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2018-04-16 07:00 by Karl Denninger
in Federal Government , 125 references Ignore this thread
FDA Reply To Comment Request
[Comments enabled]

Comment now folks; here is what I submitted. Comments close on April 23rd; get off your tush and do it today!

Please do not copy and paste this; "spam" comments are routinely ignored or rejected.  Instead, write your own.

"Marijuana" and its derivative products, in other words those derived from the plants of the genus Cannabis, should be de-scheduled under both United States and International drug conventions.

Their current scheduling under "Schedule I" in fact meets none of the criteria required for same.  These preparations are not "high" in abuse potential, they have known and recognized medical use, and an essentially-zero set of safety concerns, all of which are exactly the opposite of the criteria for such scheduling.

Known effective uses for these compounds include pain, various side effects of cancer treatments (including nausea, vomiting and appetite suppression), migrane headache and a number of seizure disorders, with the latter being especially potent in children with intractable epilepsy.  It is effective in reducing interocular pressure in glaucoma patients and there is evidence for effectiveness in several muscular-spasm and chronic inflammatory conditions, such as Crohn's disease.

In most of these cases the alternative therapies are ridiculously more expensive, less-effective or, in many cases, both.  Some alternative options, particularly for maladies involving pain, are extremely dangerous with severe addictive and overdose risks, such as the entire class of opioid compounds.  There is a developing body of evidence among marijuana-legal states that when marijuana is medically available opioid death rates fall to a significant degree. Ref: https://drugabuse.com/legalizing-marijuana-decreases-fatal-opiate-overdoses/

Marijuana and its derivatives are also demonstrably safer on a scientific basis than either tobacco or alcohol, both of which are regulated yet not scheduled.  While smoking any substance comes with risks to one's health it is not necessary to smoke marijuana to consume it since controlled heating of extracted oils and other concentrates, or the consumption of foods prepared with it, is equally effective in delivering the active compounds.  Unlike both nicotine and ethanol there is no known LD-50 associated with marijuana and its extracts. Finally, while any substance that can bring pleasure to the consumer can be psychologically habit forming marijuana and its compounds have no physical addictive properties, again in contrast with both nicotine and ethanol -- both of which are highly and moderately physically addictive, respectively.

De-scheduling marijuana and its related compounds will not remove the capacity of nation states to regulate production, import, export and distribution.  Indeed doing so will bring "into the light of day" the production, import, export and distribution of these compounds, making possible enforcement of purity standards, detection and punishment for those who adulterate these substances and dramatically increase the medical research opportunities for same.

Marijuana and its derivatives, in short, meet none of the criteria to be classified under the existing scheduling system either nationally or internationally.

De-scheduling is not only appropriate under the criteria published for same to not do so would be to continue a gross public fraud and injustice.

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