For several years now, the Iowa Medical Cannabidiol Board has recommended changing the name “Medical Cannabidiol Act” to “Medical Cannabis Act” in its annual reports to the Iowa Legislature. The act requires the board to submit annual reports to the legislature, Iowa Code § 124E.5(5):
On or before January 1 of each year, beginning January 1, 2018, the medical cannabidiol board shall submit a report detailing the activities of the board.
The board has been recommending renaming the act “Medical Cannabis Act” to be consistent with the definition of medical cannabidiol, Iowa Code § 124E.2(10):
“Medical cannabidiol” means any pharmaceutical grade cannabinoid found in the plant Cannabis sativa L. or Cannabis indica or any other preparation thereof that is delivered in a form recommended by the medical cannabidiol board, approved by the board of medicine, and adopted by the department pursuant to rule.
Cannabidiol is just one of many cannabinoids. Calling that definition “medical cannabidiol” is scientifically inaccurate and misleading. For scientific accuracy, see USP Policy Position Cannabis 2024, U.S. Pharmacopeia (USP), January 14, 2024, at page 2 footnote *:
* Cannabis sativa L. (cannabis) is a plant that contains over 100 different naturally occurring compounds called “cannabinoids.”
Cannabis-derived compounds are compounds occurring naturally in the plant, such as cannabidiol (CBD) and delta-9-tetrahydrocannabinol (THC), that are extracted directly from the plant.
For the past several years the board has asked the legislature to correct the name of the act to accurately describe the definition. Here is that recommendation from the last annual report, December 31, 2024, recommendation #1:
1. Amending the name of Chapter 124E to “The Medical Cannabis Act”
The Board recommends renaming Chapter 124E to be the “Iowa Medical Cannabis Act” to accurately reflect that products containing THC are also authorized to be sold and manufactured by the law, indicate scientific reality via inclusion of all cannabinoids, mitigate confusion with program stakeholders, and improve program education.
The term “medical cannabidiol” may have been relevant prior to HF2589 and Iowa using a 3% THC limit on products, but Iowa remains the only state using this nomenclature. As Iowa now allows product formulations similar to those in other medical cannabis programs, it is congruent with the rest of the country to update the name. Additionally, the proliferation of intoxicating products in the consumable hemp program further exacerbates this messaging issue. Following the passage of HF2589 in 2020, maintenance of the term “medical cannabidiol” has progressively created a knowledge and education barrier with law enforcement, healthcare, and other stakeholders who are otherwise unaware that high-THC products are legally available in Iowa. Under the new consolidated Bureau within HHS, the public facing messaging refers to the program as “medical cannabis.”
Why hasn’t anyone introduced a bill to implement this recommendation? What possible interest could there be in deceiving the public about this?
The board also recommends bringing the act into compliance with federal drug law. 21 U.S.C. § 822(d). so Iowans are not required to violate federal drug law as a condition of receiving health care. Here is the text of 21 U.S.C. § 822(d):
(d) Waiver
The Attorney General may, by regulation, waive the requirement for registration of certain manufacturers, distributors, or dispensers if he finds it consistent with the public health and safety.
Here is that recommendation from the last annual report, December 31, 2024, recommendation #8:
8. Seek a Federal Exemption for Iowa’s program
The Board recommends that a task force of legal experts be authorized, similar to the current board of medical experts, to assist the department in navigating the legal issues involved with requesting an exemption for Iowa’s program from necessary Federal agencies. This is related to a recommendation in the Board’s 2019 Annual Report and the passage of HF2589 in June, 2020.
Here is that recommendation from the 2019 annual report, January 1, 2020, recommendation #6:
6. Develop Language to Protect Schools, and Long-Term and Acute Care Facilities
Facilities that receive federal funding are hesitant to allow medical cannabidiol products to be administered and stored at the facilities due to the current scheduling of Cannabis at the federal level. There are Iowa patients within these facilities who are unable to store their medication at the facility, or have their medication administered by facility staff, because of concerns about adverse consequences for the facilities. Developing language to protect these facilities or seeking exemption for Iowa’s program from federal drug laws would benefit patients and facilities.
Why hasn’t anyone introduced a bill to implement this recommendation? What reason could there possibly be for authorizing federal crime and putting the public at risk?
carl-olsen.com
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