The Advisory Council on the Misuse of Drugs (ACMD) have published their response to the request from the UK Home Office to write a definition of Cannabis-Derived Medicinal Products (CDMPs)
In the most part, this is a very encouraging, detailed whilst cautious document containing sensible and well thought through recommendations We are really pleased that the ACMD have highlighted a number of very important challenges that must be addressed as a matter of urgency, such as education within the medical profession, encouraging clinical trials and the collection of clinical data, all of which are absolutely critical to an effective and inclusive medical cannabis access policy and process.
We do have a few areas for concern that we would like to address:
1: “The ACMD agrees that unlicensed CDMPs should be considered as a product of last resort and used only when no other drug with MHRA marketing authorisation meets the clinical need”
Assuming there are already a suitable range of authorised CDMPs to choose from then this is understandable, but until then and since there is good evidence that cannabis can be safer and more effective for many patients and for many conditions than currently available drugs we see no reason to classify them as a “product of last resort”. We should be more concerned with the dangerous and addictive opiates medications for which we have a serious and growing problem. In all US states that have implemented a broad enough medical cannabis policy, there has been a 24% reduction in deaths and addiction relating opiate prescription and illicit medication! CDMPs should be standard treatment options considered and offered alongside others.
2: “The ACMD agrees with the proposed initial restriction of CDMP prescribing to clinicians on the specialist register of the General Medical Council (GMC)”
Whilst there is an urgent and critical need for Doctor education, we believe this to be over cautious and question the need to restrict prescribing from GPs, even initially. Many formulations of CDMPs have an unparalleled safety profile. We estimate there are about 1.1m current medical cannabis patients in the UK, the vast majority of whom are desperate to discuss their experiences with cannabis with their GP and access a standardised, legal, quality CDMP as soon as possible, all of which will be safer than their current sources of medicine and help them to discuss their consumption with a medical professional. Besides preventing many patients benefiting from this it will also create an immediate bottle-neck whose backup will inevitably land at the GPs surgery anyway. We need to be teaching all medical professionals as soon and as efficiently as possible.
3: The ACMD is concerned that element 1 could potentially encompass a wide range of products not appropriate for medicinal use: Examples include products of known acute harm, such as very high-tetrahydrocannabinol (THC) containing solid and edible products
To describe “very high-tetrahydrocannabinol (THC) containing solid and edible products” as “of known acute harm” is misleading and inaccurate.
THC, no matter how “high” is rarely “acutely harmful” and if you refer to the recent World Health Organisation pre-report on THC, it has a remarkable safety profile.
Edibles and other solids all have justifiable therapeutic reasons for existing and as is being seen in all places where they have been made available as medicines, they can be made to the required level of consistency and quality and for many patients, this is their favoured and in some cases only effective method of consumption. Such an unscientific and unevidenced statement is unnecessary.
We are pleased to hear:
“The ACMD does not anticipate that smoking will be a permissible route of administration of a CDMP as there is evidence of harms associated with smoking Cannabis”
We would never recommend smoking as a safe and effective way of consuming cannabis as medicine and actively encourage our patients and supporters to move away to safer forms of consumption such as vapourising. That said, a third of current consumers of cannabis as a medicine do smoke it, so we recommend looking at ways to support them during their transition to a CDMP.
With the caveats and questions above, we are really pleased with this advice and hope that the Home Office adopt and implement its recommendations as a matter of urgency. We do feel strongly that future policy should benefit from the experience , expertise and preferences of patients who have been consuming this medicine for many years and we offer our insights and involvement in order to create the most appropriate, fit-for-purpose and inclusive medical cannabis policy for UK citizens.
Ultimately, our goal and what patients deserve is to have #nopatientleftbehind
So lastly, whilst this is not something that concerns the ACMDs report, or indeed their remit, we will repeat that there are an estimated 1.1m regular medical cannabis consumers in the UK today. Now that we have recognised that cannabis does have medicinal and therapeutic uses, the criminalisation of any patient for possessing or growing a personal amount for the benefit of their own well-being should cease immediately. We look forward to this unfair and cruel policy being addressed as a matter of equal urgency as all other patients.
If you want to see how cannabis is being consumed as a medicine in the UK today, check out the results from our 2016 Medical Cannabis Patient Survey
2018 #UPASurvey results our soon……..
Jonathan Liebling - Political Director