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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.

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.

IBH LEADERSHIP JOINS ADDICTION POLICY FORUM’S SCIENTIFIC ADVISORY BOARD

IBH President Robert L. DuPont, MD and IBH Vice President Caroline DuPont, MD are honored to serve on the Addiction Policy Forum’s Scientific Advisory Board to provide strategic guidance and direction for research and scientific programs. APF is a leading national non-profit organization dedicated to eliminating addiction as a major health problem. Read more.

ALEX BERENSON OP-EDS: THE ADVERSE HEALTH EFFECTS OF MARIJUANA ARE IGNORED AND DENIED BY AN INDUSTRY THAT PROMOTES ITS USE

In two op-eds, one in The Wall Street Journal and the other in The New York Times, author Alex Berenson highlights the growing support for marijuana legalization has been fueled by misinformation about a drug that is not harmless as its advocates suggest. He notes that “as marijuana use has become more socially acceptable, psychiatrists and epidemiologists have reached a consensus that it presents more serious risks than most people realize.” There are clear connections between marijuana use, psychosis and violence. Although“legalization hasn’t led to a big increase in Americans trying the drug, it has meant that those people who already use it do so far more frequently. In 2005, about three million Americans used cannabis every day. Today, the figure is eight million. Put another way, about one cannabis user in five uses it daily. By contrast, only one in every 15 drinkers, about 12 million Americans, consumes alcohol every day.” The dramatic increase in heavy use is just one of many causes for serious public health concern as the legalization and normalization of marijuana continues. Read more in the WSJ and the NYT.

VAPING BY AMERICAN TEENS SURGES SETTING NEW RECORD

The latest data from the nationally representative Monitoring the Future study shows the single-largest year-to-year increase in substance use in the US for 10th and 12th graders due to vaping. From 2017 to 2018 past-month vaping of nicotine nearly doubled among high school seniors from 11% to 21%, and did double among sophomores from 8% to 16%. Not surprisingly, the increases seen in vaping nicotine were mirrored with significant increases in vaping marijuana among 8th, 10th and 12th graders. Lead study researcher Richard Miech PhD noted that “Factors that make vaping so attractive to youth include its novelty and the easy conceal-ability of the latest vaping devices, which better allows youth to vape without adults knowing about it. If we want to prevent youth from using drugs, including nicotine, vaping will warrant special attention in terms of policy, education campaigns, and prevention programs in the coming years.” Read more.

OP-ED: THE MEDICAL MARIJUANA DELUSION

An op-ed by Paul J. Larkin in The Regulatory Review explains how “regulation of marijuana has been based on a false distinction for almost a century.” Although components of the marijuana plant may be synthesized into real medications in the future — like the FDA-approved drug Marinol, synthetic THC — medical marijuana will never meet scientific criteria of modern medicine. Larkin concludes, “The real question is whether lawmakers should revise federal law to allow marijuana to be used for recreational purposes, just as alcohol and tobacco can be so used today. If Americans are to honestly debate marijuana use, the debate must be over its utility as a recreational drug, not as medicine, and who should regulate its potential uses—the FDA Commissioner or the U.S. Attorney General. The United States has followed the wrong approach to marijuana regulation for 80 years. It is time to get it right.” Read more.

DR. ROBERT DUPONT SPEAKS TO THE JUSTICE SPEAKERS’ INSTITUTE ABOUT PREVENTION AND CHEMICAL SLAVERY

As a prison psychiatrist in the late 1960s, Dr. Robert DuPont came to understand that the rising crime at the time was directly linked to the heroin epidemic that raged in cities across America. In this conversation with the Justice Speakers Institute, Dr. DuPont discusses the journey from his realization to the present day national movement to end addiction. He discusses the science behind addiction and the important next steps humanity needs to take to finally end the drug epidemic.

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