Extract from - A Response to the Report of the Working Party on
the Use of Cannabis for Medical Purposes
February, 2001 by Dr Lisa Jackson (M.B.B.S) et al.
Cover letter
Contents
Introduction
Need for Medical Cannabis
Risks to patients using poor quality cannabis
Dear Professor Hall and the Working Party Committee,
Thank-you for the opportunity to respond to the report and recommendations of the working party.
My response at this time was prompted by the encouragement of Ethical Medical Cannabis Supplies (EMCS). I have a registered business which holds the aim of facilitating development of environmentally and socially friendly industries. More than two years of researching the potential of the cannabis plant with regard to human, environmental and economic benefits, has convinced me of the immediate need for legislation to come into line with current scientific knowledge and public opinion, so that Australians may benefit from this most useful of plants.
Firstly may I commend you for finally attempting to address some of the issues surrounding the use of cannabis for medical purposes.
However the whole debate highlights a number of incongruities:
That many people find cannabis of so much therapeutic value that they are willing to risk criminal prosecution under the drugs act,
yet when compared to drugs readily available, either from the supermarket or by prescription, cannabis is remarkably safe and absurdly highly restricted.
Why do I need to write a whole submission just to allow even one severely ill patient access to medical cannabis?
when I could just write a prescription for a much more dangerous drug, with higher toxicity and commonly more side effects?
Thankfully the Working Party has acknowledged cannabis’ medicinal value and recommends protection for the medical user and their care-givers from prosecution,
but otherwise it does very little to provide for these peoples’ needs, forcing most of them, (except the experienced gardeners with both space, time and physical mobility – uncommon in the severely ill and their caregivers), into liaison with the black market and providing none of them with the means to quality assess the medicine they are using.
As a natural herb, providing food and medicine, cannabis has been safely used for thousands and thousands of years,
however the last few decades has seen the false ideas that cannabis is highly dangerous and useless medicinally, arisen to such an extent in broad sections of the community, (quite a coup for a propaganda campaign), that prohibition itself is creating new harms.
That non-profit groups working altruistically to provide medicinal grade cannabis, to only a few of the many people in desperate need, have made valiant attempts to include scientific quality control, and use ‘herbal’ cannabis which is arguably much better medicine than cannabinoid preparations,
but that to all intents and purposes the Working Party and NSW government seem set to; in the short term, deny people safe medicine; and in the long term penalize Australians in favor of less effective chemical isolates, synthetics and proprietary owned and controlled therapeutic goods, most likely imported, definitely of much greater economic and ecological cost and for generally lesser quality medicines.
Yours Sincerely,
Dr. Lisa Jackson
PS. When I started this I never intended it to be so long – sorry, hope you find it interesting anyway.
Contents
Introduction
Need for Medical Cannabis
Summary of response to the Working Party’s Recommendations
"Following calls by the Australian Medical Association (AMA) for people with cancer and AIDS to be prescribed cannabis for pain relief, the Government convened a working party to advise the Government on:
Despite the wording ‘cannabis’ and ‘clinical needs,’ from the very first recommendation of the working party report there is an apparent emphasis on pharmaceutical preparations of cannabinoids.
I find this distressing from the perspective of a practicing doctor, a taxpayer and potentially a patient or caregiver.
The Working Party has agreed with the conclusions of the British House of Lords and the United States Institute of Medicine that some cannabinoid substances may have value in the treatment of a limited range of medical conditions, yet there is a distinct lack of research into the medicinal value of cannabis which has not been addressed
In 1985 a review article on THC commented that "Two decades after the isolation of delta 1-THC (delta 9THC) its mode of action is still obscure despite the enormous amount of research invested in it." Fifteen years on pharmaceutical preparations of THC are noted for their high expense and poor bioavailablity, with patients commonly reporting they prefer to smoke cannabis.
Whilst recommendation 5 acknowledges the importance of assessing the therapeutic efficacy of cannabis, it is ignored in recommendation 8 in favor of cannabinoids. Why is the research into chemistry and pharmacology to develop therapies with safer and more effective delivery already directed entirely into investigation of cannabinoids only? When the terms of reference of the WP include "To establish if and how cannabis can be effectively administered with the least harm to patients." Additionally, Recommendation 5 has not yet occurred, and there has not yet been any assessment of the therapeutic efficacy of either cannabis or the cannabinoids.
The development of safer and more effective delivery of cannabis is relatively quite simple, (but still in need of research and development), and definitely more cost effective than for cannabinoids.
Irregardless of the outcomes of research, a significant number of ill people are currently using cannabis and will likely continue to do so in the future, hence the additional need for relevant research, education and delivery systems for cannabis.
The compassionate regime recommended by the working party will relieve the stress and criminal liability of current prohibition from patients and their caregivers. But the idea that patients and/or their care givers will be able to readily produce a small supply of cannabis places unnecessary burdens on these people already under stress; creates easily a six month delay in access to seasonal home grown medicine; provides no known quality seed stock; provides no quality assurance; puts them at risk of theft and home invasion; is quite difficult to achieve horticulturally; forcing people into hydroponic production, with its costs and risks; or necessitating cooperative efforts, much like the Californian compassion club system. People unable to manage this will be forced to return to the black market with its attendant legal and health risks.
For no other medicine are patients or their caregivers expected to, produce it themselves, or purchase it from the black market, and to manage quality control.
The production and supply of medical cannabis needs to be addressed legislatively, and with practical common sense.
Authorization, should consider the expertise of medical practitioners from a variety of systems including Western/allopathic, Chinese, Ayurvedic, homeopathic, naturopathic and other medicines who have traditionally used cannabis as an element in their medical practice. Additionally, many practitioners will need appropriate education, following sixty years of inexperience in its use. The combination of medical systems will enhance our understanding of how to safely and effectively use this herb as an effective tool in disease and symptom management.
There is a way to best address the needs of patients, practitioners and researchers, by changing state regulations to make cannabis a controlled natural product, restricting its access to patients authorized by suitably educated and accredited practitioners, and licensing secure organic production, of quality controlled and graded of potency, natural cannabis and cannabis products.
Need and demand evident – why else this report
The fact that so many patients still choose to use cannabis for its therapeutic effects, despite its illegality, is testimony to both this plants qualities as a medicine and patients right to choose.
Obviously patients should not be persecuted for using a natural medicine to improve their quality of life.
Australia currently has around 15,000 recorded cases of HIV and NSW has the highest numbers of people with HIV or AIDs of any State.
"For many people living with HIV/AIDS, the use of cannabis is a vital component of their overall treatment regime and management strategies. Cannabis is used to maintain their life-extending allopathic treatments, making some of the side-effects they experience less acute and providing a better quality of life and more treatment choices. The issue cannot be treated academically but must give close consideration to the lived experience of those already using cannabis and gaining benefit from it."
"For patients, such as those with AIDS or undergoing chemotherapy, who suffer simultaneously from severe pain, nausea, and appetite loss, cannabinoid drugs might offer broad spectrum relief not found in any other single medication." Cannabis has at least equal, but probably greater potential to benefit people with these conditions.
Many people suffering from wasting syndromes (associated with AIDs cancer, chronic disease, etc) are at risk of dying, effectively from starvation, long before federal, importation or therapeutic goods regulations could possibly be met. Thankfully, for the sake of those in need, NSW is in a position to amend its regulations and provide for safer use and research in a much shorter time.
"Clinical trials of cannabis for the treatment of MS and chronic pain should be mounted as a matter of urgency".
While it is good that patients may be able to avoid prosecution for medical cannabis under the recommendations of the Working Party, this still leaves them with few options on how to access safe, high quality supply of cannabis in their time of need.
Knowing that some patients may be particularly susceptible to the micro-organisms sometimes present in cannabis, and to provide no realistic supply, no access to quality control, and leaving them exposed to the risks of the black-market, could be seen as negligent.
On a global level the incidence of AIDs related disease is dramatically on the increase. One of the main regions to be affected will be the Asia-Pacific region, where the disease burden will be immense and far beyond the economic and infrastructure resources of the already economically stressed countries involved. These countries will be in no position to pay for proprietarily restricted pharmaceutical cannabinoids. Local international neighbors will need to assist, with the development of know-how for safe, low cost, locally produced effective medicine.
Authorized Prescribed conditions
The potential usefulness of medicinal cannabis is much broader than the Working Party Report describes.
Anecdotally there are a number of other conditions for which patients commonly medicate with cannabis, including; hepatitis C (HCV) infection, migraines, menstrual syndromes, opiate and alcohol withdrawal; because there is either no alternative medication, or patients feel cannabis is more effective and/or with less side effects than other medications available. Practitioners should not be expected to have to make special applications for patients in need of cannabis for unusual (not already recognized conditions) when their medical expertise tells them it is the most suitable choice in medication.
Risks to patients using poor quality cannabis
This section does not address the risks of cannabinoids as they are currently not available, for a discussion of problems associated with their use please see page , nor does it address the risks of prosecution due to cannabis laws.
It is apparent that Australia has performed minimal analysis of cannabis, so we are left with overseas reports, anecdotal subjective evidence and theory.
Additionally, there has been no research into the possible effects of disordered plant physiology due to artificial growing methods.
"Viable fungal spores in marijuana pose the greatest hazard to immunocompromised patients"
Many of the patients currently using cannabis medicinally are immunosuppressed (AIDs, cancer and wasting syndromes are all strongly associated with reduced immunity to infection) and at increased risk of contracting opportunistic infections such as aspergillosis
"Although aspergillus is infrequently isolated from HIV-infected persons, the associated high mortality would support serious consideration of its clinical significance in those with advanced disease and risk factors."
Physicians should be aware of this potentially lethal complication of marijuana use in compromised hosts."
"A 34-year-old man presented with pulmonary aspergillosis on the 75th day after marrow transplant for chronic myelogenous leukemia. The patient had smoked marijuana heavily for several weeks prior to admission. Cultures of the marijuana revealed Aspergillus fumigatus with morphology and growth characteristics identical to the organism grown from open lung biopsy specimen. Despite aggressive antifungal therapy, the patient died with disseminated disease."
Black market cannabis may contain;
Response to; Report of the Working Party on the Use of Cannabis for Medical Purposes, - Full document - 144 KB, pdf file