There is something amiss in the New Mexico Medical Cannabis Program. Well, to be truthful there are a lot of things amiss in the program, but this is post is about the most recently debated issue: medical cannabis safety testing.
According to “High Standards”, a February 1, 2016 article published by The Santa Fe Reporter, written by journalist Peter St. Cyr, a group of NM Licensed Non Profit Producers, (medical cannabis producers), are suing the NM Dept. of Health who oversees the state’s medical cannabis program, because they feel that some of the standards the DOH is now enforcing regarding the testing of cannabis products, has gone too far by using standards set for pharmaceutical drugs instead of standards set for herbal products. That’s my synopsis in a nutshell, so I recommend reading the SF Reporter article yourself.
The US Pharmacopoeia sets the much needed standards for pharmaceutical drugs and dietary supplements. In more recent years they have backed away somewhat from dealing with herbal products like the ones used in Chinese medicine, Ayurvedic medicine and the like. The American Herbal Pharmacopoeia has picked up the slack, and in 2014 published their own long awaited and much celebrated monograph on cannabis. All the monographs are heavily researched by industry and scholastic professionals. The research and preparation that goes into these monographs takes years to complete, cross research and then publish, and the Cannabis Inflorescence, Standards of Identity, Analysis, and Quality Control is no exception. The people who chose to volunteer for this task in regards to cannabis is impressive, and includes names you may be familiar with, like Mahmoud ElSohly, PhD of the University of Mississippi, Raphael Mechoulam, of the Hebrew University of Jerusalem, Ethan Russo, MD, and Michelle Sexton of Americans for Safe Access among may others. My point is – these are all people familiar with cannabis and have decades of experience with the science of this plant and its uses. I wouldn’t start an argument with any one of them. They are the experts.
In stark contrast, the US Pharmacopoeia has no experience with cannabis, and doesn’t even offer any information at all with regards to this plant. They defer to the American Herbal Pharmacopoeia, as does the FDA whom actually has this herbal entity do consults for them. So, if the FDA trusts the AHP they why doesn’t the NM DOH?
Now, I would think that our DOH was ignorant of the implications of using standards set for pharmaceutical pills and potions, except for the fact that erroneously utilizing the US Pharmacopoeia standards was brought to their attention by a former Albuquerque lab owner in 2013, and again by little old me in a letter to them pointing to the AHP standards in 2014. They chose not to defer to the standards set by experts in the field, and came up with a standard for testing that was seemingly arbitrary, but was in fact set by a scientific community that doesn’t concern themselves with cannabis at all. In other words, they are using standards that apply only to pharmaceutical drugs made in a factory. Is this a fair comparison; comparing factory drugs to a plant grown in the ground or hydroponically? Not in my opinion.
What does this mean for patients? I’m not quite sure, but the cannabis producers in New Mexico who are suing the DOH with regards to testing for molds fungus certainly have a strong case. Now, is the cannabis that is tested by the standards that Colorado and Washington have set – the standards of the AHP – safe for consumption by medical cannabis patients? By my opinion, yes, because the AHP researchers and reviewers had cannabis patients in mind when they created their standards, and not just recreational users.
What about the patients who have auto-immune diseases? Does the DOH hope to protect us with these more stringent standards? Personally, I don’t believe that was the goal, because if it was, why are they NOT requiring our cannabis medicine to be tested for harmful pesticides? Why indeed!
It has been argued that patients with auto-immune diseases may be more susceptible to mold and fungus contaminants than others are. I won’t argue that. But I will say that with confirmation that the endocannabinoid system that exists in our bodies is connected to regulation our immune system and thereby immune disorders, and the introduction of phytocannabinoids into our systems aids the immune system, and that there have been no reports that I know of that people are being poisoned by cannabis tested to the standards of the AHP, I will stick with my understanding of their findings and recommendations.
With that in mind, why is our Medical Cannabis Program throwing so much weight into the recommendation of an organization that doesn’t even concern themselves with cannabis, all the while ignoring the documented harms of pesticides to the general public, let alone medical patients? Requiring the cannabis producers to put the pesticides they use on the label of their products is like asking the fox to watch the hen house and report back on how many chickens and eggs they ate. This is a ridiculous form of quality control and is truly what is putting all patients at risk.