Testimony to the New Jersey Cannabis Regulatory Commission
June 1, 2021
What non-oil-based concentrates and edible products would make medical cannabis easier to take, more effective, and more accessible? Should similar products be available to recreational users?
How would new product types—particularly those with high potency—impact public health and safety?
What products would make medical cannabis easier to take, more effective, and more accessible?
Edible products were approved for New Jersey’s Medicinal Marijuana Program (NJ MMP) patients during the Christie administration, but for minors only(!) Edible products were approved for all NJ MMP patients during the Murphy administration but have never become available through the Alternative Treatment Centers (ATCs). Only lozenges are currently available for sublingual use. Patients and caregivers have been forced to create their own edible cannabis products from the flower purchased at the ATCs. Alternately, edible products are also available on the unregulated black market.
To assist patients and caregivers, the Coalition for Medical Marijuana--New Jersey, Inc. (CMMNJ) produced the “Patient Handbook 2015” that contained easy to follow recipes, with photos, that were submitted by three CMMNJ Board members. These recipes included “Making brownies—How to prepare edibles with consistent amounts of THC,” “Cannabis butter: Crockpot small batch cannabutter,” and, “Butter and…salad dressing?”
CMMNJ also produced a 28-minute YouTube video, “CMMNJ TV with Amanda Hoffman.” CMMNJ Board member Hoffman demonstrated the process for making edible forms of cannabis. The video is available at: https://www.youtube.com/watch?v=NApjPNDAyyo
Marijuana therapy is highly individualized. The amount that is used each day is determined by what is necessary to control the symptoms of the patient.
New marijuana types have the potential to improve public health and safety. Safety can be addressed by doing exactly what the CRC is now doing—appropriately regulating the production, testing, labeling, packaging, and distribution of cannabis products, including high potency products.
Any edible, inhaled or topical product of any strength should be allowed as long as it is properly produced, tested, labelled and packaged.
CMMNJ endorses the labeling recommendations of Doctors for Cannabis Regulation (DFCR). These recommendations can be found at “Setting the Standard for Cannabis Labeling” https://dfcr.org/labeling
Edibles are especially important for patients. Some patients simply cannot use inhaled types of cannabis either because of their medical conditions, or because of their surroundings, or because of their living conditions such as at health care facilities. Other patients may have a cultural prejudice against the inhalation method of drug administration (“No drug is smoked!”)
High potency edibles get a bad reputation when an inexperienced user tries them. Patients must be made aware of the delayed onset of action of edible products along with the prolonged duration of effect compared to the inhaled method of administration. Otherwise, these patients may inadvertently consume more than is necessary for symptom control and become over sedated. The good news is that no overdose of cannabis has ever produced a fatal result. Dosage levels, generally in 10 mg portions of edible products, should be clearly labelled. Patients who are new to this type of therapy should be instructed to “start low and go slow” with their dosage titration.
On the other hand, patients with high tolerances, or patients with severe medical conditions, or multiple medical conditions, or terminal medical conditions, may need more potent edibles. When tolerance is high, patients may need 50mg or more to feel the desired effects.
In addition, some patients use a combination of edible products for their long-lasting effects while using inhaled cannabis for breakthrough pain or other noxious symptoms. Some patients may need a consistent bioavailability of cannabinoids that can most readily be achieved by edible products.
Anything that patients need should be available to them. This includes a wide variety of edible products.
Marijuana is legal and the State of New Jersey has determined that it has medically beneficial uses. It needs to be liberally available to those who are suffering, and who need it, in the widest possible array of products.
The CRC must be flexible in providing approvals as patients, medical personnel or advocacy groups bring issues to it. The CRC is encouraged to provide liberal authorizations as it develops the required regulations, as opposed to the overly restrictive regulations that were adopted for the MMP during the Christie administration.
With concentrates, medical marijuana should be tested more frequently, ideally after each harvest to allay patient concerns about contaminants.
Patients are also looking for Full Extract Cannabis Oil (FECO), suppositories, and sugar-free edibles.
Public health can be improved by making the widest possible variety of products, including all potencies, legally available to patients who require them.
Should similar products be available to recreational users?
Yes. Public safety can be improved not by banning edibles and other high potency products from the adult use markets, but by regulating the use of these products.
These are products that many New Jersey residents already want and use for their health and happiness. Many so-called recreational, or adult users experience medical benefit from cannabis products for undiagnosed or untreated medical, mental health, or emotional conditions. Patients without health insurance may not be able to afford access to most American health care, including psychiatric care. Other patients may be on the spectrum of some disorder—Anxiety, Bipolar, PTSD, etc.--that negatively impacts the quality of their lives but does not rise to the level of a diagnosable condition. These patients know that cannabis can improve their quality of life, without technically being considered medical marijuana patients.
Edible and other high potency products are already in common use in the state. To ban them only recreates the very marijuana prohibition that voters overwhelmingly rejected in the November 2020 election.
To deter the unregulated market, the legal market should have all the products the black market does. Ideally, NJ residents should have access to the whole plant, full spectrum concentrates, the leaves, roots, and raw cannabinoids, which are all medicinal.
Of course, as with flower products, the CRC should ensure that such products are sufficiently available to patients before being made available to the adult use market.
How do high potency types of marijuana impact public health and safety?
Marijuana has been used throughout the world for thousands of years. It was in the U.S. Pharmacopeia for almost 100 years before it was banned. It was not banned for medical or scientific reasons. It was banned after a campaign of misinformation.
In the 1930’s prohibitionists associated marijuana with insanity, criminality and death. In the 1960’s prohibitionists said that marijuana damaged the immune system and made men grow female breasts. In the 1990’s prohibitionists said marijuana was 10 times stronger than the marijuana of the 1960’s and that now it was REALLY dangerous. (Meanwhile, they would not allow you to have the weaker stuff, either.)
Now prohibitionists are saying there are new dangers associated with high potency marijuana, including mental illness. This is one of the most studied of all cannabis issues, going back to the 19th Century India Hemp Drug Commission report. That report, and most subsequent reports, found no causal connection between marijuana use and mental illness. Just think about it. The rates of schizophrenia in the adult population are stable at about 2% worldwide. The rate is the same in countries like Canada, that has one of the highest percentages of marijuana users, and countries like Japan that has one of the lowest percentages of marijuana users. Moreover, the rate of mental illness was the same in the U.S. before and after the 1960’s when there was an explosion of marijuana use.
It is true that marijuana can precipitate a psychotic episode in a person who is predisposed to mental illness. But so can alcohol and other substances and events in the person’s life. That is not the same thing as being a cause of mental illness.
No, the reality is that marijuana can help many people who suffer from mental illness. That is why there is an increased rate of marijuana use in this population. I am an RN, and I worked in psychiatric hospitals for over five years. It is no surprise to me that patients with mental illness seek out alternatives to currently prescribed anti-psychotic drugs that are often ineffective, often have undesirable side effects, and are often expensive to boot.
Much of the marijuana of today has greatly increased potency when compared to the marijuana of the 1960’s. However, it is a groundless fear that there are new risks associated with this stronger marijuana.
I know from personal experience that the East and West coasts of the United States were saturated with high-grade marijuana by the late 1960’s. (I attended colleges and universities in California and New Jersey from 1967 through 1976 and during that time I earned three undergraduate degrees—Associate in Arts, Bachelor of Arts, and Associate in Applied Science.)
On college campuses, there was Columbian Gold, Panama Red, Thai Sticks, various Jamaican strains, and high-grade Mexican marijuana from the state of Michoacán, to name just a few, that were the equal in THC potency to many of the strains available today.
In addition, there was a wide variety of hashish (hash) on the campuses. Hash was available from Morocco, Lebanon, and Afghanistan. Hash, which is a collection of the resin of the cannabis (marijuana) plant, typically had a THC content of 15% - 20% which made it stronger than most of the marijuana that was available then and equal to some of the stronger marijuana available now.
Hash was desirable precisely because of its potency. A supply of hash would last longer than a supply of marijuana because less was required to produce the desired effect. Also, fewer toxins were introduced into the body because less smoking was required.
A commonly observed phenomenon in the 1960’s was, “Good pot drives out bad pot.” That is, when marijuana of superior quality was introduced in an area, the more inferior marijuana was less sought after and hence became less available. The same is true today.
The explosion of sophisticated cultivation techniques has greatly increased the potency and variety of homegrown marijuana. Now, U.S. homegrown is the equal to any of the legendary international strains of the late 1960’s. This represents progress and the maturity of the U.S. marijuana market. It does not represent the introduction of a new product or a new threat.
With legalization and regulation of marijuana, consumers can have available to them products that are laboratory tested with accurately labeled contents, including cannabinoids and terpenes. Consumers will know exactly what strength they are getting in order to use the substance more safely.
I am also including a brief from the U.S. Cannabis Council on “THC Cap and Ban.” The USCC says capping and banning cannabis products:
⦁ Is not supported by scientific consensus as effective public health policy;
⦁ Have been unanimously rejected by states and state regulators;
⦁ Have negative unintended consequences in criminal justice reform;
⦁ Are pharmaceutically and therapeutically undesirable; and,
⦁ Decrease public safety and increase harms.
Thank you for the opportunity to address this commission.
Ken Wolski, RN, MPA
Executive Director
Coalition for Medical Marijuana--New Jersey, Inc.
219 Woodside Ave.
Trenton, NJ 08618
609.394.2137
www.cmmnj.org
http://cmmnj.blogspot.com/
CMMNJ TV, process for making edible forms of cannabis, with Amanda Hoffman https://www.youtube.com/watch?v=NApjPNDAyyo
Doctors for Cannabis Regulation, “Setting the Standard for Cannabis Labeling” https://dfcr.org/labeling/
U.S. Cannabis Council “THC Cap-and-Ban Policy Brief” http://www.uscannabiscouncil.org/
