Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Pharmacy
 
chapter
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]

2 comments

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11/22/11  7:46 pm
Commenter: Stephen M. LaHaye, Pharm.D. - St. Francis Medical Center

Rescheduling of Tetrahydro-cannibol from Schedule I to Schedule II for medical use
 

I am opposed to the request for Rescheduling of Tetrahydro-cannibol from Schedule I to Schedule II for medical use.  In the hospital setting, it would be impossible for pharmacists to verify the source of the product or determine an appropriate dosing regimen.  The January 2011 DEA Position on Marijuana (http://www.justice.gov/dea/marijuana_position.pdf) states,

"THE DEA POSITION ON MARIJUANA

Until the Department of Justice and the FDA can determine legitimate medicinal uses and mechanisms to insure the safety and efficacy of the supply for legitimate patients, tetrahydro-cannibol should remain a Schedule I substance in Virginia.  Thank you for the opportunity to comment.

Marijuana is properly categorized under Schedule I of the Controlled Substances Act (CSA), 21U.S.C. classification, including evidence that smoked marijuana has a high potential for abuse, has no accepted medicinal value in treatment in the United States, and evidence that there is a general lack of accepted safety for its use even under medical supervision."

CommentID: 21160
 

12/2/11  4:03 pm
Commenter: Karen Dunavant

Cannibus rescheduling to C-II
 

I am opposed to this proposed change.  I understand there is some evidence that cannibas has value in certain disease states/cases.  I think changing the schedule will put an undue burden on physicians, pharmacists and supply chain to ensure that the correct patients meet the need & have access to the correct product.  Once all the evidence is published showing the real value of this drug and the supply chain issues are addressed, then look at changing the schedule.

CommentID: 21177