On Entheogenic Practitioner Duties and Privileges under Oregon’s 109 Program

Below is my formal comment I submitted to the OHA.  Please email publichealth.rules@dhsoha.state.or.us to submit your own written comment by 5:00 p.m. PDT on April 21, and if you can, also sign up to make direct verbal comments on April 18 and 21.  Also, please click this link to join an event the Portland Psychedelics Society is hosting at 6:00 p.m. PDT on April 17.

Dear OHA:

I’m David Bronner, CEO of Dr. Bronner’s, which funds many different organizations and campaigns to integrate psychedelic medicines and healing into American culture. We were inspired by Tom and Sheri Eckert’s vision to bring psilocybin healing to a majority of a generally psychedelically naïve population, in a way that felt safe and optimized therapeutic outcomes. We were the largest funder of Measure 109 and second largest for 110, as no one struggling with addiction should be going to jail and be further traumatized; in the case of psychedelic medicines, they are often using to heal trauma. We believe psilocybin therapy is one of the most effective tools for people struggling with substance use disorder, and 109 and 110 are thus a perfect policy pairing, along with decriminalizing plant medicines generally to allow for ceremonial healing (www.plantmedicinehealing.org).

Under 109, we are excited to see Oregon blaze the path and set the example for the kind of effective, equitable and affordable regulated access program for the rest of the country to follow.  I recently was gratified to read Jon Dennis’s Entheogenic Practitioner proposal which I believe can further optimize and expand the program not only for religious groups, but for group healing generally, while helping make the program more economically accessible and ensuring safety for participants.  In particular I want to share the specific policy proposals in his proposal, and point out which are relevant for group healing generally under the program, especially those that will reduce cost and broaden access in a safe way.

Generally in terms of safety and long term mental health, responsible entheogenic communities provide a safe container for participants while also providing ongoing integration, peer support and care. The antidote to depression is connection, and ingesting medicine regularly in a community is as important as the medicine itself for many people, in many ways superior to the “one and done” therapeutic model. In the religious context, Santo Daime is an amazing example, which is a federally recognized church whose members regularly ingest ayahuasca as a sacramental medicine in ceremonial services inspired by Amazonian indigenous use. They have had great success helping people struggling with depression, alcoholism, and other mental health challenges, as well as the struggles of life generally, and serve as a model for a crucial dimension of healing we want to see allowed in Oregon’s 109 program, and eventually the rest of the world. In fact, Jonathan Goldman of the Santo Daime in Ashland closely consulted on Jon’s Entheogenic Practioners proposal, and I want to share a quote that Jonathan made in a separate email discussion I was involved in, about how to best ensure competent facilitation and safety in entheogenic community use, whether or not that’s explicitly religious in nature.  He said:

It is nobody’s business to judge anyone’s form of ceremony, spiritual perspective, lineage, politics, or opinions. In fact, in my estimation, none of that is relevant to any evaluation of a medicine work. Ceremony is necessary to hold experience. We each live in an organized body and in order to let it go and enter into communion with the transpersonal forces, our little, sensitive body needs to be held in a ceremonial ‘body.’ That’s all. The space needs to be coherent and harmonious—there needs to be form—but beyond that the actual form is irrelevant. What is relevant, whatever the form or lineage, is how people are screened for appropriateness of participation, how they are oriented to the experience, how they are made safe on all levels, how they are attended to, how the people leading and assisting in the ceremony handle whatever may come up for participants, and how participants are followed up with.

Generally speaking, the indigenous ceremonial container controls and optimizes set and setting in a culturally relevant way, and allows individuals to release and do deep work safely, and inspired the modern therapeutic container in the West, which can be considered in some sense the West’s version of the indigenous ceremonial container. No doubt one on one facilitation in a therapeutic container is appropriate and optimal for many people, especially when processing through acute or complex trauma such as childhood sexual abuse. However, ongoing integration and mutual support and care in a community, with more frequent engagement with medicine, whether religious or secular, can really help cement the healing experiences and insights into long term character traits. Thus these healing communities, religious or otherwise, are complementary to the therapeutic one on one model. The group model in the 109 regulations in some ways straddles and is inspired by both the therapeutic and indigenous ceremonial approach, but can be further optimized per Jon’s proposal.

I asked Jon to specify and list the substantive policies contained in his proposal, which I paste in full below, and wanted to discuss them first in terms of those which I think should be applied generally throughout the 109 program, especially for group use, versus the rest that would be specific to a religious carve-out.

The criteria in Jon’s proposal that I see as broadly applicable to the group model in particular, that will also help make the program more affordable and accessible, are:

  • Clients would be required to go through the screening and preparation process no more often than once per year, regardless of the number of ceremonies (sessions) the client participates in, and would be allowed to receive any number of preparation and integration sessions.
  • For groups that are meeting and healing with medicine on an ongoing basis under 109, to allow for the provision of peer support assistance where clients can be trained and “certified” to provide assistance to other community members, and increase the facilitator to client ratio.
  • Allow for outdoor healing contexts.
  • So long as a 109 trained facilitator is present and supervising who is not on medicine, whether immediately outside or inside the group healing space, that a competent client could lead the ceremonial or group healing session; for example, a visiting Mazatec shaman, who is on some amount of medicine. Generally in indigenous led ceremonies, the person leading the ceremony ingests a moderate dose of medicine, not as much as participants, that helps the person leading effectively enter sacred healing space and lead the ceremony, and also has assistants who are also on an amount of medicine to help hold the space and address anything that comes up.

Otherwise and additionally, I support the Entheogenic Practitioner program that Jon proposes, giving more freedom and leeway to sincere entheogenic communities, religious or otherwise, to safely practice and heal under the 109 program, and have the option to grow their own different varieties of psilocybin mushrooms cost-effectively as far as testing requirements. In that regard, I wanted to highlight Miraculix’s test-kits, which are an affordable option for communities and individuals to easily and cost effectively determine the amount of psilocybin in a given mushroom sample.

I also really appreciate Jon’s proposal regarding reciprocity, as it’s important for people who experience the healing benefits of mushrooms in a ceremonial context, inspired by indigenous ways of healing, being and knowing, to show their appreciation. I’m part of an effort called the Indigenous Medicine Conservation Fund that will be supporting indigenous led biocultural conservation projects around the major keystone medicines, including mushrooms and the Mazatec, in building needed infrastructure and capacity for their communities. Our partner Grow Medicine will be the more public facing face of the IMC effort, that will crowdfund from individuals inspired to give back and help in this way.

Finally, I’ll note that when I was zooming with Jon this past Saturday, that Rev. Hunt Priest was staying with Jon, who is an Episcopal priest and a participant in a psilocybin religious professional study, and is the founder of Ligare (www.ligare.org), a Christian Psychedelic Society. The vision he shares with Jon and many others, is for existing churches, denominations and faith traditions, to be able to utilize entheogens as part of their services, in a safe and responsible way, while respecting the sincerity and autonomy of the different faith traditions and community healing approaches. Under Jon’s Entheogenic Practitioner proposal, Oregon has the opportunity to open access in a cost-effective way for people to engage someday soon with psychedelic healing in the comfort of their own spiritual lineage and community. Best practices for churches and community healing groups have been developed by the Sacred Plant Alliance, which will soon be opening up for membership. And this approach is also the most economically affordable, which is crucial that we make sure this healing is available to all who can benefit regardless of their relative affluence. Please see Roberto Lavato’s “The Gentrification of Consciousness” in Alta in this regard.

Here’s the full substantive policy contained in Jon’s proposal, that Jon broke down, and I encourage careful review and adoption in full for sincere entheogenic communities:

  • The draft rules would restrict the available species of psilocybin mushrooms to Psilocybe cubensis; the Entheogenic Practitioners proposal would allow sincere communities who work with psilocybin to grow and work with a variety of species.
  • The EP proposal would allow communities to grow and handle their own sacrament onsite in accordance with their views and beliefs around the mushroom.
  • Ceremonial privileges would include:
    • To have group and outdoor ceremonies;
    • To engage in virtually any kind of ceremonial activity, so long as they are safe and otherwise compliant with M109;
    • To have ceremonies that are led by people (“clients,” in M109 verbiage) who are under the influence of psilocybin;
    • To not have state-imposed limits on the amount of psilocybin that may be consumed in religious or entheogenic practice;
  • Facilitation requirements for ceremony:
    • Entheogenic communities would have the option to have their facilitators supervise ceremonies from outside of the ceremonial space, so long as the facilitator are immediately on hand and can readily be called into the space if needed
    • Facilitators would have the option of participating in the ceremonies they supervise, so long as they do not take psilocybin and they remain attentive to client needs (this addresses the possibility that the rules may ultimately require all facilitation to be “non-directive”)
    • Communities can satisfy in-ceremony safety requirements through the provision of peer support assistance (See proposed OAR XXX-XXX-XXX6 in Jon’s proposed framework)
      • Communities would “certify” their own community members who are experienced, knowledgable, and capable of providing assistance to other community members
      • When using peer support assistance to deviate from generally applicable facilitator-to-client ratios, the facilitators and service centers must consider a list of relevant factors when deciding how many facilitators to use, which include, e.g.,:
        • The operator’s and facilitator’s familiarity with the clients participating in a ceremony;
        • The types of ceremonial activities the group intends to engage in;
        • The group and its members’ prior experience with psilocybin or other psychedelics;
        • The relevant experience of the clients who are providing peer-support assistance, etc.
      • Clients would be required to go through the screening and preparation process no more often than once per year, regardless of the number of ceremonies the client participates in
      • Clients would be allowed to receive any number of preparation and integration sessions
      • EPs must participate in one or more reciprocal exchange programs and summarize that participation to OHA each year. OHA would publish that data for consumer consideration

Thank you for your time and consideration.


David Bronner
Cosmic Engagement Officer
Dr. Bronner’s

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David Bronner

David Bronner is Cosmic Engagement Officer (CEO) of Dr. Bronner’s, the grandson of company founder, Emanuel Bronner, and a fifth-generation soap maker. He is a dedicated vegan and enjoys surfing and dancing late into the night.

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