They’re at it again, which is probably a good thing. The FDA is again seeking comments concerning cannabis like it did last May. This time, it’s looking at five categories (abuse potential, actual abuse, medical usefulness, trafficking, and impact of scheduling changes on availability for medical use) regarding 16 substances, including cannabis. Addressing only herbal cannabis and its extracts, the Ohio Rights Group responded with quotes from scientific studies. What follows is a summary:

Abuse potential:

Cannabis has a lower risk of dependence. “… the experience of dependence on marijuana tends to be less severe than that observed with cocaine, opiates, and alcohol … the severity of the associated consequences is not as extreme.” Addiction & Clinical Practice, 2007.

Cannabis is non-toxic and does not cause fatal overdose.  “… cannabinoids have minimal toxicity and present no risk of lethal overdose.” Clinical Journal of Pain, 2012.

Cannabis is not a ‘gateway drug.’ “There is no conclusive evidence that the drug effects of marijuana are causally linked to the subsequent abuse of other illicit drugs.” Institute  of Medicine, 1999. 

Actual abuse:

Cannabis is abuse statistically overstated. “It was used by 80.6 percent of current illicit drug users.” National Survey on Drug Use and Health, 2014.

Note: When coined “illicit,” marijuana’ s abuse potential is overstated, given that thirty states have legalized it in some form. In those jurisdictions, cannabis is legal.

Cannabis use in moderation is not problematic.  “… our findings advocate that regular use of small amounts of cannabis does not appear to increase an individual’s likelihood of experiencing problems.” Addiction Research, 2014.

Medical usefulness:

Cannabis has many uses. “Cannabis preparations exert numerous therapeutic effects. They have antispastic, analgesic, antiemetic, neuroprotective, and anti-inflammatory actions, and are effective against certain psychiatric diseases.” Deutsch Arzteblatt International, 2012.

Cannabis science and potential therapies are expanding exponentially. “… the steady growth in the number of indications for the potential therapeutic use of cannabinoid-related medications, is a clear sign of the emerging importance of this field.” Pharmacological Reviews, 2006.

Note: A June 2010 search of Pubmed.gov produced ~12,000 “cannabinoid” citations; as of October 2018, that number had risen to 24,152.

Cannabis treatments have conclusive or substantial evidence. “We found conclusive or substantial evidence … for benefit from cannabis or cannabinoids for chronic pain, chemotherapy-induced nausea and vomiting, and patient-reported symptoms of spasticity associated with multiple sclerosis.” National Academies of Sciences, Engineering and Medicine, 2017.

Cannabis can help alleviate the opioid crisis. “… medical cannabis laws were associated with a mean 24.8% lower annual rate of opioid analgesic overdose deaths.” JAMA Internal Medicine, 2014.

Note: The CDC reported 72,000 deaths from overdose in 2017, almost 30,000 from opiates. Simply, access to cannabis could have saved 7,500 lives. 

Trafficking:

Cannabis trafficking gives way to legalization. “… people don’t need to buy illegal marijuana anymore so drug trafficking organisations (DTOs) have far fewer customers … As revenues decrease, so does the incentive to invest in violent activity.” Independent[MJB1] , 2018.

Cannabis trafficking declines under legalization. “… marijuana seizures along the southwest border tumbled to their lowest level in at least a decade.” The Washington Post, 2016.

Cannabis trafficking offenders decrease. “The number of marijuana offenders has decreased by 43.2% from the 4,768 offenders in fiscal year 2013.” United States Sentencing Commission, 2018.

Note: With medical cannabis legal in 30 states and with eight states legalizing recreational use, arrests for trafficking in marijuana are bound to decrease.

Cannabis businesses do not attract crime. “… MML [medical marijuana legalization] is not predictive of higher crime rates and may be related to reductions in rates of homicide and assault. PLOS One, 2014.

Impact of scheduling changes on availability for medical use of cannabis:

Cannabis placed in Schedule I without scientific evidence. “… the US Congress had failed to follow its usual review process dictated by the Controlled Substances Act that requires scientific evaluation and testimony before legislative action. It declared cannabis illegal in the absence of such evidence.15” Mayo Clinic Proceedings, 2012.

Cannabis research encounters numerous obstacles “… an alphabet soup of federal agencies with divergent missions creates a series of potential barriers because several have the power to veto proposed initiatives.105 Any one of these agencies has the power to halt an initiative in its tracks.15” Mayo Clinic Proceedings, 2012.

Cannabis research gaps will be filled. “… the committee has identified [that thirteen ] research gaps exist concerning the effectiveness of cannabidiol or cannabidiol enriched cannabis …” National Academies of Sciences, Engineering and Medicine, 2017.

FDA will be considering comments for its response to the World Health Organization. In 2017, the WHO wisely concluded that CBD “does not appear to have abuse potential or cause harm. As such, as CBD is not currently a scheduled substance in its own right (only as a component of cannabis extracts), current information does not justify a change in this scheduling position and does not justify scheduling of the substance.” Perhaps the WHO has something to teach the FDA.  

 [MJB1]