International Drug Scheduling; Convention on Psychotropic Substances; Single Convention on Narcotic Drugs; ADB-FUBINACA; ADB-CHMINACA; Cyclopropyl Fentanyl; Methoxyacetyl Fentanyl; para-Fluoro Butyrfentanyl; Tramadol; Pregabalin; Cannabis Plant and Resin; and 8 additional substances; Request for Comments
International Drug Scheduling Convention on Psychotropic Substances Single Convention on Narcotic Drugs ADB-FUBINACA ADB-CHMINACA Cyclopropyl Fentanyl Methoxyacetyl Fentanyl para-Fluoro Butyrfentanyl Tramadol Pregabalin Cannabis Plant and Resin FRDTS# 2018-820 CDER James R. Hunter OPEN
2018-10-29 2018-10-29 2018-10-29 2018-10-29 2018-10-29 2018-10-29 2018-10-29 2018-10-29 2018-10-29 2018-10-29
FDA-2018-N-3685-4850 FDA-2018-N-3685-4879 FDA-2018-N-3685-4818 FDA-2018-N-3685-4886 FDA-2018-N-3685-4984 FDA-2018-N-3685-5016 FDA-2018-N-3685-5064 FDA-2018-N-3685-5068 FDA-2018-N-3685-5072 FDA-2018-N-3685-5028
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https://api.regulations.gov/v4/comments/FDA-2018-N-3685-4850 https://api.regulations.gov/v4/comments/FDA-2018-N-3685-4879 https://api.regulations.gov/v4/comments/FDA-2018-N-3685-4818 https://api.regulations.gov/v4/comments/FDA-2018-N-3685-4886 https://api.regulations.gov/v4/comments/FDA-2018-N-3685-4984 https://api.regulations.gov/v4/comments/FDA-2018-N-3685-5016 https://api.regulations.gov/v4/comments/FDA-2018-N-3685-5064 https://api.regulations.gov/v4/comments/FDA-2018-N-3685-5068 https://api.regulations.gov/v4/comments/FDA-2018-N-3685-5072 https://api.regulations.gov/v4/comments/FDA-2018-N-3685-5028
Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous
Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous
Please rethink your stance on medical cannabis. I truly believe in the healing power of a patients right to choose their medicine and more natural is better. I benefit from medical marijuana in my state of Pa. I have overcome opioid addiction and chronic pain and depression issues. Knowing that no matter what medical problems I have in my future, having access to medical marijuana is enough to help me with my pain and anxiety and depression. In regards to Cannabis Plant and Resin, I believe that anything less than full legalization is criminal.  It makes criminals of decent citizens, and it drives the plant to an unregulated black market.  With medical legalization prevalent, with growing consensus worldwide that the war on drugs is causing more harm than good, and finally with full legalization approved in Canada I believe that  the United States and the world should follow.  In doing so forgive the sentences of  past and current non-violent cannabis offenders and expunge their cannabis related records.  Finally, apologize for the destruction that the war on drugs has caused.As for the others on this list.  I recommend personalized treatment for substance abuse.  Follow Portugals lead and give help to those afflicted, not a criminal record!May this world come together in peace.  For we are far too divided. Yes marijuana should be legalized or at the very least not be a schedule 1 drug. Alcohol is terrible, give people a chance to relax with a nice calming drug that you basically cant OD on. Reap the benefits of the tax money while creating a completely new Billion dollar industry.  Cannabis is a medicinal herb that is well documented through history and is crucial to treating my glioblastoma that is predicted to kill me in six months if I cant access the herb. Classifying it as a schedule I drug is an abrogation of science, and criminalizing access and research is a crime against humanity. The only rational classification for the herb and its natural derivatives is none at all. Pharmaceutical derivatives introduce side effects, greatly increase cost, and significantly diminish the healing effect of the natural plant. Yes, marijuana should be legalized.  This will also accelerate research into the healing properties of the plant, which could lead to more uses for the different plant.  Legality aside, schedule reduction for Cannabis Plant and Resin is more than warranted.THC has a physically unreachable toxicity threshold, and causes no immediate threat to health. Alcohol, a legal and controlled substance, has a toxicity threshold among the lowest of all substances; the CDC reports During 20102012, an annual average of 2,221 alcohol poisoning deaths (8.8 deaths per 1 million population) occurred among persons aged 15 years in the United States. which makes it one of the leading causes of preventable deaths in the United States for that time frame. Comparatively, cannabis use has caused 0 toxicity related deaths in not only the same time frame, but all of recorded history.https://www.cdc.gov/mmwr/preview/mmwrhtml/mm6353a2.htmCDC reports pertaining to other drugs currently on the same schedule, and drug overdoses in general:During July 2016June 2017, among 11,045 opioid overdose deaths, 2,275 (20.6%) decedents tested positive for any fentanyl analog, and 1,236 (11.2%) tested positive for carfentanil. Fourteen different fentanyl analogs were detected.https://www.cdc.gov/mmwr/volumes/67/wr/mm6727a4.htmIn 2016, there were more than 63,600 drug overdose deaths in the United States. Factually, none of these were caused by the consumption of cannabis. Thats 63,600 Americans who died in one year because they consumed too much alcohol, or too much of any other drug. 0 Americans have ever died as a direct result of consuming too much cannabis.https://www.cdc.gov/nchs/products/databriefs/db294.htmSetting aside arguments which could be made for recreational legalization at a federal level, and for the theraputic effects of other non-psychoactive substances (such as CBD, cannabinoids, and terpenes; anything not THC) that are present in cannabis, its plain to see that the drug is not dangerous enough to remain on the Schedule 1 controlled substances list.If the FDA truly has the American Publics best interests at heart, then cannabis will be removed from the schedule 1 controlled substances list, as a first step in the right direction.  With the now long history of successful cannabis distribution in the medical fields, it no longer makes sense to have it banned as a highly dangerous substance. Coupled with the data showing increased safety and reduction in crime in states with recreational legality, the federal ban is no longer sensible.With a state level choice by citizens to determine availability and true ability to research usage, we are best able to stop the problematic sides of the issue. Real research can be done to find both the positives and negatives of cannabis usage by the public. Children can be better insulated in the same fashion as they are for alcohol and tobacco plus the criminal justice system will be more efficient. The cost of criminalizing cannabis far outweighs the benefits and the volume of low level prosecutions stops prosecutions for high level crime.So my opinion is that federal decoupling of legality and state level selective choice makes the most sense for the nation. The Cannabis Plant and Resin have already been legalized in many states, with even more putting it to a vote as soon as this coming November in one way or another. The war on cannabis happened long before we had our current scientific studying capabilities, and as such it has never had a true chance to be studied as a legitimate medicine. On top of this, the original reasons for its outlawing were highly suspect to begin with, chiefly influenced first by the business motivations of William Randolph Hearst (in conjunction with poorly attended congressional hearings and shoddy scientific studies), and later by the political motivations of the Nixon administration and the then burgeoning pharmaceutical industry, more than scientific merit. Its time we see the writing on the wall: If it wont be legalized for recreation at a federal level, the American people obviously want, at bare minimum, for Cannabis and Cannabis Resin to be changed to a Schedule IV or V drug so that it can be properly studied and the voters can make informed decisions on whether or not to continue its legalization.Speaking of the current scheduling of Cannabis and Cannabis Resin, its pretty difficult to make a coherent argument for how these drugs fit the description of other Schedule I narcotic. The definition for Schedule I narcotics per the DEAs website is as follows: Schedule I drugs, substances, or chemicals are defined as drugs with no currently accepted medical use and a high potential for abuse. Not only do Cannabis and Cannabis Resin have currently accepted medical uses (treating epileptic seizures, for example), but how is it possible to assert that a drug has a high potential for abuse if theres a dearth of coherent, factual, peer-reviewed scientific study on that subject? Without scientific evidence the scheduling must be based on hearsay, and that our government would enact rules or regulations based on hearsay is a terrifying realization.There are many other reasons why Cannabis and Cannabis Resin should be rescheduled but unfortunately theres simply not enough room in this comment to discuss them all. Its time to do right by the American people, and the ethical core that guides their principles, and reschedule Cannabis and Cannabis Resin to Schedule IV or V so it can be properly studied, after which the American people can finally be allowed to do their job: Make an educated decision on the ongoing legality of the substance. Marijuana should be legal !  It helps many people and does little harm, especially compared to alcohol.  The tax payer burden for incarcerating marijuana users is also unacceptable.   Cannabis Plant and Resin most certainly should be re-scheduled. It has medicinal benefit.  My dad has a severe case of RLS and has been on every prescription drug to combat it.  He loses sleep and has to take heavy sedatives to sleep.  I feel like cannabis would be a great option for him, but he refuses because it is not allowed in his state.  I also work with children with seizures and have seen its medicinal benefit for them.  I also think it should be re-scheduled so that recreational users can use it.  I would much rather have a stoned partner, than one that is drunk on alcohol all the time.  I also think if we have the ability to tax cannabis, we could benefit our roads, schools, and poverty issues across the states. Fentanyl should be shut down at the production line. I have had two close friends, and countless others lost their lives as a result of Fentanyl.  It doesnt even deserve a scheduling, it shouldnt be around period.