Controls To Enhance the Cultivation of Marihuana for Research in the United States
2020-05-21 2020-05-21 2020-05-21 2020-05-21 2020-04-29 2020-05-14 2020-05-13 2020-05-13 2020-05-13 2020-05-13
DEA-2020-0008-0179 DEA-2020-0008-0178 DEA-2020-0008-0192 DEA-2020-0008-0190 DEA-2020-0008-0024 DEA-2020-0008-0082 DEA-2020-0008-0055 DEA-2020-0008-0039 DEA-2020-0008-0051 DEA-2020-0008-0052
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https://api.regulations.gov/v4/comments/DEA-2020-0008-0179 https://api.regulations.gov/v4/comments/DEA-2020-0008-0178 https://api.regulations.gov/v4/comments/DEA-2020-0008-0192 https://api.regulations.gov/v4/comments/DEA-2020-0008-0190 https://api.regulations.gov/v4/comments/DEA-2020-0008-0024 https://api.regulations.gov/v4/comments/DEA-2020-0008-0082 https://api.regulations.gov/v4/comments/DEA-2020-0008-0055 https://api.regulations.gov/v4/comments/DEA-2020-0008-0039 https://api.regulations.gov/v4/comments/DEA-2020-0008-0051 https://api.regulations.gov/v4/comments/DEA-2020-0008-0052
Charlie Laurie Joan Anonymous Anonymous David Brad Anonymous Peter Timothy
Mann Finkelstein Ariel Anonymous Anonymous Lucito Bogus Anonymous Shaw Barrett sr.
Using the cannabis that is already available to consumers through dispensaries makes common sense. This ensures that the research is relevant to those who are using it. This would also help provide the kind of insight required to make responsible legislation. I believe that scientists should be able to access cannabis from any state licensed businesses the same way consumers do. The production of and research into medicinal cannabis should not be governed by the DEA, a law enforcement agency, but shifted to a public health and/or science-based institution.  It is imperative that regulations on medical cannabis research be significantly reduced and institutionally reorganized to promote the health and well-being of millions of AmericansNumerous studies have investigated the Endocannabinoid system and its documented potential to manage many diseases and its invaluable aid in the treatment of chronic pain, PTSD, Epilepsy, glaucoma, movement disorders, and cancer, among others.  Further, research and clinical applications indicate that the medicinal properties of cannabis may well protect the body against some types of malignant tumors.  Indeed, we have a friend whose ovarian cancer tumors were noticeably shrunk once she began regular, careful use of cannabis. Such significant benefit can no longer be ignored!The federal government should be facilitating wide and varied medicinal cannabis research, NOT discouraging it through restrictive regulations and bureaucracy.  It is long overdue that a major public health agency like the National Institutes of Health should be responsible for oversight of domestic cannabis production for research purposes and expand the research program eligibility of cannabis growers who operate in compliance with state laws and regulations. Millions of Americans will benefit from the approval by the FDA of cannabis based medicine.  The United States must act expeditiously to implement this life-saving science Why should the DEA whose actions are responsible for stiffling the medical research in the first place now be given the power to regulate and control the very thing they opposed.Not only should the dea be defunded all together but new agencies staffed by americans who listen and hear the voice of the people should be put in its place to ensure progress and success for the american way of life.We have become worse than the tyrants my forefathers rebelled against.  This is a chance to change the course of history and progress the values we signed up to defend 243 years ago. All the best, I believe marijuana should have never been passed in any state as there has been more and more studies leading to against marijuana use. The highest quality product is in the state programs. Why would researchers have to go through an organization that supplied bunk medicine to the research community for decades when state-level growers are readily providing the goods? The DEA is not the appropriate body to be overseeing or regulating cannabis research. Instead of facilitating research, this proposed rulemaking will serve only to further hinder research  indefinitely delay any potential positive outcomes. Most significantly, a law enforcement agency like the DEA should not be in charge of any aspect of this process. One of the many qualified public health agencies in the federal government (i.e. Health and Human Services, National Institutes of Health, etc.) should manage all of the processes related to research, including making decisions about who qualifies to grow and sell to researchers. Furthermore, the US should adopt a regulatory framework that encourages and facilitates further research, rather than chilling it (as these proposed rulemaking would). The American public has repeatedly made clear its desire for greater unimpeded, evidence-based research to be conducted on the public health benefits of cannabis. Voters across the political spectrum overwhelmingly support medical cannabis legalization. In 2017, a Quinnipiac Poll showed 94% approval for medical cannabis, including 96% of Democrats and 90% of Republicans. On more comprehensive reform, a 2019 Gallup News Poll showed two-thirds (66%) of Americans support legalizing cannabis for adult use. There is no putting the genie back in the bottle; it is clear the American public wants regulated, tested and safe cannabis. It is time for the federal government to facilitate and not hinder research into these popular products. Evidence-based medicinal research guides practicing clinicians on medications use, dosing, and monitoring. These decisions combine anecdotal evidence supported by unbiased empirical data in the form of clinical research. Despite the fact that over 3 million patients in the US use cannabis legally as medicine to treat a variety of conditions and symptoms (chronic pain being the most prevalent), key research is stifled due to its current Schedule I status. The high-risk demographics of some patients like the elderly and veterans who use medical cannabis demand that research-based evidence guide cannabis use for these populations. High-quality research supports informed and safe decision-making in medicine. This is absolutely essential in all fields of medicine, including cannabis. Expanding research capability is of critical importance for Americans across the nation and who have a vested interest in knowing as much as possible about the medicinal properties of the cannabis plant. I share the DEAs stated goal to facilitate the cultivation of cannabis for research purposes, but strongly disagree that the DEAs proposed rulemaking will best accomplish that stated goal. The cannabis industry has been waiting for three years for the release of this Federal Register Notice with the hope that the proposed regulations were drafted to advance the goal of facilitating much-needed research. If adopted in its current form, however, this proposal would have just the opposite effect; it would impose another level of unnecessary regulatory and bureaucratic obstacles in the path of valid medical-cannabis science. Most significantly, DEA is not the proper agency to act as gatekeeper for such important public health research. Indeed, this mandate is entirely outside the agencys expertise. Reminder: DEA is a law enforcement agency, not a public health agency. It is my view that one of the many qualified public health agencies in the federal government like HHS or NIH can more effectively manage all of the processes related to research into the medicinal benefits of cannabis. I believe that the DEA should withdraw its rulemaking. Instead, Congress should modify the CSA to allow for a public health agency to license the production of cannabis for medical and scientific research purposes. I do not believe that such a narrow reading of our treaty obligations is warranted, given the reality that 33 states currently regulate commercial supply chains to safely produce, store and transport any cannabis needed for medical or scientific research. This threatens to exclude many of the nations most qualified applicants, namely, state-compliant grow operations. I assume that the DEA will assert that those operating in compliance with current state law are violating federal law. The US needs to leverage the expertise of growers with 20-30 years of experience, rather than relying on growers with limited experience growing cannabis. I would prefer to see a greater emphasis on other factors, like compliance with state laws and demonstrated ability to grow research-grade cannabis. Strict reliance on past compliance would naturally tend to abdicate US leadership on these issues in favor of foreign operators. The fed gov. should be incentivizing research, not discouraging it. More positive changes for a plant...yes Limiting the supply of research cannabis is ridiculous when there is such a plentiful supply of diverse strains available under state sanctioned programs. If federal law is going to continue to be behind the curve, then decentralize the research and allow science to access the strains available within their legal state research locations. The entourage effect of phytocannabinoids, terpenes, flavinoids, etc. is not well understood, but likely to play a major role in treatment response. By limiting availability of supply to a small number of commercially sanctioned growers under DEA guidelines, we are doing the science a grave disservice. RIN 1117-AB54/Docket No. DEA-506If for individual research use, under 1301.32(a) of Action on applications for research in Schedule I substances:(a) In the case of an application for registration to conduct research with controlled substances listed in Schedule I, the Administrator shall process the application and protocol and forward a copy of each to the Secretary of Health and Human Services (Secretary) within 7 days after receipt. The Secretary shall determine the qualifications and competency of the applicant...And under the first half of (3) in 1303.12(e)(3) of AGGREGATE PRODUCTION AND PROCUREMENT QUOTAS: (e) The following persons need not obtain a procurement quota:(3) Any person who is registered to conduct research with a basic class of controlled substance listed in Schedule I or II (this is the second half of the sentence: and who is authorized to manufacture a quantity of such class pursuant to Sec. 1301.13 of this chapter. Which reads; 1301.13 Application for registration; time for application; expiration date; registration for independent activities; application forms, fees, contents and signature; coincident activities.(a) Any person who is required to be registered and who is not so registered may apply for registration at any time. No person required to be registered shall engage in any activity for which registration is required until the application for registration is granted and a Certificate of Registration is issued by the Administrator to such person.)Why, if the Administrator and the Secretary both review patients and caregivers state registrations, which are a research based program, hence issuing registered patient IDs. And it would be unlawful without said registration. Are we as patients and caregivers, required to submit a secondary application reviewing the same qualifications already approved and registered by and for use by the state as referenced in (3)? The state should be mandated to include both requirements in one application with one set of fees. If requirements are automatic. Then allocate fees accordingly to the partnered governmental departments from one application who receive the benefits of fees. 