DEA CANNABIS RESCHEDULING

PUBLIC COMMENT VIEWER

Here is a random public comment on the rescheduling of cannabis to Schedule III from Laura Bruce.
The high potency THC available on the legal and illegal market in my community is only making substance use worse in my neighborhood and region. With THC vapes, which are very available to youth and come in a variety of flavors, delivering potencies over 70% (compared to the 2-3% THC potency available in the 1970's), we are seeing more addiction and early youth initiation. While tobacco and alcohol use is going down, youth use of marijuana is increasing. This rescheduling will cause undue harm to my community, and allow another addiction-for-profit industry (Big Marijuana) to take hold. I am writing to register my opposition to the recommendation to move marijuana from Schedule I to Schedule III of the Controlled Substances Act. Rescheduling marijuana would allow the marijuana industry to deduct normal business expenses, including advertising and marketing expenses. This would make the industry profitable and incentivize them to spend even more on advertising and marketing. This would likely cause marijuana sales and the harms associated with marijuana use to rise in tandem. Big Tobacco taught us the deleterious impact of advertising on youth: the more teens are exposed to tobacco advertising, the more likely they are to start smoking. The same will be true with marijuana. The marijuana industry will undoubtedly take a page out of Big Tobacco’s marketing playbook, making marijuana use look glamorous and benign with celebrity endorsements, candy flavoring (already seen in marijuana edibles), product placement in movies, and more. Even without the expected deluge of ads and marketing, marijuana use is at an all-time high. Teen use of marijuana is at 30- year high, with more teens reporting smoking marijuana than tobacco. Among young adults 19 to 30, 26% used in the past month compared to 17% in 2011, and 11% were daily users, up from 6% in 2011. HHS' recommendation failed to account for actual/relative potential for abuse or harms associated with use. Contrary to popular narrative, marijuana can be addictive. In fact, as many as 1 in 3 past year marijuana users met the clinical criteria for Cannabis Use Disorder. People who self-medicate with marijuana are not exempt from becoming addicted. According to research at Massachusetts General Hospital, “using cannabis products to treat pain, anxiety and depression failed to improve these symptoms while doubling the risk of developing the addictive symptoms of cannabis use disorder.” With the exception of one study of medical marijuana patients in Maryland, the review from HHS failed to acknowledge or consider the link between marijuana and psychosis. This is especially concerning in light of the rising potency of marijuana. Daily users of marijuana over 10% THC are nearly five times more likely to develop a psychotic disorder than non-users. A 2023 study in Denmark determined that 30% of cases of schizophrenia among 21–30-year-old males could have been averted if cannabis use disorder had been prevented. A 2022 study found that hospital discharges for marijuana-associated psychosis were higher in states with legal marijuana, another precursor if those who push full-scale commercialization have their way. Marijuana use is especially concerning in young people, a factor HHS failed to adequately address. The National Center for Education Statistics said, “adolescent marijuana use has been associated with lower academic performance and a higher risk of dropping out of high school.” Colorado, the first state to legalize recreational marijuana, warns, “Youth who use marijuana regularly are more likely to have a hard time learning, problems remembering, and lower math and reading scores. These effects can last weeks after the last time they used marijuana.” Recognizing that much remains unknown about marijuana, NIDA noted, “researchers are still studying how long marijuana’s effects last and whether some changes may be permanent.” Finally, while some states recognize “medical marijuana” there is no currently accepted medical use. Unlike other drugs in Schedule III, marijuana is not FDA approved to treat or cure any disease and it is not available for prescription in any state. In 2023, the American Medical Association adopted a position statement that “encourages hospitals and health systems to: (a) not recommend patient use of non-FDA approved cannabis or cannabis-derived products within healthcare facilities until such time as federal laws or regulations permit its use; and (b) educate medical staffs on cannabis use, effects and cannabis withdrawal syndrome.” I encourage you to follow the science and public health evidence on this issue and keep marijuana in Schedule I.
Over 42,000 public comments were submitted. Public commenters, thank you for your courage!