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The 1990 Amendments In 1990, Congress enacted more stringent controls with higher criminal penalties for offenses involving the illegal distribution of anabolic steroids and human growth hormone. This new legislation, which was enacted as part of the Anabolic Steroids Control Act, Pub.L. No. 101-647, title XIX, §§ 1901-05, resulted in a reconfiguration of the statutory scheme regulating the distribution of both anabolic steroids and human growth hormone. The 1990 Act reclassified anabolic steroids as Schedule III controlled substances, effective February 27, 1991.[FN5] See 21 U.S.C. § 812(c) (1992). The 1990 Act also amended 21 U.S.C. § 333(e)(1) to explicitly criminalize as a five-year felony the distribution and possession, with intent to distribute, of human growth hormone "for any use . . . other than the treatment of a disease or other recognized medical condition, where such use has been authorized by the Secretary of Human Services . . . and pursuant to the order of a physician . . . ."[FN6] Pub.L. No. 101-647, title XIX, § 1904 (codified at 21 U.S.C. § 333(e)(1) (1992)). The 1990 Act also provided that criminal forfeiture would be available as an additional penalty for convictions involving illegal distribution of human growth hormone under the newly amended 21 U.S.C. § 333(e)(1). See Pub.L. No. 101-647, title XIX, § 1904 (codified as 21 U.S.C. § 333(e)(3) (1992)).
In 1993, these provisions outlawing the distribution of human growth hormone for non-medical purposes were recodified at 21 U.S.C. § 333(f) pursuant to Pub.L. No. 103-80, § 3(e), 107 Stat. 775. |