We are writing to request that marijuana NOT be rescheduled to a lesser class of drug under the Controlled Substances Act.
Potency and Toxicity: The Escalating Threat of Marijuana
In our professional opinions, the increasing potency of marijuana poses a significant threat to public health, necessitating a cautious approach in its classification and regulation. No other drug with such a spectrum of problems has been considered for rescheduling to a lower CSA schedule.
Our review of the scientific literature on marijuana does not support rescheduling. IASIC professionals reviewed the scientific and medical research on marijuana in the following areas and share these resources in our library.
Questionable Medicinal Applications: An Overstated Narrative
Our ongoing review of the literature on the medicinal applications of marijuana suggests that the medicinal applications have been highly overstated. Dispensary marijuana has hundreds of potentially physiologically active molecules with variable actions, toxicities, and concentrations. It is impossible to scientifically test or approve as medicine a drug that has variable and unpredictable components.
Dispensary marijuana has not been proven effective in any medical condition, a requirement for rescheduling the drug. To cast aside the requirement for controlled scientific testing of drugs upends policy, which for nearly 100 years has given Americans confidence that when something is classified as “medicine”, it has been tested and is safe and effective at treating disease. For this reason alone, it is extremely dangerous policy to reschedule dispensary cannabis.
Criteria for Rescheduling: Failure to Meet Standards
When the decision to reschedule marijuana is evaluated using the CSA criteria, it fails on all accounts. Thus, marijuana cannot be considered a “medicine” because it fails to meet any of the standards required for a substance to be considered a medicine.
- The drug’s actual or relative potential for abuse
- The scientific evidence of the drug’s pharmacologic effect, if known
- The state of current knowledge regarding the drug
- The drug’s history and current pattern of abuse
- The scope, duration, and significance of abuse
- The risk, if any, to public health
- The drug’s psychic or physiological dependence liability, and
- Whether the drug is an immediate precursor of a controlled substance. § 811(c).
Public Health Risks: Addressing Marijuana-Induced Health Harms
Rescheduling decreases the perception of harm in the public’s view at a time when the drug is being engineered to be more potent and more addictive and consequently presents a greater risk to patients’ physical and mental health. As physicians, we need to highlight the devastation and unpredictability of marijuana-induced psychosis, the burden of marijuana-induced vomiting, suicidality, cardio and cerebrovascular injury, and automobile fatalities which are more frequently appearing in the nation’s emergency departments.
Specific Elements that compel marijuana continuing to remain classified in Schedule I are:
- High Abuse Potential
- No compelling evidence of medicinal benefits of the crude drug over available medications
- Presence of significant harmful toxic properties
- No clearly agreed upon beneficial therapeutic dosage.
Learning from State Legalization: The Industry vs. Medical Community Perspective
As we saw with individual states’ legalization and commercialization of marijuana, a decrease in perception of harm from federal rescheduling would hurt public health as the drug will falsely be seen as more benign. State changes have been driven by the marijuana industry and not the medical community.
In summary, the leadership of the International Academy on the Science and Impact of Cannabis (IASIC) opposes the rescheduling of marijuana and urges continued classification as a dangerous, addictive, and harmful drug of abuse.
Eric A. Voth, M.D., FACP
Internal Medicine, Pain, Addiction Medicine
President, The International Academy on the Science and Impact of Cannabis (IASIC)
Ken Finn M.D.
Pain Management and Physical Medicine & Rehabilitation Drug Policy
Roneet Lev, M.D.
Emergency Medicine & Drug Policy
Elizabeth Stuyt, M.D.
Addiction Psychiatry & Drug Policy
Catherine Antley, M.D.
Pathology & Drug Policy