VandeKemp Response to MMAR
Mr. Bruce Erickson
Office of Controlled Substances
Drug Strategy and Controlled Substances Programme
Healthy Enviroments and Consumer Safety Branch
Address Locator: 3503D
Dear Mr. Bruce Erickson:
I am writing to give you my opinion regarding the new proposed regulations for medical cannabis as Mr Allan Rock requested in his letter to me dated April,12, 2001.
Upon reading the proposed regulations I see you have not yet dealt with the “compassion club issue” for the sale, manufacture and distribution of medical cannabis. This outstanding issue is very critical to the well being of medical users of marijuana and should be dealt with sooner than later. I personally am a member of three such clubs who often provide me with medicine(even tho I grow my own),when my own medicinal garden is in peril from various potential catastrophes. I also used these clubs before I obtained an s.56 exemption to obtain medical grade cannabis and bypass the street drug dealers in the potentially dangerous black market, further protecting and insuring my own saftey. These compassion clubs, already existing and other potential clubs yet to appear, are essential to our wellbeing and should be allowed to continue unfazed by these new and forthcoming regulations. Tho perhaps licenses could and should be issued to the compassion clubs and their growers and rural distributors so as to legitamize their crucial and important existence to my fellow ill cannabis users. To shut these clubs down or restrict their distribution and growing methods would be catastrophic to all sick Canadians and a severe festering blemish on Health Canada’s record for which the public outcry would be deafening to your ears!
Now after reading through the new proposed regulations my initial impression was that the rules were more strict, costly, time consuming, restrictive, too comprehensive, confusing, and required much more paperwork, trips to the doctors, and threatened my personal privacy and my physicians integrity. If that is your defintion of greater clarity and compassion to sick and dying Canadians then I am taken aback by your ignorance and gall.
To be specific I will provide my opinions on certain parts of the new regulations as follows:
– There was no mention that I could find about existing exemptees and how the new rules would affect them-would they be grandfathered?
– there was no mention that I could see that reflected my use of harm reduction techniques such as eating or vaporizing cannabis?
-there was no mention that I could see of quantities of plants and amounts of dried marijuana needed to produce sufficient amounts of hashish /or cannabis resin to reduce any harm that smoking raw plant material may cause?
-There seems to be a conflict of interest for my health and well being when you state that ” to employ marijuana is best determined by my physician” as it should be! Yet your beauracratic organization may or may not grant me safe access to the drug by exempting me from the laws?
-The three categories of illness are not needed and contribute unwarranted strain and fustration on us. It should be good enough that my physician has written me a cannabis perscription for whatever ails me. I should not have to prove I am going to die in 12 months or seek out the approval of 2 or 3 specialists to have safe acess to marijuana. This is way too costly, time consuming and difficult for a disabled person! In my case I did’nt have the approval of a specialist and you still approved me!! And thank GOD you did because I am now back on my feet and looking for fulltime emloyment! Seems strange my physician can perscribe me heroin and opiates and synthetic pharmecuetical concoctions far more harmful than cannabis- yet to obtain cannabis I must jump through 2 or 3 extra hoops? If these rules are not refined and made less restrictive the majority of medicinal pot smokers will simply bypass your compassionate process and further contribute to the flourishing black market already in existence. Perhaps endangering their health in the process to which you will be to blaim.
-For all three categories, a 30 day treatment supply is way way too low! It takes at least 90 days and many times longer to refurbish supplies. I would suggest a minimum of a 90 day supply on hand at any given time, even better would be a 180 day supply so as to counter any negative gardening experiences.
-The rules regarding a license to produce marijuana are too limiting! The fact that I am an expert grower and cannot grow for any other exemptees because I need to grow for myself is assinign. The majority of the exemptees I know of personally are having either no luck or a very difficult time becoming an expert indoor farmer. Their medicinal supplies are almost nonexistent and the quality of their pot is substandard at best.
-The rule stating that a “growing” representative can only be designated by one person and cannot grow for more than one patient is ridiculous at best. See above.
– Growing indoors or outdoors is an option I like! The cost of growing outdoors is a substantial savings to us. Besides most people have some past experience growing pot outdoors and have little expertise growing indoors.
-A criminal record check of potential caregiver growers will not protect us exemptees from the vile people who pray on us everyday while we struggle to become expert indoor farmers. I know of many medical use people like myself who have been betrayed and abused by potential growing teachers and the like. I myself had to seek out the best grower in my small town to teach me indoor cultivation techniques. Unfortunatley he turned me into the police after I would not co-operate with him and give him 1/2 my crop so he could sell it to local school children. Don’t get me wrong, caregiver growers, I think, are the life blood of most of us exemptees. However honesty and trust is earned and not stated in a criminal check by police to prove that my local drug dealer caregiver was not caught in the past. Besides the chances of living nextdoor to a superb pot grower is akin to winning the lottery at best and finding a knowledgable producer will prove most difficult if not impossible.The best solution is to allow exemptees to help one another without undo restrictions and for expert pot growers regardless of past indescretions be allowed to produce under license for as many sick people as space and resources will allow. Who best to look after our own concerns and tribulations than fellow sick and caring people and expert pot growers. In my case I am healthy enough now to grow for many people who have cried out for my help but alas I am confined and bound by your restrictive chains.
-The increased administrative burden to medical practioners will prove costly and time consuming for patients. Further backing up the processing system and delaying exemption approval which is totaly unacceptable.
-The decision to allow the use of marijuana in hospitals should be refined so as not to discriminate against the patient but allow use in designated areas or outside if nessessary.
-To allow use of medicinal pot in the correctional system at the discretion of the institution is also discriminatory when other inmates are fully known to engage in such activities regardless of their legality.
– To have sick and disabled people, already exempted from the laws, remain under threat of police invasion because of generally small discrepencies in usage or growing methods or for sharing or giving medicine to help each other out is unnessessary and indispicable. Living with this threat over our heads while we fight the courts , Health Canada, the public and our illnesses is unbearable. A truce is called for. The police should only be involved if insurmountable evidence exists of high level trafficking or exportation.
-Inspections of our homes for compliance of inventories, records, and security of the proposed regulations is warrantless invasion of our personal privacy and should be condemed.
-5 grams daily dosage should not be put under such heavy scrutiny, especially if the patient is eating or vapourizing their cannabis. Most exemptees I know are growing very weak and mild pot-5 grams of their marijuana would not satisfy the needs of most people.So the dosage restrictions should be abolished. My physician will remain the ultimate judge of what is the proper daily dosage for me based on numerous criteria pertinent to the issue.
-The statement regarding outdoor production within one Kilometer from a school, playground, or day care centre or other public place is ludicrous. I live within the boundries of all the places you state. I even have young children at home of my own. It would be impossible to comply with this rule. As long as the area is not exposed to the general public there should be no such restrictions.
-I’ve always remembered this statement I found on the internet one day:” If the quality of your life depended on growing your own medicine-how much would you grow?” Most people would grow more than they need to compensate for when things go wrong in the garden or if your state of health deteriorates and you can no longer cultivate as well. So in other words your formulas for number of plants and quantity of dried marijuana are way off base. I understand you need to place a number on amounts but weighing in on the liberal side would be the best advice for patients. You have no idea what it’s like to run out of medicine and be desparate. By my calculations a daily dosage of 5 grams would require 1825 grams per year or 64.38 ounces per annum. Divided by a 3 month indoor growing and harvest cycle and an average of one ounce of dried, cleaned and pruned marijuana per mature indoor plant, would result in requiring 16.10 ounces per growing cycle or 16 mature plants and not the 10 suggested by your inadequet formula. The same goes for your overly conservative formula for dried marijuana.
-Record keeping with respect to growing cannabis, places another burden on us and is useless and irrelavant to our medical needs.
In conclusion: I find the new regulations cumbersome, overly complicated and restrictive. Showing no compassion or common sense and further hindering the application process and implementation of our medical requirements. However I do appreciate the opportunity to comment.
Stephen J VandeKemp