Peter Reynolds

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Bad Behaviour On Both Sides Of The Cannabis Debate.

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Is Mr Angry For Or Against?

Cannabis evangelists, with their conspiracy theories and religious ‘belief’ that cannabis is totally harmless and cures everything, are every bit as delusional as those who subscribe to ‘reefer madness’.

We see this every day on the CLEAR Facebook page.  Anything we share that is even slightly negative about cannabis or that suggests some people might be vulnerable to some harm from using it, produces a hostile, often hysterical reaction.

100% Fake News

Actually, the evangelists play straight into the hands of prohibitionists.  They make fools of themselves by behaving as if we have committed the most heinous blasphemy by daring to criticise their favourite plant.  Particularly amongst our American followers, many cannot distinguish between sharing something and endorsing it.  We share many news items we disagree with but when it comes to science we neither agree nor disagree, it’s all part of the body of evidence that needs to be considered and balanced.

Of course, the reality of social media is that those who shout loudest or comment most frequently are not necessarily representative of the whole audience.  We put a lot of effort into moderating our page to make it as informative as possible.  We have a very strict policy on bad language.  We won’t tolerate commenters abusing each other or launching vicious personal attacks (even if they are against Donald Trump or Theresa May).  All single word comments are deleted.  No one wants to read an endless string of “bullshit”, “BS” or worse.  Far too often we have to ban some commenters immediately.  We simply don’t want people who can express themselves only through a string of obscenities getting in the way of our newsfeed.

A few days ago we shared the study presented at the American College of Cardiology’s 66th Annual Scientific Session, held in Washington, D.C.  It suggests that cannabis use can raise the risk of stroke and cardiac failure.  The furore and firestorm of abuse that erupted is quite ridiculous and only serves to make the cannabis campaign look completely ridiculous.  There are clearly limitations in the study.  Firstly, it doesn’t show causation, merely statistical correlation.  Secondly, all the subjects had been discharged from hospital so clearly had suffered some serious health problem.

It is a ridiculous way to behave for anyone who wants to advance the cause of cannabis law reform.  It’s also utterly stupid constantly to accuse scientists, researchers or indeed CLEAR of being corrupt, dishonest, ‘in the pocket of Big Pharma’ or often far, far worse.

It is true that the history of cannabis prohibition is all about lies, deceit, misinformation and propaganda.  There are still some people, even in elevated positions such as UK prime minister Theresa May, who wish to continue with this form of repression but wiser counsel is prevailing in most parts of the world.

More and more scientists, researchers and doctors are studying the effects of cannabis and rarely does a day pass without a cannabis report being published somewhere in the world. What were almost accepted prejudices such as the ‘gateway theory’ and that ‘cannabis causes psychosis’ are being debunked more and more often.

Of course, scientists, researchers and doctors, just like everyone else, have been subject to all the propaganda for the past 100 years, so there is still much prejudice and confusion to dispel but we should respect and value the work of such people even if we don’t like all their conclusions.

On any subject, truth lies in assessing and balancing all the evidence that is available.  CLEAR will continue to share all significant evidence published about cannabis whether it is positive or negative.  Similarly, we will continue to share stories from the tabloid media that seek to demonise or scaremonger about cannabis.  It is important that people see the propaganda that is being published and the way that public opinion is formed.

 

Written by Peter Reynolds

March 12, 2017 at 3:48 pm

‘This House Would Say No To Drugs’, The Oxford Union, 16th February 2017.

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Peter Reynolds, Stephen DeAngelo

On Thursday, 16th February 2017, the Oxford Union held a debate on the motion ‘This House Would Say No To Drugs’.

thwsntd-graphicI was honoured to be invited to speak against the motion in the august company of Paul Hayes and Stephen DeAngelo. Speaking for the motion were Andrew Ng, Assistant Commissioner Patricia Gallan and Shaun Attwood.

We successfully defeated the motion by approximately 120 votes to 90.  A video of the debate will be released shortly.  I reproduce my speech below.

“Reefer makes darkies think they’re as good as white men.”

These are the words of Harry Anslinger, who in 1930 was appointed the first ever commissioner of the US Federal Bureau of Narcotics. 

And this is the exactly same standard of argument and evidence that we have in favour of drug prohibition today.

Anslinger went on to start the war on drugs 40 years before Richard Nixon invented the term.  His anti-cannabis crusade was based on racism, the suggestion that it caused madness, violence and depravity – yes, the same scare stories, myths and deceit that we still see published every day in the pages of the Daily Mail and the Daily Telegraph.  Indeed, exactly the same nonsense which every home secretary continues to trot out and on which our present prime minister bases UK drugs policy.

Don’t be in any doubt about it, the Home Office, under successive governments, has been engaged in the systematic deception of the British public.  It misleads, misinforms and repeatedly publishes bare faced lies about drugs and drugs policy and subverts every effort towards reform advocated by more enlightened politicians. 

In 2013, according to Norman Baker and Nick Clegg, Theresa May tried to falsify the international comparators report which showed that across the world harsh penalties make no difference to the level of drug use.  The facts simply don’t fit with her ideology.

And this idiocy pervades our society.  It is reflected in this motion which I oppose.  The premise of ‘This House Would Say No to Drugs’ is false from the very start.  It’s preposterous! We all say yes to drugs, every day, inevitably, in cocktails of medicines and recreational stimulants, in food, drink, in endogenous highs released through exercise and emotions, repeatedly, regularly, all of us, without exception, do drugs.

That our governments have seen fit to draw arbitrary lines as to which drugs are acceptable and which are not, which drugs that we can celebrate and which we will be locked up for, has nothing to do with evidence, science and, least of all, absolutely nothing to do with how harmful or dangerous they are. They are based on prejudice and thinking in 2017 that has advanced no further than Harry Anslinger in 1930. 

Sometimes these prejudices have strange echoes in the past. Coffee was banned in Mecca in 1511, as it was believed to stimulate radical thinking – the governor thought it might unite his opposition. What does that remind you of?

Often these lines are not arbitrary, they are based on vested interests. In 1777, Frederick the Great of Prussia also tried to ban coffee. He argued it interfered with the country’s beer consumption.  Before the first International Opium Convention in 1925 Egyptian cotton farmers successfully lobbied for cannabis to be banned as they feared the superior fibre crop of hemp.  Back to Harry Anslinger and he was in league with the timber barons who greatly feared the far better option of using hemp to make paper and the fledging oil industry which had just invented nylon, a synthetic alternative to the job that hemp fibre had done for thousands of years.  When Henry Ford invented the Model T he designed it to run on ethanol produced from hemp. He planted hemp on his own land for the purpose.  It’s no conspiracy theory to argue that the entire oil industry in predicated on the prohibition of cannabis, it’s just good, solid evidence.

Today, in the UK, prohibition of much safer substances like cannabis and MDMA is enforced to preserve the monopoly of legal recreational drugs that belongs to the alcohol industry – a drug that is at least a dangerous as heroin and causes far more misery and death in our society.  It’s no surprise when the UK alcohol industry spends £800 million every year on advertising that the media which enjoys that income supports the alcohol monopoly.

As if we didn’t have the clearest possible lesson from the prohibition of alcohol which gave birth to organised crime and demonstrated beyond any doubt that prohibition never works, it just makes the problem worse.  

The UK is more backwards, more disgraced, more shamed by a drugs policy that causes far more harm than it prevents, than almost any other first world country.

Prohibition is a fundamentally immoral policy.  If you remember one thing that I say today, please make it this. It sets law enforcement against the communities it is supposed to protect.  Being a police office is a noble and honourable calling.  Every society needs policing but drugs policy has perverted this profession.  The demand for what are deemed illicit drugs comes from society but instead of protecting us from danger, police action increases the dangers we are subject to.   The harder the police clamp down, the more the price of drugs rises, the more unscrupulous and violent the unregulated criminal trade becomes and the more contaminated, more concentrated and more dangerous are the drugs themselves.

In Amsterdam, there is no problem with Spice, the synthetic cannabinoid that is ravaging our streets and British prisons at present.  In sane, civilised society like California, Colorado or Washington, where adults can access safe, properly regulated cannabis, there is no Spice problem like we have in the UK. This disgusting, horrible product is the direct responsibility of the politicians who continue to pursue our ignorant anti-cannabis policy.  It is just one example of the great, immoral evil that prohibition causes.  And I ask you, if this crazy policy of prohibition cannot be enforced in prisons, then how do we expect to enforce it in wider society?

It is prohibition and drugs policy based on prejudice that destroys police and community relations.  It is current policy that means 70% of all acquisitive crime is caused by drug addiction – for which we send sick and poorly people to jail where they find easy access to more and nastier drugs.  This is the real madness that drugs cause.  It is the madness of deranged government ministers and their refusal to consider evidence or to resist pressure from their masters in Fleet Street.

What we need to do is say yes to a drugs policy that is designed to reduce harm and protect our communities.  Alcohol is promoted and so easily available as to be ridiculous, in every other shop on the high street, yet we control the access of children to alcohol and tobacco quite effectively.  But we abandon them to the street weed dealer who sells them muck grown by other children who have been trafficked from overseas and locked in hidden farms which are dangerous fire risks.  This is the shameful reality that our policies have produced.

Doctors freely prescribe anti-depressants, tranquilisers, highly toxic opioids such as tramadol, weird drugs for pain and epilepsy like gabapentin, which we don’t really understand at all.  Yet it is a criminal offence for a doctor to prescribe cannabis, a remedy that mankind has used safely and effectively for at least 10,000 years.

We mislead and misinform.  We encourage young people to go out and drink, yet we make ecstasy, MDMA, a drug far safer than even paracetamol, a class A substance , and we threaten people with years in jail just for handing a single dose to a friend.  It’s estimated that between two and ten million doses of MDMA are taken every weekend in the UK and we get about 50 deaths a year.  200 people die every year from paracetamol.  How much safer would MDMA be if the product was regulated with known strength and purity? It would probably be virtually harmless.

Now everyone is a victim of this drug war propaganda and the terrible effects of prohibition. Politicians, police officers, social workers, mothers and fathers have all been drenched in this propaganda from birth.  Many sincerely believe the rubbish they have been fed and they do all they can to pass on misguided ideas to the next generation.

We need to grow up, get a grip and drag Britain out of the dark ages. Drugs can cause harm but British drugs policy is a scourge on our society.  It damages the lives of millions and costs us billions.  Please oppose the motion, saying no to drugs is a nonsense.  Let’s say yes to a rational drugs policy.

More Misguided Expenditure From The Monkeys At The BBC.

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baby-chimp

The BBC can mount a year-long investigation into the trade in baby chimpanzees and drown us all in heartbreaking, sentimental images for days on end.

But when it comes to the hundreds of thousands of people who live in pain, suffering and disability in the UK, in constant fear of a knock at the door because they use medicinal cannabis, the BBC are just stooges and slaves to government misinformation.

The only time the BBC covers the medicinal cannabis issue is when it’s forced to by proceedings in Parliament or when its promoting the work of cannabis oil scammers and rip off artists as it has done on BBC3 recently.

One properly funded documentary, interviewing patients, scientists, doctors and people involved in the genuine campaign could force our government to change its wicked and cruel policy.  That wouldn’t suit the BBC’s paymasters though would it?   They’re the same people as enforce the evil policy in the first place.

Written by Peter Reynolds

February 2, 2017 at 5:05 pm

The UK Government’s Very Last Excuse For Denying Access To Medicinal Cannabis.

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hop-cannabis-leaf
Essentially, UK government policy on cannabis hasn’t altered since 1971.  Despite the vast amount of new evidence published since then and revolutionary change, particularly on medicinal use, all across the world, successive governments have stubbornly and obstinately refused to consider any sort of reform.

It doesn’t matter which party has been in power, Conservative, Labour or the coalition, it’s a subject that ministers and MPs simply refuse to engage with.  It’s easier that way for them and be in no doubt: laziness, fear of a media backlash and deeply ingrained prejudice are the key factors in this impasse.

Grubby, Corrupt Deal Between Brown And Dacre

Grubby, Corrupt Deal Between Brown And Dacre

We had the downgrade to class C in 2003 and then back up to B in 2009 but this was a turgid and useless effort.  No notice was taken of any evidence arising from this experiment.  It was enacted to enable police to concentrate more on class A drugs and reversed based on Gordon Brown’s ‘Presbyterian conscience’ and a grubby, corrupt deal with Paul Dacre to win the Daily Mail’s political support.  In fact, use went down while cannabis was class C and back up again when it was upgraded but governments have no interest in facts or evidence on this subject, only in political expediency and spinning advantage with the media.

The clamour for medicinal access has increased enormously, just as the evidence for its safety and efficacy has become overwhelming. The UK is now virtually isolated amongst first world countries with a cruel, inhumane and anti-evidence policy which makes us a laughing stock with all who are properly informed. It’s not a laughing matter for the victims though.  For those persecuted by this nasty policy it is tears, pain, suffering, disability – all of which could be alleviated to at least some extent just by a stroke of the Home Secretary’s pen.  It is sickening that all those who have held that office over the last 45 years escape without any shame or opprobrium on their character.

comp-home-secretaries

Home Secretaries Have A Lot To Answer For

CLEAR receives hundreds of letters and emails every year from people who have written to their MP about medicinal cannabis and it is astonishing that unlike almost every other policy, exactly the same words are used by all MPs. They slavishly repeat the Home Office line which is ruthlessly enforced across party lines.

There have been some subtle changes.  The marketing authorisation issued for Sativex in 2010 has led to a minor change in the tired and inaccurate line ‘there is no medicinal value in cannabis’.  It’s now become ‘there is no medicinal value in raw cannabis’.  This is scientifically and factually incorrect.  Pharmacologically, Sativex  and the ‘raw’ plants from which it is made are identical.  It is whole plant cannabis oil and its authorisation by the MHRA as an extract of THC and CBD is fundamentally dishonest.  GW Pharmaceuticals reveals it contains more than 400 molecules, the MHRA says it only contains two and “unspecified impurities”.

More recently, and in the face of an explosion of supportive evidence, another line has been added.  This states that ‘the UK has a well established process for the approval of medicines through the MHRA and that any company wishing to bring a medicinal cannabis product to market should follow this procedure.  In fact, inside sources suggest that the government is very keen to see new cannabis-based medicines approved by the MHRA.  It would take the wind out of the sails of the medical cannabis campaign

This is the very last excuse for denying access to medicinal cannabis. It is nothing but an excuse and one that is misleading and based on deception.  If we can expose how weak, inappropriate and fake it is, the government will have nowhere else to hide.

Firstly, as demonstrated with Sativex, the MHRA process is incapable of dealing with a medicine that contains hundreds of molecules.  It is designed by the pharmaceutical industry for regulating single molecule medicines, usually synthesised in a lab, which have the potential to be highly toxic.  CLEAR rejects the tired, boring theory that ‘Big Pharma’ is engaged in a massive conspiracy to deny access to cannabis and to ‘keep people ill’ so it can continue to sell its products to the NHS. The MHRA isn’t engaged in such malevolent conduct, it’s simply incapable of sativex-with-cannabis-leafproperly evaluating a whole plant extract through its existing methods.

The bright, shining truth of this, that totally demolishes the government’s position, is that in every jusrisdiction throughout the world where medicinal cannabis has been legally regulated, it is through a special system outside pharmaceutical medicines regulation. Every other government that has recognised the enormous benefit that medicinal cannabis offers has come to the same conclusion: cannabis is a special case.  It is far more complex but much, much safer than pharmaceutical products.

Of course, there is also the ludicrous status  of cannabis as a schedule 1 drug, which prevents doctors from prescribing it.  If it was moved to schedule 2, alongside heroin and cocaine, or to schedule 4 alongside Sativex (the logical choice), doctors could be prescribing it tomorrow and high-quality, GMP and EU regulated medicinal cannabis from Bedrocan would be immediately available.

So the MHRA is the final excuse, the last obstacle to a revolution in healthcare in the UK.  We need an ‘Office of Medicinal Cannabis’ as there is in the Netherlands, or ‘Access to Cannabis for Medical Purposes Regulations’ as administered by Health Canada. Colorado has its ‘Medical Marijuana Registry Program’ and other US states have similar arrangements.  Israel’s Ministry of Health has its ‘Medical Cannabis Unit’.  In Australia, its equivalent of the MHRA, the Therapeutic Goods Administration, has established its own set of medical cannabis regulations.

This is now the most important factor in achieving medical cannabis law reform.  Next time you contact your MP or in any advocacy or campaign work you do, this is where to focus your energy.  Cannabis is a special case, it is not like other medicines.  Once we can open the eyes to this truth the path ahead will be clear.

Written by Peter Reynolds

January 31, 2017 at 11:56 am

The Facts About CBD In The UK. December 2016.

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On 3rd October 2016 the Medicines and Healthcare products Regulatory Agency (MHRA)  issued notices to a number of CBD suppliers stating that cannabidiol (CBD) was being designated as a medicine and that sale of all CBD products must stop within 28 days, ostensibly by the 1st November.

A lot has happened since.  Most importantly, the Cannabis Trades Association UK (CTAUK) has been established to represent the industry and protect the interests of CBD consumers but there remains great confusion as to the legal status of CBD and whether these products will still be available.  This article sets out the facts and explains how the market is likely to develop. The most important point is that there is no need for panic.  There will be some changes but no one will lose access to CBD for the foreseeable future.

Background

Through the summer of 2016, rumours and half stories had been swirling around about the MHRA taking action on CBD. When the news broke it caused real panic, both for the thousands of people using CBD products and for those working in CBD businesses.  It looked like a real disaster for everyone. On the one hand the government, through the MHRA, was finally recognising the truth that CBD and cannabis are medicine.  On the other, it seemed that the whole industry was going to be shut down, businesses would close, people would lose their jobs and, most importantly, those who rely on CBD products for maintaining their health were going to suffer real harm.  If CBD was going to be regulated as a medicine it would require the investment of hundreds of thousands of pounds to obtain the necessary authorisation to put any products on the market.

It quickly became clear that the MHRA was unprepared for the reaction it received. Its switchboard was swamped by worried callers.  Social media exploded with the inevitable Big Pharma conspiracy theories and even the national press covered the story demonstrating that medicinal cannabis is now an issue of mainstream interest.

ctauk-logoCLEAR took action to rally our friends and colleagues in the legitimate cannabis business and this led to the creation of CTAUK.  The same day the news broke we wrote to the MHRA notifying it of the formation of the trade association and seeking a meeting.

On 13th October, the MHRA issued a statement on its website explaining its actions.

CLEAR’s advisory board members, Professor Mike Barnes issued a statement to the media and Crispin Blunt MP wrote to Dr Ian Hudson, the chief executive of the MHRA.  Even the British Medical Journal covered the story.

On 19th October the MHRA finally confirmed a meeting with the CTAUK to take place on 3rd November.  On 21st October, Dr Ian Hudson replied to Crispin Blunt’s letter.  CTAUK appointed solicitors who in turn obtained counsel’s opinion and on 28th October a solicitor’s letter was sent to the MHRA formally objecting to its action. On 1st November the MHRA updated its statement on its website softening its position by claiming that its notices to CBD suppliers were merely its “opinion” that it should be designated as a medicine.

The meeting took place at MHRA headquarters on 3rd November.  It was cordial and constructive and on 16th November CTAUK wrote to the MHRA formally proposing a system for the regulation of CBD.  Essentially this suggests that CBD products with daily adult dosage of up to 200mg should continue to be marketed as a food supplement.  Products with a daily adult dosage of up to 600mg would require a Traditional Herbal Registration and higher dosage products would require a full Marketing Authorisation.  We await the MHRA’s response.

The MHRA has since written to CBD suppliers requiring them within seven days to provide samples of their products along with various information about them.  However, CTAUK has been able to negotiate that our members have until the end of January to comply.  This is excellent news and demonstrates recognition of the association by the MHRA.

Is CBD Legal In The UK?

Yes, CBD is not a controlled drug under the Misuse of Drugs Act 1971, neither is it covered by the Psychoactive Substances Act 2016.  As long as it is marketed as a food supplement without any medicinal claims it is perfectly legal to sell and to buy.

Is The MHRA Going To Ban CBD?

No, the MHRA will have to assess each product on its own merits, particularly taking into account how it is marketed and whether any claims of medicinal benefit have been made.

What Will Happen In the Future?

We hope that the MHRA will accept our proposals for a system of regulation, meaning that only the highest dose products, such as GW Pharma’s soon-to-be- released ‘Epidiolex’ will require a full Marketing Authorisation.  However, even if the MHRA tries to take formal action about any other products, this is going to take many months and probably a much as a year before anything changes.  We remain confident that we will come to an agreement that will enable everyone to continue to access CBD products.

Guidelines On Cannabis For Medical Professionals.

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In a new initiative, CLEAR’s scientific and medical advisor, Professor Mike Barnes, has written to the presidents of several Royal Colleges proposing the development of guidelines around the use of cannabis as medicine.

Professor Mike Barnes

Professor Mike Barnes

This is a tricky situation for doctors.  Surveys and individual reports from CLEAR members indicate that many doctors tacitly endorse their patients’ use of cannabis but clearly cannot recommend the illegal use of cannabis, however safe and effective it may be.

Professor Barnes’ letter refers to the recent APPG report, his own paper ‘Cannabis: The Evidence for Medical Use’ and says:

“…cannabis now has a reasonable evidence base for the management of chronic pain, including neuropathic pain, and the management of spasticity as well as in the management of anxiety and a use in nausea and vomiting in the context of chemotherapy.”

In conjunction with CLEAR, Professor Barnes has written to:

Royal College of Anaesthetists
Royal College of General Practitioners
Royal College of Paediatrics and Child Health
Royal College of Physicians
Royal College of Psychiatrists

His letter goes on to explain that about one million people are using cannabis as medicine:

“I do feel that doctors need guidelines to assist them when patients request advice on the use of cannabis…doctors should be properly informed about harm reduction advice and should be aware of the clinical evidence that is now guiding medicinal use in several other countries around the world.”

Our proposal is for an initial meeting to discuss the idea.  If one or more of the Royal Colleges is prepared to back this initiative, CLEAR will set up and fund a working group of clinicians and medical education specialists to develop a set of guidelines.

 

Report Of Meeting With MHRA On Regulation of Cannabidiol (CBD).

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Tom Whettem, Cannabidol; Anthony Cohen, Elixinol UK; Tom Rowland, CBD Oils UK; Karl Spratt, Hempire; Peter Reynolds, CLEAR Cannabis Law Reform; Mike Harlington, GroGlo Research & Development

Tom Whettem, Canabidol; Anthony Cohen, Elixinol UK; Tom Rowland, CBD Oils UK; Karl Spratt, Hempire; Peter Reynolds, CLEAR Cannabis Law Reform; Mike Harlington, GroGlo Research & Development

Yesterday, 3rd November 2016, six delegates from the UK Cannabis Trade Association (UKCTA) met with Medicines and Health Products Regulatory Agency (MHRA) representatives at the agency’s headquarters in Victoria.

We were courteously received. The meeting was cordial, productive and enabled both sides to clarify their positions and better understand each other’s perspective.

In summary, in my opinion, there is no immediate threat to to CBD consumers or businesses. The MHRA has now extended until 31 December 2016 the date by which businesses should voluntarily comply with its opinion, either by withdrawing existing products from the market, or by complying with necessary regulation. Thereafter, the next step would be to begin the process of statutory enforcement.  This would take a matter of some months and I believe, even were this to be started, we are looking at more than a year before any impact would be felt.  More importantly, based on the meeting, I think the outcome is likely to be that we can negotiate a form of regulation that will work for everyone.

The MHRA team was led by Gerald Heddell, Director of Inspection, Enforcement and Standards. Also present were regulatory advisors David Olszowska and Chris Groutides; Dr Chris Jones, Manager of the Medicines Borderline Section; Greg Markey, Senior Medical Assessor and Malcolm Evans, Head of Patient, Public and Stakeholder Engagement.  Mr Heddell opened the meeting by thanking us for bringing to the agency’s attention just how many people are using CBD, some for quite serious medical conditions.

The MHRA set out its reasons for its opinion that products containing CBD used for medical purposes are medicines.  Greg Markey explained the mechanisms of action and pharmacology that had been considered and Dr Jones explained that the Borderline Section existed to deal specifically with products where it was difficult to determine whether they should be regarded as medicines or food supplements.  The example was offered of vitamin C where if it was being used to treat scurvy then it was clearly a medicine, whereas if it was used to supplement a normal diet it could be regarded as a food supplement.  We were able to explain that all so-called CBD products on the market, with the exception of crystals, are actually whole plant extracts from low-THC cannabis, usually industrial hemp.  We pointed out that the growth in the CBD market had been driven by people seeking the therapeutic benefits of medicinal cannabis which until now had been denied by the British government.

The nub of the issue is really the nature of the condition for which CBD is used.  The MHRA has already issued orphan designations for CBD for Dravet Syndrome, graft versus host disease and perinatal asphyxia.  Orphan designations are granted where the benefit of a medicine can be recognised even though necessary regulatory processes have not yet been completed.  It is important to understand that this is what has guided the MHRA’s opinion, viewing CBD as a medicine for very serious conditions.

We discussed a range of options whereby, at the lowest level, CBD products could continue to be marketed as a food supplement.  For minor conditions, not requiring medical supervision, it may be possible to obtain a Traditional Herbal Registration (THR) at a cost of a few hundred pounds.  A third option is a ‘Specials’ exemption where a doctor or prescriber has specified and taken responsibility for an unlicensed medicine for a particular patient.  Finally, the highest level is a Marketing Authorisation (MA) where the costs including fees and clinical trials are probably a minimum of £250,000.

It is our view that CBD products should be regulated at all these different levels dependent on the purpose for which they are used and the concentration at which CBD is present.  We have agreed that we will write formally setting out these proposals and the MHRA will respond accordingly.

The UKCTA and a number of individual companies have now obtained legal advice including counsel’s opinion.  We have shared this with the MHRA and formal solicitors letters have already been served.  In essence, the advice is that the MHRA has failed to comply with its own guidelines and requirements in issuing its opinion to CBD suppliers and that any requirement to comply with regulations would have to be addressed on an individual, product by product basis.

So, all in all, we believe the meeting was a success.  We demonstrated that the new trade association is to be taken seriously and that we will work constructively with the agency.  There was visible surprise at the level of professionalism we presented, particularly with the legal advice we had obtained.  I believe we convinced the MHRA that we could establish a set of rules, guidelines and standards that would enable the industry to comply with its requirements.

The CBD market in the UK is presently worth several million pounds a year.  If it is to continue to grow, provide safe, effective products for consumers and patients and job security for its workers, then we need to establish UKCTA so that it effectively represents the whole industry.  We need to show that we are responsible, we care, we are professionals and we are ready to put our collective head above the parapet as a legal, ethical and regulated industry.