This weeks blog entries will be a three-part series. Blog posts for the week of January 8, 2018, are focused on questions posed by Health Canada’s consultation paper on their proposed approach to regulating cannabis. I encourage you to fill out the online questionnaire, email or write your responses before January 20, 2018.

If you haven’t already read Part 1, please click here. Part 2 can be found here.

Part 3 (Questions 9-12 of 12)

Canada’s Premier, Justin Trudeau (Liberal), has committed to legalize, strictly regulate and restrict access to cannabis [emphasis added]. Health Canada is soliciting feedback from interested parties who want to have their voice heard concerning the proposed regulations.

As much information as possible will be posted via the Canadian Gazette later this year.

9. What do you think about the proposed rules for the packaging and labeling of cannabis products? Do you think additional information should be provided on the label?

Doubling down on the previous government’s Health Minister Ambrose’s outcry to crack down on illegal cannabis advertising, mandatory health warning for cannabis products will be similar to tobacco products according to the proposal. What appears clear is that cannabis will be sealed, locked away from view; strain names have already begun sterilization from names such as AK-47 and Green Crack to Canadian lakes and landmarks.

The days of evaluating cannabis prior to purchase could be over, and with concern over promotion of consumption, strain reviews may have restrictions placed. Ad Standards has created a document outlining the proposed standards, in partnership with licensed producers no less. A push to allow for branding to differentiate their products from the black market is an argument by the Coalition for Responsible Cannabis Branding.

How cannabis will be sold in storefronts is lacking.

I would expect, in a government run cannabis storefront, such as CannabisNB’s planned locations, cannabis being sold in pre-packaged plastic containers, likely with a minimum of 5g. I would hazard a guess you won’t be able to make a purchase at a legal cannabis location in New Brunswick for under $20.

Mandatory Health Warning similar to tobacco products. Yes, you heard that right.

Smoking-related illnesses kill 100 Canadians per day. Cannabis is a non-toxic plant that has been cultivated for thousands of years, and to date has no confirmed deaths.

  1. What do you think about the proposed approach to providing cannabis for medical purposes? Do you think there should be any specific additional changes?

Firstly, cannabis that is prescribed by a health care practitioner should not be taxed.

Secondly, it is imperative to discussion is Health Canada’s opinion of cannabis can be summed up in the following quotes:

“The Government of Canada does not endorse the use of marijuana, but the courts have required reasonable access to a legal source of marijuana when authorized by a healthcare practitioner.”

“Cannabis is not an approved therapeutic product and the provision of this information should not be interpreted as an endorsement of the use of cannabis for therapeutic purposes, or of marijuana generally, by Health Canada.”

I wonder how long until they change their tune to match the growing body of research on the therapeutic properties of cannabis. Prescribing doctors knew more about the healing properties of cannabis 100 years ago than their modern day equivalent.

The willful ignorance on the subject of cannabis aside, the suggestion of prescription transfers between licensed producers is a step forward. Current patients can find themselves locked in purchasing from one specific licensed producer. If a strain is out of stock, too bad so sad. Patients proactively ask for their prescriptions to be split between multiple producers to lessen the risk of going without medication.

The adjustment to initial registration date from rather the date your doctor signed the authorization is significant for medical patients who want to grow their own medicine. In the context of producing your own medical cannabis, this equates to a patient being able to grow for a full year (the length of the prescription), instead of waiting months, I’ve heard of wait times of 6 months, before being granted the permission to start growing at home.

The removal of the 30-day cap can assist with those who want to order large amounts when their strain comes in stock, but this inclusion seems like it offers more benefit licensed producers more than it would for the average patient. After all, profits are tied to sales. Reduce the barrier to sales and you can increase your profits.

The inclusion of pharmacists to fill orders for cannabis makes Loblaw’s acquisition of Shoppers Drug Mart in perspective. Licensed producers, specifically Aphira have outlined a pharmacy model for distribution for some time.

11. What do you think about the proposed restrictions on the sale of health products containing cannabis authorized by Health Canada? Do they strike an appropriate balance between facilitating access to safe, effective and high quality health products, and deterring illegal activities and youth access?

The proposed restrictions are facilitating a boom in cannabinoid-based cosmetics which will likely be headed by the likes of Loblaws. Importation of cannabis from countries like Uruguay is in place to cheaper alternative than to wait for Canadian producers to ramp up.

12. What do you think about the overall regulatory proposal? Is there any additional feedback that you would like to share on the proposed approach to the regulation of cannabis?

I do not attempt to hide my personal thoughts; I feel strongly against much of the proposal as it was built on objectives that do not benefit the public but rather large corporations and filling the Liberal’s coffers.

The proposal for regulating paints cannabis plant as if it were a dangerous substance. The medicinal value of cannabis was first recorded in ancient China, some 4,700 years ago. The most dangerous part about cannabis in Canada, besides the licensed producers spraying harmful pesticides on your medicine, is law enforcement’s direction to collect and arrest instead of serve and protect. That’s the real danger.

 

It’s being legalized! Yes, but at what cost? Legalization without decriminalization is not true legalization. More Canadians face prison under the new system. Don’t believe me? Consider this:

 

If you were to buy alcohol for someone under the legal age? That mistake will cost you between $100 to $500 for an individual.

 

Cigarettes to a child? Pay up! Selling cigarettes to someone under the legal age in Ontario starts at $490 and could be as high as $300,000.

 

Passing a joint to someone 17 and under? Up to 14 years in prison. If you think: “that can’t be right”, you’d be wrong. Justice Minister defended this law, reported the Globe and Mail.

 

Overall, the proposed regulations inflate the position of authority Health Canada holds on cannabis medical or otherwise. Their bias against cannabis blatant and indisputable. All the while, large corporations lobby to tailor a new industry for the benefit of a small few, at the expense of the public.

 

Thank you for reading and I hope you will provide your feedback on the proposal or anything I have mentioned in my article.

 

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