Three federal agencies—the Food and Drug Administration (FDA), the Environmental Protection Agency (EPA) and the Drug Enforcement Administration (DEA)—are now accepting comments from the public on cannabis-related topics such as hemp pesticides, the legal classification of marijuana globally, and opioid production reduction.
The comment period for the Proposed Aggregate Production Quotas for Schedule I and II Controlled Substances (opioid production reduction) opened last week, and as of this writing 25 people have weighed in at this point. Submissions posted to the site so far are primarily aimed at the DEA’s proposed reduction of opioid production, with several chronic pain patients arguing that they will be negatively impacted. Caregivers and healthcare providers have even vocalized they are concerned that seniors that rely on these medications will be left without needed medications. People can send comments on the cannabis and other drug quotas through October 15.
The Food and Drug Administration (FDA or the Agency) is reopening the comment period for the notice entitled “International Drug Scheduling; Convention on Psychotropic Substances; Single Convention on Narcotic Drugs; World Health Organization; Scheduling Recommendations; Dronabinol (delta-9 tetrahydrocannabinol) and its Stereoisomers; Cannabis, Cannabis Resin, Extracts and Tinctures; Cannabidiol Preparations; and Pharmaceutical Preparations of Cannabis” that appeared in the Federal Register of March 1, 2019. The Agency is taking this action to allow interested persons additional time to submit comments. So far there are 3233 formal public comments.
The FDA made this request for input on cannabis’s global treaty status back in March, but it was closed because an expected United Nations (UN) vote on a proposal to remove marijuana from the most strictly regulated category was postponed.
Maxwell Boyea stated, “I am a public health worker and it’s plain to see to me that legalization, regulation and education are not only more cost effective than the current system but will actually work. Common basic psychology tells us that people will do drugs whether the law says it’s okay or not. A public health approach of harm reduction and regulation is the only scientific and proven way to address drug use in America. If anything, give the public health workforce a much needed boost and focus arresting people for real crimes.”
Clarke Hinks stated, “Article Four, section 2, clause 1 of the US Constitution: “The Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States.” It is absolutely ridiculous that millions of Americans are incarcerated and have their lives greatly hindered while several states have recorded large decreases in opioid and dangerous illicit drug use, increases in tax revenue, lowering of stress on law enforcement, and citizens in general approving of and experiencing a greater quality of life in several avenues from the legalization of recreational and medicinal cannabis. Regardless of whatever anecdotal positions present themselves, there is a mountain of empirical evidence that cannabis has numerous medical uses and social value.”
The EPA has received applications to add a new site (hemp) to the labeling of currently registered pesticide products that contain active ingredients with established tolerance exemptions. Due to EPA’s expectation that these initial applications involving hemp may be of significant interest to the public and to enhance transparency, EPA is hereby providing notice of receipt and opportunity to comment, although not required pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). EPA said it’s not required to take public comment on the applications but is doing so “because of the potential significant interest from the public in these initial applications and in furtherance of being completely transparent about these applications.”
One person noted that the 10 pesticides under review contain almost the same ingredients and said “it really limits the ability of producers to manage pests and diseases.”
Jessica Schick stated in a comment, “My partner and I are transitioning from growing cannabis in California to growing hemp in North Carolina…We have used the products under discussion with great effectiveness, especially the biological controls. Because hemp can be so susceptible to mold, fungus, and pests, it is imperative to have these tools to ensure a healthy and plentiful product. In a place like North Carolina, mold and fungus prevention will be even more of an issues than it has been in drier climates like Colorado and California. To be honest, I’m not sure how we could accomplish the same yields and successes without these tools to help.”
If you would like to make a public comment, time is running out to do so. Do not let your chance for you voice to be heard be swallowed by inactivity.
