DEA CANNABIS RESCHEDULING

PUBLIC COMMENT VIEWER

Here is a random public comment on the rescheduling of cannabis to Schedule III from Aaron Miller.
I am submitting comments in strong support of the reclassification of botanical cannabis (Docket No. DEA–1362). The Department of Health and Human Services (HHS) has appropriately concluded that cannabis “has a currently accepted medical use” and that its abuse potential does not justify its classification as either a Schedule I or Schedule II controlled substance. HHS reached this conclusion based on widespread recognition within the medical community that cannabis has legitimate therapeutic uses, particularly in pain management, and can be administered safely under medical supervision. Thirty-eight states currently regulate the production and sale of botanical cannabis and related products to eligible patients. An estimated six million patients and approximately 30,000 healthcare practitioners participate in these programs, many of which have been in operation for decades. Not a single state has repealed access to plant-derived medical cannabis products, demonstrating that medical cannabis can be regulated safely and effectively, with public health benefits far outweighing any potential costs. Nationwide, 69 percent of practicing clinicians believe in the medical utility of cannabis, and more than one-quarter have recommended it to their patients, according to 2022 survey data from the US Centers for Disease Control and Prevention. Additionally, several prominent medical societies and associations, including the American Nurses Association and the American Public Health Association, have called on the federal government to “move expeditiously to make cannabis available as a legal medicine.” Cannabis has a superior safety profile compared to many other controlled substances and does not meet the stringent criteria for either a Schedule I or Schedule II classification. HHS has stated, “The risks to the public health posed by marijuana are low compared to other drugs of abuse,” such as benzodiazepines (a Schedule IV drug) or alcohol (which is unscheduled). They further concluded, “No safety concerns were identified in our review that would indicate that the medical use of marijuana poses unacceptably high safety risks for the indications where there is some credible scientific evidence supporting its therapeutic use.” In summary, cannabis does not meet the criteria for a Schedule I or Schedule II controlled substance. While I advocate for the complete removal of cannabis from the Controlled Substances Act (CSA) to align federal policy with that of most US states, I support the HHS recommendation to reclassify botanical cannabis to Schedule III or lower. It would be arbitrary and capricious for the DEA to reject the factual findings of the HHS and to maintain the existing prohibitions on the cannabis plant.
Over 42,000 public comments were submitted. Public commenters, thank you for your courage!