Compassion Clubs Presentation to Health Canada - 2003 Forum
Below are speeches made to Health Canada on May 12, 2003 by the founding directors from 2 major compassion clubs in Canada.
In 2002, the Canadian Senate Committee advised the Canadian federal government that "No attempt has been made in Health Canada's current research plan to acknowledge the considerable expertise currently residing in the compassion clubs." Here's what Health Canada is ignoring:
Vancouver Island Compassion Society - Medusers Group
Health Canada Presentation by Philippe Lucas
May 12th, 2003
Introduction:
Today Hilary and I will present you with a working model of compassionate medicinal cannabis distribution. The distribution of therapeutic cannabis through compassion societies is safe, self-policing, and effective.
It is done on a non-profit basis and at no cost to the taxpayer; and unlike Health Canada's own Office of Cannabis Medical Access, it has succeeded in relieving the suffering of thousands of critically and chronically ill Canadians.
History of Medicinal Cannabis:
Used by all of the major civilizations as a medicine. Its safety profile is legendary, with no overdose deaths in over 3000 years of recorded use.
It was an important component of pharmaceutical medicines worldwide until well into the 20th century (part of U.S. pharmacopoeia from 1850-1941).
Cannabis-based medicines were marketed by Squibb, Eli Lilly, and Parke-Davis until the introduction of the Marijuana Tax Act in 1937.
Modern day
Early nineties, at the peak of the AIDS epidemic: Dennis Peron and the San Francisco Cannabis Buyer's Club. In 1996, California's prop 215 made medical marijuana a legal reality at the state level. There are currently 8 states that have legalized medicinal cannabis since then.
In Oakland I recently visited a club that serves over 15,000 members and sells over $60,000 of cannabis each and every day. It is estimated that California alone has over 30,000 users, dwarfing our own national program.
In Canada
The story begins with Hilary Black and the BCCCS - over 6 years in operation, over 2400 members. Unlike American clubs, Canadian organizations have overwhelmingly chosen the non-profit route for the distribution of medicinal cannabis.
The VICS. 3.5 years in operation, over 300 members, all with a physician's recommendation for cannabis. As for Health Canada's own history: in 1999, Health Canada was forced through the Terry Parker ruling at the Ontario Court of Appeals to institute a therapeutic cannabis program.
This led to the section 56 exemption program, which was then found by the courts to be too onerous and arbitrary, resulting in the Medical Marijuana Access Regulations. This year the MMAR were found to be unconstitutional (and therefore illegal), and that brings us up to date.
Overview of clubs, their membership, and legal status:
There are currently about 12 established orgs in Canada; over 5000 Canadians currently get their medicinal cannabis from compassion clubs.
Except for the Nelson and the Vancouver clubs, all of these organizations have have suffered legal difficulties. Over the last three years, clubs in Montreal, Toronto and Victoria have suffered police busts.
The Sunshine Coast Compassion Society had to close when the police threatened the director - a young mother - with the removal of her child. A for profit club in Victoria has suffered 4 busts over the last 24 months.
Some of these prosecutions haven't been for naught. Both the busts in Montreal and at the VICS have resulted in excellent legal decisions. In the case of the Montreal club the judge cited Health Canada's ineffective OCMA program as reason enough to stay the charges; and as for my arrest on behalf of the VICS, the judge praised our good work and granted me an absolute discharge, ordering the police to return our money and our equipment.
The bust at the Toronto Compassion Club has led in part to the Hitzsig decision, which declared the MMAR unconstitutional and gave Health Canada until July 8th of this year to begin distribution, or to have all laws governing personal possession of cannabis in Canada rendered null and void. Although Health Canada has appealed the decision, the judge's order - and that July 8th deadline - stands.
Unfortunately, even these positive legal decisions have come at a high cost: the continued prosecution and suffering of some of Canada's sickest citizens.
History between Health Canada and the clubs:
Over 2 years ago Hilary and I met privately with then Health Minister Alan Rock to discuss the evolution of the medical marijuana program:
At that time Health Canada had the full intention of distributing the PPS cannabis directly to exemptees. In fact, preceding the ministerial change they came within a few weeks of doing so (this fact has been introduced and accepted by the courts in the Hitszig decision).
At that time HC recognized that the unique experience and expertise found within Canada's compassion clubs would be invaluable to the OCMA. Unfortunately, since Minister McLellan took over the portfolio, our relationship with Health Canada has not been nearly as productive or cooperative - until now, that is.
Research:
Health Canada has consistently stated that it wants to research the potential therapeutic benefits of cannabis before making the drug available to patients. The truth is that despite the near absence of North American clinical research into cannabis during the 80's and 90's, cannabis is one of the most studied therapeutic agents known to man. There are literally thousands and thousands of in vivo and in vitro studies that have been conducted over the last 30 years.
Because of the restrictive legal regime in North America, clinical cannabis research has been severely restricted.
Currently the only legal source of cannabis for research purposes is a product grown at the University of Mississippi and tightly controlled by the National Institute on Drug Abuse.
This cannabis is legendarily bad:
It is low in active cannabinoids (meaning people have to smoke more in order to get positive affects), full of stems and seeds, and far below the quality of most street cannabis.
It is so bad that American researchers have seen their studies stymied because participants have chosen to go back to black-market supply rather than continue using NIDA's weed.
Sadly, until this week's HC announcement regarding the suitability of the PPS stock for research, this was the only supply available for Canada's own research projects. By comparison, here's a product grown organically by one of our cultivators.
Not only has the supply of research-grade cannabis been inadequate, Health Canada's own research agenda leaves much to be desired:
In over 3 ½ years and more than $10 million spent, HC has only approved two research proposals, neither of which has actually begun.
It has taken over two years for even good research proposals like Dr. Mark Ware's neuropathic pain study to even get off the ground.
We feel that it is absolutely unethical for a compassionate use program to make those who could immediately benefit cannabis wait for an anemic and otherwise theoretical Health Canada research agenda to be completed before allowing access to this incredibly benign substance.
Health Canada is forcing critically and chronically sick Canadians to get their medicine from the black market; as the courts have consistently found, this is unconstitutional, immoral, and totally unacceptable. I'm sure that you'll agree that the clubs offer a safer, saner, more compassionate alternative.
As a result of the slow pace and politics involved in North American therapeutic cannabis investigations, some of the clubs have decided to take research into their own hands; the VICS and the BCCCS has been at the forefront of this move.
At the VICS, we feel that medical marijuana is a scientific and health issue, not a political one; so we have reached out to interested researchers and organizations - both public and private - to develop a research agenda that already dwarfs Health Canada's own investigations:
Over the last 6 months, the VICS has begun a strain/symptom survey protocol with the other Canadian compassion clubs in order to determine if certain strains of cannabis are more effective for certain symptoms or conditions.
We have also launched a fascinating hep-c and cannabis study with Dr. Diana Sylvestre of the University of California, San Francisco. Her research has suggested that Hep-c sufferers who use cannabis have a much higher success rate with the interferon/ribovarin treatment than non-users.
The VICS has teamed with the BCCCS to see if our joint member base has a similar success rate. This discovery could potentially save the Canadian health care system millions of dollars through improved treatment outcomes.
We are currently awaiting final approval from the UBC Ethics committee to begin research with UBC and UVic into cannabis, nausea, and pregnancy.
Perhaps most exciting, before the end of the summer the VICS will begin a double-blind clinical study investigation into the analgesic effects of different cannabinoids - specifically CBD and THC - on chronic pain; we're hoping to determine whether or not CBD play a role in pain modulation. This study protocol is similar to Dr. Ware's fascinating McGill study, except that we'll be using much stronger, organically-grown medicine. We hope to have the results of this study by mid-fall.
All of this groundbreaking research is being conducted for free, and with the intention of making the results of all of these studies publicly available; so that both medical users and researchers alike can benefit from our knowledge and experience.
So before I introduce Hilary, let me reiterate: the Canadian Compassion Clubs are an established, effective, safe source of medicine; we are now also the main source of therapeutic cannabis research in Canada.
Unlike the OCMA, we have actually succeeded in helping ease the suffering of sick Canadians; and, as you will soon hear from Hilary, our work goes far beyond simply supplying cannabis.
In closing, I'm going to ask you all to draw on as much empathy as you can for the situation of those that depend on medicinal cannabis for their health. I'd like you to imagine that for you, medical marijuana isn't just some controversial political term, but a reality.
Imagine that your own experience undeniably led you to know that it worked. Imagine that it allowed you, or perhaps your wife, or husband, or son or daughter to sleep, or to eat, or to keep working, or to simply ease suffering and maybe even add a bit of happiness to a stunted life.
This is a reality for thousands of Canadians. For myself, a sufferer of hep-c, medicinal cannabis isn't a theory, it's an undeniable reality.
Now please imagine that you have gone through almost 4 years of effort to get Health Canada to recognize even this most basic of medical needs.
Imagine constantly fearing arrest for using something that you know helps to keep you healthy, and being told that it may be years still before a supply is made legally available. Imagine not even having direct representation in the Advisory Committee charged with deciding your fate through this program?
I ask you, the members of this important committee, how would you tolerate these continued injustices? How frustrated, scared and angry would you be?
And I ask you, knowing what I know to be true - that cannabis is undeniably a medicine - I ask: what laws wouldn't you break to help ease the suffering of someone that you love?
Thank you for your time and your continued hard work; together I know that we can help thousands of Canadians.
Now may I present Miss Hilary Black.
(see below continuation)
Hilary Black and the B.C. Compassion Club Society:
Presentation to Health Canada Medical Marijuana Stakeholder Advisory Committee - May 12th, 2003.
Introduction
Good morning. I am glad to have this opportunity to share with you some of the knowledge essential to the task before you. Thank you for having me.
The package before you contains reports, forms and other information answering some of your questions more thoroughly than I am able to in the limited time available here today.
In particular I want to point out the standards for medicinal cannabis distribution. This document outlines the framework for operating a successful cannabis dispensary and contains valuable information.
Values
I am going to read you our values and the philosophies that guide our work.
Developing a value-based foundation would assist this committee in your work and would answer many questions other stakeholders have about what you are working towards.
Club
This presentation will give you an overview of our organization, and answer some of your questions about our work.
The BC Compassion Club Society is a registered non-profit society. We have been successfully distributing medicinal cannabis to those in need for six years. We currently serve a membership of 2500 and employ 42 staff.
Our organizational structure is non-hierarchical and we utilize a consensus model of decision-making.
Authorities
We are a functioning model of a community-based, cannabis distribution center with no government involvement. We have solid relationships with our neighbors and local authorities. Any concerns that they have had are not because of the services we provide, but because we are breaking the law.
The Vancouver police have left us in peace, only coming to the club when their assistance is requested. We have met with the head of the Drug vice squad, and have a mutual understanding.
The municipal government has never interfered in the delivery of our services and we are presently working together to develop a strategy for our expansion, in order to meet the overwhelming demand for our services.
We have also worked with government at the federal level. Former Federal health minister Allan Rock consulted with us in the original development phase of the MMAR regulations. The report we prepared for him is in your package.
We testified before the senate committee on illegal drugs, and met with the senators in our facilities. The Senates' recommendations pertaining to the Compassion Club and Health Canada are in your package.
Access, Eligibility & Requirements
Our method for determining who is eligible for membership is important for authorities to understand in order to feel comfortable with our organization.
Ultimately, we believe cannabis should be accessible and available in a similar manner as other medicinal herbs. Cannabis is a non-toxic and highly effective medicinal herb that can be safely self-prescribed and its dosage safely self-titrated.
Due to the current legal climate we require recommendations for cannabis from physicians, Naturopathic Doctors, or Doctors of Traditional Chinese Medicine, or a Health Canada license. We believe practitioners of natural healthcare are more knowledgeable about the recommendation, dosage, and monitoring of herbal medicine.
Health care practitioners often refuse to recommend cannabis based legal concerns and pressure from their governing bodies, such as the CMA, and due to the stigma surrounding this herbal medicine.
While Allopathic Doctors are the gatekeepers to medical cannabis, it is your responsibility to ensure Doctors are educated, and empowered to recommend cannabis, so patients are not shamed and shut down as they ask for their support, as so often happens. Potential members have come to us in tears after requesting support for their use of medical cannabis, and being treated like a naughty teenager.
Doctors are refusing to fill out both the MMAR and Compassion Club forms. Therefore, in some cases we accept members based on a confirmation of diagnosis, without a specific recommendation for cannabis faxed from the Drs office. Some Doctors are more comfortable with this.
Please look at the physician statement, left side, second document, third page.
We verify each recommendation over the telephone and collaborate with Doctors as necessary, particularly in regards to mental health patients.
Medical Community
The medical community sends us referrals every day, and we are consistently asked to present to a wide variety of organizations and institutions who want information regarding medical marijuana, such as:
Multiple Sclerosis Society
HIV/AIDS society
BC Coalition of People with Disabilities
Riverview Psychiatric Hospital
St. James Hospice
University of British Columbia
Capilano College
The Justice Institute
groups of nurses and physicians.
Who Our Members Are - Demographics
The medical community refers to us members from every walk of life. They range in age from 9-90
Uses
The vast range of symptoms and conditions for which we have received Doctor recommendations is detailed in your package. The most common conditions are:
HIV/AIDS
Cancer
Multiple Sclerosis
Arthritis
Chronic Pain
Seizure disorders
Glaucoma
Hepatitis C
Crohn's/Colitis/IBS
Anxiety
Depression
Insomnia
Anger Management
Eating disorders
Substance abuse
Harm Reduction
With access to cannabis and alternative healthcare, and support of the community at the Compassion Club, we have assisted people to overcome their addiction to heroin, cocaine, crack, methadone, alcohol, morphine, codeine and other prescription medications.
Education
Each new member is given an orientation session tailored to their condition. These hour and a half sessions cover:
The basics about the plant
The products available, such as baked goods and tinctures
Techniques for safe use
The variety of stains available and their effects
Please see the safe and effective of medicinal cannabis pamphlet in your package.
It is important to thoroughly educate members about the strains because cannabis from the Indica and Sativa families have very different cannabinoid profiles and therefore have very different effects.
Armed with this information, members are able to relieve their symptoms effectively.
The following are general tendencies but effects vary from person to person:
Primarily, the effects of Sativas are on the mind and emotions. In this regard they tend to stimulate, uplift, energize and enhance creativity. These benefits can be particularly helpful for the psychological component of many illnesses. Sativas are generally better for daytime use.
Some reported benefits of Sativa strains are:
reduces depression
relieves headaches and migraines
reduces awareness of pain
reduces nausea
stimulates appetite
and is an expectorant
The effects of Indicas are predominantly physical although the relief of physical symptoms can have an emotional result as well. Indicas tend to relax, sedate, and reduce pain. Indicas are generally best for later in the day and before bed.
Some reported benefits of Indica strains are:
relaxes muscles
relieves spasms
reduces inflammation
aids in sleep
reduces anxiety and stress
reduces nausea
stimulates appetite
relieves headaches and migraines
reduces intra-ocular pressure
is an anti-convulsant
reduces seizure frequency
is an expectorant
Hybrids or crosses are the result of cross-pollination of various strains. The characteristics, and the effects, of one strain will usually be dominant. For example, Indica-dominant crosses are good for pain relief, with the Sativa component helping with energy and activity levels, making it particularly effective for day-time pain relief.
We are beginning to identify particular varieties that are effective for sleep, pain, appetite and energy as well as for other specific conditions. In the future, we will conduct research on strain and symptom correlations and will have cannabinoid profiles for our members so they can more accurately select the desired strain for the desired effects.
Distribution
Our daily menu offers 7-10 varieties of cannabis, which can be accessed in person, through our home delivery service, or through our mail out program.
It is essential, for all our members to have access to a wide range of strains in order to effect a wide variety of symptoms and conditions. The prolonged use of a single strain will result in tolerance, while using a variety of strains will minimize the build up of therapeutic tolerance.
It is important to have a variety of cannabis products available. These products include:
Baked goods, some of which are wheat and sugar free, as many patients must avoid these ingredients in their diets.
Hash, which provides a concentrated dose of cannabinoids, allowing members to consume less plant matter to obtain the desired effect.
Tinctures
Cannabis infused oil and butter for cooking at home.
Note that the Access Regulations (MMAR) do not allow possession of hash, oil or tincture. This unreasonably restricts the ability to medicate effectively.
Members keep track of their own use in order to find the most effective strain and mode of ingestion. We also keep close records monitoring members purchases, in order to assist members to track their own consumption, and for us to prevent reselling and to encourage responsible use.
Each member may access the equivalent of five grams per day. Some people actually require more to control their symptoms and compassionate exceptions are made. Others may be using cannabis as an escape from emotional issues, or may have an increased tolerance from over use of a particular strain. For these members we offer access to counseling as an option for handling emotional issues. We also recommend a therapy, such as acupuncture or herbs, to assist in the relief of symptoms, therefore potentially lowering the quantity of cannabis required.
Cost
Cost of medicine is a huge concern for all Canadians, and is no different for users of cannabis.
We encourage our members to use the smallest quantity possible to minimize bronchial irritation and to reduce the cost of their medicine. The price of our cannabis ranges from $5-$10 a gram. Some of our growers give us compassionate prices, which are passed on to our members.
The price of cannabis is artificially inflated. Due to prohibition, the price is closer to the cost of gold, rather reflecting the actual cost of production, which is closer to the cost of tomatoes. There are times when members must choose between buying groceries and buying their cannabis. Rather than have food rotting in the fridge that they are too ill to eat, they buy their medicine.
Since most of our members are living on very low fixed incomes, we try to provide some of their medicine to them at no cost. Our donation program provides 2 grams per week to each member, while supplies last. With our growing membership and increase in poverty due to devastating provincial government cuts to the disability benefits, our program is not able to meet the need for free cannabis.
It is imperative that this medicine, like other medicines that are used for the same purposes, be covered by provincial health care insurance.
Supply
It is essential that medicinal cannabis is both affordable and of the highest quality. This means it must be free of chemicals and micro-organisms.
Many people using medicinal cannabis have compromised immune systems, or chemical sensitivity and may be seriously harmed by consuming contaminated cannabis.
Compassion clubs reduce this, and other potential harms of procuring medicine on the black market. We have an arrangement with a laboratory willing to engage in civil disobedience in order to guarantee the cleanliness of our medicine.
The Compassion Club aims to have a 100% organic supply. We presently educate our growers on organic growing methods. Eventually we hope to see all cannabis dispensaries distributing only certified organic cannabis.
It is unnecessary for suppliers of medicinal cannabis to be certified botanists or horticulturists. The cultivation of high quality cannabis requires experience and dedication.
The producer's priority must be to create a high quality product, rather than high quantities, as is the priority with commercial growers. Medicinal growers will work with challenging strain that require more time and space to cultivate than commercial strains, although this increases their costs.
We give contracts to these compassionate growers who are growing high quality medicine and offer below black market prices. It is important in this legal climate of prohibition to have a verbal contract or written agreement in order to verify the relationship in a court of law.
We prioritize purchasing from the few members who are also growers, as we are committed to their financial empowerment.
Our members face many challenges in growing their own medicine:
Setting up a medical grow facility requires a significant initial investment which is out of reach of many of our members
Those living in poverty do not have extra space in their homes to dedicate to cultivation
Most of our members do not own their homes, and have landlords to contend with. Even some of those with Health Canada licenses have been threatened with eviction for cultivating their legal medicine.
Some, who are home-owners have had their house insurance revoked.
We work with as many growers as necessary to fulfill the demand of quantity and variety of strains. It is preferable to work with a diverse group of growers in order to offer assurance of our supply.
The medicinal cannabis community is concerned that the only legal supply will be limited to one or a few government-approved producers. Competition in a free market, on the other hand, will increase the quality, broaden the selection, and decrease the end cost of the medicine.
The illegal work of the medical cannabis community must be legitimized, valued and protected.
Staffing
While the legal status of medicinal cannabis remains dubious, it is crucial employees of a cannabis dispensary fully understand the legal risk they are undertaking to distribute medicinal cannabis.
Those distributing cannabis are not required to be healthcare professionals, however they should have should have experience with persons with disabilities, and be very familiar with cannabis.
It is important they have first aid training in be prepared to handle infected blood, seizures, strokes, falls, and mental health issues. They should also have an understanding of poverty and the surrounding issues, and be truly compassionate people.
Upon being hired at the Compassion Club employees are thoroughly educated regarding cannabis.
Wellness Centre
The Compassion Club also employees the practitioners of our Wellness Center: clinical Herbalists, clinical Counselors, a Nutritional Counselor, Doctors of Traditional Chinese Medicine, a Reiki practitioner, an Acupressure Massage Therapist, and a Yoga instructor.
These services are subsidized by the distribution of the cannabis. Members are charged on a sliding scale of $3-$30 for Wellness Center services.
Through our Wellness center, we encourage the holistic use of cannabis, one of many medicinal herbs, as we recognize that cannabis is generally not a cure, but a tool, which is a preventative medicine, provides symptom relief and improves the quality of life.
Community
The community aspects of the Compassion Club also ameliorate the quality of life for our members.
We have a smoking lounge where our members can medicate in a safe space, leaving the fear and stigma of being a lawbreaker at the door. This is an environment that facilitates social support. Many of our members lived in isolation before becoming apart of our community, and the club has become their only social outlet. Members have become best friends, roommates, and even gotten married and begun a family.
The pharmacy model simply cannot provide the benefits of the environment or community we are able to provide.
Member Satisfaction
Our members appreciate the services we provide for them. They understand we are risking arrest, imprisonment, our ability to travel, to be employed, and our freedom, in order for them to have access to their medicine of choice.
They are satisfied with our services. Many times members have given us credit for saving their lives.
We have regular contact with our members, allowing us to note changes in their health and well being, and to answer any questions and address their concerns on an ongoing basis.
We have an environment of open and honest communication and encourage member feedback. This happens verbally, in writing, or at our monthly members meetings.
We also have a formal process for handling serious conflicts and complaints. We believe an environment of transparency and accountability is essential.
Recommendations
The following 9 recommendations address our current concerns, and those of medical users who feel this is not an inclusive, transparent or accountable process.
These recommendations are outlined in your package:
1. Inclusiveness and Transparency
The regulation have been unable to meet the needs of medical cannabis users both those with and with out licenses. As a result this program has been considered unconstitutional in the courts.
In order to address the needs of medical cannabis users and meet the criteria set for the by the courts it is obvious this committee must have permanent inclusion of medical user and compassion club representatives.
2. Decentralization
We recommend that like other natural health products and pharmaceutical medications, the lawful possession of medicinal cannabis should not require authorization from a centralized federal body.
If cannabis is to be regulated within the healthcare system and require the input of a healthcare practitioner, the choice as to its use must be a health care decision made by both the patient and the health care practitioners. It is inappropriate for the government to interfere in this decision by limiting its use.
3. Practitioner Authorization
We recommend that regardless of the condition in question, one recommendation from a general practitioner or certified alternative healthcare provider, such as a Naturopathic Dr., or a Dr. of traditional Chinese Medicine, is sufficient authorization to legitimize use, or to access Health Canada's medicinal cannabis program.
The current application process is far too onerous especially for non-terminal patients who must seek the support of one or two specialists. The specialist requirement also places an unnecessary burden on the healthcare system.
4. Costs
The costs of medicinal cannabis must be subsidized by our healthcare system.
It is essential that people be able to access their medicine of choice regardless of their level of income. Seriously ill people also tend to be those living in the most poverty. People who have obtained their doctor's recommendation for the use of cannabis have substantiated their medical need. This should be sufficient for cost coverage as is given for other prescription drugs.
5. Amnesty
Medicinal cannabis users, distributors and their suppliers must be given amnesty immediately.
Many have been and will continue be tied up in lengthy and expensive legal proceedings. These resources should be spent on providing suffering Canadians with access to medicinal cannabis, instead of fighting criminal charges. While the regulations regarding the supply and distribution of medicinal cannabis are being developed, prosecution of those doing this valuable work must end.
6. Legitimize Community-Based Distribution Centers
All non-profit, Compassion Clubs should be licensed and accepted by all levels of government.
The Compassion Club model has been recognized by the Senate and many provincial judges for providing the services the government has so far failed to provide.
Non-profit compassion societies provide a wealth of services, knowledge and experience the pharmacy model cannot recreate. The pharmacy model for the distribution of cannabis will not meet the needs of all medical cannabis users. Legitimizing non-profit distribution centers will provide those in need with access to valuable services and knowledge, save the government a significant amount of money, and will prevent commercialization of and profiteering off medicinal cannabis distribution.
7. Whole Plant Cannabis vs. Synthetic Pharmaceutical Products and Extracts
It is crucial that medicinal users of Cannabis continue to have the choice to use the whole plant medicine.
Our members have reported tremendously negative side effects from synthetic versions of the isolated active ingredients of cannabis. Were pharmaceutical companies able to replicate the exact ratios of all the active ingredients in Cannabis, many people would still prefer to use natural healthcare products.
This right to choose natural health care products must be defended as an essential health care choice.
The regulations mention pharmaceutical products and apply the language of pharmaceutical drugs to Cannabis. While it is evident that synthetic Cannabis is of great interest to the pharmaceutical industry, those interests should not supercede the interests of the already existing and flourishing natural medicine industry.
8. Monopoly of Supply
The plethora of experience and expertise regarding production within the medical cannabis community must be legitimized, valued and protected.
We are concerned that the only legal supply will continue to be limited to one or a few approved producers. Competition, in a free market, on the other hand will increase the quality, broaden the selection, and decrease the end cost of the medicine.
9. Natural Health Product
Cannabis is a natural health care product and should be regulated as one.
Conclusion
Compassion Clubs are stakeholders in the development of these regulations. We are actually providing access to this effective medicine, while members of this committee who are deeply invested in the status quo of prohibition, are influencing the creation of regulations, which cater to prohibition, not to a true healthcare agenda.
Community based, non-profit Compassion Clubs are an effective, affordable, sensible, and time proven way, not only to distribute medicinal cannabis, but also to provide suffering Canadians with valuable services no other model can offer.
The success of the Compassion Clubs in providing access to thousands of patients is possible because we believe that the prohibition of cannabis does not apply to those in desperate need, nor to those providing their medicine.
The pharmacy model may work for some, but receiving a bottle of cannabis from a pharmacist without the education and support we offer, will certainly not work for most. We are not here to protect our livelihoods. I earn 14$ hour. We are here because we are dedicated to the people whose lives you now hold in your hands.
Hilary Black
Presentation to Health Canada
May, 2003.
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