Community Coalitions of Virginia (CCoVA) is a non-profit organization that consists of representation from substance abuse prevention coalitions (#41), organizations (#5) and individuals (#4) across the state.  CCoVA works collaboratively to prevent and reduce substance abuse and related risk factors in Virginia communities in ways that are measurable and improve quality of life.  For more information please see our website, www.communitycoalitionsofva.com

Community Coalitions of Virginia provides this public comment in response to the Virginia Board of Pharmacy New Regulations Governing Pharmaceutical Processors; May 17, 2019. 

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 grows 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 illness 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 to provide written certification for the promotion and use of marijuana as a medicine in the form of CBD-THC-A-THC oil without FDA approval because there is insufficient scientific evidence of the benefits and effects on patient safety are unknown.  

8.      It is ethically inappropriate for pharmacists to grow and dispense CBD-THC-A-THC oil without sufficient research on dosage and interactions.     

9.      Attorney General Jeff Session has reversed the Cole Memo, now instructing federal law enforcement to enforce federal law with regard to marijuana manufacturing and possession.

10.  Increased access to marijuana oils increases usage in 12-17 year olds. (The National Survey on Drug Use and Health reports, SAMHSA)

11.  Marijuana usage, including oils, is linked to mental illness and opioid use.

12.  If the Virginia Board of Pharmacy adopts these new 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. 

Contact Information:

Dr. Mary Crozier, CCoVA Chair, 252-864-1478, mkcrozier@gmail.com

Keri Jones, CCoVA Legislative Chair, 540-332-3806, joneskd@ci.staunton.va.us

Keenan Caldwell, KC3 Consulting, LLC, 804-937-2673, kc3consulting@outlook.com