Jason Barker - Medical Cannabis Patient & Organizer with LECUA Patient’s Coalition Of New Mexico 
dukecitywellness.blogspot.com
Tuesday, February 28th 2017
New Mexico State Department of Health
Medical Cannabis Advisory Board
Medical Cannabis Program
PO Box 26110
Santa Fe, NM, 87502-6110
Medical Cannabis Program
PO Box 26110
Santa Fe, NM, 87502-6110
Petition: Medical Treatment; Adequate Supply: Removal Of Maximum THC Content Of Concentrates & Other Cannabinoids For Concentrates
(Removal of: 7.34.4.8 L Maximum Concentration of THC in Concentrates)
Table of Contents
Pg. 1 Cover Page
Pg. 2 - 4 Petition Introduction
Pg. 4 - 12 Petition Purpose and Background
Pg. 12 - 14 Relief Requested In Petition
Pg. 14 References
Pg. 14 - 15 Appendix A
Printing Provided By:
Petition Introduction: Adequate Supply: Requesting Removal Of Maximum THC Content Of Concentrates & Other Cannabinoids For Concentrates
New Mexico’s medical cannabis history started in 1978, after public hearings the legislature enacted H.B. 329, the nation’s first law recognizing the medical value of cannabis. The New Mexico’s medical cannabis program (MCP) is the only program in the U.S. that places sole responsibility for regulation on the state’s Department of Health. Doctors must comply with state requirements for patients to be considered for applying to the medical cannabis program.
The Santa Fe New Mexican reported on February 13th (2017) that the New Mexico Medical Cannabis program has grown dramatically from 9,000 patients in 2013 to more than 33,000 today. The Department of Health estimates approximately 500 to 800 new patients join the program weekly. The tremendous growth of the Medical Cannabis Program with new program participants, an increase of 75% during 2016, so that currently means we have almost 45,000 patients benefiting from medical cannabis. The medical cannabis program office is currently processing applications in a 12-14 day range and recommends submitting renewal and new patient applications a minimum of 60 days prior to expiration to allow ample time for processing.
In the Lynn and Erin Compassionate Use Act, (2007) the law states; The Secretary of Health shall establish an advisory board consisting of eight practitioners representing the fields of neurology, pain management, medical oncology, psychiatry, infectious disease, family medicine and gynecology. The practitioners shall be nationally board-certified in their area of specialty and knowledgeable about the medical use of cannabis. The members shall be chosen for appointment by the Secretary from a list proposed by the New Mexico Medical Society. A quorum of the advisory board shall consist of three members. The advisory board shall:
A. review and recommend to the department for approval additional debilitating medical conditions that would benefit from the medical use of cannabis;
B. accept and review petitions to add medical conditions, medical treatments or diseases to the list of debilitating medical conditions that qualify for the medical use of cannabis;
C. convene at least twice per year to conduct public hearings and to evaluate petitions, which shall be maintained as confidential personal health information, to add medical conditions, medical treatments or diseases to the list of debilitating medical conditions that qualify for the medical use of cannabis;
D. issue recommendations concerning rules to be promulgated for the issuance of the registry identification cards; and
E. recommend quantities of cannabis that are necessary to constitute an adequate supply for qualified patients and primary caregivers.
First, do no harm. As an important step in becoming a doctor, medical students must take the Hippocratic Oath. And one of the promises within that oath is “first, do no harm”.
A. review and recommend to the department for approval additional debilitating medical conditions that would benefit from the medical use of cannabis;
B. accept and review petitions to add medical conditions, medical treatments or diseases to the list of debilitating medical conditions that qualify for the medical use of cannabis;
C. convene at least twice per year to conduct public hearings and to evaluate petitions, which shall be maintained as confidential personal health information, to add medical conditions, medical treatments or diseases to the list of debilitating medical conditions that qualify for the medical use of cannabis;
D. issue recommendations concerning rules to be promulgated for the issuance of the registry identification cards; and
E. recommend quantities of cannabis that are necessary to constitute an adequate supply for qualified patients and primary caregivers.
First, do no harm. As an important step in becoming a doctor, medical students must take the Hippocratic Oath. And one of the promises within that oath is “first, do no harm”.
We have a sound law in the Lynn and Erin Compassionate Use Act, as Section 2 reads; PURPOSE OF ACT.--The purpose of the Lynn and Erin Compassionate Use Act is to allow the beneficial use of medical cannabis in a regulated system for alleviating symptoms caused by debilitating medical conditions and their medical treatments.
“ARTICLE 2B. LYNN AND ERIN COMPASSIONATE USE ACT
N.M. Stat. Ann. § 26-2B-2 (2009)
§ 26-2B-2. Purpose of act
The purpose of the Lynn and Erin Compassionate Use Act [26-2B-1 NMSA 1978] is to allow the beneficial use of medical cannabis in a regulated system for alleviating symptoms caused by debilitating medical conditions and their medical treatments.
HISTORY: Laws 2007, ch. 210, § 2.
EFFECTIVE DATES. --Laws 2007, ch. 210, § 12 makes the act effective July 1, 2007.”
Mosby’s Medical Dictionary states that “medical treatment” means; the management and care of a patient to combat disease or disorder. Medical treatment includes: Using prescription medications, or use of a non-prescription drug at prescription strength; and or treatment of disease by hygienic and pharmacologic remedies, as distinguished from invasive surgical procedures. Treatment may be pharmacologic, using drugs; surgical, involving operative procedures; or supportive, building the patient's strength. It may be specific for the disorder, or symptomatic to relieve symptoms without effecting a cure.(Mosby's Medical Dictionary, 9th edition.)
What is a chronic medical condition?
A chronic disease is one lasting 3 months or more, by the definition of the U.S. National Center for Health Statistics. Chronic diseases generally cannot be prevented by vaccines or cured by medication, nor do they just disappear. Harvard Medical Dictionary defines chronic as: Any condition that lasts a long time or recurs over time; chronic pain as: Pain that persists after an injury has healed or a disease is over; and chronic pain syndrome as : Long-term, severe pain that doesn't spring from an injury or illness, that interferes with daily life, and is often accompanied by other problems, such as depression, irritability, and anxiety.
A chronic disease is one lasting 3 months or more, by the definition of the U.S. National Center for Health Statistics. Chronic diseases generally cannot be prevented by vaccines or cured by medication, nor do they just disappear. Harvard Medical Dictionary defines chronic as: Any condition that lasts a long time or recurs over time; chronic pain as: Pain that persists after an injury has healed or a disease is over; and chronic pain syndrome as : Long-term, severe pain that doesn't spring from an injury or illness, that interferes with daily life, and is often accompanied by other problems, such as depression, irritability, and anxiety.
What is the meaning of debilitating?
Something that's debilitating seriously affects someone or something's strength or ability to carry on with regular activities, like a debilitating illness. Debilitating comes from the Latin word debilis, meaning "weak." That's why you'll often see the adjective used to describe illness, despite the negative reference.
Something that's debilitating seriously affects someone or something's strength or ability to carry on with regular activities, like a debilitating illness. Debilitating comes from the Latin word debilis, meaning "weak." That's why you'll often see the adjective used to describe illness, despite the negative reference.
Petition Purpose and Background
The purpose of this Medical Treatment petition is for addressing; “Concentrated cannabis-derived product (“concentrate”)” as it relates to “Quantity of Useable Cannabis That May Be Possessed By A Qualified Patient Or Primary Caregiver”: “Maximum THC content of concentrates”.
The petition for the Medical Treatment; Adequate Supply: Removal Of Maximum THC Content Of Concentrates & Other Cannabinoids For Concentrates (Removal of: 7.34.4.8 L Maximum Concentration of THC in Concentrates) is being provided to bring the state Department of Health Medical Cannabis Program in compliance with the Lynn and Erin Compassionate Use Act.
Currently for patients and primary caregivers in the medical cannabis program, rules and regulations has established to limit patients and primary caregivers to a “Maximum THC content of concentrates: A qualified patient or primary caregiver shall not possess a concentrated cannabis-derived product that contains greater than seventy percent (70%) THC by weight.”
Maximum Concentration Limit ( 7.34.3.9 ) Should be Stricken.
This current regulation is blatantly contradictory to the LECUA, 2007. Concentrates are condensed cannabis medicine with very little plant matter, making them a safe and healthy alternative method of consuming medicine. Cannabis concentrates can have anywhere from 60-90% THC content. Concentrates can be vaporized, baked into edibles, infused into topicals or smoked. Since concentrates are significantly more potent, they are much more effective for use as medicine for patients with serious issues. (http://www.cannlabs.com/patient-resources /concentrates/ )
This current regulation is blatantly contradictory to the LECUA, 2007. Concentrates are condensed cannabis medicine with very little plant matter, making them a safe and healthy alternative method of consuming medicine. Cannabis concentrates can have anywhere from 60-90% THC content. Concentrates can be vaporized, baked into edibles, infused into topicals or smoked. Since concentrates are significantly more potent, they are much more effective for use as medicine for patients with serious issues. (http://www.cannlabs.com/patient-resources /concentrates/ )
Many patients in the MCP wish to minimize smoking medical cannabis. The use of BHO, Rick Simpson oil and similar products can allow users to minimize smoking. Higher quality products also contain fewer contaminants (contaminants here is defined as anything that has not been shown to cure or alleviate patients’ conditions). That the department would seek to ensure quality by testing, then reduce quality by requiring inferior products to be produced/ possessed seems contradictory.
Cannabis concentrates, when used properly, are making revolutionary contributions to the field of cannabis-based medicine. Limiting the amount of THC to the absolute lowest level typically in concentrates will be almost impossible for producers to comply with and restricts the medicinal value. This rule is arbitrary, capricious and completely unreasonable.
Cannabis concentrates, when used properly, are making revolutionary contributions to the field of cannabis-based medicine. Limiting the amount of THC to the absolute lowest level typically in concentrates will be almost impossible for producers to comply with and restricts the medicinal value. This rule is arbitrary, capricious and completely unreasonable.
In the Lynn and Erin Compassionate Use Act, (2007) the law states; The Secretary of Health shall establish an advisory board consisting of eight practitioners representing the fields of neurology, pain management, medical oncology, psychiatry, infectious disease, family medicine and gynecology. The practitioners shall be nationally board-certified in their area of specialty and knowledgeable about the medical use of cannabis. The members shall be chosen for appointment by the Secretary from a list proposed by the New Mexico Medical Society. A quorum of the advisory board shall consist of three members.
The advisory board shall:
A. review and recommend to the department for approval additional debilitating medical conditions that would benefit from the medical use of cannabis;
B. accept and review petitions to add medical conditions, medical treatments or diseases to the list of debilitating medical conditions that qualify for the medical use of cannabis;
C. convene at least twice per year to conduct public hearings and to evaluate petitions, which shall be maintained as confidential personal health information, to add medical conditions, medical treatments or diseases to the list of debilitating medical conditions that qualify for the medical use of cannabis;
D. issue recommendations concerning rules to be promulgated for the issuance of the registry identification cards; and
E. recommend quantities of cannabis that are necessary to constitute an adequate supply for qualified patients and primary caregivers.
First, do no harm. As an important step in becoming a doctor, medical students must take the Hippocratic Oath. And one of the promises within that oath is “first, do no harm”.
A. review and recommend to the department for approval additional debilitating medical conditions that would benefit from the medical use of cannabis;
B. accept and review petitions to add medical conditions, medical treatments or diseases to the list of debilitating medical conditions that qualify for the medical use of cannabis;
C. convene at least twice per year to conduct public hearings and to evaluate petitions, which shall be maintained as confidential personal health information, to add medical conditions, medical treatments or diseases to the list of debilitating medical conditions that qualify for the medical use of cannabis;
D. issue recommendations concerning rules to be promulgated for the issuance of the registry identification cards; and
E. recommend quantities of cannabis that are necessary to constitute an adequate supply for qualified patients and primary caregivers.
First, do no harm. As an important step in becoming a doctor, medical students must take the Hippocratic Oath. And one of the promises within that oath is “first, do no harm”.
Dr. William Johnson, former chair of the New Mexico Medical Cannabis Advisory Board in 2014 told KUNM public radio that many of the changes proposed by the Department of Health would hurt patient access to medical cannabis. After the Rules and Regulations changes from the medical cannabis meetings in 2014 went into effect in February of 2015, the results for patients and caregivers in the program has been clearly harmful to patient well being and overall program health. And it is the patient’s, producers, and medical cannabis community members that are now paying the price in regards to health and financial costs.
How Is The Medical Cannabis Program Out Of Compliance With The LECUA, 2007?
We have a sound law in the Lynn and Erin Compassionate Use Act, in the rules and regulations the Department of Health MCP and MCAB has defined “Concentrated cannabis-derived product (“concentrate”)” means a cannabis-derived product that is manufactured by a mechanical or chemical process that separates any cannabinoid from the cannabis plant, and that contains (or that is intended to contain at the time of sale or distribution) no less than thirty-percent (30%) THC by weight. (7.34.3.7 - DEFINITIONS: L)
The Legislature did not authorize the Department of Health to insert itself into the doctor-patient
relationship and second-guess the merits of a particular prescription. My medical provider, with Lovelace and and another at UNM, has expressed great concern about this because that the explicit and sole purpose of the Lynn and Erin Compassionate Use Act “is to allow the beneficial use of medical cannabis in a regulated system for alleviating symptoms caused by debilitating medical conditions and their medical treatments.” Yes, we can petition to get concentrates above 70% but no one is making them for us to be able to do that because of the Rule.
relationship and second-guess the merits of a particular prescription. My medical provider, with Lovelace and and another at UNM, has expressed great concern about this because that the explicit and sole purpose of the Lynn and Erin Compassionate Use Act “is to allow the beneficial use of medical cannabis in a regulated system for alleviating symptoms caused by debilitating medical conditions and their medical treatments.” Yes, we can petition to get concentrates above 70% but no one is making them for us to be able to do that because of the Rule.
Once more the Department of Health has opened themselves up for even more potential lawsuits for not being compliant with the Lynn And Erin Compassionate Use Act in doing this.
And then that will bring us to Title 7-Chapter 34-Part 3: Registry Identification Card for the complete definitions in Rules and Regulations for “unit” and “useable cannabis” :
“ QUANTITY OF USABLE CANNABIS THAT MAY BE POSSESSED BY A QUALIFIED PATIENT OR PRIMARY CAREGIVER:
A. Maximum quantity: A qualified patient and a qualified patient’s primary caregiver may collectively possess within any three-month period a quantity of usable cannabis no greater than 230 total units. For purposes of department rules, this quantity is deemed an adequate supply. (For ease of reference: 230 units is equivalent to 230 grams, or approximately eight ounces, of dried usable cannabis plant material.) A qualified patient and primary caregiver may also possess cannabis seeds.
B. Calculation of units: For purposes of department rules, one unit of usable cannabis shall consist of one gram of the dried leaves and flowers of the female cannabis plant, or 0.2 grams (200 milligrams) of THC for cannabis-derived products.
C. Maximum THC content of concentrates: A qualified patient or primary caregiver shall not possess a concentrated cannabis-derived product that contains greater than seventy percent (70%) THC by weight.
D. Medical exception: A greater quantity of usable cannabis, not to exceed 115 additional units, may be allowed, and a concentrated cannabis-derived product with THC content greater than seventy percent (70%) by weight may be allowed, at the department’s discretion, upon the submission of a statement by a medical practitioner explaining why a greater number of units of usable cannabis, or a higher concentration of THC in concentrated cannabis-derived product, is medically necessary. Any such allowance shall be reviewed for approval by the program’s medical director. [7.34.3.9 NMAC - N, 2/27/2015]” http://164.64.110.239/nmac/parts/title07/07.034.0003.htm
Concentrated cannabis-derived product (“concentrate”) and “Maximum THC content of concentrates” can not be properly defined or lawfully enforced. The Department of Health can not define this using unknown variables and without having done an assessment of physical and pharmacokinetic relationships in medical cannabis production and consumption. This leads to further examination of how these definitions pertaining to concentrates were determined in the past years.
In order for the Department of Health Medical Cannabis Program to allow for the medical treatment of cannabis, the Department must properly understand “concentrates” and the potency from a medical cannabis and scientific point. For the Department to have both “adequate supply” and understand “concentrates”, they would need to know the different amounts of plant material that goes into all the different types of medicine being produced in the MCP. Dried cannabis flower (bud), pre-rolls, edibles, tinctures, topicals/salves, and concentrated forms of cannabis- all require different amounts of cannabis plant material to produce. This is empirical data that has not been collected, studied or researched within the state’s medical cannabis program by the Department of Health. Even if the patient or primary caregiver is granted the “Medical Exception”, there is no producer currently making concentrates above the maximum limit, and so the state and MCP would still not be in compliance with the LECUA law.
For example, a cancer patient or a patient with Chronic pain, in the medical cannabis program, to be able to receive beneficial use of medical cannabis in a regulated system for alleviating symptoms caused by debilitating medical conditions and their medical treatments under the current law; both patients would need to be allowed to use THC concentrates with potency content of 80-95% THC and a minimum quantity of usable medical cannabis of 425.243 grams per 3 months (or 2.5 ounces every two weeks) to be able to producer this medicine. Types of medicine made from the medical cannabis plants for treating cancer and other debilitating health conditions are a concentrated medical cannabis oil. A three month supply of this concentrated medical cannabis oil requires 450-500 grams (or Units) of dried cannabis flower plant material. (The oil is also known as, hemp oil, Phoenix Tears, and Rick Simpson Oil (RSO), whole-plant cannabis oil can be orally administered or applied directly to the skin. Sublingual delivery is the preferred method of treatment for many cancer patients.)
"Best RSO is 95-98% THC and extremely potent and sedative (with 70% cure rate).” -Rick Simpson
Medical Cannabis Concentrates: Misconceptions Are Leading to Arbitrary Potency Caps
Medical cannabis concentrates are condensed cannabis medicine with very little plant matter, making them a safe and healthy alternative method of consuming medicine. Medical cannabis concentrates can have a potency anywhere from 50-100% THC content (500-1000 mg) and for CBD derived concentrates, a content of 20-50% (200-500 mg) . Concentrates can be vaporized, baked into edibles, used in tinctures, infused into topicals or smoked. Since concentrates are significantly more potent, they are much more effective for use as a delivery system of medicine for people in medical cannabis programs. While pictures or videos of people rolling up joints, smoking pipes or bongs and eating trays of pot brownies are what’s primarily seen of cannabis consumption shown by the media, many prefer concentrated medical cannabis products and wish to minimize smoking medical cannabis. More recently, the media has turned it’s focus to dabs, showing people with a oil rig smoking concentrates and depicting this form of medicine as a concern.
The use of these types of concentrates like; rosin, butane hash oil (BHO), CO2 extracted oils , Rick Simpson Oil and similar products can allow a person to minimize smoking. Higher quality cannabis concentrated products also contain fewer contaminants (contaminants here is defined as anything that has not been shown to cure or alleviate patients’ conditions). Medical cannabis concentrates, are making revolutionary contributions to the field of cannabis-based medicine. For those seeking a stronger effect to target a medical ailment, it is perfect because they can flood their system with cannabinoids and remedy the situation quickly and efficiently. Limiting the amount of THC in concentrates restricts the medicinal value and inadequate dosage necessitates the purchase of multiple products where one would suffice. This in turn increases expense to consumers and creates additional packaging and waste.
Higher quality cannabis concentrate products also contain fewer contaminants (contaminants here is defined as anything that has not been shown to cure or alleviate patients’ conditions). Cannabis concentrates, are making revolutionary contributions to the field of cannabis-based medicine.
However, there are perception issues among people unfamiliar with these potent substances that come in many forms and under many names, from shatter to wax, honey oil, live resin, budder, taffy and others. Adding to the stigma surrounding concentrates are the special pipes and other equipment sometimes used to consume concentrates, including “oil rigs” with nails for dabbing, use of butane torches, and the extraction processes that can be volatile under certain circumstances. In addition to false news stories fostering the “reefer madness” demonization of cannabis reporting fake claims of concentrate consumption related deaths and overdoses. A person can not die from over consumption of cannabis in any form.
Types of Cannabis Concentrates
Butane Hash Oil, commonly referred to as BHO, is a type of cannabis concentrate made using butane as the main solvent. While a number of variables can determine the final consistency of BHO (mostly temperature), people use different names when referring to each of the different consistencies. Shatter for instance, refers to the glass-like consistency that often snaps or “shatters” when handled. Budder, honeycomb, crumble, and sap are also used to describe the different textures, though they all fall under the category of BHO.
Under this form of extraction, THC content can be as high as 80-90%. This makes BHO a popular choice for many medical cannabis patients suffering from chronic pain, sleep disorders, and other intractable symptoms. Always be sure that your oil is lab tested for purity, as improperly purged BHO may contain traces of butane, pesticides, or other unhealthy ingredients/contaminants.
Under this form of extraction, THC content can be as high as 80-90%. This makes BHO a popular choice for many medical cannabis patients suffering from chronic pain, sleep disorders, and other intractable symptoms. Always be sure that your oil is lab tested for purity, as improperly purged BHO may contain traces of butane, pesticides, or other unhealthy ingredients/contaminants.
Carbon dioxide (CO2) is a supercritical fluid, often referred to as CO2 Oil, meaning it converts into a liquid form when under pressure. At the same time, CO2 is a pure chemical substance that occurs naturally and leaves behind no residues. In fact, supercritical CO2 extraction is already a standard extraction method for the food, dry cleaning and herbal supplement industries. It is a common food additive as well. The CO2 extraction process allows compounds to be extracted with low toxicity; it utilizes a high pressure vessel containing cannabis. Supercritical CO2 is inserted into the vessel and pumped through a filter where it is separated from the plant matter once the pressure is released. Next, the supercritical CO2 evaporates and is dissolved into the cannabinoids.
Rick Simpson Oil (RSO), also known as cannabis oil, hemp oil, Phoenix Tears, and whole-plant cannabis oil can be orally administered or applied directly to the skin. Taken as a edible, placing a does under the tongue for delivery is the preferred method of treatment for many cancer patients. Not only is it a convenient way to medicate, but intake through the oral mucosal membranes in your mouth provides for rapid and effective absorption directly into your systemic circulation because of the increased bioavailability of the cannabinoids.
Whole-plant cannabis oil is not the same as “hemp seed oil.” Hemp seed oil is a cold-pressed oil made from the seeds of the hemp plant. It is rich with essential fatty oils and is used mostly for its nutritional benefits. You can easily buy it in health food stores. It often gets mislabeled as “hemp oil,” but it is not. True whole-plant oil derived from the cannabis plant, on the other hand, is made from the buds/flower of the female cannabis plant and is comprised of many different cannabinoids including THC, CBD, CBN, and more — in addition to terpenes and other compounds. Many other businesses now sell their own renditions of Rick Simpson Oil, some of which are high in THC while others contain only non-psychoactive compounds like CBD. Be sure to do your research before making/buying any RSO products.
Whole-plant cannabis oil is not the same as “hemp seed oil.” Hemp seed oil is a cold-pressed oil made from the seeds of the hemp plant. It is rich with essential fatty oils and is used mostly for its nutritional benefits. You can easily buy it in health food stores. It often gets mislabeled as “hemp oil,” but it is not. True whole-plant oil derived from the cannabis plant, on the other hand, is made from the buds/flower of the female cannabis plant and is comprised of many different cannabinoids including THC, CBD, CBN, and more — in addition to terpenes and other compounds. Many other businesses now sell their own renditions of Rick Simpson Oil, some of which are high in THC while others contain only non-psychoactive compounds like CBD. Be sure to do your research before making/buying any RSO products.
Rosin has been gaining a lot of traction in the medical cannabis community as of lately and for good reason. Rosin is a solid form of resin that is obtained by adding pressure & heat to vaporize volatile liquid terpenes, typically with an industrial heat press (or even a hair straightener for small batches).
The rosin technique is quick, simple and affordable, allowing anyone to create quality solventless hash in a matter of seconds. To get started making Rosin, you only need a few basic tools in order to create a quality finished product, but not nearly as many as you need with other extraction techniques.
The rosin technique is quick, simple and affordable, allowing anyone to create quality solventless hash in a matter of seconds. To get started making Rosin, you only need a few basic tools in order to create a quality finished product, but not nearly as many as you need with other extraction techniques.
Concentrates Are Just As Safe As Traditional Flower Use
Researchers at the University at Albany, State University of New York (SUNY) released a study in October of 2014, about the recent widespread popularity of dabbing, including the growing concern in regards to safety. Analysts concluded that dabbing, a slang term that refers to the vaporization of concentrated cannabis, “created no more problems or accidents than using flower cannabis.”
According to the SUNY researchers, this study was conducted with the purpose to “gather preliminary information on ‘dabs’ consumers and test whether ‘dabs’ use is associated with more problems than using flower cannabis.” The results were published in the journal Addictive Behavior.
Abstract
A new method for administering cannabinoids, called butane hash oil (“dabs”), is gaining popularity among marijuana users. Despite press reports that suggest that “dabbing” is riskier than smoking flower cannabis, no data address whether dabs users experience more problems from use than those who prefer flower cannabis.
Objective
The present study aimed to gather preliminary information on dabs users and test whether dabs use is associated with more problems than using flower cannabis.
Method
Participants (n = 357) reported on their history of cannabis use, their experience with hash oil and the process of “dabbing,” reasons for choosing “dabs” over other methods, and any problems related to both flower cannabis and butane hash oil.
Results
Analyses revealed that using “dabs” created no more problems or accidents than using flower cannabis.
A new method for administering cannabinoids, called butane hash oil (“dabs”), is gaining popularity among marijuana users. Despite press reports that suggest that “dabbing” is riskier than smoking flower cannabis, no data address whether dabs users experience more problems from use than those who prefer flower cannabis.
Objective
The present study aimed to gather preliminary information on dabs users and test whether dabs use is associated with more problems than using flower cannabis.
Method
Participants (n = 357) reported on their history of cannabis use, their experience with hash oil and the process of “dabbing,” reasons for choosing “dabs” over other methods, and any problems related to both flower cannabis and butane hash oil.
Results
Analyses revealed that using “dabs” created no more problems or accidents than using flower cannabis.
The study notes that recent press reports have considered “dabbing” to be riskier than smoking flower cannabis. However, the results of this survey refute those claims – there is no data to suggest that “dabbers” experience more problems than those who smoke traditional cannabis flowers.
Use of medical cannabis concentrated oils (or Dabbing) is not a new practice, and in fact, it's been around since the 1970s. Many experts attribute its growing popularity to the commercial production and development of legal medical marijuana and marijuana legalization in some states. In these states, users can often buy hash oil extracts.
Facts About The Medical Conditions That Qualify For The Medical Cannabis Program.
Patients in New Mexico diagnosed with one or more of the following medical conditions qualify into the program and are allowed legal protection under the Lynn and Erin Compassionate Use Act:
Amyotrophic Lateral Sclerosis (ALS) : Can't be cured, but treatment does help. Chronic: lifelong.
Cancer : Chronic disease, can be treated, & average treatment plan length 5 years or more.
Crohn’s Disease : Can't be cured, but treatment does help. Chronic: Lasting several years or lifelong.
Epilepsy : Is a chronic neurological disorder. Can't be cured, but treatment does help.
Glaucoma : Chronic, can't be cured, but treatment does help. ( Can braille cards be printed ? )
Hepatitis C : Chronic, but treatment does help.
HIV/AIDS : Can't be cured, but treatment does help. Chronic: lifelong.
Huntington’s Disease : Can't be cured, but treatment does help. Chronic: lifelong.
Hospice Care :Palliation of a chronically ill, terminally ill or seriously ill patient's pain and symptoms.
Inclusion Body Myositis : Can't be cured, but treatment does help. Chronic: lifelong.
Inflammatory Autoimmune-mediated Arthritis Can't be cured, treatment does help. Chronic: lifelong.
Multiple Sclerosis Can't be cured, but treatment does help. Chronic: lifelong.
Damage to the nervous tissue of the spinal cord :No cure, treatment does help. Chronic: lifelong.
Painful peripheral neuropathy :Can't be cured, but treatment does help. Chronic: lifelong.
Parkinson’s disease :Can't be cured, but treatment does help. Chronic: lifelong.
Post-Traumatic Stress Disorder (PTSD) :Can't be cured, but treatment does help. Chronic: lifelong.
Severe Chronic Pain :Can't be cured, but treatment does help. Chronic: lifelong.
Severe Anorexia/Cachexia :Often a sign of disease, such as cancer, AIDS, heart failure, or advanced chronic obstructive pulmonary disease (COPD). Chronic but treatment does help.
Spasmodic Torticollis (Cervical Dystonia) :Can't be cured, but treatment does help. Chronic: lifelong.
Ulcerative Colitis: Can't be cured, but treatment does help. Chronic: lifelong.
Cancer : Chronic disease, can be treated, & average treatment plan length 5 years or more.
Crohn’s Disease : Can't be cured, but treatment does help. Chronic: Lasting several years or lifelong.
Epilepsy : Is a chronic neurological disorder. Can't be cured, but treatment does help.
Glaucoma : Chronic, can't be cured, but treatment does help. ( Can braille cards be printed ? )
Hepatitis C : Chronic, but treatment does help.
HIV/AIDS : Can't be cured, but treatment does help. Chronic: lifelong.
Huntington’s Disease : Can't be cured, but treatment does help. Chronic: lifelong.
Hospice Care :Palliation of a chronically ill, terminally ill or seriously ill patient's pain and symptoms.
Inclusion Body Myositis : Can't be cured, but treatment does help. Chronic: lifelong.
Inflammatory Autoimmune-mediated Arthritis Can't be cured, treatment does help. Chronic: lifelong.
Multiple Sclerosis Can't be cured, but treatment does help. Chronic: lifelong.
Damage to the nervous tissue of the spinal cord :No cure, treatment does help. Chronic: lifelong.
Painful peripheral neuropathy :Can't be cured, but treatment does help. Chronic: lifelong.
Parkinson’s disease :Can't be cured, but treatment does help. Chronic: lifelong.
Post-Traumatic Stress Disorder (PTSD) :Can't be cured, but treatment does help. Chronic: lifelong.
Severe Chronic Pain :Can't be cured, but treatment does help. Chronic: lifelong.
Severe Anorexia/Cachexia :Often a sign of disease, such as cancer, AIDS, heart failure, or advanced chronic obstructive pulmonary disease (COPD). Chronic but treatment does help.
Spasmodic Torticollis (Cervical Dystonia) :Can't be cured, but treatment does help. Chronic: lifelong.
Ulcerative Colitis: Can't be cured, but treatment does help. Chronic: lifelong.
All of these types of debilitating medical conditions have some common medical facts; treatment plan for 5 years if not lifelong, most all have no cure, all of them are chronic health conditions, and sadly some take a person’s life. They all also require a medical treatment plan with several visits to more than one medical practitioner throughout the course of a year.
For those rules and regulations that have been established limiting patients and primary caregivers to “Concentrated cannabis-derived product (“concentrate”)” as it relates to “Quantity of Useable Cannabis That May Be Possessed By A Qualified Patient Or Primary Caregiver”: “Maximum THC content of concentrates” limited at 70% THC. This current format being used by the Department of Health Medical Cannabis Program in devising adequate supply does not allow for the beneficial use of medical cannabis. This in fact prevents patients from fully being able to alleviate symptoms caused by debilitating medical conditions and their medical treatments and that creates a liable situation for the state being out of compliance with the LECUA, 2007.
Along with the massive medicinal benefits of CBD oil, RSO also contains THC and other key cannabinoids resulting in patients having a much more euphoric medicating session than if they took CBD oil on its own. Research has found tetrahydrocannabinol (THC) to offer very promising therapeutic benefits for many conditions. This is one reasons some patients prefer whole plant cannabis oil over individual cannabinoids. ( Source )
A 30 day supply of medical cannabis oil with a potency of 80-95% THC is 60 grams or ml of oil with a dose of 2 grams or ml per day. It requires 450-500 grams of dried cannabis flower plant material to make high quality cannabis oil. So a 90 day supply or three months is 180 grams or ml of oil or 1425 grams of dried cannabis flower plant material ( Source: Rick Simpson ). Those rules and regulations that have been established limiting patients and primary caregivers does not allow for the beneficial use of medical cannabis and further prevents the purpose of the law to be fulfilled as stated in section two. This also does not allow for the beneficial use of medical cannabis for other medical cannabis medicine products like tinctures and medibles, which further prevents the purpose of the law to be fulfilled.
Medical cannabis patients registered in the New Mexico MCP use the different kinds of cannabis oil with all types of conditions including, but not limited to, Amyotrophic Lateral Sclerosis (ALS), Cancer, Crohn’s Disease, Epilepsy, Glaucoma, Hepatitis C, HIV/AIDS, Huntington’s Disease, Hospice Care, Inclusion Body Myositis, Inflammatory, Autoimmune-mediated Arthritis, Multiple Sclerosis, Damage to the nervous tissue of the spinal cord, Painful peripheral neuropathy, Parkinson’s disease, Post-Traumatic Stress Disorder (PTSD), Severe Chronic Pain, Severe Anorexia/Cachexia, Spasmodic Torticollis (Cervical Dystonia), Ulcerative Colitis, arthritis, diabetes, depression, osteoporosis, psoriasis, insomnia, asthma, burns, migraines, regulation of body weight, chronic pain, and mutated cells (polyps, warts, tumors).
Rules, Regulations, & Policy Solution For The Removal Of Maximum THC Content Of Concentrates & Other Cannabinoids For Concentrates
This petition for the Medical Treatment; Adequate Supply: Removal Of Maximum THC Content Of Concentrates & Other Cannabinoids For Concentrates (Removal of: 7.34.4.8 L Maximum Concentration of THC in Concentrates) approval would make it so the state Department of Health Medical Cannabis Program is in compliance with the Lynn and Erin Compassionate Use Act.
This petition for the Medical Treatment; Adequate Supply: Removal Of Maximum THC Content Of Concentrates & Other Cannabinoids For Concentrates (Removal of: 7.34.4.8 L Maximum Concentration of THC in Concentrates) approval would make it so the state Department of Health Medical Cannabis Program is in compliance with the Lynn and Erin Compassionate Use Act.
WhereAs: "written certification" means a statement in a patient's medical records or a statement signed by a patient's practitioner that indicates, in the practitioner's professional opinion: (1) that the patient has a debilitating medical condition and the practitioner believes that the potential health benefits of the medical use of cannabis would likely outweigh the health risks for the patient [A written certification is not valid for more than one year from the date of issuance]; and (2) the maximum amount of THC concentration that would be beneficial to the patient.
And then that will bring us to Title 7-Chapter 34-Part 3-Section A: Medical cannabis registry identification cards, where the definitions in Rules and Regulations for “unit” and “useable cannabis” needs to be adjusted with a quantity of usable cannabis increased to 425.243 grams per 3 months (2.5 ounces every two weeks). Along with the inclusion of a medical exception that would still allow for the patient or primary caregiver to petition the MCAB for a medical exception increase of units (or grams) with the amount of the medical exception increase to be determined by a patient's medical practitioner.
In order for the Department of Health Medical Cannabis Program to allow for the medical treatment of cannabis, the Department must properly have “adequate supply” and have it properly defined. And for the Department to have “adequate supply” they would need to know the different amounts of plant material that goes into all the different types of medicine being produced. Dried cannabis flower (bud), pre-rolls, edibles, tinctures, topicals/salves, and concentrated forms of cannabis all require different amounts of cannabis plant material to produce. Adequate Supply can not have a set definition in the rules and regulations and needs to be reviewed to coincide with MCP growth and patient/caregiver needs. Adequate Supply should be reviewed quarterly (4 times per year) with a current census completed of qualified patients, caregivers and licensed non-profit producers.
(Ad·e·quate: (ˈadəkwət/) adjective; satisfactory or acceptable in quality or quantity.
Sup·ply (səˈplī/) verb; 1. make (something needed or wanted) available to someone; provide.
"the farm supplies apples to cider makers" or a noun; 1. a stock of a resource from which a person or place can be provided with the necessary amount of that resource.)
"the farm supplies apples to cider makers" or a noun; 1. a stock of a resource from which a person or place can be provided with the necessary amount of that resource.)
This is empirical data that has not been collected within the state’s medical cannabis program by the Department of Health. Therefore “adequate supply” can not be properly defined by the department by using unknown variables it has not collected. This further prevents the Department of Health from being able to set a proper plant count for each kind of licensed producer in the program for the means of achieving adequate supply within the medical cannabis program as required by law.
This is empirical data has been studied and researched by the state of Colorado by the Colorado Department of Revenue: “An assessment of physical and pharmacokinetic relationships in marijuana production and consumption in Colorado”.
How is the purpose of the law able to be fulfilled without knowing Adequate Supply and by preventing patients from properly treating themselves due to adequate supply limits?
Section 2. PURPOSE OF ACT.--The purpose of the Lynn and Erin Compassionate Use Act is to allow the beneficial use of medical cannabis in a regulated system for alleviating symptoms caused by debilitating medical conditions and their medical treatments.
“ARTICLE 2B. LYNN AND ERIN COMPASSIONATE USE ACT
N.M. Stat. Ann. § 26-2B-2 (2009)
§ 26-2B-2. Purpose of act
The purpose of the Lynn and Erin Compassionate Use Act [26-2B-1 NMSA 1978] is to allow the beneficial use of medical cannabis in a regulated system for alleviating symptoms caused by debilitating medical conditions and their medical treatments.
HISTORY: Laws 2007, ch. 210, § 2.
EFFECTIVE DATES. --Laws 2007, ch. 210, § 12 makes the act effective July 1, 2007.”
The approval of this would bring the Department of Health in compliance with the intent of the law and uphold the spirit of the Lynn and Erin Compassionate Use Act, 2007. New Mexico’s medical cannabis history started in 1978. After public hearings the legislature enacted H.B. 329, the nation’s first law recognizing the medical value of cannabis...the first law.
References
The solution provided above was derived from the following sources:
Americans For Safe Access [http://www.safeaccessnow.org/policy_shop], Colorado Medical Marijuana Program [https://www.colorado.gov/pacific/cdphe/medicalmarijuana], Colorado Department of Revenue- An assessment of physical and pharmacokinetic relationships in marijuana production and consumption in Colorado [https://www.colorado.gov/pacific/sites/default/files/MED%20Equivalency_Final%2008102015.pdf], Cannabis Yields and Dosing by Chris Conrad (court qualified cannabis expert) [http://chrisconrad.com/], and the Hawaii Medical Cannabis Program-Medical Marijuana Dispensary Task Force Study 2015 [http://files.hawaii.gov/auditor/Reports/2014/14-12.pdf].
“IF, what we want is for the cannabis industry to maintain BEST PRACTICES, then the careful cleaning up of concentrates, removing the majority of impurities, is the closest thing we have to proper pharmaceutical technique. IF the state forces you to less appropriate techniques, that produce a less cleaned-up product, then the state is taking on the legal liability of forcing the industry into bad techniques. This means that if the industry is pushed by the state, then when patients get sick for these poorer quality medicines, the state becomes a co-defendant in these cases… more over, the cannabis company getting sued can also sue the state.” - Dr. Kymron ( Steep Hill Labs )
Appendix A: An Americans for Safe Access (ASA) national report was released on December 8th, 2016 and calls for an end to contradictions between federal and state guidelines with regard to medical cannabis policies. The Americans for Safe Access briefing book, “Medical Cannabis in America”, showing that not only do opiate related deaths drop an average of 24.8% in states with medical cannabis laws, the report also notes that the Department of Justice has spent an estimated $592 million to date in arrests, investigations, enforcement raids, pretrial services, incarceration, and probation.
Plant Count For Producers Based On Patient Population Growth For Adequate Supply Proposed: Legislators could easily solve this by looking to Americans For Safe Access for this policy.
About Americans for Safe Access.
The mission of Americans for Safe Access (ASA) is to ensure safe and legal access to cannabis for therapeutic use and research. ASA was founded in 2002, by medical cannabis patient Steph Sherer, as a vehicle for patients to advocate for the acceptance of cannabis as medicine. With over 100,000 active members in all 50 states, ASA is the largest national member-based organization of patients, medical professionals, scientists and concerned citizens promoting safe and legal access to cannabis for therapeutic use and research. ASA works to overcome political, social and legal barriers by creating policies that improve access to medical cannabis for patients and researchers through legislation, education, litigation, research, grassroots empowerment, advocacy and services for patients, government's, medical professionals, and medical cannabis provider.
The mission of Americans for Safe Access (ASA) is to ensure safe and legal access to cannabis for therapeutic use and research. ASA was founded in 2002, by medical cannabis patient Steph Sherer, as a vehicle for patients to advocate for the acceptance of cannabis as medicine. With over 100,000 active members in all 50 states, ASA is the largest national member-based organization of patients, medical professionals, scientists and concerned citizens promoting safe and legal access to cannabis for therapeutic use and research. ASA works to overcome political, social and legal barriers by creating policies that improve access to medical cannabis for patients and researchers through legislation, education, litigation, research, grassroots empowerment, advocacy and services for patients, government's, medical professionals, and medical cannabis provider.
Lynn & Erin Compassionate Use Act Patient’s Coalition of New Mexico ~ A GrassRoots Movement!
UNITE-NETWORK-GROW-INFORM-KNOW-EDUCATE-ACTIVISM-VOTE-HEALTH-WELLNESS(All Rights Reserved 04/20/2016)
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