New Packaging Rules Throws Colorado Marijuana Industry For A Loop

The packaging rules were implemented to reduce the risk of accidental ingestion by children -- a type of incident that has increased in recent years.
By @katierucke |
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    According to Colorado law, marijuana sold in the state must now come in opaque, child-resistant bags.  (AP Photo/Ted S. Warren, File)

    According to Colorado law, marijuana sold in the state must now come in opaque, child-resistant bags. (AP Photo/Ted S. Warren, File)

    A new rule regarding how marijuana must be packaged has some dispensary operators in Colorado worried they may not be able to legally sell any cannabis products — from buds to brownies — come Jan. 1.

    When the sale of recreational marijuana becomes legal at the first of the year, part of the new legalization rules in the Rocky Mountain state include the required use of opaque, child-resistant packaging. The packaging rule was instituted by officials hoping to to reduce the risk of accidental ingestion by young children — a type of incident that has increased in recent years, along with the growth of the industry in the state.

    But several dispensary owners say that they are struggling to find vendors that manufacture a package that complies with Colorado’s new rules, since the packaging requirements were approved Sept. 9 and implemented Oct. 15.

    “A number of our members are having an incredibly difficult time,” Mike Elliott, director of the Medical Marijuana Industry Group, the state’s largest marijuana business group, told the Denver Post. “We’re all looking for ways to comply with this rule, and everyone is worried we’re not going to be able to, basically.”

    Matt Brown is the owner of the only marijuana tourism company in North America, My 420 Tours, and is a recreational marijuana user and advocate. Talking to MintPress, Brown said forcing an industry to make changes in less than two months is asking a lot, especially since a few extra months of implementation time is “not the end of the world.”

    While Brown agrees that the new packaging rules are a good idea, especially compared to the “old Ziploc bag mentality,” he says the industry should be given a little bit more time to implement the new requirements, since state officials would never try to force a fast change on a company like Walmart.

    “This is now the third year in a row the state legislature has passed some sort of improvement or tweaks” to the state’s marijuana laws, Brown said, adding that packaging was a big issue that was discussed throughout the past year.

    Although the expedited packaging rule changes caught some people off guard, Brown says the new laws illustrate how the marijuana industry is trying to take up issues that other legal industries such as alcohol, tobacco, and pharmaceutical companies have looked at as well.

    However, according to Julie Postlethwait, spokeswoman for the Colorado Marijuana Enforcement Division, state regulators say that they have no sympathy for dispensary owners who are not prepared. Postlethwait in particular said she found it disappointing store owners had waited to the last minute, and said the new rules are “not a surprise that came and hit them over the heads.”

    “The main point here, the focus the industry tends to forget, is we exist in order to ensure public safety,” she said. “You don’t want a child ingesting high-potency infused products. The risk is a child’s health.”

    But some store owners who tried to order new packaging before the rules were finalized have found themselves at a loss of money and in potential legal trouble if they can’t muster up the money for new packages.

    Ryan Cook, a co-owner of The Clinic in Denver, which is a chain of six medical marijuana dispensaries in the area, said he ordered $40,000 worth of packaging from a manufacturer in China before the rules were finalized, since it takes about three months to receive the packages. But since the bags are transparent on one side, they don’t meet the state’s new marijuana packaging requirements.

    “For us, it was an unfortunate situation,” Cook told the Denver Post. “But now I think the whole industry is faced with, ‘Can everyone get the packaging they need in the time frame they need it?’ That might be an uphill battle.”

    Cook explained that all marijuana products sold at the company’s six different dispensaries are prepackaged at a warehouse before they are sent out to the dispensaries. He said the company has used transparent bags to make tracking the products easier and more secure. Plus, he said, customers want to see what they’re getting before they buy it.

    “It stinks,” Cook said. “It’s our mistake. We knew the rules were coming out. But we were under the impression we had a package that was considered child-proof, re-sealable and tamper-proof.”

     

    Finding the perfect package

    One of the greatest concerns among lawmakers, doctors and law enforcement officials regarding marijuana legalization, including medical, has been the risk that young children could accidentally get into a patient or user’s supply.

    But as Rebecca Brown, a mother of a pediatric medical marijuana patient told MintPress earlier this year, she has never been concerned about someone getting into her son Cooper’s medical marijuana supply, including her other son.

    “In our family, we look at this as medicine,” she said. “We have lots of medicines around that are more addictive and more dangerous.”

    Jim Johnson, who is working to legalize medical marijuana in Minnesota so his young daughter Luella could qualify for the medicine, agrees. Although Johnson has three other young children at home, he says cannabidiol would be one of the safer medications his children could possibly get into.

    But Jodi Duke, a faculty member at the University of Colorado-Denver, School of Pharmacy, said that due to the lack of scientific evidence regarding the safety of marijuana, people may want to “err on the side of being more cautious,” since she said much of marijuana’s safety has come from anecdotal evidence.

    According to the Denver Post, the opaque-colored requirement came from a report released this past August from researchers at the Colorado School of Public Health and Children’s Hospital Colorado, which predicted that accidental marijuana ingestion by children could be cut in half if the state required opaque, child-resistant packages.

    To be considered child-resistant, the state requires the packaging be “significantly difficult for children under 5 years of age to open and not difficult for normal adults to use properly,” which is based off an international standards organization.

    Duke, a co-author for the report on how to best package marijuana, said that the group evaluated how to effectively package marijuana, and thought that since colors and characters on packages are appealing to kids, dispensaries should do the opposite — make the packages as bland as possible to discourage kids from being interested in marijuana.

    Gregory Tung, an assistant professor at the Colorado School of Public Health and co-author of the report along with Duke, told MintPress that while the report examined how to keep kids from unintentionally ingesting marijuana, the researchers recognize there may be other equally or more dangerous than marijuana, but those items were not included in this report.

    Tung said that while the researchers thought about how tobacco, alcohol, household products and pharmaceuticals were packaged, he said the sole purpose of this report was determining how to best package marijuana so kids can’t accidentally consume it. He called researching the report an “interesting experience,” and said that everyone came together — from child-health advocates to those in the marijuana industry — to create regulations that would protect children but be practical in a business-sense.

    Tung added that as part of their research, he and his co-authors spoke with packaging manufacturers and provided information for companies with approved packaging in the report to help dispensary owners in the state comply with the new rules.

    One possible packaging solution for Denver dispensaries is a product called the “Stink Sack,” which is a smell-proof bag that has a double-locking mechanism. The bags are manufactured by a New York company and come in three “pot-friendly” sizes.

    Ross Kirsh is the owner of the company that produces Stink Sack’s. He said a half million of his opaque bags are currently in production and should be ready for delivery by Jan. 1.

    Postlethwait said the exact penalties for not complying with the packaging requirements are still being finalized, but she said violators can be fined by the state and more serious action can be taken against dispensary operators if the violation continues.

    But Matt Brown expressed concern that failing to properly package marijuana by Jan. 1 could result in a business losing its license and being labeled as a drug dealer.


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      • AntiSocialSailor

        I’m so effing sick and tired of the “Isn’t anyone thinking of the children?” hysteria this country’s been suffering from for the last 20 years or so. We’ve gone to absurd and ridiculous lengths to make the world child-safe and ended up with a generation of pampered and spoiled kids who’ve been so protected, coddled and hovered over they don’t have the sense to get in out of the rain.

        So who’s going to do the research to find out how much raw marijuana it takes to actually do any harm to a child? Nobody. It’ll never be done and the paranoia will just continue to grow. Dozens, if not hundreds of children will ingest cannabis, both accidentally and purposefully without ill effect, but nobody will hear about this for fear of prosecution. Nobody’s going to call the doctor to report his child ate pot and nothing happened. It could be 100% harmless, yet for the next 100 years, we’ll be acting like it’s poison.

        Here’s a perfect example: I have a friend whose 5 year old son got into his stash and ate at least 2 grams of high quality bud. My friend caught him with the empty baggie and he readily fessed up to having eaten it. Did dad panic and rush him t the ER? No. That would have brought on a legal quagmire in the wake of a hysterical reaction. They likely would have pumped his stomach, which would do him more harm than the pot he ate.

        So, my friend simply watched the kid. Within 2 hours, he curled up on the couch and went to sleep for about 4 hours. That was it. End of story. That was the big tragedy that legislatures wasted god-know-how-much money and time to prevent and that has put dispensaries in a panic to avoid.

        Likewise with nicotine in e-cigarettes. Lawmakers are all in a tizzy worrying about the possibility of kids getting into the liquid they use, even though there has yet to be a single recorded fatality. It’s a more realistic concern than having a kid eat your stash, but virtually every case of nicotine poisoning in children has been the result of them eating cigarette butts. Where’s the urgent call for legislation requiring childproof ash trays?

        This country makes me sick with it’s incessant fawning and coddling of kids. No wonder we have such a generation of spoiled, panty waisted cowards coming up.

      • Priya Pant

        Driven by rapid advancements in time-temperature indicators (TTI), intelligent packaging is anticipated to witness a strong growth. Smart packaging systems are offering product differentiation at lower prices. This system could be able to detect food contamination and change of color incase the food is not fit for consumption by the consumer. http://www.uflexltd-packaging.com/

        • Charles Waller

          Petro-chemical, non-biodegradeable, correct?

      • Charles Waller

        As inane, unnecessary and ridiculous as requiring patients to pay for a license and enter their names on a state registry, while cannabis remains listed as a Schedule 1 Controlled Substance. No other patients are required to pay fees and be listed on a special registry to access medication, much less go to ridiculous lengths to avail themselves of an herbal substance which has never been responsible for a single human death in recorded history. This is simply another example of the ongoing war against the most beneficial plant known to humanity, to protect corporate profits and persecute citizens who choose not to take toxic chemical compounds responsible for serious adverse side effects, pain, suffering, addiction and death from fatal overdose. Judge Francis Young made the facts clear in his 1986 ruling against the DEA, which then DEA Head John Lawn illegally refused to implement as a part of the internal petition process. This totally hypocritical, onerous requirement does not protect a single child, as there is no risk from the ingestion of phytocannabinoids in raw, acid molecule form. The worst effect from ingestion of decarboxylated plant cannabinoids is a long nap. I wonder if the federal government intends to comply with the packaging requirements for the metal cannisters of prerolled cannabis cigarettes they send each month to the remaining 5 patients in the Compassionate IND program.

        http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2100129/ge
        Medscape General Medicine
        WebMD/Medscape Health NetworkDosing Medical Marijuana: Rational Guidelines on Trial in Washington State
        Sunil K. Aggarwal, MS III, PhC, BS, BA, third-year medical student,, Muraco Kyashna-Tocha, PhD, Cultural Anthropologist; Ethnobotanist, and Gregory T. Carter, MD, MS, Clinical Professor of Rehabilitation Medicine
        Additional article information
        Introduction
        The medicinal value of cannabis is well documented in the medical literature.[1,2] Cannabinoids, the active ingredients, are found in the resin-producing pistillate inflorescences of the Cannabis sativa plant.[3]
        Since the early 1900s, cannabis has been referred to as mari(h/j)uana, a
        pejorative term derived from Mexican Spanish-Portuguese colloquial
        slang. Cannabinoids have many distinct pharmacologic properties. These
        include analgesic, antiemetic, antioxidative, neuroprotective, and
        anti-inflammatory activity, as well as modulation of glial cells and
        tumor growth regulation.[1]
        We now know that there is an endogenous molecular signaling system in
        our bodies that is run by cannabinoids. The discovery of this endogenous
        cannabinoid system with specific receptors and ligands has led to the
        progression of our understanding of the therapeutic actions of cannabis
        from folklore to valid science.[4]
        It now appears that the cannabinoid system evolved with our species and
        is intricately involved in normal human physiology, specifically in the
        control of movement, pain, appetite, memory, immunity, and
        inflammation, among others. The detection of widespread cannabinoid
        receptors in the brain and peripheral tissues suggests that the
        cannabinoid system represents a previously unrecognized, ubiquitous
        network in the nervous system. On that basis, exogenous cannabinoids
        appear to have tremendous potential in treating neurodegenerative
        disorders.[5,6]
        For example, in amyotrophic lateral sclerosis (ALS), there is animal
        model evidence that exogenous cannabinoids have disease-modifying
        potential.[7–12]
        Further, in a large survey, ALS patients reported that marijuana
        relieved the major symptoms of the disease better than prescription
        medications.[13] The most common reason cited by ALS patients for not considering using cannabis to treat their symptoms was lack of access.[13]

        Dense cannabinoid receptor concentrations have been found in the cerebellum,
        basal ganglia, and hippocampus, accounting for the effects of cannabis
        on motor tone, coordination, and mood state.[4]
        Low concentrations are found in the brainstem, accounting for the
        remarkably low toxicity of cannabis. Of note, lethal doses for cannabis
        in humans have not been described. So far, we know of at least 2
        molecular receptor proteins (CB1 and CB2) and 2 endogenously produced
        lipid cannabinoids (anandamide and 2-acylglycerol) found in numerous
        tissues throughout the body, including neural and immune tissues, which
        comprise the endogenous cannabinoid system.[1,3,4]
        The cannabinoid system helps regulate the function of other systems in
        the body, making it an integral part of the central homeostatic
        modulatory system – the check-and-balance molecular signaling network in
        our bodies that keeps us at a healthy “98.6.” Despite all of the
        advances in understanding the physiology and pharmacology of cannabis
        and cannabinoids, there remains a strong need for developing rational
        guidelines for dosing cannabis. We (Gregory T. Carter [GTC] and Muraco
        Kyashna-Tocha [MKT]) have previously attempted to address this issue,
        deriving a dosing scheme with the available known chemistry and
        pharmacology of cannabis.[14] However, it would appear that there is still considerable controversy over this issue.

        Legal Ease: What the Law Really Says (and Why You Should Know)

        Fourteen states and the District of Columbia have passed medical marijuana
        legislation attempting to provide protection for medical marijuana
        patients. Our own state law dates back to November 3, 1998, when voters
        in Washington passed I-692, also known as the medical marijuana
        initiative, by a 59% margin (RCW 69.51A). The law states that
        “Qualifying patients…shall not be found guilty of a crime under state
        law for their possession and limited use of marijuana.” One might ask,
        “Why do I need to know this much about the law?” For starters, the law
        does not protect patients (or their caregivers) from arrest or
        prosecution.[15,16]
        It only allows them to present a medical marijuana defense in court.
        One of us (GTC) has had several patients who were following the law
        perfectly well, only to be arrested for either possession or
        cultivation. Moreover, he (GTC) has had to go to court to testify on
        their behalf and have had several occasions in which a judge or
        prosecuting attorney will directly question my medical judgment. This
        occurs despite the fact that this is an area in which my peers in
        medicine generally consider me an expert – granted that the charges are
        usually dropped but not without the expense and time taken going to
        court. Patients have had their growing equipment confiscated, only to be
        returned later in damaged condition.

        Patients should always be advised that any state medical marijuana law, such as our I-692, does not offer any protection from federal law. Federal law still
        makes marijuana possession, distribution, or manufacture illegal for
        any purpose. Furthermore, the US Supreme Court has also ruled that the
        federal government can arrest state-recognized medical cannabis
        patients.[17,18] These are the legal absurdities and risks under which state-permitted medical marijuana patients exist.

        Popular press and patient networks have estimated that there are approximately
        20,000 qualifying medical marijuana patients in Washington state. If the
        physician-authorizing rate in Washington state resembles Oregon, which
        has a similarly aged program, we can estimate that roughly 1000–2000
        licensed physicians have authorized the use of medical marijuana for
        their patients in Washington state. Given the sheer number of patients
        and physicians involved, one would think that there would be rather
        defined recommendations with regard to dosing. Indeed, the law as it has
        existed states only that an individual may “possess, in combination
        with and as an agent for the qualifying patient, no more marijuana than
        is necessary for the patient’s personal, medical use, not exceeding the
        amount necessary for a sixty-day supply.” Adding to the confusion,
        recently passed legislation amending the existing state law has given
        the Washington State Department of Health (WA DOH) the rulemaking
        authority to “define the quantity of marijuana that could reasonably be
        presumed to be a sixty-day supply for qualifying patients.”

        Given the controversy that this has generated, not only here but also in
        virtually all states dealing with medical marijuana, we would like to
        further derive a scientifically grounded, logic-based framework to help
        states with a medical marijuana policy address the issue of dosing.
        Specifically for Washington state, we will also address the question of
        what “could reasonably be presumed to be a sixty-day supply for
        qualifying patients?” It should be obvious that defining a 60-day supply
        is equivalent to defining a 1-day supply and multiplying that figure by
        60. It is also roughly equivalent to defining a 1-week supply and
        multiplying that figure by 8 or dividing an annual supply by 6.

        Deriving Dosing Guidelines for Medical Marijuana: Clearing the Smoke

        Let us begin with some basic definitions. According to state law, “Medical use of ‘marijuana’ means the production, possession, or administration of marijuana,
        as defined in RCW 69.50.101(q), for the exclusive benefit of a
        qualifying patient in the treatment of his or her terminal or
        debilitating illness” (RCW 69.51A.010, Section 1, emphasis added). In
        this definition, the concept that is most relevant to the question at
        hand is the administration of marijuana. This is a technical concept
        defined in law. The relevant statute cited is RCW 69.50.101(q). The
        definition there for our purposes is as follows: “Administer” means to
        apply a controlled substance, whether by injection, inhalation,
        ingestion, or any other means, directly to the body of a
        patient…by…(2) the patient.” Thus, the “medical use of marijuana”
        means the administration of a supply of marijuana directly to the body
        of a qualifying patient by the patient. Route of administration is an
        important determinant of the pharmacokinetics of the various
        cannabinoids in cannabis, particularly absorption and metabolism.
        Typically, cannabis is smoked, which has the advantage of rapid onset of
        effect and easy dose titration.[19–21]
        Due to their volatility, cannabinoids will vaporize at a much lower
        temperature than combustion, allowing them to be inhaled as a warm air
        mist.[22] This is a much healthier option than smoking.[22]
        However, there may be differing vaporization points for the individual
        cannabinoids. Thus, vaporized cannabis may have differing concentrations
        and ratios of cannabinoids compared with smoked cannabis.[22,23]
        Cannabinoids in the form of an aerosol in inhaled smoke or vapors are
        absorbed and delivered to the brain and circulation rapidly, as expected
        of a highly lipid-soluble drug.[24,25]
        With smoking, up to 40% of the available cannabinoids may be completely
        combusted or lost sin sidestream smoke and thus be biologically
        unavailable.[21]

        Cannabis may also be ingested orally, but this delivery route has markedly
        different pharmacokinetics compared with inhalation. The onset of action
        is delayed and titration of dosing is more difficult.[14,23]
        Maximum cannabinoid blood levels are only reached up to 6 hours post
        ingestion, with a much longer half-life, as long as 20–30 hours.[23] This would apply to dronabinol (Marinol), the pharmacokinetics of which were used as the foundation of our original dosing guidelines.[14]
        With respect to dronabinol, which is 100% pure, synthetic delta-9
        tetrahydrocannabinol (THC), this is converted in the liver to
        11-hydroxy-THC, a potent psychoactive agent. This metabolite accounts
        for the considerable sedation that patients often experience with
        dronabinol. Despite the persistent warnings from the Drug Enforcement
        Agency (DEA) that “today’s marijuana is stronger,” both the US Food and
        Drug Administration (FDA) and the DEA agreed to reclassify the
        scheduling status of dronabinol from a Schedule II (CII) to a Schedule
        III (CIII) controlled substance, due to its remarkable safety profile
        (which is inherent to all cannabinoids). The cannabinoids may also be
        made in to a liniment and absorbed through the skin. This was a common
        treatment for arthritis around the turn of 20th century. However, this
        is the least efficient mode of delivery.

        The WA DOH must be aware of these common modes of administration and establish a 60-day supply that presumes that any and all of these common methods of administration of medical marijuana are being employed by qualifying
        patients. Given the inherent variations in strain and phenotype of
        cannabis, the various routes of administration employed, and the
        multitude of debilitating or terminal conditions being treated in
        patients using medicinal cannabis, standards must be set that maximize
        the potential for symptomatic relief. To do anything less would be
        unethical.[26]
        Minimally, this implies setting standards with respect to the use of
        the least potent strains of marijuana and the most amount-intensive
        routes of administration.

        The logical place to begin with regard to addressing the question of what constitutes a medically reasonable supply range is to investigate current dosing/supply precedents in American cannabinoid medicine. First and foremost, the WA DOH should draw from the experience of the longest running medical
        marijuana supply program in the United States, this being the ongoing,
        now 3-decades-old, Compassionate Single Investigational New Drug
        Program. The National Institute on Drug Abuse (NIDA) and the FDA jointly
        administer this. This program has supplied enrolled patients with
        nearly half a ton of marijuana throughout its cumulative history! The
        cannabis plants are grown at a federally funded farm in Oxford,
        Mississippi. After curing (air-drying), the cannabis is rolled into
        cigarettes at the Research Triangle Institute outside of Durham, North
        Carolina. Grey metal tins are used to package the cannabis cigarettes,
        which are then shipped monthly to 5 secured pharmacies in the United
        States for delivery and consumption by the 5 individuals whose
        healthcare providers long ago attested in writing to the vital health
        and medical benefits that consumption of cannabis affords them. The
        director of the Mississippi farm has stated on the public record that
        they have been able to produce, stock, and supply medicinal cannabis
        with strengths as high as 14% THC.[27]
        The marijuana is produced and supplied for consumption with the full
        financial backing and imprimatur of the US federal government, the NIDA,
        and the FDA, as part of a program that was reluctantly started 3
        decades ago on the order of a federal judge who ruled that “medical
        necessity” to use marijuana was an unalienable right possessed by one
        man whose vision was deteriorating from glaucoma, and which the US
        government is legally obligated to respect, protect, and fulfill.

        One of us (Sunil K. Aggarwal [SKA]) can attest to personally meeting with
        the horticulturalist who has been growing medical marijuana for the
        federal government’s marijuana supply program for nearly 3 decades, Dr.
        Mahmood El Sohly. In addition, he (SKA) has met with 3 of the qualifying
        patients in the program who have chosen to go public: George McMahon,
        who suffers from nail-patella syndrome; Irv Rosenfeld, who suffers from
        multiple congenital cartilaginous exostoses; and Elvy Musikka, who
        suffers from congenital cataracts and glaucoma. Russo and colleagues[28]
        summarized the supply that 4 of the 5 remaining patients in the program
        are receiving. On the basis of those reported figures, Conrad[29]
        summarized the average supply for each patient in the federal program,
        assuming roughly equal strain strength. According to Conrad, the annual
        dose is between 5.6 and 7.23 lb of cannabis bud mixed with leaf. Thus,
        the documented federal single-patient dosage averages 8.24 g/day, or
        about one fourth ounce per day, which amounts to 6.63 lb smoked per
        year.

        Do the MathThus, following the federal guidelines, an average of 6.63 lb of smoked medical marijuana, per patient per year, translates to a 60-day supply
        of 1.105 lb (assuming six 60-day periods per year) per patient. We
        emphasize here that this calculation is for administration of herbal
        cannabis through combustion-driven lung absorption only because this is
        the sole method of administration considered in the federal program, as
        the marijuana is delivered prerolled into cigarettes for smoking. In
        order to administer an equivalent amount of marijuana through gut
        absorption, an estimated 3–5 times greater quantity of marijuana is
        required, assuming equal efficiency and loss in both processes.
        Validation of this conversion factor comes from dose considerations
        elucidated by Dr. Reese Jones, MD, a professor of psychiatry at the
        University of California, San Francisco, School of Medicine.

        • Charles Waller

          In a published federal document, submitted on record, to Congress, Dr.
          Jones opined: “THC has been estimated to be 3 to 5 times more potent
          when inhaled than when ingested.[30]”
          He then gave a concrete example: “A marijuana cigarette containing 2
          percent THC would deliver slightly less than 10 milligrams of THC to the
          lungs where must [sic] is probably absorbed. But to reach an equivalent
          state of intoxication when taken orally, from 30 to 50 milligrams of
          THC would have to be consumed.[30]”
          We can use this same conversion factor, even though we are interested
          in medically desired endpoints. Applying an average multiplication
          factor of 4 (which is between 3 and 5) would mean that if the federal
          medical marijuana patients received a supply of marijuana intended for
          gut absorption in order to achieve pharmacologically equivalent blood
          levels as achieved through combustion and inhalation, an annual supply
          of 6.63 lb x 4 = 26.52 lb per patient would be required. Dividing by 6,
          this translates to a 60-day supply of (26.52 lb/6 =) 4.42 lb or 70.72 oz
          per patient.

          • Charles Waller

            In our previous study, we (GTC and MKT) used a different
            method to estimate a 60-day supply. In that study, we based our supply
            recommendations on the dosing regimen of dronabinol, a soft
            gelatin-encapsulated, synthetic THC isomer dissolved in sesame seed oil.
            This has been sold since 1985, with FDA approval, under the trade name Marinol.
            We took the very conservative dronabinol dosing model and applied it to
            standard combustion-and-inhalation pharmacokinetics for cannabis.
            Applying this to the least potent strains, we derived a 60-day cannabis
            supply of 15.7 oz, which is essentially 1 lb. This is strikingly similar
            to the 1.105 lb of smoked marijuana as calculated above. Applying our
            gut delivery 4-fold conversion factor, this translates to a 60-day
            supply of 62.8 oz or 3.925 lb.Admittedly,
            there are limitations with this approach, given the fact that much
            higher doses of THC are tolerated when delivered as part of the full
            cannabis chemical cocktail vs when taken in pure form, but its logical
            results do seem concordant with what patients who are delivering
            combusted cannabis via the lungs have reported. However, in our prior
            dosing article, we stressed 3 very important points that should not be
            overlooked: First, long-term cannabis users can, and probably will,
            develop some degree of tolerance. Thus, it is conceivable that a
            long-term cannabis user may require significantly larger amounts of
            cannabis to achieve a therapeutic effect. Given that there is no known
            LD50 for cannabis, this should not be a major concern.

        • Charles Waller

          Conclusion

          We
          end by concluding that any government agency, including the WA DOH,
          should adopt presumptive dosing and supply limits that are based on an
          understanding of the best scientific evidence that is currently
          available in the field of cannabinoid medicine. Any other presumption
          would go against the prevailing tide of evidence-based guidelines in
          medicine and public health. To do otherwise would also be contrary to
          the mission of our WA DOH – or any state agency in any state in our
          country, for that matter.

          As for the
          question of how many cannabis plants should a patient or caregiver be
          allowed to have (which would theoretically provide the aforementioned
          amounts of medical marijuana), this is not necessarily germane to the
          question of dosing. Rather, this is an issue that is best addressed by
          authorities in the sciences of cannabis botany and horticulture.
          Anything short of that would be a validation of the excessive
          politicization of cannabis germplasm maturation, which continues to be a
          federal felony. Thus, if the Department of Health feels compelled to
          establish a plant limit, then they should choose an upper bound that
          respects the excesses of federal law. The figure of 99 plants is most
          appealing because at 100 plants the federal mandatory minimum 5-year
          incarceration penalty applies. It is time to value the promotion of
          health and quality of life over such legal absurdities.

      • gmo2ashes

        Absolutely ridiculous. Never in the history of mankind has marijuana harmed a human being.The rule is absurd as having to legalize cannabis in the first place.

        • Aletheya

          True, but it’s vital that Colorado and Washington bend over backwards to
          demonstrate that they can legalize successfully without causing
          problems for neighboring states, or allowing kids to have access, etc.
          Because if they can, other states will follow suit, but if people
          perceive significant problems, legalization could be stopped in its
          tracks. The Feds, for example, could decide to crack down. So,
          ridiculous or not, they need to go the extra mile, and I’m glad they’re
          doing so. The game needs to be played well, so we can all win in the end.

          • Charles Waller

            Playing their game concedes that their position has validity, which it does not. Prohibition has been unconstitutional since CA used racial bias to pass the first laws against “marihuana”, which was not even cannabis – although it typically did contain cannabis leaves and flowers as a component of a widely varying mixture of tobacco, “locoweed” and various other herbage and ingredients. Combined with alcohol use, it actually was responsible for some extreme behavior in users. The Tax Act was rammed through Congress, riding the wave of hysteria and racial bias promulgated by vested interests with Harry Anslinger as the front man. The Controlled Substances Act was passed in a similar manner, with cannabis assigned to Schedule 1 “temporarily”, until research could determine the appropriate classification. There is remains over 40 years later, despite the scientific evidence which was available at the time (since Dr. W.B. O’Shaughnessy reported on the therapeutic benefits in 1842), despite all the scientific evidence considered by DEA Chief Administrative Law Judge Francis Young before he ruled against the DEA and ordered rescheduling in 1986, calling cannabis, in natural form, one of the most therapeutically beneficial plants known to mankind, despite all the evidence amassed by research in the nearly 3 decades since that ruling, despite the fact 3 ineffective synthetic singular cannabinoids have been approved by the FDA and despite the current phase 3 trials of GW Pharma products Sativex and Epidiolex, both less effective than pure whole plant cannabis extract oil being used to treat pediatric seizure disorder patients such as Jayden David, Charlotte Figi, Vivian Wilson and untold others. Despite the pain, suffering and death of children who are prevented from accessing this safe medicine, simply to insure profits are not lost by those with vested interests in perpetuating prohibition. The game is killing people, and I refuse to accept the status quo, I refuse to concede the necessity of going along to get along, I refuse to credit those who refuse to accept reality with any humanity, conscience or validity. I believe sincerely after over 40 years of being patient the time has come for everyone everywhere possible to sow seed this coming spring – to force the inevitability of restoration of this beneficial plant to people in dire need. We have the right to refuse to obey unjust, unconstitutional laws and the “establishment” cannot persecute, prosecute and incarcerate us all. The time for being reasonable and rational with unreasonable and irrational people has ended. The time to stand up for our rights has come, and I hope every person reading this will spread the word. We, the people need a new revolution – a green revolution in every sense of the word. Renewable resources, clean energy, natural medicine and food & clothing that doesn’t make us sick and wear out in a year. Time to return to Mother Earth, Father Sun, Brother Wind and Sister Water. Time to become Children of Gaia again.

            • Aletheya

              Charles – I agree with everything you say, but you’re talking principle whereas I’m simply acknowledging the political and practical reality. Things are going the right way with respect to weed, but it’s going to take a little more time, and going too “in your face” about it could blow up the whole thing. It can still easily swing back the other way. Logic and politics are two different things. We must keep our eyes on the goal, but be smart about the tactics, or we can still lose. Be happy, great progress is being made. Don’t let the perfect be the enemy of the good.

              • Charles Waller

                I understand your points, position and perspective. I simply disagree. I view the current developments as nothing more than a combination of stalling tactics to keep the general public confused about the facts, until the corporate co-opting of cannabis as another rigidly controlled profit method for vested interests exemplified by entities such as GW Pharma, Medical Marijuana, Inc. and other profit based corporations can be assimilated as the new paradigm. I believe unregulated personal cultivation and possession will transition to civil offenses for small amounts, and remain criminal offenses for anything else. Everything occuring at the state level remains illegal under federal law unless, and until, cannabis prohibition is completely eliminated and govermental regulation limited to activities involving commerce only, as is indicated by the Constitution and Bill of Rights. Anyone under the illusion their activities are legal under state law can be forced to face the rude reality at any time. The federal government is obviously being deliberately obfuscatory and intransigent in this matter, and it is not due to lack of knowledge. Consider that if the Civil Rights activists over half a century ago had taken the same position some states would still be overtly repressing citizens rights to this day.

                • AntiSocialSailor

                  I agree completely. Vested interests have the gov’t firmly in control, spreading whatever disinformation and propaganda they can get away with. The end game is to monopolize marijuana via ridiculous and excessive regulation, passed in response to orchestrated PR campaigns sponsored by pharmaceutical companies and the PIC.

                  This is the exact same thing they’re attempting to do with e-cigarettes. Since the tag team of PHARMA and Big Tobacco failed to get them classed as drugs, Big Tobacco has bought into the industry and is now attempting to influence upcoming FDA regulations in such a way that only they, with their overpriced and crappy performing products, can meet them. When e-cigs must include tamper-proof, disposable cartridges made in FDA certified labs under strict conditions, an entire cottage industry will be wiped out overnight and millions of people will be doomed to continue smoking after trying and hating the substandard products marketed by Big Tobacco. And, of course, the overblown and illusionary risk of children picking up a nicotine habit will be the pretense for the elimination of the flavored liquids that have weaned millions of adults off the nasty taste of tobacco.

                  Someone above (you?), recommended sowing seeds. I agree wholeheartedly. Problem is, much of today’s marijuana has no seeds. But for those who still get the old fashioned bag with seeds and stems, save your seeds. Throw them everywhere they have a chance of sprouting. We need to blanket this country in so much marijuana that it becomes an impossible task to try to stop it all or to try to monopolize its production or distribution.

                  • Charles Waller

                    You hit the nail on the head, and provided an extremely relevant example to support the point. I’ve watched with amusement the rush to profit from the vaporizing market before the FDA responds to corporate dismay at the loss of money in their bottomless pockets.

                    As regards seeds, there is still an enormous amount of questionable “brick” product being distributed, and while some of it is substandard varieties, not worth cultivating, from everything I have read a large portion of it is high quality genetics with poor production, processing and handling. People don’t have to return to the same dealers if they have anywhere at all to cultivate. Even the substandard varieties are useful for sowing in public places. I hope that more people realize that relying on others ultimately places them at their mercy.