Dear Co-chairs Maroney an D’Agostino and esteemed members of the General Law Committee,
I am a Fairfield County resident and have been practicing nursing in Connecticut for nearly two decades. Early last year, I completed additional studies at an accredited university on the endocannabinoid system and medical cannabis care. I am also a medical cannabis patient. I believe it is imperative that we approach conversations about cannabis regulation and education with full awareness of history and use the highest quality, currently available research to guide decisions. Reiteration of false and exaggerated claims are epidemic in discussions of drug use. These positions hinder progress and perpetuate bias, doing nothing to advance the agenda of public safety at the root of this conversation. There are several elements of HB5434 that I support, but several I am compelled to oppose and provide clarity on for those who will be voting on this bill.
Regarding Amendment 2:
I work for an organization called Doctors for Cannabis Regulation. Our founder, Dr. David Nathan, working with the standards organization ASTM, designed the International Intoxicating Cannabis Product Symbol (IICPS). The IICPS was adopted by the state of Montana and went into effect on January 1, 2022. New Jersey and Vermont have also incorporated the IICPS design into their state symbols, making the IICPS the most widely adopted cannabis product symbol in the United States. IICPS incorporates a cannabis leaf, the graphic element most associated with cannabis, into the internationally-compliant standard triangular caution sign (ISO 3864), creating an instantly familiar symbol for all cannabis product packages. Absence of text (e.g., “THC”) inside the triangle complies with existing international caution sign standards, avoids linguistic & jurisdictional ambiguity, and prevents the need for future changes in the symbol as cannabis science and policy evolves. I would be happy to facilitate cooperation from DFCR in adding IICPS to our labeling standards. (https://www.dfcr.org/universal-cannabis-symbol)
Regarding the precautions for the labels proposed in this bill, I have significant reservations. 1) Addiction; US government scientists have long understood that cannabis is one of the least addictive substances. A NIH study from 2015 lists alcohol as MOST and cannabis as LEAST addictive among recreational drugs, including alcohol and tobacco (https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4311234/). Several researchers throughout the years have supported that cannabis is no more addictive than caffeine. 2) I am unable to locate a single human study for which there is significant medical evidence that cannabis causes birth defects and I believe adding this to product labels would not only be unwarranted and unsupported by fact, but only serves to further perpetuate fear. 3) Regarding psychosis, the evidence shows no causal relationship between cannabis use and the onset of mental health conditions. Many opponents misrepresent a 2017 report by the National Academies of Sciences, Engineering, and Medicine, which found an association between cannabis use and schizophrenia, not that cannabis use causes schizophrenia. In fact, the report itself noted, “in certain societies, the incidence of schizophrenia has remained stable over the past 50 years despite the introduction of cannabis into those settings.” Surely if marijuana use caused schizophrenia, that would not be the case. Further, one of the committee members of the study, Ziva Cooper, rebutted the claim that cannabis use causes schizophrenia. Cooper wrote, “Since the report, we now know that genetic risk for schizophrenia predicts cannabis use, shedding some light on the potential direction of the association between cannabis use and schizophrenia.” Similarly, if cannabis causes psychosis, rates of psychosis should rise if cannabis use goes up, but that has not happened. According to a report published by the prestigious British medical journal The Lancet, cannabis use skyrocketed in the 1960s and 1970s, but there was no significant increase in rates of psychosis (W. Hall, “Is Cannabis Use Psychotogenic?,” Lancet 367 (2006): 193–5). In 2009, researchers at the Keele University Medical School in Britain arrived at a similar conclusion: “[i]ncreases in population cannabis use have not been followed by increases in psychotic incidence” (Frisher, et al., “Assessing the Impact of Cannabis Use on Trends in Diagnosed Schizophrenia in the United Kingdom from 1996 to 2005,” Schizophrenia Research 113 (2009): 123–8).
Regarding Amendment 5
I have some reservations regarding the requirement to have a certified budtender in dispensaries. There is no formal national certifying board for budtenders and the programs that do exist are created by industry interests, usually with an emphasis on selling cannabis products. If, by including this requirement, you are hoping to protect consumer safety, then you need messaging and resources from informed health professionals like myself. I believe the state would be better off using the resources that already exist here to create a training program for our dispensary employees that helps them understand their role. People with little cannabis experience, especially older adults, go to adult use dispensaries with questions about how to use this product for a specific problem (like sleep or pain) or how it will affect their medical problems. A budtender, like a cashier at Target, is not qualified to explain the potential risks or benefits of a supplement or over the counter medicine and they should not be doing so, regardless of any industry training they might have.
Regarding Amendments 7 and 8
Parts 7 and 8 of this bill simply propose to continue to criminalize people for using cannabis. We have voted and passed a law in this state that made this substance legal and we should not be implementing laws that further criminalize people or risk them losing their jobs, children, etc. Part 8 of this bill, regarding parents “visibly under the influence of cannabis” when picking up children from school is dangerous and disturbing. Beyond my above point about legalization, consider that despite using cannabis at roughly the same rates as whites, Blacks in the U.S. are nearly four times more likely to be arrested for cannabis possession and this law could be used to further perpetuate this disparity and abuse.
Regarding Amendment 9
Though some research has found a modest increase in traffic fatalities in Colorado and Washington post-legalization, other studies have reached different conclusions, and there are good reasons to doubt claims that legalization causes an increase in fatal crashes. A paper published by the National Bureau of Economic Research analyzed the rates of drivers found with THC (cannabis’s primary psychoactive ingredient) in their systems after fatal car crashes from 2013 to 2016. The researchers then compared the patterns of THC-positive drivers in Colorado and Washington during that time period to those in other states. In a summary of their results, the authors wrote, “We find the synthetic control groups saw similar changes in marijuana-related, alcohol-related and overall traffic fatality rates despite not legalizing recreational marijuana.”
Furthermore, according to data from the Fatality Analysis Reporting System, four of the eight states that legalized cannabis from 2012 through 2016 saw decreased rates of fatal car crashes following passage of legalization laws. These reduced crash rates were greater than the reduction seen on the national level over the same time period. Data from the Colorado Department of Transportation do not support the assertion that cannabis-impaired driving is becoming a more significant problem in the state. In 2016 Colorado initiated uniform reporting procedures for cannabis impaired driving cases. They have shown a relatively flat rate of vehicular deaths where the driver had >5ng THC in their system. (https://www.codot.gov/safety/impaired-driving/druggeddriving/campaign-news/cannabisdrivingdata)
It is clear that cannabis and driving can be dangerous. So are driving under the influence of alcohol and many prescription drugs. We do not have to reinvent the wheel for intoxicated driving nor do we need to re-institute stop and search based on the smell of cannabis. The police are already trained to identify impaired or distracted drivers and can continue to do so. CT has a program in place to train more (there are already at least 50) drug recognition officers. There is absolutely no reason to stop adult use sales. If we had seen 1000 traffic fatalities since 1/10, maybe, but as you have seen, the mass hysteria of suddenly being overwhelmed by high drivers did not come to fruition. I do believe that student drivers should learn that driving under the influence of any substance is dangerous. By creating a specific program regarding cannabis and driving, I fear we would present the message to new drivers that cannabis is the most dangerous substance, when all the data shows that driving under the influence of alcohol is far more dangerous. Government funded research states, again, that “epidemiological studies have been inconclusive regarding whether cannabis use causes an increased risk of accidents; in contrast, unanimity exists that alcohol use increases crash risk.” (https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2722956/)
Regarding Amendment 10
Why should we prohibit edibles? I have noticed several trends regarding the rampant media coverage of kids accidentally eating edibles. First, the vast majority of the edibles that children confuse with real candy brands come from the illicit market. These are the unregulated and poorly made products that a legal, regulated system will avoid. No licensed retailer in CT is selling candies in “Sour Patch Kids” or “Nerdz” wrappers. If we do not allow the licenced retailers to sell edibles, then the people who are all ready using them will continue to obtain them from the illicit market and the problem will no stop. Proper education to those with children in the home on safe storage, education about what to do in the event a child eats an edible, and, primarily, breaking down stigma and normalizing talking to kids about cannabis will do more to prevent misuse than the prohibition that we have seen does not work. Most parents have talked to their kids about alcohol and store alcohol in their homes, and their kids don’t get drunk. Most parents have talked to their kids about prescription and OTC pills and store alcohol in their homes, and their kids don’t OD on pills. Many parents keep cannabis and edibles in their homes and have had the same conversations with their children about what these things are and that they are not for children. It’s a direct result of criminalization and stigma that parents feel hesitant to let their children know they use cannabis or have it in the home. Public service education is how we change this, not further prohibition.
Regarding Amendment 12
Section 12 tasks the DCP with the job of reviewing and approving all product types and doses. DCP is not a medical authority and doses are likely outside their area of expertise. This section needs to be more specific in terms of the criteria for approval of products. Adding THC or cannabis to schedule 2 is not possible at this point. Schedule 2 drugs require a prescription and therefore could not be sold at an adult use dispensary.
Regarding Amendment 13
I am not sure where this information will be used, but not a single human study has been conducted on second hand cannabis smoke and therefore there is no medical basis for the claim that second hand cannabis smoke is toxic (https://nida.nih.gov/publications/research-reports/marijuana/what-are-effects-secondhand-exposure-to-marijuana-smoke). I would urge that the language be changed to state that second hand smoke “may be” toxic. We need to be careful with the language we use. We should substantiate fact and stop perpetuating lies and misinformation.
Please consider me a resource going forward and I am happy to coordinate any regulatory assistance that the Doctors for Cannabis Regulation may be able to offer. As a health professional and a medical cannabis patient, I feel I have a unique role and ability to educate my community, including lawmakers, about the facts and evidence related to cannabis and entheogenic medicines. You have experts in this state on these subjects, use us. Thank you all for your service to our community.