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Dear Mr. Smith:

By Hempology | August 11, 2005

Mr. Leon Smith
International Hempology 101 Society
826 Johnson Street
Victoria, British Columbia V8W 1N3

Thank you for your correspondence of February 3, 2005, addressed to the Minister of Health, the Honourable Ujjal Dosanjh, concerning the inclusion of cannabis resin and other cannabis-based products in the Marihuana Medical Access Regulations (MMAR). The same letter was also received by the Office of Cannabis Medical Access at Health Canada. I regret the delay in replying.

In Canada, marihuana under the Controlled Drugs and Substances Act (CDSA). This legislation allows Canada to fulfill its international commitments under three Conventions of the United Nations: the 1961 Single Convention on Narcotic Drugs; the 1971 Convention on Psychotropic Substances; and the 1988 Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances. Under these conventions, Canada is required to criminalize certain activities with respect to particular drugs, including marihuana.

Marihuana is not approved as a therapeutic drug in any country in the world. It cannot be approved in Canada without adequate scientific evidence of benefits and a favourable risk/benefit profile for the therapeutic indication(s) for which it is proposed. At present, while pointing to some potential benefits, current scientific evidence does not establish the safety and efficacy of cannabis to the extent required by the Food and Drug Regulations for marketed drugs in Canada.

That is why our policy on medical marihuana has two components. The first component in the MMAR, which allow people with authorizations to possess and cultivate marihuana for medical purposes, and the second component is research. Conducting research will allow us to better understand whether, and for which medical conditions, marihuana may be effective medicine, and the risks associated with its use in such conditions.

The MMAR were developed following the Canadian regulatory process which affords an opportunity for the public to provide comments regarding the regulations and any proposed changes. The most recent amendments to the MMAR came into force on June 7, 2005, and were published in the Canada Gazette, Part II on June 29, 2005. These amendments to the MMAR and the Regulatory Impact Analysis Statement are available on the Canada Gazette Web site at:

The MMAR currently authorize the possession of dried marihuana only, as the evidence in support of its use for medical purposes only comes from the use of the dried plant material. There is very little, if any, anecdotal evidence regarding the use of cannabis resin for medical purposes. Compared to dried marihuana, cannabis resin may also pose greater risks to the patient due to the difficulty in dosing resulting from the increased concentration of tetrahydrocannabinol (THC) and greater variability in the THC content.

In closing, I understand that these may not be the answers you are looking for. However, the MMAR were designed to regulate the use of marihuana for medical purposes, and we will continue to follow these guidelines, as well as continue our research efforts.

Again, thank you for writing.

Yours truly,

Susan Fletcher

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