Recreational Use Labeling: Benadryl Case Study

Originally posted on Drug Law Blog by attorney Alex Coolman

Part of this blog’s proposal for making drugs boring — that is, making them something we can trust to the judgment of individuals rather than the coercion of the police, courts and prisons — involves creating more accurate packaging and labeling for all types of drugs, both substances that are currently illegal and substances that are legal but can be used recreationally.

One step in this direction would be the creation of “recreational use” labels for drugs. And a requirement that drug manufacturers provide information about the nature and risks of such use any time it is reasonably forseeable that their drug could be used recreationally.

Take Benadryl, for example. It’s a pretty common household drug. It’s also one that would be required to include recreational use labeling under a “Make Drugs Boring” regime.

Benadryl is the brand name for Diphenhydramine. That drug is an antihistamine, and it’s typically used to reduce the severity of the body’s reactions to allergens or, (when sold as Sominex) to help people sleep. But it’s also a drug that people sometimes use recreationally, because at fairly high doses it can produce vivid hallucinations that are said to be very difficult to distinguish from reality. In general, Diphenhydramine sounds like a lousy way to have fun, because the hallucinations are reported to be quite frightening and disorienting.  Even worse, it’s a trip that comes at the cost of all kinds of unpleasant physical side effects, including motor skill impairment, extreme drowsiness, blurred vision, and so forth. But that doesn’t stop people from using it for “fun.” A quick glance at the Wikipedia page for Diphenhydramine or the  Erowid experience reports for the drug provides plenty of information about people who, for lack of anything better to do, pop a bunch of Benadryl and wait for the effects to start warping their brain.

The current labeling for Benadryl says nothing about recreational use. That’s no surprise, because almost no drug packaging currently provides any useful information about employing a drug for something like pleasure. The closest things we have to such labeling are the elliptical notices provided with some drugs (including alcohol) that one should not operate a vehicle while under the influence of the drug. Why shouldn’t you operate a vehicle after doing tequila shots or gulping down a bunch of Oxycontin? Because you might bedrunk. You might be stoned. You might be high as a kite. But the packaging doesn’t come right out and say as much; it’s just something that everybody knows.

(Above: Label on a box of Benadryl Allergy & Sinus Headache – click to enlarge)

(Above: Label on a bottle of Scotch. The second of the two warnings on this bottle is the closest thing we have to “recreational use” labeling. It doesn’t exactly say that you can get drunk from drinking alcohol, but it’s implicit in the idea of being “impaired.”)

The dearth of information related to recreational use of drugs isn’t such a big deal when it comes to something like alcohol, because most people have at least some experience drinking alcohol and know how a given dose of that drug will affect their bodies. But when it comes to drugs that are a little more off-the-beaten-path in terms of recreational use, like Benadryl, or Morning Glory seeds, or nutmeg, there is a much greater risk that individuals — especially young people who are likely to be the people experimenting with this stuff — will make errors of judgment. The risk is that people will overdose and kill themselves or will have experiences that leave them physically or psychologically damaged.

Recreational use labeling could make these kinds of bad outcomes less common.

Of course, recreational use labels could also encourage some people to take drugs who might not otherwise do so. But in the case of a drug like Benadryl, the number of people who would be encouraged to try the drug recreationally would probably be extraordinarily small. That’s because full, accurate information would make people realize that the effects of higher doses of Diphenhydramine are mentally unpleasant and physically very debilitating. Maybe such labeling could even refer would-be trippers to the Erowid experience report from a person who described his experience with Diphenhydramine as a trip “into the cold lonely depths of insanity” that left him “deep in a chemical fog. I feel like shit, my mouth is a desert. My head pounds, my eyes sting.” Or this one, which concludes with the bizarre line “I’ll still always do drugs but from now on I’m sticking to the illegal ones.”

That type of language is obviously a little raw for something one would typically see on a drug label. But the point is that it’s a lot more meaningful — and frankly, a lot more off-putting — than the type of useless non-information that has been disseminated around recreational drug use for decades. It’s the kind of information a person can actually use to make an intelligent decision, as opposed to a decision based purely on fear and guilt or a decision based solely on what somebody’s older brother said after school one day.

So what would a recreational use label for Benadryl look like? It probably would not be that different from what is described on the Wikipedia page linked to above, except with more detail about the nature of the experience and the physical side effects. Something like:

Recreational Use
Overdoses of [insert drug brand name here] in the range of 225mg (for an unknown weight) to 600 mg for a 200 lb male can cause vivid visual and auditory hallucinations that are difficult to distinguish from reality and are often accompanied by strong feelings of dread or unease and paranoia. Such high doses may cause severe physical side effects, including heavy drowsiness, dry mouth, loss of motor control, convulsions, heart attack, cardiac arrhythmia, coma or death. These effects may be exacerbated dangerously if used with other drugs, such as alcohol. Do not use [brand name] recreationally without a sober sitter and do not use it before driving or operating machinery. Recreational use of [brand name] is physically very risky and is strongly discouraged.

I don’t claim, by the way, that this proposed language is reliable in terms of the way Diphenhydramine actually behaves. But the drug companies and the FDA have accurate information about this stuff, and they are also undoubtedly aware of the potential, however limited, for recreational use. Under a standard of reasonable forseeability, it makes sense to require the drug packaging to include a brief description along these lines.

Probably sounds a little crazy. But the status quo around drug use is already crazy. We’ve already got tens of thousands of people in prison for nonviolent drug offenses and tens of thousands of other people who abuse legal drugs with very little understanding of the risks they undertake. So it’s time to start thinking of some alternatives. Recreational use labeling might be a way toward healthier outcomes.

Trickier questions: how should a recreational use label for marijuana be worded? What about one for heroin? And what about one for glue or solvents?