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DARK Classics in Chemical Neuroscience: Loperamide


Cori A. Malinky, Craig W. Lindsley, and Changho Han*

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ABSTRACT: Loperamide, a popular and inexpensive over-the-counter


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antidiarrheal medicine, is a potent μ-opioid receptor agonist approved by


the U.S. Food and Drug Administration (FDA). It has been on the market
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since 1976 and is relatively safe with no central nervous system-related side
effects when used for a short period of time at the recommended
therapeutic dose (2−8 mg/day). In recent years, loperamide has become
notoriously known as the “poor man’s methadone” for people with
substance dependence due to the increase in loperamide overdoses from
self-administered medication to treat opioid withdrawal symptoms. As a
result, in 2018, the FDA decided to limit the available packaged dose of
loperamide to stop prominent abuse. This review provides the synthesis
and chemical properties of loperamide as well as the pharmacology and
adverse effects of its use and the social effects of such abuse.
KEYWORDS: Loperamide, Imodium, μ-Opioid receptor agonist, Abuse, Cardiotoxicity

■ BACKGROUND
Loperamide, also known as Imodium, is a readily available
bind to opioid receptors in the CNS and show strong analgesic
and sedative effects.25−28 Because of their therapeutic value,
antidiarrheal medicine.1,2 It was first discovered in 1969 by opioid analgesics have been widely used for various medical
purposes in patients.28−32 The role of opioid receptors in the
Paul Janssen from Janssen Pharmaceutica.3 Initially, it was
GI tract are quite different from those localized within the
introduced as a schedule V drug by following a study that
CNS.33−36 In general, these inhibitory receptors in the GI tract
showed a potential risk of opioid physical dependence at
contribute to increase gut transit time by stimulating
supratherapeutic doses.4−6 However, loperamide exhibited
nonpropulsive contractions and increase the rectal tone (see
outstanding efficacy as well as a favorable safety margin at
ref 18 for additional information).35,37,38 Among those three
the therapeutic dose (2−8 mg/day) in subsequent studies
receptors, the MOR shows the highest expression level in the
conducted on human volunteers. This resulted in its removal
enteric nerve cells and therefore is considered as a major
from the FDA’s controlled substance list in 1982.6−10
contributor for the GI tract-related effects of loperamide.2,33,39
Loperamide has since become a nonprescription, over-the-
As an inexpensive MOR agonist, substance-dependent
counter (OTC) antidiarrheal medicine.11 In addition, it has
people began to take loperamide far more (70−100 mg/day)
been used as a first-line treatment of chemotherapy-induced
than the recommended dose (2−8 mg/day) to induce a mild
diarrhea (CID), a side effect associated with a gastrointestinal
high for the self-treatment of opioid withdrawal symp-
toxicity of chemotherapy agents.12 It also showed therapeutic
toms.9,40−43 Loperamide is significantly more affordable for
potential as a peripheral analgesic to treat inflammatory pain,13
people with substance dependence because it only costs
neuropathic pain,14−16 and cancer pain.17 Loperamide can $36.75−52.5/week for the self-treatment (35−50 caplets × 7
inhibit voltage-gated L-type calcium channels and trigger days) in comparison to typical methadone treatment, which
autophagy-dependent cell death as well.18,19 It currently costs around $126/week (medication and supplemental
remains an OTC drug with an affordable price (∼$0.15/ medical services costs).44 Moreover, people have shared their
caplet) which can be purchased online or at a local store.20,21 experiences on social media, and the Internet community
Loperamide is a peripherally restricted potent μ-opioid
receptor (MOR) agonist, and its importance has recently been
showcased by the World Health Organization (WHO) by its Received: June 8, 2021
inclusion in the model list of essential medicines.22 μ, κ, and δ Accepted: July 22, 2021
opioid receptors (MOR, KOR, and DOR) are inhibitory G
protein-coupled opioid receptors found in the central nervous
system (CNS) as well as in the gastrointestinal (GI) tract.23−25
Blood−brain barrier (BBB) permeable opioids and opiates

© XXXX American Chemical Society https://doi.org/10.1021/acschemneuro.1c00382


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Figure 1. X-ray crystal structure of loperamide (HCl salt)1 and its chemical properties.

Figure 2. Synthesis of loperamide (1).3,60

began calling it a “poor man’s methadone” or “Lope”.45 The


number of Internet posts with loperamide mentions has
■ CHEMICAL PROPERTIES AND SYNTHESIS
Loperamide is a phenylpiperidine derivative which was first
exponentially increased since 2005, and the social media synthesized and discovered in 1969 from a synthetic opioid
attention has triggered a huge increase in documented cases of antidiarrheal agent discovery effort.3 While in development,
loperamide misuse.5,9,42,46−49 As expected, there are an loperamide was known as R 18553. Its IUPAC name is 4-[4-
increasing number of reports on patients with fatal (4-chlorophenyl)-4-hydroxypiperidin-1-yl]-N,N-dimethyl-2,2-
cardiotoxicity due to this abuse.9,41,43,49−53 The FDA reported diphenylbutanamide.3 As reported in Figure 1, its molecular
weight is 476.2 g/mol. Loperamide is shelf stable in the
15 761 total loperamide-related adverse cases with 7204 being
absence of light and relatively lipophilic (logP = 5.5).3,58
considered serious instances, including 403 total fatalities.54 A Loperamide hydrochloride exists in the crystalline state as two
total of 63% of these reported cases have occurred since distinct polymorphs and a tetrahydrate.3 It is usually
2015.54 Between 2010 and 2015, intentional loperamide distributed in the form of polymorph I which is recrystallized
exposure nearly doubled from 201 cases to 383 cases.55 in cold isopropanol while being stirred.3 This form of
Surveys conducted in the third quarter of 2017 of ∼40 000 US loperamide has a melting point of ∼224 °C, is soluble in
and UK participants actively taking loperamide revealed that polar organic solvents such as methanol (28.6 g/100 mL) and
4.9% (US) and 22.5% (UK) of users take loperamide to treat methylene chloride (35.1 g/100 mL), and is considerably less
soluble in neutral water (pH = 7, 0.4 g/100 mL) as well as
or prevent withdrawal symptoms. In addition, 4.2−6.8% (US)
acidic water (pH = 1.7, 0.14 g/100 mL).3,58 Loperamide
and 14.3−41.5% (UK) of users take loperamide recreation- hydrochloride can be formulated with various glycerols to
ally.56 As consequence, since 2018, the FDA has limited the improve its aqueous solubility.59
packaged dose of loperamide to prevent its abuse and to The original synthesis of loperamide hydrochloride is the
encourage safe use as an antidiarrheal medication.57 main synthetic route used in production since 1969.3,60
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Figure 3. Metabolism of loperamide (1). (A) Major human phase I metabolites of loperamide and relative ion chromatogram peak intensities of
metabolites.68 Loperamide (20 μM) was incubated in NADPH-supplemented human liver microsomes. (B) Other reported minor metabolites.

Loperamide hydrochloride is synthesized convergently over six reagent 10 is reacted with 9 to form 11, which then undergoes
linear steps.3,60 As shown in Figure 1, 2 is subjected to a catalytic hydrogenation to afford the desired piperidine core
sequence of ring closing and ring opening steps to form 12. Intermediates 8 and 12 are then condensed to afford the
lactaminium bromide salt 8. This is accomplished over four loperamide free base 1. 1 is then transformed into a salt in the
synthetic steps, and the first transformation can be achieved via presence of hydrochloric acid and crystallized in isopropanol to
two different approaches. In the original disclosure, 2 is afford loperamide hydrochloride.3,60 Each distinct polymorph
hydrolyzed and subsequently cyclized in the presence of acetic as well as the tetrahedral crystalline form can be preferentially
acid and water to afford 5. Alternatively, more stable starting formed depending on the recrystallization conditions.3
material 3 can be reacted with 4 in the presence of sodium Loperamide hydrochloride is currently synthesized and
manufactured on an industrial scale.59


hydroxide to provide 5. The resulting lactone 5 is then opened
with HBr to give the alkyl halide 6. 6 is then cyclized over two
steps to produce the lactaminium bromide salt 8. The DRUG METABOLISM AND PHARMACOKINETICS
piperidine core of loperamide (Figure 2; 12) is synthesized Loperamide (Figure 3; 1) can be well absorbed in the GI tract;
over two steps starting from benzylpiperidone 9. Aryl Grignard however, its plasma concentration is usually very low due to
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rapid metabolism (Figure 3) and, as a result, poor ability to penetrate the BBB and induce morphine-like
pharmacokinetic properties (Table 4).3,7,61,62 Upon being euphoria that has led to its ongoing abuse.70


administered, loperamide is extensively metabolized in the liver
where it undergoes N-demethylation, hydroxylation, and/or PHARMACOLOGY
oxidative N-dealkylation (Figure 3).3,62−66 These metabolites
have been confirmed by independent groups using different Within in vitro binding assays, loperamide displays a potent
methods such as high-performance liquid chromatography- affinity for the human MOR (Ki = 3.3 nM), 50-fold more
atmospheric pressure ionization mass spectrometry analysis of potent than morphine with a longer duration of action.71−73 It
human excretion,63 in vivo radiolabeled studies in rat exhibits 15-fold selectivity over DOR (Ki = 48 nM) and 350-
models,3,64,66 and in vivo/in vitro LC-MS analysis of human fold selectivity over KOR (Ki = 1156 nM).71 [35S]GTPγS
and rat hepatocytes.62 A study consisting of in vivo and in vitro binding studies indicate the agonist character of loperamide on
analysis of human and rat hepatocytes suggests the most human MOR (EC50 = 56 nM).71 Moreover, loperamide
abundant loperamide metabolite is M3 (Figure 3A) and inhibited forskolin-stimulated cAMP accumulation (IC50 = 25
continued demethylation affords M7 (Figure 3B).62 It is nM) in human MOR transfected cells.71
unclear if both M3 and M7 are formed during first-pass Because of its poor systemic bioavailability, loperamide
metabolism or if M7 is formed during subsequent metabolism. mainly stimulates MORs at the large intestinal myenteric and
CYP3A4 and CYP2C8 have been implicated in playing a key submucosal plexi of the enteric wall at recommended
role in the demethylation process, whereas CYP2B6 and therapeutic doses (2−8 mg/day).40,61,62 This stimulation
CYP2D6 appear to only play a minor role.43 An in vivo analysis inhibits the release of acetylcholine and prostaglandins and
of human plasma and urine showed that M3 was the major results in decreased peristaltic activity, antisecretory activity,
metabolite and was detected in higher concentrations than and increased intestinal transit time.40,73 As a result, more
both M1 and M7 within urine samples.63 A study consisting of fluids and electrolytes can be absorbed.40,61,62,73 Loperamide
in vivo and in vitro analysis of human and rat hepatocytes has also been shown to affect many other receptors and signal
suggests another major metabolite of loperamide as being transmission pathways. For example, it modulates serotonin
hydroxylated metabolite M2.62 Other hydroxylated metabolites release and enteric 5-hydroxy-tryptamine (5-HT) release.73
of loperamide were also identified (Figure 3; M1 and M6). M1 Loperamide is a known antagonist of various calcium channels,
is believed to be converted into glucuronides.3,64,66 Approx- the NK2 receptors, and calmodulin as well.73 In recent years,
imately 15% of the administered dose is later metabolized into there have been a variety of reports on the analgesic effects of
glucuronides which are excreted in the bile.3,64,66 It is loperamide.15,17,42,74,75 Considering its lack of CNS pene-
noteworthy that minor metabolite M5 contains a potentially tration potential at the therapeutic dose, the use of loperamide
neurotoxic pyridinium cation moiety.3,64,66 Additionally, to manage pain could be beneficial compared to other
oxidative N-dealkylation of loperamide generates fragmented analgesics because of a lower potential of abuse while
metabolites M8 and M9, which are then excreted in both the displaying a higher MOR potency and longer duration of
urine and bile without any other effects.3,62−66 action.13,15,16,71−74,76,77 The studies conducted have adminis-
Within an aqueous environment, loperamide hydrochloride tered loperamide in a plethora of different methods, including,
begins to degrade through hydrolytic cleavage of the piperidine orally, intravenously, intrathecally, via spinal tap, and as a
connection to form M8 and M9, and/or is dehydrated to form topical ointment.13,15,74,78 When delivered intravenously to
pyridinium cation, M5.3 In vitro and in vivo DMPK studies mice, loperamide was shown to inhibit sodium channels to
have identified similar loperamide metabolites which are alleviate inflammatory hyperalgesia.13 On the other hand,
detailed in Figure 3A,B.3,62−67 inflammation became more severe and accelerated arthritis
The pharmacokinetics of loperamide has been studied in progression when applied as a topical ointment to Lewis rats.79


detail, but reports have varied significantly based on the dosage
and subject variability.61,62,65 A simplified PK profile of BEHAVIORAL PHARMACOLOGY
loperamide is discussed here (Table 4), and a more thorough
discussion can be found in the research conducted by Zamek- Loperamide lacks CNS activity at prescribed doses (2−8 mg/
Gliszczynski et al.61 Loperamide has an oral bioavailability (F) day) due to its poor systemic bioavailability, rapid metabolism,
of 4% with a clearance (CL) of 30 mL·min−1·kg−1 in Han and P-gp liability.3,7,61,62 However, at supratherapeutic doses
Wistar rat.61,62 In humans, oral bioavailability is much lower (70−400 mg/day) or in combination with P-glycoprotein
(%F = 0.3%).61 The free fraction of loperamide in rat plasma inhibitors, it can also cause opioid-like behavioral effects.9,40−43
(f ur) was reported to be 5.8% with a recovery rate of 95%, There are multiple reports that show the analgesic effects of
which signifies loperamide’s stability within plasma.3,64,66 As loperamide in animal models.13,15,16,71−74,76,77 A recent study
discussed above, the hepatic first-pass metabolism is the from Bartus and colleagues used the tight junction relaxing
primary source of major metabolites of loperamide.3,63−66,69 agent, Cereport, to increase brain levels of loperamide.75 In
The total plasma concentration (Cmax) after oral administration their studies, loperamide produced a significant analgesic effect
was reported to be 0.02 μΜ, resulting in a total plasma when animals were tested on a hot plate apparatus.75 However,
concentration unbound (Cu,max) of 1.2 nΜ.3,64,66 Although it is noteworthy that analgesic effects were only observed under
loperamide has a high volume of distribution (Vdss= 4 L/kg), extremely rigorous study conditions. People have also tried to
studies conducted with tritiated loperamide have shown that overdose on loperamide to achieve euphoric effects, but
loperamide and its metabolites are scarcely found within successful cases are very rare.9,41,67,80,81 This may be because
tissue.3,61,62,64,66 The half-life (t1/2) varies depending on the the loperamide misusers experienced dangerous side effects,
dose, 2 and 11.5 h for 5.1 μmol/kg and 10.1 μmol/kg, such as respiratory depression and paralytic ileus, before
respectively.62 The prolonged t1/2 of supratherapeutic doses of reaching sufficiently high levels of loperamide in the
loperamide is of the utmost concern when considering its brain.51,80,82
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ADVERSE EFFECTS AND DOSAGE Loperamide misuse at supratherapeutic doses (e.g., 50−300
The OTC antidiarrheal loperamide is readily available with or mg/day) can cause severe opioid poisoning symptoms such as
without a prescription in many different formulation types: respiratory depression as well as catastrophic cardiac
tablets, capsules, liquid forms, and orodispersible tablets.40 The abnormalities, including the QTc prolongation (≥500 ms)
recommended maximal dose does not exceed 8 mg/day and the QRS interval widening (≥120 ms).51 The American
without prescription or 16 mg/day with prescription.40,65,83 Association of Poison Control Centers (AAPCC) data indicate
The healthcare professional recommends 4 mg as a starting about a 7-fold increase in poison center calls related to
dose for acute diarrhea, followed by 2 mg dosing after each loperamide misuse from 2011 to 2015.86 Therefore, the FDA
unformed stool while keeping maximal daily dose (8 mg/day issued a safety alert about loperamide misuse on June 7,
or 16 mg/kg with prescription).83 However, loperamide is not 2016.11
recommended for children less than 2 years old, and the Table 2 shows an exemplary demographic profile of
suggested dose for chronic use is much lower (2 mg, twice a loperamide as well as other antidiarrheals reported in the
day).84 At the recommended therapeutic dose (2−8 mg/day), 2019 AAPCC report.52 In 2019, 1310 loperamide-related cases
effects of loperamide are restricted to periphery, especially the were mentioned. Among them, 902 cases were related to
gut (due to its P-gp liability (efflux ratio = 10.4)85 and low oral loperamide single exposure, and 56 reported cases were related
bioavailability (%F = 0.3%)86). At a therapeutic dose, the to either major medical issues or death. As shown in Table 2,
plasma concentration of loperamide remains <2 ng/mL.40 the potential risk from the abuse of loperamide could be higher
Thus, loperamide generally shows a wide margin of safety and compared to other antidiarrheals, and healthcare providers
a less potential for abuse at the recommended dose. should educate their patients of its potential risk at
Commonly reported adverse effects of loperamide both at supratherapeutic doses. Juurlink et al. studied 24 reported
therapeutic doses and supratherapeutic doses are listed in cases (published between 2014 and 2017) of loperamide-
Table 1.5,11,51,84,87 Minor adverse effects at therapeutic doses associated cardiac toxicity.41 Their case study showed that
patients came to the clinic with various symptoms (e.g.,
Table 1. Reported Side Effectsa of Loperamide presyncope, palpitations, loss of consciousness, recurrent
(1)5,11,51,84,87 syncope, dyspnea, presyncope, seizurelike activity, generalized
weakness, cardiac arrest, dyspnea, meiosis, vomiting, anxiety,
therapeutic doses supratherapeutic doses and chest tightness).41 Loperamide plasma concentration was
common minor serious side effects short-term very high (22−210 μg/L) in most of the cases. In some
side effects with long-term use overdoes long-term overdoes extreme cases, patients were reported to have taken 800 mg/
• constipation • toxic megacolon • stomach • severe day of loperamide for 18 months.7 Four of the twenty-four
discomfort cardiotoxicity patients died from overdosing.41
• dry mouth • paralytic ileus • vomiting • cardiac Interaction between loperamide and CYPs (especially,
arrhythmias
CYP2C8, CYP3A4), or P-gp inhibitors is well studied,41,67,70
• dizziness • angioedema • drowsiness • respiratory
depression and selected brand names of therapeutic agents that can
• tiredness • Stevens− • abdominal • central nervous interact with loperamide are listed in Table 3.53 As expected,
Johnsons pain system
syndrome depression Table 3. Potential Loperamide Interactors53
• headache • allergic reactions
• nausea brand name of potential interactors
a
The most commonly discussed side effects from publicly accessible • Tagamet HB • Eryc
Web sites are highlighted in bold. • Prevpac • Eryped
• Biaxin • Lopid
• Ery-Tab • Onmel
include constipation, dizziness, tiredness, headache, nausea,
• Sporanox • Nuedexta
and dry mouth. Patients can develop more severe side effects
• Zantac • Qualaquin
with long-term usage. These include toxic megacolon, paralytic
• Kaletra • Technivie
ileus, angioedema, Stevens-Johnsons syndrome, and allergic
• Norvir • Viekira Pak
reactions. Additionally, accidental overdose can cause vomit-
ing, drowsiness, abdominal pain, and stomach discomfort.

Table 2. Exposure Cases of Antidiarrheals Listed in the 2019 AAPCC Report52


reason for exposure medical outcome of human exposurec
no. of case no. of single treated in health
antidiarrheals mentionsa exposuresb care facility unintentional intentional none minor moderate major death
loperamide 1310 902 395 574 261 276 91 78 50 6
diphenoxylate and atropine 192 101 54 74 17 32 8 8 5 0
containing
non-narcotic containing 31 25 3 21 0 10 1 0 0 0
(excluding salicyl containing)
other narcotic containing 2 1 0 1 0 0 0 0 0 0
paregoric containing 3 3 3 2 1 0 0 0 1 0

a
The number of times the specific substance generic code was reported in any human exposure case. bThe number of human exposure cases that
identified only one substance. cThe rests are not counted due to no follow-ups and other reasons.

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Figure 4. SAR overview of loperamide in relation to MOR.

the aforementioned side effects of loperamide can also occur Table 4. In Vivo Pharmacokinetic Profile Comparison of
when users took loperamide with its interactors. Bowman et al. Loperamide (1) and Sila-loperamide (13) in Rat (Han
studied trends in the potential for loperamide misuse using Wistar Rats)62
available case studies.40 67% of reported loperamide misuse
cases examined are related to coadministration; yet, loper-
amide was a primary source of adverse effects. Studies have
shown that coadministration of loperamide interactors can
increase plasma concentration of loperamide up to 4.2 fold and
increase its t1/2 up to 36.9 h.88 Case reports published after
2014 indicate loperamide users are using other OTC
medications (such as antihistamines and/or cimetidine) to
elevate the exposure and effect of loperamide.40,52

■ STRUCTURE−ACTIVITY RELATIONSHIPS
Nearly 50 years after the discovery of loperamide, Sakamoto
and co-workers reported structure−activity relationship (SAR)
studies on the piperidine core of loperamide.3,89 To expedite
the SAR exploration process, the piperidine core was replaced
with a piperazine (Figure 4).89 Although this modification
resulted in a 10-fold loss in potency, they were able to quickly
generate various analogues using rather simple chemistry, such
as an SN2 reaction. Another study replaced the C4 carbon
atom with a silicon atom to generate a sila-loperamide
analogue that was shown to exhibit enhanced metabolic
stability and exhibited diminished BBB permeability (Table 4;
13).62 The resulting sila-loperamide analogue exhibited similar
PK properties yet was less prone to metabolism.62 Moreover, ring systems. Various substituents on the aryl group (Me-,
the sila-loperamide (13) exhibited lower BBB permeability, MeO-, OH-, F-, and Cl-) are well tolerated and reported to
suggesting that a carbon/silicon switch may be a viable option exhibit equivalent or better potency.89,91,92 In nearly every
for manipulating pharmacological properties and preventing instance, substitution at the 6-position provided more potent
abuse (Table 4).62 analogues than substitutions at the 7- or 8-positions (Figure
A computational docking study of loperamide suggests that 4).89,92 In some cases, substitution at the 6-position provided a
the basic nitrogen of the piperidine core (N1) may participate 20-fold increase in potency with good selectivity.92
in a charge−charge interaction with the Asp128 residue within Reported SAR studies of the left side of loperamide (N,N-
the binding pocket of hMOR.90 An in vitro study result with dimethyl-3,3-diphenylbutanamide component) are limited
loperamide N-oxide seems to support the claims of the docking (Figure 4). Changing the amide group into 1° or 2° amides
study; the loperamide N-oxide was not as active as resulted in a slight loss of potency.91 Replacing the amide with
loperamide.3,91 Deletion of the C4-OH is tolerated, resulting a carboxylic acid was 1000-fold less active, and complete
in potency similar to loperamide.89,91,92 The original patent for deletion of the amide group resulted in a 100-fold loss in
loperamide contained various structural alterations of the potency.91 Interestingly, replacement of the amide with a
piperidine core, including methyl substitutions, as well as methyl ester retained potency in some cases.91 SAR studies of
replacement of the C4-OH with a methyl group, all of which the gem-diphenyl moiety have not been reported to our
resulted in a dramatic loss of potency.60 knowledge.90 However, a docking study suggests the spatial
The most studied structural feature of loperamide is the right orientation of the diphenyl groups in relation to the amide
side of loperamide (chlorophenyl moiety), which has been group is responsible for the different binding modes of the
shown to tolerate many structural alterations (Figure 4).89,91,92 MOR and DOR binding pockets.90 Follow-up SAR studies
Such structural alterations include fused aromatic and pyridyl around this moiety are warranted.
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HISTORY AND IMPORTANCE IN NEUROSCIENCE Author Contributions


Loperamide was discovered in 1969 at Janssen Pharmaceutica C.A.M., C.W.L, and C.H. all researched and wrote sections of
as a potent MOR agonist and has gained a certain notoriety this review manuscript.
over the years. It has come to be known by many names: Funding
commercially available as Imodium, referenced in literature as We thank William K. Warren, Jr., and the William K. Warren
the “Poor man’s methadone”, and termed as “Lope” on social Foundation who funded the William K. Warren, Jr. Chair in
media.5,9,42,46−49 The use of loperamide as a means to Medicine (to C.W.L).
attenuate opioid withdrawal remains a topic of debate due to Notes
its cardiovascular toxicity and potential of physical dependence The authors declare no competing financial interest.
through repeated administrations.41,80,81,93,94 It was first
approved by the FDA as a schedule V narcotic drug but was
later removed from the controlled substance list and has since
■ ACKNOWLEDGMENTS
We thank Dr. Darren Engers, Dr. Aaron M. Bender, and Dr.
become an OTC available antidiarrheal medication.4−10 In Julie Engers for their help in the review process.


2016, loperamide was the single best-selling OTC drug in
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