch during an administration session, if any, as described in OAR 333- 333-5120(6).

(c) Participation in a training practicum, including information regarding training program students and instructors who will be present during the client’s administration session. The client must have an opportunity to meet any students or instructors who will be present during their administration session prior to the commencement of an administration session.

Comment:

Unclear; define “training practicum”.

Where is doc section 3070?  pdf skips.

(g) The use of different facilitators to conduct a client’s preparation, administration sessions or integration session.

(h) Consuming secondary doses of psilocybin products after the administration session has begun, including the total amount of psilocybin analyte that a client agrees to consume, not to exceed 50 mg of psilocybin analyte.

Comment:

Agree on redosing technique to flatten and extend intensity curve.  Determine the duration between redosing to flatten: maybe at t = 1:15:00.  

(i) Participating in an administration session where licensed representatives of a service center will be present pursuant to OAR 333-333-5200(9).

(8) During a preparation session, facilitators must provide clients an opportunity to discuss internal and external factors that could impact a psilocybin experience including but not limited to the client’s intention and expectations. If the client will participate in an outdoor administration session, the facilitator must provide an opportunity to discuss the client’s specific concerns that may be relevant to participating in an outdoor administration session, including but not limited to allergies and sensitivity to sun exposure.

Comment:

Agree on avoiding sunburn.

(9) Preparation sessions may be completed in person or virtually using video conferencing technology.

Comment:

Agree online could work well. 

(10) The requirements of this rule may be satisfied by conducting multiple preparation sessions. 

Comment:

Agree multiple prep sessions often could be best.

(11) A facilitator must complete an initial preparation session with every client before conducting an administration session with that client for the first time. After completing the initial preparation session, a facilitator is not required to complete additional preparation sessions prior to conducting an administration session with that client for a period of 12 months.

(12) If a facilitator does not complete additional preparation sessions as allowed by section (11) of this rule, the facilitator must confirm that the information contained in the client’s previously completed client information form remains accurate prior to conducting additional administration sessions.

(13) A facilitator must discuss the process for verification of license status and process for making complaints to the Authority during a preparation session.

Statutory/Other Authority: ORS 475A.235, ORS 475A.340

Statutes/Other Implemented: ORS 475A.340

333-333-5080

Safety and Support Plans

(1) A facilitator must work with every client who will participate in an administration session to draft a safety and support plan that identifies risks and challenges specific to the client’s circumstances and resources available to mitigate those risks and challenges, including the client’s existing support network and appropriate external resources.

Comment:

My “Requirements for Guides” defined in my webpage concern not client-specific risks, but universal standard risks of the peak psilocybin state. 

333-333-5020

Group Preparation Sessions

Comment:

Canterbury psalter’s cubensis initiation image depicts group initiation sessions in the banquet scene and mushroom tree scene.  Not only using cubensis in a 1-on-1 session with the facilitator.  

Objection/comment:

Do the Rules cover group psilocybin sessions?  If not, this is an inherent limitation of the “therapy” model, which is distinct from a group spiritual initiation model. 

Update: I asked to add the term in Definitions, “group administration session”.

333-333-5240

Consumption Limits

(2) “secondary dose”

Comment:

Agree with strategy of “secondary dose”, to form a rectangular (flattened) intensity curve instead of a hill shape.

Redosing stretches the duration of the optimal intensity level.

end of per-section comments

_____

Please enter this message into the record about defining the nation’s first regulatory framework for psilocybin services.  

Egodeath Theory: Qualifications for Guides

In drafting rules for Measure 109, please read these cubensis initiation rules derived from the main illuminated manuscript from the middle ages.  

Requirements for Guides/Facilitators:

https://egodeaththeory.wordpress.com/2020/11/24/strict-requirements-for-teachers-initiation-guides-and-students-prior-to-initiation/

Psilocybin mushrooms are centrally present in Western religious history.  

Regarding Western religious history, entheogen scholarship overemphasizes Amanita at the expense of inattention to psilocybin.  

Within hellenistic mystery religion, the mixed-wine banqueting tradition, and Christian art of the middle ages inside the Church, there is plentiful evidence in religious mythology and psilocybin mushroom imagery in art.  

The crown jewel of such imagery is the great Canterbury psalter’s cubensis ego death initiation panel, which I have interpreted in detail:

Canterbury Psalter, folio 134
https://gallica.bnf.fr/ark:/12148/btv1b10551125c/f134.item.zoom
High-resolution, zoom, & fullscreen.

On mobile, use landscape orientation.

Discovered by author John Lash, interpreted and explained by Michael Hoffman (the Egodeath theory).

The image depicts control loss and transformation and shows the initiation training process for high dose re-stabilizing of personal control while directly engaging “the shadow” and submitting to the transcendent controller.  

— Michael Hoffman, theorist of the cognitive and control aspects of ego death

Egodeath.com

https://egodeaththeory.wordpress.com