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Letter to Health Canada

By Hempology | September 22, 2006

Tony Clements
Minister for HEALTH CANADA
Dear Sir
Thank you for the last letter sent to the International Hempology 101 Society by Beth Pieterson of Health Canada on Feb 24, 2006.  If you are unaware of the correspondence between us, I am including in this package of information copies of our newsletter, Cannabis Digest, in which you will find the earlier letters.
            Also in this package is a copy of the letter that Victoria mayor and council wrote to Health Canada stating their concerns regarding the inadequacies of the MMAR and requesting that the entire program be reviewed.  We remind you of this letter because it was largely due to our continued efforts that the city council condemned Health Canada’s programs, as you can see by our inclusion in the list of official recipients.  This letter was written because in January a representative from Health Canada refused to participate in a public meeting with local elected officials and instead held a small, superficial meeting with a few city staff, police and health authorities.
            While we found some of the information in the last letter useful, two of the three answers were not addressed to our satisfaction.  We are proceeding with amendments to the MMAR that would allow license holders to produce cannabis products without risk of being charged with possession of cannabis resin or THC.  Thank you for your explanation as to how this process can be instigated.
            The second question was, “If cooking with cannabis is illegal, 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??  However, the answer we received ignored the first half of the question.  It appears from your answer that license holders are not specifically told that if they make cannabis food or skin products, they could be prosecuted for producing cannabis derivatives.  In fact, your response indicates that license holders are warned not to produce hashish or hash oil but makes no mention of edible products, which is the focus of these questions.


 We have never seen the information that you send to license holders that states they cannot produce hashish or hash oil.  We would greatly appreciate it if you could send us that information with the response to this letter.
            There is much historical evidence that eating low doses of cannabis has many medical benefits with few negative side effects.  Most of the historical literature regarding the smoking of cannabis as medicine, ironically, confirms the use of hashish because of it’s high concentration of THC.  However, most historical records show people like Queen Victoria using products such as cannabis tincture for different medical problems, not the unprocessed dried plant. 
While we have referred you to, WOMEN AND CANNABIS; MEDICINE, SCIENCE AND SOCIOLOGY, by Ethan Russo, Melanie Dreher and Mary Lynn Mathre, The Hawthorne Press, 2002, your response ignored this book entirely and stated that your department was unable to find any scientific information about hash oil.  For some reason, Health Canada’s response totally ignores our references to eating cannabis cooked in butter and vegetable oil and pretends we are only referring to hash and hash oil.  Does Health Canada consider cooking cannabis leaves in butter to be essentially the same as producing hashish?
Health Canada’s final answer states that they has not done any research about cannabis resin.  This is very disappointing because it was claimed in an earlier letter that research was actually a priority for Health Canada.  In that earlier letter it was claimed that, “Compared to dried marijuana, 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.?  If Health Canada has no research about cannabis resin, then where does this statement come from? 
The process of cooking cannabis into food and skin products should be understood and promoted by Health Canada.  Eating cannabis and applying it to the skin can provide great relief from pain and other symptoms related to serious medical problems.  We are absolutely positive of this because of the living experience of the approximately 1800 members of our club who use cannabis food and skin products to help eat, sleep, walk and think better every single day. 
We will continue to advocate for changes to the MMAR to include cannabis resin and cannabis (THC) until it happens.  Many people’s lives depend upon ingesting using methods other than smoking.  It is ironic to think that we are trying to convince Health Canada that eating and topically applying cannabis can be a safe alternative to smoking.  If drugs can be made using the various cannabinoids of cannabis, how can you deny sick people the right to make simple, natural food and skin products that are often more effective than prescription drugs with fewer negative side effects?
As you can tell from the letter from the City of Victoria, there are many people who believe that the MMAR have fundamental flaws which cause unnecessary suffering.  Your job, and many people’s lives, would be much easier if compassion clubs such as the CBC of C had exemptions from the CDSA to provide the cannabis products and services that sick people are demanding.
Though we do not expect any sudden changes in Health Canada that would quickly see the changes we want come into effect happen soon, we do hope that you will at least attempt to answer our questions with some thought in mind towards the sick and vulnerable people who depend upon this medicine.
Thank you for your time and if you have any questions about our club or products, please do not hesitate from calling me.
Leon ‘Ted’ Smith
President, International Hempology 101 Society

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