Non-smoked Forms of Ingestion for Medical Cannabis Policy

Issue:

Many patients who use cannabis for medical purposes rely on preparations and derivatives made from dried marihuana, which are not permitted for sale under the MMPR. These products include (but are not limited to): separated cannabis trichomes; solvent-extracted cannabis concentrates; cannabis-infused vegetable oils; cannabis tinctures; cannabis capsules; baked goods and food products; and others.

Prescription cannabinoid preparations are limited to Dronabinol and Nabilone, THC-only synthetic preparations and Nabiximols, a THC-CBD extract in an oro-mucosal spray.

Background:

For many patients, inhalation of cannabis via smoking or vaporization is contraindicated, and other methods of ingestion are recommended. At the 2014 Canadian Medical Association General Council, a motion was adopted opposing the “smoking of any plant material”, including medical marihuana.

Preparations and derivatives made from dried marihuana offer patients a wider variety of dosing options and cannabinoid profiles when compared to currently available oral prescription cannabinoids. This issue has garnered a substantial amount of attention through the stories of pediatric patients living with intractable forms of epilepsy.

Including oral cannabis preparations and derivatives in the MMPR, would be of benefit for both consumers and industry as it would provide consumers with more cannabis products of known purity and potency, while allowing Licensed Producers to diversify their product lines, more efficiently recover marijuana production costs, and pass the savings on to patients.

Health Canada’s Information for Health Care Practitioners document describes:

  1. the pharmacokinetics of SIX methods of absorption, (smoked, vaporized, oral, oro-mucosal, rectal, topical)
  2. dosing ranges for FOUR methods of ingestion (smoking, oral, oro-mucosal, vapourization)
  3. the metabolic processes for inhaled and orally ingested cannabinoids

Recommendations:

We urge Health Canada to engage with the CMCIA, LPs and other stakeholders to develop a policy on the quality manufacture and sale of non-smoked forms of ingestion for medical cannabis including but not limited to:

  • Separated cannabis trichomes
  • Purified marijuana extracts made from medical-grade solvent
  • Marijuana-infused food products
  • Pre-dosed formats such as capsules and tinctures