DR. ROBERT L. DUPONT'S WRITTEN TESTIMONY TO THE FDA REGARDING THE HEALTH IMPACTS OF CBD

***Click here to view or print a PDF copy of this commentary.***

We also encourage you to file your own testimony with the FDA about this important issue. You can do so via docket FDA-2019-N-1482 before July 2, 2019

Docket No. FDA-2019-N-1482, Scientific Data and Information about Products Containing Cannabis or Cannabis-Derived Compounds; Public Hearing; Request for Comments

As a Harvard Medical School graduate, a board-certified and practicing psychiatrist, a veteran of NIH training and a clinical professor at Georgetown Medical School since 1980, I’ve witnessed many dramatic changes over my career. Yet the hoopla and hysteria surrounding the medical use of marijuana and cannabinoid-containing products is unlike anything I have ever seen. It is frightening to me and should be to all who are trusted to protect the public’s health and safety.

With that perspective as context, I commend the FDA for tackling the enormous challenge of creating a regulatory pathway for cannabis-derived products. I believe that Congress had products like these in mind when it passed the Food, Drug and Cosmetic Act in 1906. Yet even with an eye toward protecting the public’s health and safety as the motivation for the act, a century ago people couldn’t have imagined the amount of deceptive advertising we’re seeing today for cannabidiol (CBD). To hear the marketers tell it, CBD cures everything.

We are watching the explosive creation of a multi-billion-dollar industry poised to make tremendous profits off desperate patients and their loved ones. Anecdotes and testimonials, not science, drive the marketing of unregulated, non-prescription forms of CBD. It is reminiscent of 19th century patent medicines, with its peddlers commonly known as “snake oil” salesmen.

A POWERFUL NEW “STATEMENT OF CONCERN” ISSUED BY MASSACHUSETTS DOCTORS, CLINICIANS, AND SCIENTISTS

A powerful new “Statement of Concern” was published recently by a cohort of Massachusetts doctors, clinicians, and scientists. They strongly reject their state’s treatment of marijuana as an “ordinary commodity” that requires little or no consideration of its impact on the health of the citizens of Massachusetts, and call for it instead to be “Regulate[d] and govern[ed]… using a Public Health Framework…[that] prioritizes population-level health over commercial market interests…”

They observe that while not all marijuana users will experience negative effects, “the risk is substantial enough to require policies which discourage use.”

Among the key points of the Statement are:

  • that just like the previous “regulatory failure[s]” of the state regarding tobacco, opiods, and vaping, such regulatory failure is likely in the case of marijuana as well if the state does not prioritize public health

  • Marijuana is a potentially addictive drug, and its potency is ever-increasing, thereby increasing the risks of harm

  • “the tobacco industry has spent billions of dollars” to enter the vaping and marijuana markets, and they are likely to combine the two interests to produce high-THC vapes, which are of particular and growing risk to youth.

  • “Marijuana use by adolescents can impair brain development…reduce academic success, impact long-term career growth, and even lower user IQ. (These two points are a particular focus of IBH through its One Choice teen drug use prevention initiative.)

  • Massachusetts doctors and clinicians are seeing these effects first-hand in their own patients.

IBH encourages everyone who cares about public health to read this Statement of Concern, and to actively seek to implement its conclusions in their own states as well as at the federal level.

Click here to read the Statement of Concern via marijauna-policy.org

Click here to visit the Marijuana Policy Initiative’s web page about the Statement.

DRUG CRISES OVER THE HORIZON

Two important aspects of the drug epidemic are at the forefront of national attention. The first is the legalization of the production, sale, and use of marijuana. The second is the explosion of drug overdose deaths that has resulted in overdose becoming the leading cause of death for Americans age 50 and younger[1] and has led to a remarkable decline in U.S. life expectancy for the third consecutive year.[2] These are the poles of drug policy: efforts to relax and even eliminate prohibition of marijuana on the one hand and increasing restrictions on opioids to discourage use and to reduce overdose deaths on the other. As we consider present and future drug crises, we can learn useful lessons both from expanding the focus beyond marijuana and opioids and from exploring the path that has led the nation to the current drug epidemic.

PERSPECTIVES ON LONG-TERM RECOVERY

The goal of addiction treatment is recovery. Recovery is not just abstaining for a lifetime from any use of alcohol, marijuana and other drugs but far more. This reality is visible every day all over the country and the world. The evidence that this goal is achievable for all people with substance use disorders is apparent in the lives of of the millions of people who are spending their lifetimes joyfully in recovery. They are quietly and gently sharing their recovery with everyone to whom they relate. There are no hopeless cases of addicted people; just individuals yet to enter long-term recovery.”
— Robert L. DuPont, President, Institute for Behavior and Health

In many health settings "recovery" is used routinely to mean "getting better”, from something as simple as “recovering from a sore knee” to something as serious as “recovering from metastatic cancer.” And while this general, vague sense of recovery is sometimes used in the context of addiction to alcohol and other drugs, here at IBH we use the word to mean something far better and more profound.

When people “recover” from a sore knee, they simply go back to their life before knee pain. With addiction, however, people who successfully “recover” do not go back to being the people they were before their addiction. Instead, they become far better people as a result of their ongoing "recovery" work.

IBH did not invent this specific and widely used definition of “recovery from addiction”, but rather we adopted it from the 25 million strong American recovery community, from the people who through their own sustained hard work have created this special definition of a common word.

Our colleague Bill White has recently begun to regularly blog for the Faces and Voices of Recovery website, and he has posted a remarkable selection of thoughts on the many people that he and Galen Tinder have met over the years who have achieved this true recovery from addiction. Please have a look - it is an inspiring and wide-ranging view of what the recovery community - and IBH - mean when we use the word “recovery”.

Reflections on Long-Term Recovery by Galen Tinder & Bill White

Addiction recovery is far more than the removal of drugs from an otherwise unchanged life...The authors have carried on a decades-long interest in what has been christened full recovery or amplified recovery—a state of enhanced quality of life and personal character in long-term recovery. We each know individuals we believe have achieved such status and have asked ourselves what unique characteristics distinguish such persons. Here are some of our initial reflections on this question, offered here as an expression of gratitude to such people who have enriched our own lives.
— Galen Tinder and Bill White

Click here to view their full thoughts.

REGISTRATION FOR GLOBAL DRUG POLICY SUMMIT IS NOW OPEN

Join leaders in drug policy, treatment, prevention and recovery from around the world for Think Globally, Act Locally: A Global Drug Policy Summit on June 26, 2019 in Phoenix, Arizona. The Institute for Behavior and Health is pleased to organize this exciting event with the World Federation Against Drugs (WFAD), Smart Approaches to Marijuana (SAM) and Drug Free America Foundation (DFAF). Attendees can choose from two engaging policy tracks including “International Drug Policy Perspectives and Innovations” and “Local and National Impacts of Changing Marijuana Policy.” Learn more and register today!

9 THINGS WE WISH WE’D KNOWN - A LETTER FROM FAMILIES WHO HAVE LOST A LOVED ONE TO ADDICTION

Addiction Policy Forum, a nationwide non-profit organization dedicated to eliminating addiction as a major health problem, released a letter from families as part of the #192aDay awareness campaign to honor those lost to drug overdose and other complications of substance use. In their letter, families explain, “This letter to you is about the things we wish we had known — the things we’ve learned since we suffered our losses and wish we had done differently.” From learning the signs of a problem to paying attention to early substance use, to finding quality treatment and finding support, these hard-learned lessons can help other families across the country facing addiction. Read more.

LINDESMITH AND BEJEROT - COULD THEY MEET TODAY?

The antagonists in the drug policy field, Alfred Lindesmith and Nils Bejerot, made completely different conclusions in the past. Could they have agreed today? IBH President Robert L. DuPont, MD presents an analysis in DrugNews. After reviewing this history, he notes, “Bejerot saw clearly the risks of compromising with drug use and the value of labeling this use as unhealthy and unacceptable. Sweden provides a model for the world in drug policy today.” Read more.

ROBERT DUPONT, MD FEATURED ON PODCAST FROM DRUG PREVENTION SUMMIT

IBH President Robert L. DuPont, MD served as the plenary speaker at the 7th Annual Southeastern US Regional Drug Prevention Summit. Following his presentation, he was interviewed by The Addiction Podcast - Point of No Return, reviewing his work in the field of addiction treatment and national drug policy and advocating for renewed focus on youth prevention and defining the goal of substance use disorder treatment as long-term recovery.

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