Letter to the FDA on Descheduling Cannabis – Ryan Boren

The FDA is accepting comments on descheduling cannabis until April 23rd.

The United Nations World Health Organization is due to review the current international classification of marijuana, THC, cannabidiol, and other related compounds and preparations this year. In the lead up, the WHO is asking member nations submit feedback, of which no nation is more influential than the United States.

Source: Take Action: FDA Seeking Comment On The International Scheduling Of Cannabis – NORML.org – Working to Reform Marijuana Laws

Here’s my comment.

Cannabis can replace shelves full of physically addictive pharmaceuticals. Benzos, if you get behind on a dose by even a couple hours, gnaw at you body and soul. Not so cannabis. Cannabis is kind and not possessive. A tolerance break requires no slow ramping down of doses, you just stop.

I’ve been in neurological wards where the talk is of cannabis. Every single one of my doctors has said they wish they could prescribe it to me. Parents of autistic kids and kids with seizures are blowing hash oil in their back yards so kids can get relief (or uprooting their families and heading to legal states). Picture this: white, middle-class, suburban families all over the country making hash oil in their backyards so that their kids and neighbors have medicine. Is that your image of cannabis users? Does that fit the biases inculcated in us by decades of racist and immoral messaging?

Cannabis is the least harmful way for we humans to cope with sentience, senescence, and mortality. Cannabis is popular in STEAM cultures, at least the ones I’ve inhabited. It is part of the process of living, creating, and coping. Neurodivergent people have long used it to regulate and cope in a world that does not accommodate. If your neurodivergence is accompanied by tics, seizures, paresthesia, fasciculations, panic, anxiety, sensory processing disorders, or self-harming stimming, as but a handful of examples, then cannabis is a tool and ally. There are as many human operating systems as there are humans. The endocannabinoid system is a useful interface to all of those operating systems, one for which we have a natural, easy-to-grow, non-physically addictive key. All humans and their mammalian kin share this interface and this plant. We plucky Prometheans figured out how to decarboxylate with fire.

The drug war preys on and abuses the different and the powerless. It puts marginalized kids in pipelines to prisons and foster systems where the incentives are to drug minds into compliance so that bodies can be more conveniently warehoused and souls more conveniently iced. It tears apart families so savagely that the effects are felt epigenetically. The great many of us using cannabis to medicate and regulate are under constant threat of violence, humiliation, and confinement in inhumane jails and prisons where we will be denied the medicine that works. The drug war’s perverse notions of addiction, addicts, and coping limit our vocabulary, stifle our empathy, and harm us all. The drug war and the zero tolerance and compliance cultures born of it are enemies of neurodiversity and disability and all marginalized people.

Cannabis is a neuroprotectant and powerful harm reducer that is friendly to neurodivergence and the human condition. It is the safest active ingredient in humanity’s medicine cabinet, yet we shame and punish its use. The reasons cannabis is schedule 1 are racist and without science. “According to a comprehensive review by the United States National Academy of Sciences, cannabis’ dependence liability is similar to that of caffeine (7 percent) or anxiolytics (9 percent), and is far lower than the dependence liability associated with other substances like alcohol (15 percent) and tobacco (32 percent).

We have taken what is arguably one of nature’s (or God’s, if you’re so inclined) greatest gifts to humanity and reduced it to a way to put souls under carceral control.

See also,

Using data on all prescriptions filled by Medicare Part D enrollees from 2010 to 2013, we found that the use of prescription drugs for which marijuana could serve as a clinical alternative fell significantly, once a medical marijuana law was implemented. National overall reductions in Medicare program and enrollee spending when states implemented medical marijuana laws were estimated to be $165.2 million per year in 2013. The availability of medical marijuana has a significant effect on prescribing patterns and spending in Medicare Part D.

Source: Medical Marijuana Laws Reduce Prescription Medication Use In Medicare Part D

The researchers found that in states with medical marijuana laws on the books, the number of prescriptions dropped for drugs to treat anxiety, depression, nausea, pain, psychosis, seizures, sleep disorders and spasticity. Those are all conditions for which marijuana is sometimes recommended.

If the trend bears out, it could have other public health ramifications. In states that legalized medical uses of marijuana, painkiller prescriptions dropped – on average, the study found, by about 1,800 daily doses filled each year per doctor. That tracks with other research on the subject.

Marijuana is unlike other drugs, such as opioids, overdoses of which can be fatal, said Deepak D’Souza, a professor of psychiatry at Yale School of Medicine, who has researched marijuana. “That doesn’t happen with marijuana,” he added.

Source: After Medical Marijuana Legalized, Medicare Prescriptions Drop For Many Drugs : Shots – Health News : NPR

A 2002 review of seven separate studies involving 7,934 drivers reported, “Crash culpability studies have failed to demonstrate that drivers with cannabinoids in the blood are significantly more likely than drug-free drivers to be culpable in road crashes.” This result is likely because subject under the influence of marijuana are aware of their impairment and compensate for it accordingly, such as by slowing down and by focusing their attention when they know a response will be required. This reaction is just the opposite of that exhibited by drivers under the influence of alcohol, who tend to drive in a more risky manner proportional to their intoxication.

Today, a large body of research exists exploring the impact of marijuana on psychomotor skills and actual driving performance. This research consists of driving simulator studies, on-road performance studies, crash culpability studies, and summary reviews of the existing evidence. To date, the result of this research is fairly consistent: Marijuana has a measurable yet relatively mild effect on psychomotor skills, yet it does not appear to play a significant role in vehicle crashes, particularly when compared to alcohol. Below is a summary of some of the existing data.

The results to date of crash culpability studies have failed to demonstrate that drivers with cannabinoids in the blood are significantly more likely than drug-free drivers to be culpable in road crashes.

“Cannabis leads to a more cautious style of driving, but it has a negative impact on decision time and trajectory. However, this in itself does not mean that drivers under the influence of cannabis represent a traffic safety risk. … Cannabis alone, particularly in low doses, has little effect on the skills involved in automobile driving.”

1. There is no evidence that consumption of cannabis alone increases the risk of culpability for traffic crash fatalities or injuries for which hospitalization occurs, and may reduce those risks.

In contrast to the compensatory behavior exhibited by subjects under marijuana treatment, subjects who have received alcohol tend to drive in a more risky manner. Both substances impair performance; however, the more cautious behavior of subjects who have received marijuana decreases the impact of the drug on performance, whereas the opposite holds true for alcohol.”

Evidence from the present and previous studies strongly suggests that alcohol encourages risky driving whereas THC encourages greater caution, at least in experiments. Another way THC seems to differ qualitatively from many other drugs is that the formers users seem better able to compensate for its adverse effects while driving under the influence.”

Source: Marijuana and Driving: A Review of the Scientific Evidence – NORML.org – Working to Reform Marijuana Laws

The reduced rate of opioid-related fatalities translated into about 1,700 fewer deaths in 2010 alone. The researchers suggest several possible explanations for this effect. “Patients with chronic noncancer pain who would have otherwise initiated opioid analgesics may choose medical cannabis instead,” Bachhuber et al. write. “In addition, patients already receiving opioid analgesics who start medical cannabis treatment may experience improved analgesia and decrease their opioid dose, thus potentially decreasing their dose-dependent risk of overdose. Finally, if medical cannabis laws lead to decreases in polypharmacy-particularly with benzodiazepines-in people taking opioid analgesics, overdose risk would be decreased.”

That last possibility could be more significant than you might think, since opioid-related deaths typically involve mixtures with other drugs, with benzodiazepines playing a substantial and increasing role. Bradford and Bradford found that medical marijuana laws were associated with decreases in prescriptions for drugs used to treat anxiety and sleep disorders. Benzodiazepines are commonly used for both purposes.

“We find fairly strong evidence…that states providing legal access to marijuana through dispensaries experience lower treatment admissions for addiction to pain medications,” Powell et al. write. “We provide complementary evidence that dispensary provisions also reduced deaths due to opioid overdoses….Our findings suggest that providing broader access to medical marijuana may have the potential benefit of reducing abuse of highly addictive painkillers.” Like Bachhuber et al., they found that the longer medical marijuana was legally available, the bigger the apparent benefit.

Source: Medical Marijuana Replaces More Dangerous Drugs – Reason.com

“The Silk Road website was in many respects the most responsible such marketplace in history, and consciously and deliberately included recognized harm reduction measures, including access to physician counseling,” he wrote. “Transactions on the Silk Road website were significantly safer than traditional illegal drug purchases and included quality control and accountability features” that kept purchasers “substantially safer” than regular drug purchases.

Many reformers, myself included, have long been highlighting the forward-thinking benefits of Silk Road and the ways it began to slowly revolutionize drug sales around the world. For instance, it provided a platform that could allow indigenous growers and cultivators around the world to sell directly to the consumer, potentially reducing cartel participation and violence… None of the transactions on Silk Road, for instance, resulted in women drug buyers being sexually assaulted or forced to trade sex for drugs, as is common in street-level drug transactions. Nor did any Silk Road transactions result in anyone having a gun pulled on them at the moment of purchase.

In his declaration, Caudevilla testifies that the site “espoused a harm reduction ethos which was reflected in the individual buyer-seller transactions on the site and in the community created on the site’s forums.” That community “enabled some site participants to reduce, if not entirely eliminate, their drug use.”

Caudevilla participated on the Silk Road forums for seven months and states that he “never came across even a single report of a Silk Road-related drug overdose.” Ulbricht’s lawyers point to the lack of such a “report” as a telling fact, although one wonders which section a user who had overdosed was expected to post in.

Source: Ulbricht’s lawyer: Silk Road was “the most responsible” drug market in history | Ars Technica

Source: Letter to the FDA on Descheduling Cannabis – Ryan Boren

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google+ photo

You are commenting using your Google+ account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

This site uses Akismet to reduce spam. Learn how your comment data is processed.