This is the definition of a Black Swan Event from ChatGPT

A black swan event refers to an unpredictable and rare occurrence that has a major impact. The term was popularized by Nassim Nicholas Taleb in his 2007 book, “The Black Swan: The Impact of the Highly Improbable.” The metaphorical black swan was used to describe an event that was considered impossible or highly improbable based on prior observations (as the conventional wisdom was that all swans were white), but that had profound consequences when it occurred.

In the context of finance and economics, black swan events are typically events that are unforeseen, have a major impact, and are often rationalized in hindsight. Examples of black swan events in history include the 2008 financial crisis, the 9/11 terrorist attacks, and the collapse of the Soviet Union. These events are characterized by their extreme rarity, the severe impact they have on systems, and the difficulty of predicting or preparing for them.

The concept of black swan events underscores the limitations of relying solely on historical data and statistical models for predicting future events, as it emphasizes the importance of being prepared for unexpected and rare occurrences that can have far-reaching consequences.

I have made a blog post before about the agreement between 41 state AG’s and the 3 major drug wholesalers to REDUCE the controlled meds that are sold to community pharmacies  Opioid Settlement Hinders Patients’ Access to a Wide Array of Drugs    Recently the DEA published proposals to cut Pharma opioid production quotas, as required by law, and had a period for interested parties to make comments, as required by law. I am not aware that the DEA had any requirement to give any serious consideration to the comments made, so it has been reported that they have posted the original proposed cuts as their final decision.

Earlier this year, the DEA stated that <1% of pharma opioids are being diverted, so for the DEA cutting of production quotas will almost guarantee further shortages of opioid meds. The “special twist” that the DEA has put into the process. They are moving from an annual production quotas to a QUARTERLY PRODUCTION QUOTA!

I have read that some of the Pharmas have stated that their cycle of ordering raw material to final production of the medication could be as long as SIX MONTHS!  This suggests that the availability of opioid meds could end up in a highly unpredictable availability.

If this comes to fruition, how many pts are going to be thrown into cold turkey withdrawals, because their meds are not available, and how many times is this going to happen to these pts?  If the DEA ignores the concerns of the pharmas about having quarterly production quotas, would suggest that the DEA has a dedicated purpose to disrupt the medical care of those in the chronic pain community. In no way can they claim that such a disruption has unintentional consequences/outcomes.

All of us can just imagine the anxiety levels of chronic pain pts as their refill date approaches.

Maybe it is time for all involved (pharmas, wholesalers, pharmacies, prescribers) in the treatment of pts dealing with medical issues that require being prescribed controlled meds, to challenge the CSA constitutionality and the DEA’s violation of a federal law that was on the books BEFORE the CSA was signed into law.

This may be an excellent example of our judicial system, where/how Congress can pass a bill and the President can sign it into law and there are no checks and balances if a new law is actually constitutional but can be enforced until some entity challenges it constitutionally in our courts. Some of us remember that the CSA was strongly supported by our then President “tricky dick” Nixon. Who was a known racist, and bigot and wanted to put all hippies and blacks in jail.

Here is the law that may apply:

42 USC 1395: Prohibition against any Federal interference

https://uscode.house.gov/view.xhtml?req=(title:42%20section:1395%20edition:prelim)