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 Schedule II criteria are somewhat different: (I) the drug (2)(B). In a scheduling proceeding involving another drug,
 "has a high potential for abuse," (2) it "has a eu'rre_ztly the Administrator determined that "It]he charach:2ristics of a
 accepted medicoZ use in treatment in the United States or a drug or other substance _th an accepted medical use" it>
 currently accepted medical use with severe restrictions," and elude:
 (3) "[a]buse of the drug ... may lead to severe psychdogical
 or physical dependence." 21 U.S.C, § 812(b)(2) (1988) (em_ (I) scientifically determined and accepted knowledge of
 phasis added). Petitioners' central claim is that the Adminis- its chemistry;
 trator misinterpreted the language italicized above. (2) the toxicology and pharmacology of the substance in
 animals;
 B. Procedural History (3) establishment of its ef%ctiveness in human_ through
 This is the latest chapter in petitioners' efforts to move scientifically designed clinical trials;
 marijuana into a less restrictive CSA schedule. They claim (4) general availability of the substance and informatio_
 that marijuana is misclassified because it l'ms been shown to regarding the _ ,_" * -_.
 ....... s_a _e and its use;
 serve various medicinal purposes. SpecificaEy, they contend (5) recognition of its clinical use in generally accepted
 that marijuana al!ev%tes some side effects of chemotherapy pharmacopeia, medical references, journals or textbooks:
 in cancer patients, aids in the treatment of glaucoma, an eye (6) specific indications for the treatment of recognized
 disease, and reduces muscle spasticity in patients suffering disorders;
 from multiple sclerosis and other maladies of the central
 nervous system. In support of these contentions, they intro_ (7) recognition of the use of the substance by organiza-
 duced affidavits and testimony of a number of patients and tions or associations of physicians; and
 practicing physicians who insist that, in their experience, (8) recognition amt use of the substance by a substantial
 marijuana has proven safe and ef%etWe, segment of the medical practitioners in the Unit_,d
 The petition to resehedule marijuana was first flied in 19'72 States.
 and has been before this court on four prior occasions-- 53 Fed. Reg. 5J56, 5,15'7-58 (Feb. 22, 1988).
 National Org. jbr the R@rm of Ma_j_m_a Le:vs v. Infer- Applfrqng these criteria to the petition to reschedule mart-
 soK 497 F.2d 654 (D.C. Cir. 1974); Natio_aZ Org. for the juana, the Administrator %und on December 29, 1989, ;.l;at
 R@'rrn qf Ma'rijuana Laws _a D m_g Enjb_:ernent Admin., marijuana had no currently accepted medical use and thus
 559 F.2d 735 (D.C. Cir. 1977); National Org. ]tar the R@r_ had to remain in Schedule I. 54 Fed. Reg. 53,747. 5a,7(;_;
 of Marijuana Laws v, Drug EnNrcement Admi_z,. & Dep't of (1%9). The eight-factor test had been published in the
 Heagth Education & Welfare, No. 79-1660 (D.C. Cir. Oct. 16, Feder£ Register on Febnmw 22, Iggqs, I7 (lays aft,.,,." tee
 1980); and most recently, ACT, %0 F.gd 9B6 (D.C. Cir. 1991). dvse _i" the evidence but be%re t_m oral arLg. arner_ts to the
 AC) _s the only part of this history we need recount, administrative law judge in the marijuana reschedu!ing pro-
 In ACT, the Alliance for Cannabis Therapeutics ("Alli- ceedings.
 anne") and the National Organization for the Reform of On reviewing t_=e Administrator's decision, we f_:_,:! t}_e
 Marijuana Laws ("NORMIf') ar_md filet the Administrator's
 eight-factor test for determining whether a drug had a "cur_
 refusal to resehedule marijuana rested on an unreasonable rently accepted medicai use" to be "in the main accepta/_[e."
 interpretation of the statutory phrase, "currently accepted ACT, 930 F.2d at 937. We noted the ambiguity of the phrase
 medical use." 930 Fo2d at 939; ,see 21 U.S.C. §§ 812(b)(1)(B), and the dearth of legislative history on point and deferred to