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 Drugs recognized under the FD(_ for research use only,
 not for use in treatment, such as alphacetylmethadol and
 marijuana, were placed by Congress into Schedule I.
 Unfortunately, Federal records are not complete enough
 to do a comprehensive mathematical mapping, tracing every
 drug in the initial Controlled Substances Act schedules back
 to its legal status under the FDCA° Nevertheless,
 determining legislative intent does not require mathematical
 certainty. Probability based on circumstantial evidences on
 samplings, and on inductive reasoning can sufficer
 especially when there is nowhere else to turn.
 The pattern of initial scheduling of drugs in the
 Controlled Substances Acts viewed in light of the prior
 legal status of these drugs under the FDCA_ convinces me
 that Congress equated the term "currently accepted medical
 use in treatment in the United States" as used in the
 Controlled Substances Act with the core FDCA standards for
 acceptance of drugs for medical use°
 This is not to say that every FDCA requirement for
 GRASE status, or for NDA approvals is pertinent to
 scheduling determinations under the Controlled Substances
 Act+ There are differences° But the core FDCA criteria
 appear to have guided the Congress in the decisions it made
 concerning the initial scheduling of drugs in the Act+
 These same core FDCA criteria served as the basis for
 an eight_point test used by my predecessor as Administrator

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