Category Archives: Uncategorized

The Most Misunderstood Plant

Cannabis must be the most misunderstood plant on the face of the planet.  Even among it’s supporters there is a great deal of misunderstanding.

It’s detractors would have you believe that the plant or it’s use is at it’s worst akin to being in league with the devil himself.  Among the many things it is said to have caused is Rape, Murder, Child Abuse, Mental Illness, among a slew of medical ailments.

It’s proponents are generally falling into one of three camps.   Industrial Hemp,  Medical Marijuana, and Recreational Marijuana.  While each of the groups would like to see the other succeed in their actions many times they oppose each other when they shouldn’t be.

The problem comes from a single chemical found in the Cannabis Plant  THC.  THC is the active psychoactive chemical associated with the high that people get from ingesting or smoking the plant or it’s extracts.  THC is a drug that has been made synthetically pure in a pill or liquid form, is FDA approved, and is available from the pharmacy for certain medical conditions.  The DEA doesn’t even really track how much THC is made or used in the US, it’s a low schedule drug.  However when it comes to the plant well it’s a totally different situation.

So what’s the problem.  Hemp proponents would have you believe that Cannabis with a THC content below a certain percentage is “Hemp” and not Marijuana.  They believe that by reducing the THC content of the plant to a point that it isn’t desirable for medical or recreational purposes that they will be able to grow the plant and use if for it’s industrial purposes.  They hope that this will allow the mass cultivation of Cannabis across the United States and world.

While it’s true that Cannabis can be breed to have a low THC content, it’s the fiber and other parts of the plant including the tops that contain the multi-level value that farmers need to succeed with the crop.  Fiber content can be breed into the plant just as THC can be breed out, but no one knows if the fiber is being affected by the concentration on THC content.  Look at it this way, Breeders of plants for cultivation do not look at the chemical makeup of the plant they look at what it is their customers want.  In the case of Cannabis there are customers for all parts of the plant from it’s fiber to it’s various Cannabinoids.

Cannabis is a unique plant.  You can grow Cannabis in a manner similar to how industrial Cannabis is grown and produce not only high quality fiber, hurds, but also the top itself for medical and recreational purposes.  Looking at a field of Cannabis you can not determine if it is low THC Cannabis or High THC Cannabis.  It’s simply not possible.   So the THC content of the field only is important to law enforcement.  This would be absurd if applied to other crops.  There is no evidence that the THC content of Cannabis produces anything better than any other variety of Cannabis.

There is no reason to breed out the THC from Cannabis for the crop to be successful.  Actually the cultivation of large quantities of low THC Cannabis near medical or recreational Cannabis will result in crossbreeding.  This crossbreeding will result in seed stock of each grower that has a THC content different from that of it’s original plants and presents all kinds of problems.

There is no reason, other than political, to regulate the amount of THC that can be produced by a Cannabis plant to determine it’s use.  Cannabis is Cannabis, while there might be varietal differences just as there is with all other crops and plants, doesn’t change the fact that it is still Cannabis.

For government to set an arbitrary limit on the THC content for it to be “Industrial Hemp” is insanity at it’s finest.   For proponents of the use of Cannabis for it’s industrial applications to allow this is even more insane.  It’s not known how THC interacts with the fiber quality, quantity and other factors of the plants ability to survive diseases.  For THC to be used as something that needs to be controlled is simply not going to work in the long run.

It’s time for Industrial Cannabis people to stop hiding behind the word Hemp and make any attempt to discriminate themselves into legalization.  I say this from being an Industrial Hemp Advocate.  For years I focused on it’s industrial applications.  When pushed I said it’s possible to breed out THC and that many countries had, but it wasn’t necessary.  It gave me an opportunity but the opportunity has been used and worked.  I personally talked more about Industrial use than even Medical use.  Now, Cannabis is Cannabis, is Cannabis you simply can’t have one without the other as they are so inter-related that the more we discover the more we may regret allowing low THC Cannabis to be something different than the Medical and Recreationally used Cannabis.

 

 

FAA releases Documents About Cannabis

It came to light recently, via an article by Tom Angell “The Obscure 45-Year-Old-Law Exempts State-Legal Marijuana” ,  that the FAA (Federal Aviation Administration) had a rule regarding Cannabis.

The Rule authorizes the transportation of Cannabis when authorized by the State or Federal government.

Sec. 91.19 — Carriage of narcotic drugs, marihuana, and depressant or stimulant drugs or substances.

(a) Except as provided in paragraph (b) of this section, no person may operate a civil aircraft within the United States with knowledge that narcotic drugs, marihuana, and depressant or stimulant drugs or substances as defined in Federal or State statutes are carried in the aircraft.

(b) Paragraph (a) of this section does not apply to any carriage of narcotic drugs, marihuana, and depressant or stimulant drugs or substances authorized by or under any Federal or State statute or by any Federal or State agency.

This article sent us on a document hunt with the FAA.  We wanted to see why the FAA made this rule change.

It appears from the documents revealed that the FAA had a regulation which made it a violation to transport against Federal Law and between the US and Mexico.  They wanted to update the regulation to include those that violated a state law as well.  The purpose was to be able to remove licenses of those convicted of federal or state law.

However the way it ended up, the wording is clear that State Legal Cannabis is EXEMPT from Federal Aviation Regulations.  It makes sense that they allowed this change too.  If a State Law Agency needed to transport something via Air it needs to be allowed.  However they didn’t include that provision in the regulation.  This leaves open the legal door to legally be allowed to transport cannabis so long as your following state laws, and if you are your EXEMPT from federal law.

You can view the original filing and final rule change announcements made in the Federal Register back in 1973 in our FOIA documents section, specifically the FAA page.

DEA has 5 Importers and 3 Manufacturers of Cannabis in the US

According to information just released under FOIA there are only 5 importers and 3 “manufacturers” of Cannabis in the US.  Under the Freedom Of Information Act we just obtained a listing of the current importers and manufacturers of Cannabis that are licensed with the DEA.

The importers are Minnesota Depart of Ag, North Carolina Depart of Ag, PA Department of Ag, Washing State Department of Ag and Palomo Farms of North Carolina.  These people are most likely importing seed for use in the test plantings of Cannabis for Hemp Stalk production.

The three Manufacturers are Natl Ctr Natural Products Research, Catalent Pharma Solutions and Synthcon LLC.

Catalent puts it’s self as a “provider of drug delivery technology and development solutions for drugs, biologics and consumer health products.”  From their website information it appears they are actively looking at delivery methods for cannabinoids.

Synthcon appears to be a company that “develops and manufactures innovative medical devices“.  There isn’t much more information available about the company.

Natl Ctr Natural Products Research, is the University of Mississippi Farm.

 

DEA Information Removed From Site

Back in January ASA filed a suit against the DEA about information that was on the Public Website for the DEA that was faulty.  The DEA removed information from the site.

We were interested in what did the DEA remove from it’s website.  We filed a FOIA request with them and received a response.  In the response it appears the DEA has only removed two documents from it’s website.  The total content of materials removed constitute about 17 pages mostly dealing with Medical Cannabis.

The Documents they released are here at this link 17-00351-F documents

While this is a small victory it could lead to additional victories against other agencies which use essentially the same information on their sites.

If you would like to see the other information we have collected from the DEA and other agencies check this link – DEA FOIA

DEA Releases Legal Cannabis Import Data

The DEA today replied to our FOIA request for information on Legal Cannabis Seed imports into the US in the last 20 years.  While they weren’t able to supply some information as it was contained on a “retired” PC, they did supply information since 2010 and the numbers are amazing.

The clear trend has been a dramatic increase throughout the last 7 years.  It is assumed that this is Cannabis Seed that is being imported for hemp production but it will take further investigation to determine who is importing what.  Unfortunately the DEA doesn’t keep track of the difference between Cannabis Seed Imports and other forms of Cannabis.

The numbers are clear, yet muddied and we are seeking clarification but it appears that they are counting Grams in the report. (*EDIT 03-30-2017 – DEA confirms the weight unit is Grams** )

In 2010 it appears must be the year in which the switch was made from the old retired PC to the new system, so taking the low of 18,000 grams  (roughly 33 lbs) in 2011 and the high of almost 60 million grams (131,825 lbs) in 2016 the growth in imports is on a steady increase year over year.

The full FOIA can be found on our DEA FOIA page or this link 17-00256-F (DET)

 

DEA says Inhaled is Better

Today the DEA announced that they have a new FDA approved form of THC called Syndros.  Syndros is the result of work of Insys Therapeutics to create a new oral THC that has 5mg per ML of solution. – FEDERAL REGISTER LINK

In the DEA’s findings they are planning to schedule this as a Schedule II drug because.

Dronabinol is a generic name for the (-) delta-9-trans isomer of tetrahydrocannabinol (THC). THC is the primary psychoactive substance in marijuana. Dronabinol is the active pharmaceutical ingredient in Syndros. As stated by HHS, Marinol (synthetic dronabinol in sesame oil and encapsulated in a soft gelatin capsule) was approved by the FDA for medical use on May 31, 1985 and placed in schedule II based on its accepted medical use and high abuse potential. On July 2, 1999, Marinol was rescheduled from schedule II to schedule III because of the findings of the DEA that the difficulty of separating dronabinol from the sesame oil formulation and the delayed onset of behavioral effects due to oral route administration supported a lower abuse potential of Marinol as compared to substances in Schedule II. 64 FR 35928.

Going on to state:

HHS indicated that the formulation of Syndros (oral solution) is easier to abuse than Marinol because this liquid formulation can be manipulated to produce concentrated extracts of dronabinol for abuse by inhalation (smoking or vaping) or through other routes of administration. Because of the large amount of dronabinol in Syndros oral solution it has a greater potential for extraction than Marinol and thus has a greater abuse potential.

Based on the use of Cannabis by the general public DEA feels that this form of THC needs to be a Schedule II drug.

What you find when reading further down is that it appears DEA would rather people smoke it because of the onset of effects are easier to control.

Oral consumption of dronabinol, compared to inhaled THC, may result in psychoactive effects that are delayed and stronger with an increased risk of experiencing serious adverse events.

But then they quickly add:

When dronabinol (THC) is smoked, the drug rapidly reaches the brain and psychoactive effects are felt within minutes of inhalation, which allows the subject to control the dose more readily.

The DEA is full of contradictory things but this just about takes the cake.  Using a substance via oral methods pose issues that smoking or inhalation don’t and is better at controlling the dose.  However they are afraid that people will do just that.  Take this new drug and turn it into something they can control the dose better.

There is a time that this potential rule can be commented on, see the link at the top of the page to the federal register.

Congressional Research Service Report on Cannabis

On March 10th the Congressional Research Service released it’s report on “The Marijuana Policy Gap and the Path Forward”

“Given the current marijuana policy gap between the federal government and many of the states, there are a number of issues that Congress may address. These include, but are not limited to, issues surrounding availability of financial services for marijuana businesses, federal tax treatment, oversight of federal law enforcement, allowance of states to implement medical marijuana laws and involvement of federal health care workers, and consideration of marijuana as a Schedule I drug under the CSA. The marijuana policy gap has widened each year for some time. It has only been a few years since states began to legalize recreational marijuana, but over 20 years since they began to legalize medical marijuana. In addressing state – level legalization efforts and considering marijuana’s current placement on Schedule I, Congress could take one of several routes. It could elect to take no action, thereby upholding the federal government’s current marijuana policy. It may also decide that the CSA must be enforced in states and not allow them to implement conflicting laws on marijuana. Alternatively, Congress could choose to reevaluate marijuana’s placement as a Schedule I controlled substance.”

Here is the document – R44782

And a link to the CRS report

World Health Organization to Review Cannabis

It is going largely unknown, unreported and ignored that the World Health Organization (WHO) the arm of the UN that controls the schedule of substances is looking at Cannabis.

As part of the UN the US and the FDA is looking for input from people and organizations about the changes and surprisingly no one is commenting.  The comment period ends Feb 10th at midnight eastern time and so far they have gotten 3 comments.

https://www.regulations.gov/docket?D=FDA-2016-N-4619

3 comments, that is really pretty sad considering a change in the scheduling of Cannabis on an international level could lead to changes in scheduling on a federal level here in the US.

The United States is also a party to the 1961 Single Convention on Narcotic Drugs (1961 Single Convention). The Secretary of State has received a notification from the Secretary-General regarding two substances to be considered for control under this convention. The CSA does not require HHS to publish a summary of such information in the Federal Register. Nevertheless, in an effort to provide interested and affected persons an opportunity to submit comments regarding the WHO recommendations for narcotic drugs, the notification regarding these substances is also included in this Federal Register notice. The comments will be shared with other relevant Agencies to assist the Secretary of State in formulating the position of the United States on the control of these substances. The HHS recommendations are not binding on the representative of the United States in discussions and negotiations relating to the proposal regarding control of substances under the 1961 Single Convention.

Of the substances being considered

The Committee recommended that a specific ECDD meeting dedicated to cannabis and its component substances should be held within the next eighteen months from the 38th meeting, and will carry out pre-reviews for the following substances:

—Cannabis plant and cannabis resin;

—Extracts and tinctures of cannabis;

—Delta-9-tetrahydrocannabinol (THC);

—Cannabidiol (CBD);

—Stereoisomers of THC.

The recommendations and the assessments and findings on which they are based are set out in detail in the Report of the 38th Expert Committee on Drug Dependence, which is the Committee that advises me on these issues. An extract of the Committee’s Report is attached in Annex 1 to this letter.

 

Here is a copy of the WHO Review Report – WHO-cannabis-report

 

 

VA releases Medical Cannabis Report

If anyone has been watching the VA website they had a report about the medical use of Cannabis for Pain and PTSD.  The document has not been available for the public but through the power of the Freedom of Information Act we were able to get a copy.

This 124 page, well researched document is probably one of the most extensive looks at Cannabis done by a Government agency.  It not only looks at the use of Cannabis for Pain and PTSD but also looks at the harms of Cannabis use.

While they didn’t find much quality research on the medical use of Cannabis for Pain or PTSD they did find a lot of information.  The research they cite from all kinds of sources indicate that the lack of research is limiting their ability to make quality decisions on Cannabis for Medicine or Safety.

CONCLUSIONS

Although cannabis is increasingly available for medical and recreational use, there is very little methodologically rigorous evidence examining its effects in patients with chronic pain or PTSD. There is limited evidence that cannabis may be helpful in improving pain and spasticity in selected populations with MS, but there is insufficient evidence in other populations. There is insufficient evidence examining the effects of cannabis in PTSD populations. Cannabis is associated with an increased risk of short-term adverse effects, but data on its effects on long- term physical health vary; harms in older patients or those with multiple comorbidities have not been studied. Cannabis has been associated with short-term cognitive impairment and potentially serious mental health adverse effects such as psychotic symptoms, though the absolute risk and application specifically to chronic pain and PTSD populations are uncertain.

You can get the entire document here at this link – Benefits and harms of cannabis in chronic pain or post traumatic stree disorder

DEA/DOJ not the Problem

I’m sorry but the DEA/DOJ are not the problem with Cannabis legalization on a federal level or even Scheduling of Cannabis.  The real problem is with HHS, FDA, NIDA and other “Medical” organizations that continue to feed DEA/DOJ faulty information.

While I’m not going to say that the DEA doesn’t want to have Cannabis in Schedule I for ease of prosecution, they are not to blame for failed Petitions.  The problem is in the petition process.  First the DEA is required to ask the FDA, NIH for a recommendation.  Well they both ask NIDA to give them the information and everyone knows that NIDA is opposed to Cannabis.

NIDA provides FDA and NIH with information about Cannabis and all it’s “Hazards”.  Rather than do a real investigation like it’s own PubMed and other resources it barfs up NIDA information and gives it to the DEA.

DEA then takes that information and says sorry not going to change anything.

There is also the fact that the petitions in the past 6-7 years have been faulty in their filing and haven’t been really challenged in court.

HIA has offered DEA resistance and met with success.  ASA is currently suing the DEA for it’s compliance with the little known “INFORMATION QUALITY ACT”.  This requires agencies to provide Quality Information when they give it out.  Frankly NIH, NIDA and any other agency that has information opposing Cannabis should be challenged.

If your not following on social media NIH, FDA, and NIDA then you should be:

FDA https://www.facebook.com/FDA/

NIDA https://www.facebook.com/NIDANIH/

NIH https://www.facebook.com/nih.gov/

USDA https://www.facebook.com/USDA/