Substance Abuse Free Environment, Inc. (SAFE), is a non-profit substance abuse prevention coalition serving Chesterfield County since 1999.  Our mission is to engage key community stakeholders in working together to prevent and reduce substance abuse.  www.chesterfieldsafe.org

SAFE provides this public comment in response to 18VAC110-60. Regulations Governing Pharmaceutical Processors and states: 

1. Marijuana and its extracts are dangerous and addictive illegal Schedule 1 drugs according to federal law and the DEA. 
2. The Virginia Board of Pharmacy is violating federal law by setting up marijuana growers and dispensaries.  Virginia law nor the board’s regulations preempt federal law.
3. CBD-THC-A-THC oils are not FDA approved medicines. 
4. There are already FDA approved drugs (dronabinol and nabilone) available that contain THC and parallel the effects of marijuana. 
5. Epidolex is now an FDA approved medication that is available to treat intractable epilepsy patients. Treatment options already exist for other illnesses covered in these regulations. 
6. FDA approved drugs are the only way to ensure proper recommended dosage and patient safety through side effect and drug interaction warning labels.
7. It is medical malpractice for physicians, physicians’ assistants and nurses to provide written certification for the promotion and use of marijuana as a medicine in the form of CBD-THC-A-THC oils without FDA approval because there is not sufficient scientific evidence of the benefits and effects on patient safety.  
8. It is ethically inappropriate for pharmacists to grow and dispense CBD-THC-A-THC oil without sufficient research on dosage and interactions.  
9. A registered agent model for pickup and delivery of CBD-THC-A-THC oils will increase the risk of diversion and access to non-registered patients.      
10. Increased access to marijuana oils may contribute to increased usage in 12-17 year olds. (The National Survey on Drug Use and Health reports, SAMHSA 2016 )
11. Marijuana usage, including oils, is linked to mental illness and opioid use.
12. If the Virginia Board of Pharmacy adopts these new emergency regulations as permanent regulations, it will further open the door to marijuana legalization in Virginia.  All states that have legalized marijuana began with medical marijuana.
13. Revenues collected from marijuana do not outweigh the negative impacts on public safety, public health, the workplace, academics, health, black market and natural resources. 

Regina Whitsett, SAFE Executive Director, 804-694-7794, whitsett@chesterfieldsafe.org