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Dear Mr. Smith:

By Hempology | March 27, 2006

International Hempology 101 Society
826 Johnson Street
Victoria BC V8W 1N3
Mr. Leon Smith

This is in response to your letter dated January 4, 2006, wherein you specifically asked Health Canada to address three questions.

The first question asked in your correspondence was: “Could you explain to us how amendments are made to the MMAR?”
The development of any regulatory proposal, including amendments to existing regulations (such as Marihuana Medical Access Regulations, (MMAR)), follows the Government of Canada Regulatory Policy. This Policy describes the principles that govern the development of regulations, including consultation with Canadians in developing or modifying regulations. A ten-step process is described in the Regulatory Process: Guide to Developing a Regulatory Proposal.

In general, proposals for new regulations or regulatory amendments are published in Canada Gazette Part I, followed by an opportunity for stakeholders to provide comments. Consultation with stakeholders often takes place even before this step. Input on the regulatory proposal is taken into consideration before the regulations are finalized and published in Canada Gazette Part II. In the case of the Medical Marihuana Access Regulations, information on regulatory change is also made available on Health Canada’s website.

For more information on this process (Regulatory Policy and Guide to the Regulatory Process) and on the proposed Government of Canada Regulatory Policy, you may want to consult the following web sites:

Regulatory Process:

Government of Canada Regulatory Policy:

The Canada Gazette website can be found at:

Information on the Medical Use of Marihuana and Marihuana Medical Access Regulations can be found at Health Canada’s website at:

The second question relates to cannabis resin. “Should Health Canada not tell license holders they could be arrested for producing cannabis resin a.k.a. hashish or cannabis (THC) if they try?”

Cannabis, its preparations, derivatives and similar synthetic preparations, including cannabis resin are listed in Schedule II of the Controlled drugs and Substances Act (CDSA). All activities with respect to cannabis are prohibited except as authorized under the regulations.

The MMAR refer specifically to dried marihuana, which is defined in the Regulations as harvested marihuana that has been subjected to any drying process. The Regulations specifically refer to dried marihuana for Authorizations to Possess or Licences to Produce. As stated in the Regulations, marihuana means the substance referred to as �Cannabis (Marihuana) in sub-item
1 (2) of Schedule II to the Controlled Drugs and Substances Act (CDSA) and therefore does not include Cannabis resin. In addition, the information material provided when an Authorization to Possess or a Licence to Produce is granted, clearly states that the authorization or licence does not apply to any derivatives of marihuana such as hashish, hash oil, etc.

Your final question pertains to research. “Do you have any research about cannabis resin?”

Health Canada has not conducted research on cannabis resin. An extensive review of the existing scientific literature ahs failed to uncover any clinical trials assessing the safety, tolerability or efficacy of hash oil for therapeutic purposes.

I trust you will find this information useful.

Beth Pieterson
Director General
Drug Strategy and Controlled
Substances Programme

Topics: Articles, CD-9th, Spring 2006 | Comments Off

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