Medical and Research Groups Call for Funding, Clarity on Synthetics Cannabinoids in Rescheduling Comments

Monday marked the end of the public comment period for the Biden Administration’s proposal to move cannabis from Schedule I to Schedule III of the CSA. 

We’re sifting through the pile of more than 40,000 comments to identify the major — or, in some cases, surprising — entities that submitted comments. 

This batch focuses on medical and research entities. You can also find comments from justice, law enforcement, labor, and religious entities and transport, safety, and alcohol entities. You’ll notice that these are all non-cannabis entities. Tomorrow, we’ll have cannabis regulators, advocacy groups, companies, etc.

Remember: there was another deadline, back in June, to request a hearing, as Cannabis Wire reported at the time. Catch up on our coverage of who submitted those requests here.

 • American Academy of Hospice and Palliative Medicine (support) 

 • American Academy of Neurology (supports rescheduling from Schedule I to II to “encourage further scientific research into its safety and benefits.”)

 • American Academy of Pediatrics (support, with concerns) 

AAP does not explicitly support Schedule III. “The AAP strongly supports research and development of pharmaceutical cannabinoids and supports a review of policies easing restrictions on research into the medical use of these compounds. The AAP supports moving cannabis from a Schedule I status drug to facilitate this research.” 

• American College Health Association (no stated position)

“ACHA supports efforts to reduce the illegal use of marijuana on college campuses. Medical marijuana is a separate issue that requires separate considerations and further discussions.” 

 • American College of Occupational and Environmental Medicine (ACOEM) (no position)

“While ACOEM does not have a formal position on the legalization of marijuana, we are acutely concerned about the broad public health and safety consequences of the reclassification of marijuana on workers, workplaces, and the general public. We believe there are serious potential unintended consequences that may impact public safety if not addressed prior to any change in marijuana’s schedule under the Controlled Substance Act.” 

• American Herbal Products Association (support)

Note: AHPA is focused on herbal products and supplements, not medicine, but was included in this list as a related entity.

 • American Lung Association (support)

 • American Medical Association (no stated position)

AMA’s comment is lengthy and nuanced, but largely reiterates its concerns. “While AMA policy has adapted to the changing landscape of state and federal law governing cannabis use, possession, distribution, and related matters, the AMA maintains that there are significant public health and other concerns regarding cannabis use—particularly for vulnerable populations, youth and adolescents, and people who are pregnant or breastfeeding.”

 • American Nurses Association (ANA) (support)

 • American Pharmacists Association (support)

 • American Psychiatric Association (oppose)

“APA recommends that the Department of Justice, in coordination with the DEA and HHS, review and update regulations that would support the ability to conduct further high-quality research, without reclassification to a Schedule III.” 

 • American Society of Addiction Medicine (“could support”)

ASAM “could support a final rule that transfers only marijuana with lower THC concentrations to Schedule III, so long as any such final rule clearly states that (1) the Food, Drug, and Cosmetic Act (FDCA)4 will continue to apply, and (2) Schedule III requirements/controls will be enforced for those who take advantage of federal tax benefits due to 280E no longer being applicable after such a rescheduling.” 

 • Association of American Medical Colleges (support)

 • California Society of Health-System Pharmacists (support)

• Epilepsy Foundation (support)

• Illinois Pharmacists Association (supports full descheduling)

 • Texas Pain Society (opposed)

• U.S. Pharmacopeia (support)

• Washington State Medical Association (WSMA) (support)

 • Cannabis Research Institute at Discovery Partners Institute, Part of the University of Illinois System (support)

 • The National Center for Natural Products Research (NCNPR) and the National Center for Cannabis Research and Education (NCCRE), research centers within the University of Mississippi (UM) School of Pharmacy (support)

 • University of California San Francisco (support)

• University of California system (support)

However, they ask that DEA “include synthetically derived delta-9-THC in the rulemaking and apply the eight-factor analysis to THC isomers, analogs, and other THC derivatives.” 

They continue, “Experts in chemistry at UC agree that delta-9-THC, whether naturally derived or synthetically derived, is one and the same molecule. Therefore, drawing a line between naturally derived or synthetically derived delta-9-THC creates unnecessary confusion amidst an already complicated regulatory landscape when it comes to conducting research.”