Exploring the Seven Dimensions of Cannabis
Last week, while the Obama administration was dealing with the embarrassment of the Secret Service scandal at the Summit of Americas in Columbia, developments on the far more important issue of the failed War on Drugs were taking center stage.
It began back in March at a regional Central American meeting between Guatemalan President Oscar Pérez Molina and the presidents from Costa Rica and Panama. During the meeting, President Molina pointedly stated:
“We have realized that the strategy in the fight against drug trafficking in the past 40 years has failed. We have to look for new alternatives….”
To President Molina, this means that:
drug use, production, and sales should be legalized and regulated. He suggested that the region jointly regulate the drug trade, perhaps by establishing transit corridors through which regulated drug shipments could pass.
While no agreements by the heads of state were made at either the March meeting or at last week’s Summit of Americas, President Molina has indeed succeeded in moving this issue of critical import to all nations to the forefront of international debate. President Molina’s call was heard loud and clear by Obama inciting this response at the Summit:
“I think it is entirely legitimate to have a conversation about whether the laws in place are ones that are doing more harm than good in certain places…. I personally, and my administration’s position, is that legalization is not the answer.”
Understandably, embroiled in a re-election dogfight, Obama will not take the bait by adopting a new policy regarding drugs now. Yet, by suggesting a “conversation” is warranted he is leaving the door open to working on a change to the tired drug war approach – perhaps upon re-election, but more likely in year three of a second term. To most of us, primarily the Central American nations ravaged by the failed War on Drugs, change cannot come soon enough.
Today, the unofficial holiday of medical and recreational cannabis consumers – 4/20 – the Atlantic published a great speech Obama ought to give. It begins:
After careful consideration and a through review by the Justice Department, and with the consent and cooperation of other relevant federal agencies, I announce today that this Administration will have a new approach to the issue of medical marijuana in those states which have legalized it. Our new policies are consistent with the promises I made as a candidate, they finally make good on pronouncements I made early in my term, they are faithful in their traditional deference to states’ rights, and they sensibly redirect federal resources at a time when we need every budget dollar we can find.
I have directed the attorney general to issue a directive to all U.S. attorneys and other federal officials that they may no longer raid or threaten to prosecute medical-marijuana growers and distributors in those states that have legalized the use of the drug.
However, a federal crackdown on medical cannabis, particularly in California, is in full force, and has been since last October. Could it be that developments in nearby Central American nations are what it takes to make those inside the beltway so impervious to majority opinion on drugs in general, and cannabis specifically, finally reform the current U.S. drug policy that has so obviously failed? Maybe, maybe not.
Earlier this week, the Huffington Post highlighted an open letter by 300 economists to the President and Congress calling attention to a paper by Harvard economist Jeffrey Miron. Mr. Miron’s study asserts that the U.S. could save $13.7 billion by legalizing cannabis. Even during recessionary times this economic report is not enough to reform our archaic drug policy. So what will it take?
A perfect storm. Pressure from the south, from the north, and from within. Pressure from all of us that we’ve had enough of the lobbied interests ruining so many lives in the veiled name of their self-interest, not common sense. Enough is enough. Pick up the phone or pen – do something – our neighbors to the south depend on it.
By Arthur Cote
As the doctor moved his fingers around the protruding mass on my neck, he stood back and looked in my eyes and told me to go across the street at that moment to get a biopsy done of the lump. He said the last biopsy wasn’t conclusive. The urgency startled me, I left the office and went directly to the pathology lab.
One year earlier, I had gone to an ears nose and throat specialist. After a biopsy, I heard those wonderful words “its not cancerous”. At a dentist appointment later in the week, an oral surgeon assured me not to worry about the lump in my neck. That it was related to the root canal I had had and it would go away. In fact the surgeon showed me he also had a lump from dental work he had done. I dodged a bullet that day. So I relaxed and went on my way.
We took off from San Francisco international airport en route to Wilmington North Carolina to attend a wedding.
It was May. Beautiful weather.
We touched down, got our rental car and drove to our hotel to start our 2 week vacation. My wife, Debbie, had to travel up to Canada for a few days on business while in NC, I would stay with a friend while she was away.
I was very excited to hit up a great burger place in town with my buddy Jim the first full day of our trip. This burger, found at PT’s Burgers, is one of the wonders of the world, with the most crispy and delicious french fries. As we sat down to eat, my phone rang. It was my ENT doctor. He said calmly and without stopping, “Mr. Cote, unfortunately the biopsy came back positive. You have a Squamous Cell Carcinoma on your neck and it must come out immediately.!”
My lunch was over.
I sat for awhile, unable to speak, pick up my burger, or move. It felt as if sound itself had ceased, that I sat in a vacuum. My legs trembled a bit. I asked the caller if I’d be alive in a year. The doctor was silent for a few seconds, then told me he couldn’t say until he saw the tumor. I asked if I should return to California immediately, he demanded I enjoy my vacation. I was in for a rough course when I returned home.
Returning to Jims’ office, I sat at a desk trying to work. It was an impossible task. All I could think of was how much trouble I was in. After about an hour, Jim suggested we leave the office for the day. We picked up a bottle of Tequila, and headed to his house for an evening of forgetting. Thankfully, the night passed.
Morning had come, cancer was my first thought. That I may be dying was the second. I was down right scared out of my wits. But I was able to get some work done. Debbie had called the evening before and told me the doctor had called her too, but she hadn’t spoken with him. I told her the news. I eagerly looked forward to her returning to Wilmington.
We partied for the remaining days as “cancer” kept pushing itself into my consciousness. As we drove to the airport on our way back home, we spoke about what we were going back home to. Surgery had been scheduled for Jun 2nd, a few days after our return.
June 2nd arrives.
Hospitals have always been a place of refuge to me since working as an EMT in NYC whilst in my twenties and in school. I had complete confidence in my doctors, and in the hospital, UCSF Medical Center in San Francisco Mount Zion. While I was terrified as they wheeled me into the operating room, and strapped me down on the table, I wasn’t sure I w
ould come out of the surgery in tact, but I knew I was in good hands. My surgeon, a top guy in head and neck cancer, told me point blank how serious the surgery was.
As I woke up in recovery and saw Debbie’s beautiful face, I knew I had made it. But when I saw her expression, I knew it was serious. When my surgeon came in to check on his handiwork, Deb had sort of confirmed to him that my prognosis was good. That I would just “Need some radiation and then I’d be fine.” He shot back asking who had given her that news. That in fact, the tumor was stage 4. It was very serious and offering a prognosis was to early. The biopsy and planned MRI would tell the story. My next step was to recover from surgery and see a radiation oncologist.
The first night in my room. I suddenly felt a gushing of pain all over my head and neck. I called the nurse to request more pain meds. She informed me I had gotten my quota of tylenol for the day therefore I would have to wait for tomorrow! I asked her if she was kidding, that I had had surgery earlier today. She wasn’t. I sat up all night in screaming agony.
The next morning I told my surgeon what happened. He went out to the nursing station and changed the order from PRN (as needed) to every 4 hours.
Entering the exam room I glanced up at the signage over the room: oncology consult. It slammed me in the face as if I ran into the wall.
The doctor introduced herself as a radiation oncologist. Her second was chief resident. As Dr Kam moved in front of me, she rattled off a check list: MRI, Radiation, then Chemo. When I asked her if I would be in need of Chemotherapy, she snapped back we needed to wait for the surgical biopsy to return, but she was just setting things up as she saw them. This doctor was very matter of fact. I could tell by her bedside demeanor they didn’t hold high hopes for my survival. I presented as a very ill young guy at 53, in relatively excellent shape – running 3 miles a day.
As the exam progressed, Dr. Kam pressed their must be a primary tumor somewhere in my body and that it has to be discovered and treated. Result? An MRI, and a Pet Scan. She also scheduled me for radiation therapy: 33 days 5 days a week.
While the MRI and Pet Scan was negative, no additional tumors were found, Dr. Kam pushed hard for me to begin radiation. She informed me I would most likely have dental problems resulting from the treatment, moderate hair loss, and other bothersome side effects up to and including getting a feeding tube installed in your nasal cavity. I told her I would not have a feeding tube, and that I would make it out on my own two feet in the end. She politely smiled.
Day 1 Radiation assessment exam.
I walked into the radiation oncology unit with great trepidation. As I sat down, Dr. Kam explained how I would need to be measured for a mask that aids in keeping the head still during treatment (right).
As the system shoots rads at you in the general direction of where the tumor lived, ones whole body has to be screwed down onto a table that based on computer commands, moves to required positions for deliverying treatment.
The measurements were taken, I was given my treatment start date, and went on my way. I recall feeling like my life was in its waning days, that all this action by doctors on my behalf was an attempt. That in fact my prognosis was on shaky ground.
The pain got worse as I healed from the surgery and started radiation treatment. My sons strongly suggested I try cannabis to ease the pain and to ease my high anxiety over beginning treatment. I tried it and was amazed that I was able to sleep for the first time through the night. Cannabis saved me.
First Day Of Radiation Treatment
I arrived right on time for my first appointment, thinking I can get in and out as fast as possible to get the hell away from the hospital.
Upon entering the waiting room in the basement of the hospital (UCSF), I was met by a fellow who took me around to show me the “ropes”; first change into hospital garb – opened-in-the-back gown, and surgical pants.
Entering the patient waiting area, I was shocked to find it crowded with what looked to me like the walking wounded. Some looked worse than others. The room was hot, very uncomfortable. Watching the waiting patients gave me a sick feeling in the pit of my stomach. A man sitting next to me told me he had prostate cancer and was almost done with his treatment; he looked like a corpse that was unaware of his death.
When the technician called my name I was relieved to get the hell out of that room, only realizing I’d be sitting in that room at 3:20 every day for 33 visits! Yikes.
I entered the treatment room. The staff placed me on the table, nailed down my face mask using clips that connected my head to the table. As I laid there waiting, I thought “What happens if there is an earthquake? I’m screwed, thats what!” A warm blanket was placed on me, and I was told the treatment would start once the techs left the room.
My mind was racing. Panic set in. What the hell was happening here? Why was this happening to me? Then the machine whirred to action and the treatment started.
Each day, the treatment lasted 10 minutes. Each day I loathed more and more to go to the hospital for treatment.
Before the first full week of treatment had concluded, it was Friday, I woke up feeling very ill. Vomiting, bad stomach cramps, dizzyness. Feeling really ill and in bad pain.
The doctor said it most likely was the flu, and that I should drink lots of fluids. After 2 days, I ended up in the emergency room.
The ER physician examined me and called in internal medicine consult. My sodium level was dropping dangerously low, and they didn’t know why. They admitted me.
Endocrinology consult came to my room the following morning. She explained the suspected culprit was my adrenal glands. That perhaps they weren’t working fully if at all, and that would cause a drop in sodium level. Dr. Bellgo ordered an MRI of my brain, and blood work.
Dr. Bellgo delivered the results. Somehow along the way, my adrenal glands were “blown out”, or as she put it, atrophied. I asked how this could’ve happened. She mentioned she had looked at my pre-op labs and that my sodium levels and other metrics were normal. So it happened sometimes from the tumor surgery forward.
No doctor would address what exactly happened. When I mentioned it to my surgeon, he shrugged. He wouldn’t address it. No one would. Until this day.
To stay alive I need to take 2 steroids replacement therapy. This continues 2 years later.
After I left the hospital, my doctor was VERY anxious for me to start up radiation again, so it was rescheduled. And I went through each day of treatment feeling like a hot dog in a microwave oven. My body ached, and burned from the results of surgery, and now new pain from the radiation treatment.
I concluded the radiation treatment, and am left with chronic neuropathic pain, and muscular pain on my right side where the tumor was. If I didn’t have access to cannabis, I would be in big trouble. Cannabis relaxed me enough to be transfixed to a table for radiation treatment, and it relaxes me every night, blocking the steroids enough to let me get a good nights sleep.
By Amanda Reiman PhD MSW
Schedule I Barriers
To understand the duality of cannabis, why this is a barrier to its use as a treatment for addiction, and how dispensaries fit into all this, it’s important to look at the impact of Schedule I and a Deontological Framework for drug use. There are beliefs in society that cannabis is recreational, curative and therapeutic. The investigation into these uses has been slowed by the Schedule I restriction in several ways: 1) It has slowed research into the components of the plant and its development into a pharmaceutical drug, interrupting the normal progression of botanical to medicinal discovery. So what we are just learning about the role of cannabis and addiction now, we could have known before; 2) It was labeled as having “no medical value” before any controlled efficacy studies had been done, and after people had been using it as a medicine for thousands of years. While petitions were being consistently filed to remove it from Schedule I ever since it was placed there, cannabis was gaining a reputation among users as being fairly benign and fun to use. Yet, even in the face of modern controlled studies of efficacy and the recognition of medical value in 16 states, the Feds remain adamant about keeping cannabis in Schedule I, WHY?
Drug Laws and Deontology
Drug laws are highly deontological, meaning that there is a belief that possession and use are inherently wrong regardless of the consequences. Cannabis policies are centered on prohibiting access regardless of the consequences of use. It is assumed that all illicit drug use is problematic and that is it NOT possible to be a responsible drug user. This is contrary to gun laws which are based on consequentialist beliefs. Gun policies are centered on regulating access and punishing consequences. Education is centered on safe use and avoiding unintended consequences. It is recognized that a small percentage of gun owners cause a majority of the problems. It IS possible to be a responsible gun owner. So, once cannabis was deemed wrong regardless of the consequences and Scheduled as having no medical value, it was very hard to justify changing that, regardless of the research on the health and social consequences associated with cannabis that have since emerged. Furthermore, it is extremely taboo to suggest that cannabis, a drug placed in the most restrictive category could be a treatment for a drug placed in a lower schedule (such as cocaine). At the same time, the government is funding research on cannabinoids as a treatment for among other things, addiction. This duality confuses the public, the industry and those who seek to regulate it, and distracts from the development of practical applications for cannabis in practice.
Cannabis as a Treatment for Addiction
So, how do we break free from this political and philosophical deadlock and move forward to reflect what we now know about the health and social consequences of cannabis and its potential as a treatment for addiction? The duality of cannabis as herb vs. cure is slowly tearing the issue apart. On one side, you have cannabis as wellness whether that is for therapeutic or recreational purposes. In this view, the use of the cannabis plant in its many forms (flowers, oils, fibers) is vital for maintaining a healthy balance within the body and for the health of the planet. This model most relates to the growing use of Complementary and Alternative Medicine in the United States. Individuals looking for alternatives to pharmaceutical drugs (from Oxycontin to Tylenol) are turning to acupuncture, chiropractic work, and herbal supplements such as cannabis. On the other side you have cannabis as cure. The discovery of the endocannabinoid system fueled research into the role of cannabinoids in the regulation of almost every bodily system. Pre-clinical research with animal models shows that cannabinoids such as THC and CBD have the potential to negate diseases such as cancer, HIV, Alzheimers, Parkinson’s Disease, and MS.
How does this duality and the role of dispensaries relate to an issue like substance use? As a treatment for addiction, both the herbal supplement and cannabinoid based medicine model apply, but in different ways. As an herbal supplement, cannabis in its raw form can be used as a behavioral substitute for the drug of addiction. Additionally, patients report that cannabis facilitates a mind/body connection which can help those in recovery tune into their issues rather than trying to numb them. Finally, the use of cannabis as an herbal supplement in its raw form can assist with harm reduction by helping patients get through moments of craving to stay within their own boundaries of drug use, and to move them from a more harmful substance, such as alcohol, to a substance that poses less harm like cannabis. Development is also happening on cannabinoid based medications for addiction. These medications work similarly to what report from the raw product, but at a more targeted level by interfering with brain messaging. Research on cannabinoids show the ability of these chemicals to block receptors in the brain stimulated by cocaine, which can help reduce cravings for the drug. Furthermore, cannabinoid based medications have been shown to reduce the seizure activity associated with alcohol withdrawals, as well as prevent liver damage from excessive alcohol consumption. Granted, most of this research is not on humans, and most of the research on humans is anecdotal, but its thousands of years of anecdotal evidence.
What might cannabis treatment for addiction look like and how do dispensaries fit in? From the CAM perspective, cannabis based addiction treatment would encompass the alternative therapies such as acupuncture and mediation, along with the use of cannabis as flowers, tea, edibles, etc. as a method of easing the mind and changing behaviors while reducing harm. This is the model currently exhibited by dispensaries such as Berkeley Patients Group, Harborside Health Center, and SPARC. From the FDA approved medicine perspective, cannabis based addiction treatment would encompass the use of medicines delivered perhaps by mouth spray such to prevent cravings, or an IV solution containing cannabinoids being given to an alcoholic in the hospital during detox. These interventions might be better suited for a hospital setting. Perhaps it is both, with utilization changing throughout the course of treatment. You cannot overdose on cannabinoids.
How are Patients Using Cannabis?
When asking medical cannabis patients about their reasons for use, we are already seeing these two sides come together in patient behavior, with both medical and wellness effects being reported. A chart review was performed on a sample of 175 patients seeking medical cannabis recommendations at a Northern California Medi-Cann clinic. The sample was 69.5% male, the mean age was 42.2, with a range of 19-86, 52.3% report a physical condition, 2.9% a mental health condition, and 44.8% both. Sixty nine percent of the sample reported using cannabis as a substitute for alcohol, illicit or prescription drugs. The most common reason for substitution was less side effects from cannabis (24%). The benefits from cannabis most commonly reported were: Pain relief (85%); Sleep (77.7%); Relaxation (50.9%); Rx med substitute (46.3%); anxiety (46.3%). The benefits least commonly reported: Anti-Diarrhea (3.4%); Anti-Itching (3.4%); Prevent Seizure (3.4%); Prevent involuntary movement (5.7%). The bothersome effects most commonly reported were: Dry mouth (29.7%); Hunger (23.4%); Mood disturbance (17.7%). The bothersome effects least commonly reported were: Confusion (none); Dizziness (.6%); Palpitations (.6%); Movement problems (.6%). The benefits reported fit both the wellness model (relaxation, sleep) and the curative model (rx med substitute, anxiety, prevent seizure/involuntary movement).
While these two uses of the plant should be harmonious, these two sides may pull the issue farther and farther apart. This tension is reflected in the disagreements over the proper channels for cannabis regulation. What the two sides do not seem to realize is that: 1) cannabis in its many forms can be harmonious with the body, establishing balance, whether this is to maintain wellness or address disease; 2) stress relief and relaxation is absolutely a medical use, given the research on the role of stress in the development of disease; and 3) points one and two in no way mean that the entire family of cannabis products and preparations should be regulated the same way. We do not regulate wheat and beer the same way, nor do we regulate Valerian root and Valium the same way. The attempt to include both sides in any one policy is futile because the avenues for regulating herbal supplements and FDA approved medications are very different. If cannabis policy is to succeed in a way that honors the complexity of the plant and its many forms and uses, each camp might have to support each other and learn from each other, but head their own way. These treatments are complimentary, but they are not the same and should not be regulated the same way. It muddles the message and inhibits the use of cannabis in practice. A policy does not exist that would satisfy both these parties. Ironically, there are a myriad of practice situations, such as the treatment of addiction, that would be optimal both.
AB 2552: Misguided From Every Angle by Patrick Goggin
Assembly member Norma Torres (D-CA) introduced AB 2552 earlier this legislative session. The bill would effectively criminalize driving with any detectible level of THC in the system. None. The ramifications of such a bill becoming law are tremendous indeed.
Never mind that government testing is unreliable – the lack of minimum levels would not only criminalize medical cannabis patients but the millions among us who consume healthy hemp foods. Other states like Colorado are considering legislation similar to Torres’ and together they have sparked a debate over what minimum levels should be reasonably established to recognize medical cannabis patients and hemp food consumers.
Torres’ short-sited legislation and its ilk should be emphatically rejected by the respective state legislatures. Alternatively, the legislatures should work with cannabis industry leaders to establish reasonable standards if they want enact to measured laws to minimize driving under the influence.
Quality Assurance Priorities for the Medical Marijuana Industry
The Four Pillars of Quality; Product Safety, Truth in Labeling, Tamper evident Packaging, and Dosage
R.W. Martin, Ph. D.
Since its beginnings at the turn of this century, California Cannabis Testing Laboratories have been focused primarily on cannabinoid testing. The motivation for most users or dispensaries to use laboratories has been driven by the eagerness to find more potent strains and understand the potency of extant strains. The discovery of more cannabinoids and the promising data surrounding the efficacy of CBD in particular has fueled even more interest in the further understanding of these cannabinoids.
Terpenoids (aromatic compounds associated with plants) have also been gaining interest of many of the Cannabis Testing Laboratories, at least within California, even though these compounds exist at almost trace amounts. These terpenes are thought by some to be related to specific symptomatic issues relating to patient care. Others believe that the terpenes enhance aroma therapy and taste of fresh products during consumption. Preliminary investigations are underway in several laboratories to further identify and quantify these compounds in the various strains currently being commercialized.
To date, little emphasis has been placed upon the three pillars of Quality Assurance, namely 1) product safety, 2) labeling, and 3) tamper evident packaging that are usually considered major quality components in most consumer or patient-based delivery systems. Dosage is added here as the forth pillar as it becomes very important to understand the strength of a certain medicine delivery system. This emphasis is, in part, due to the fact that the experience base of most California Cannabis laboratories is primarily chemistry. Hence, these chemist led laboratories play to their strength, and offer really top notch, very impressive chemical analyses to their patients. There are labs that offer a wide range of cannabinoid and terpenoid profiling because they have the background to do so. However, these cannabinoid and terpenoid analyses don’t begin to address the quality needs of the industry. The following is a document that seeks to share existing concepts and principles of Quality Assurance and how they may relate to the medical marijuana industry in California.
1) Product Safety
First and foremost in any Quality Assurance program is the concept of product safety. In the medical marijuana industry,” products” refer to (1) the fresh prepared flowers as well as, (2) food processed with the infusion of cannabinoids:
1) Prepared Flowers
It has been shown through testing that prepared flowers can yield very high numbers of bacteria and mold spores. These high numbers, in most cases, indicate, for bacteria: poor handling or hygiene during processing and drying; and for mold the presence of a fungal species pathogenic or saprophytic on the flower. High bacterial spore counts also increase the probability for the presence of human pathogens. Pathogens such as Pseudomonas spp. have been identified on flowers grown and processed in California (CW Analytical file data). Aspergillus has also been reported, a pathogen that produces Aflatoxin, an exocellular excretion known to be toxic to all mammals.
It has also been shown that residues of pesticides and fungicides can be present on prepared flowers, especially those grown indoors. These residues are known to sequester in human tissues and are implicated in a wide range of physiological disorders.
The minimum testing for QA approval of a flowered product=Residue Testing, Bacterial Screening, and Yeast and Mold Screening with potency testing optional (AOAC 986.33, 991.14, and 997.02). Potency will be discussed in the Dosage Section below.
2) Food processed with infusion of cannabinoids
Cannabinoid infused food should be tested similarly to food processed and distributed in existing food channels. The minimum tests for acceptable Quality Assurance for edible food products infused with cannabinoids are= Bacterial Screening and Yeast and Mold Screening. (AOAC 986.33, 991.14, and 997.02) Potency will be discussed in the Dosage Section below.
2) Product Labeling
The Sherman Food, Drug, and Cosmetic Law of 2008 clearly states that all food products be labeled accurately and consistently with standardized descriptions and labels (NLEA, 1991, Sherman Food and Cosmetic Act, 2008). This should be considered appropriate for both (1) prepared flowers as well as (2) food products infused with cannabinoids:
1) Prepared flowers
Dried flowers should be tested, bagged and sealed prior to dispensing to patients. Vacuum, nitrogen flush and hermetic sealing are all options currently available. Efficient bagging will maintain freshness and guard against further contamination. Labels indicating date of bagging, level of testing (cleanliness), and potency (if desired) should be prominently displayed on each bag.
2) Food processed with infusion of cannabinoids
All food products must be labeled using the 1997 convention adopted by the NLEA*. That is, all labels must include mandatory reporting of nutritional values based on serving size. These values include calories, fat, protein, carbohydrate, cholesterol, sodium, Trans fat, fiber, sugar, with vitamins A and C, and iron. Further, all potential allergens must be clearly identified and labeled to guard against accidental ingestion. An ingredient statement in order of preponderance is also mandatory. Labels may be based on either calculated data or actual nutrition testing. Minimum requirement for label compliance= NLEA convention food label and accurate ingredient statement.
*= It is understood that some municipalities are uncomfortable with current labeling doctrine and that they seek to make packaging as different as possible to guard against mistakes with non-patients. CW Analytical strongly suggests that nutritional labels be offered at point of sale as information sheets or addendum added to the purchase of an edible in these situations.
3) Tamper Evident Packaging
Tamper evident packaging should be required for all medical marijuana products whether fresh or processed. The accidental exposure of non-patients to these medications should be taken very seriously and barriers such as these should be mandatory.
The US Code of Federal Regulations (21 CFR 211.132) defines OTC Drug tamper evidence as = – Tamper-evident packaging requirements for over-the-counter (OTC) human drug products:
“A tamper-evident package is one having one or more indicators or barriers to entry which, if breached or missing, can reasonably be expected to provide visible evidence to consumers that tampering have occurred. To reduce the likelihood of successful tampering and to increase the likelihood that consumers will discover if a product has been tampered with, the package is required to be distinctive by design or by the use of one or more indicators or barriers to entry that employ an identifying characteristic (e.g., a pattern, name, registered trademark, logo, or picture).”
Minimum requirement for medical marijuana industry = tamper evident packaging meeting requirements listed above
Potency ranks fourth on the Quality Assurance priority as a nice to know datum point in one aspect and a need to know in another. The potency of prepared flowers and concentrates is a nice to know in terms of commercial value and psychoactive potential but becomes a need to know datum point when calculating the potency for a dosage calculation in edible form*. Whether it be prepared flower or concentrate, the accurate depiction of cannabinoid levels are necessary for dosage calculations and serving size coordination to the patient. Minimum cannabinoid testing should include THC, CBD, and CBN values.
*It should be noted that there is currently no known dosage widely accepted for this industry. Patient response to various dosages is very diverse and should be considered as a case by case basis. CW Analytical recommends 20-25 mg as a standard single dose of THC.
These opinions are respectfully submitted and based upon 30+ years within the food industry serving as a Director of Research and Quality Assurance in large multinational food corporations. This document is intended soley for educational purposes and should be considered preliminary in scope and a precursor to formal ISO and HACCP program development. All questions should be directed to:
Dr. Robert Martin
Director, CW Analytical Laboratories
Pat Robertson tells the New York Times “I really believe we should treat marijuana the way we treat beverage alcohol,” Mr. Robertson said in an interview on Wednesday. “I’ve never used marijuana and I don’t intend to, but it’s just one of those things that I think: this war on drugs just hasn’t succeeded.”
Robertson argues that legalizing cannabis is a way to bring down soaring rates of incarceration and reduce the social and financial costs. His closing statement in the article is “I just want to be on the right side,” he said. “And I think on this one, I’m on the right side.”
Deep Green is pleased to welcome the Luminaries to this years festival. They have just release this enlightening video produce by Elevate films.
The content below is taken from the material that accompanies the video, which is part of a edutainment video series sponsored by Nutiva.
Hemp is the most durable of natural fibers and is a very eco-friendly crop. It requires no pesticides and needs little water, yet it renews the soil with each growth cycle. It’s long roots prevent erosion and help retain topsoil. Hemp grows readily in most temperate regions.In many ways, hemp could be considered a miracle fiber. Consider the advantages:
- Strong: Clothing made of hemp fiber is lightweight, absorbant and, with three times the tensile strength of cotton, strong and long lasting.
- Weather Resistant: UV and mold-resistant, hemp is excellent for outdoor wear.
- Versatile: Hemp can be blended with other fibers for different qualities in the garment. Hemp/silk and hemp/cotton garments are now available.
- Cost-Effective: Hemp is less expensive to farm because of its minimal growth requirements.
- Easy on the Environment: Hemp farming uses very little water, does not require the use of chemical pesticides or fertilizers, and is a readily renewable resource.
The cellulose fiber from hemp is used to make many products, including
jeans, shirts, dresses, hats, bags, ropes and canvas, skin care
products, building materials, paper and many food products. Until the
1920’s, 80% of clothing was made from hemp textiles.
Hemp can be grown with little or no chemical fertilizers, herbicides
or pesticides. Nothing is wasted in the production process: seeds are
used to make oil and food supplements, while the stalks are used for
fiber. Hemp also produces more fiber per acre than trees, and can be
renewed two to three times per year!
China, the world’s leading producer of hemp fabric, uses chemical
methods for processing hemp, while producers in Europe have begun
using cleaner biologically-based enzyme technology. Neither method
produces fabric with the same whiteness and softness as cotton. As a
consequence, hemp clothing is often blended with cotton, which from an environmental perspective, consumes far more resources than hemp.
To address this concern, Hemptown Clothing and the Canadian Federal
Science Organization NRC have collaborated to patent an innovative
enzyme process that transforms industrial hemp into a soft, white
Canadian cotton product, called crailar.
Unfortunately, the politics of hemp has for over 60 years interfered
with the development of hemp-based textiles and many other useful hemp products. A campaign of misinformation, initiated early in the 20th century, stands in stark contrast to scientific evidence. The hemp
plant commercially grown for fiber has no significant value as a
Today, hemp is grown around the world. The plant is harvested all
throughout Europe, Russia, China and Canada. The best way to encourage the legalization of commercial hemp farming in the United States, which is getting closer every year, is by purchasing hemp-based
products. Supply will follow demand.
The value of this versatile, easy to grow, eco-friendly crop is
becoming more and more apparent. For example, Canadian hemp farmers make $80 per hectare while American grain farmers make $8. This represents a promising option for farmers whose current crops
experience reduced demand. Tobacco farmers take note!
Deep Green Festival and Conference Brings Medical, Ecological and Economic Benefits of Cannabis to Light
Second Annual Earth Day Weekend Event Combines Speakers, Music, Vendors and Educational Exhibits at the San Francisco Bay Area’s Craneway Pavilion
February 22, 2012, San Francisco – At a time when 50% of the U.S. populace believes cannabis should be legalized and the federal government is attacking the existing state-regulated medical cannabis industry, Deep Green will for the second year present a thorough and insightful exploration of the cannabis plant as a vital medical and industrial resource.
Featured on the Discovery Channel reality TV show, Weed Wars (Season 1, Episode 4, aired December 22, 2011), Deep Green is the leading high level gathering of leaders in the cannabis and hemp fields, visionaries and musical performers.
The Festival will feature 3 stages of music and performances, presentations by top experts, industry leaders, and luminaries, and 100 vendors and exhibitors in a public exposition of the cannabis plant and its range of uses and benefits to society. Main stage music acts include the conscious hip hop group Luminaries, Indubious, Dogon Lights, Human and Jillian Ann. Festival speakers include Chris Conrad, Debby Goldsberry, Ed Rosenthal, Dale Gieringer, Ralph Metzner, Steve and Andrew DeAngelo (founders of Harborside Health Center and stars of Weed Wars).
The festival will also feature entertainers Swami Beyondananda, Ngaio Bealum and Sherry Glaser, an Eco Fashion Show MC’d by cannabis journalist and model Dragonfly De La Luz, an outdoor green edu-tainment zone from the nationally acclaimed Sustainable Living Roadshow, plus a variety of informational displays and multimedia conveying the 21st Century story of cannabis hemp.
The Conference will feature in-depth panels and workshops with 25 top experts addressing current medical cannabis research, cannabis/hemp legalization, organic agriculture, medical dispensary management, families and prohibition, industrial hemp, organic agriculture and more.