New York City, NY– April 23, 2018: Acreage Holdings (“Acreage”) , one of the nation’s largest, multi-state cannabis corporations, has submitted a response to the U.S. Food and Drug Administration’s (FDA) request for comments about cannabis.
Kevin Murphy, the CEO and Founder of Acreage, submitted the following statement to the FDA:
In the United States, cannabis and its derivatives are Schedule I controlled substances in international law. The 1961 Single Convention on Narcotics Drugs and 1971 Convention on Psychotropic Substances both place cannabis in this category, meant for narcotics with a high potential for abuse and limited medical usefulness. The 1971 Convention stipulates that, in making scheduling decisions, the World Health Organization should consider “the extent or likelihood of abuse, the degree of seriousness of the public health and social problem and the degree of usefulness of the substance in medical therapy.”
Because cannabis and its derivatives do not fit this description, our firm belief is that they should be removed from all scheduling. Cannabis presents a low potential for abuse, a low degree of seriousness of public health and social problems, and a fantastic array of medical applications for people suffering from a variety of treatable conditions. Removing it from scheduling under international law would give member nations the freedom to decide whether and in what manner to responsibly regulate the cannabis plant.
Enforcement of cannabis prohibition is expensive. Estimates on its economic cost vary, and are often difficult to ascertain, but global spending on enforcement alone amounts to billions of dollars each year. This money is largely wasted: the global black market for cannabis exceeds $100 billion annually. While these funds could be spent in many better ways, removing cannabis from scheduling would also allow governments to generate additional revenue in the form of sale and excise taxes. In the United States, over $1.3 billion in tax revenue has already been generated from regulated cannabis sales in Colorado, Washington and Oregon alone.
Worse than this hemorrhage of money caused by Schedule I control is that patients in need are suffering from lack of access to the cannabis plant. Cannabis is known to treat dozens of medical conditions ranging from intractable epilepsy to severe pain, from the side effects of chemotherapy to Post-Traumatic Stress Disorder. In the United States, more than two million people have already registered as state-regulated medical cannabis patients.
This is a small fraction of the number who could potentially benefit from cannabis. As an example, we need look no further than our nation’s veterans: 20% reportedly use cannabis to self-treat various medical conditions, but a tiny fraction are registered users due to the VA’s stance against issuing medical cannabis recommendations.
Considering its high degree of medical utility and low potential for abuse, cannabis is wholly unfit for Schedule I controls, which impede not only its medical use but further research. The WHO Expert Committee on Drug Dependence has repeatedly recognized this fact, having called for a move to Schedule II or IV on multiple occasions.
We would suggest, however, that cannabis should not be on any schedule. Like alcohol and nicotine, it is simply not the type of substance for which control is appropriate: its widespread use, and the high degree of uselessness and wastefulness associated with its prohibition, should lead the FDA to recommend to the WHO that cannabis no longer be controlled under international law, freeing member nations as well as regional and local governments to legalize and regulate this extraordinarily useful plant as they see fit.
The FDA’s interest in public opinion is tied to the World Health Organization (WHO)’s recent inquiries into cannabis.
The public comments will be considered in preparing a response from the United States to the World Health Organization (WHO) regarding the abuse liability and diversion of these drugs. The WHO will use this information to consider whether to recommend that certain international restrictions be placed or removed regarding these substances.