June 29, 2005
Administrative Law Judge Mary Ellen Bittner
Drug Enforcement Administration
Office of Administrative Law Judges
Washington, D.C. 20537
Re: Professor Lyle Craker, Ph.D., Docket No. 05-16
Dear Judge Bittner:
I am Jack Lewin, M.D., CEO and Executive Vice-President of the California Medical Association. I am writing in the matter of Craker v. DEA, Docket No. 05-16 to express our view that it is in the public interest for the DEA to issue research licenses to appropriate researchers and facilities to produce marijuana exclusively for federally-approved research.
The CMA is a non-profit, incorporated professional association of more than 30,000 physicians practicing in the state of California. CMA’s membership includes California physicians engaged in the practice of medicine on hospital medical staffs, both at public sector and private hospitals, throughout the state, and in all specialties. CMA’s primary purposes are to promote the science and art of medicine, the care and well-being of patients, the protection of public health, and the betterment of the medical profession. CMA and its members share the objective of promoting high-quality, cost effective health care for the people of California.
CMA endorses appropriate research to determine the medical safety and efficacy of cannabis. CMA supported Senate Bill 847 (Stats. 1999, Ch. 750), authored by Senator Vasconcellos, which established Californias Cannabis Research Act. This legislation authorized the University of California to implement a three-year research program (the California Cannabis Research Program) to ascertain the general medical safety and efficacy of cannabis and, if it is found to be therapeutically valuable, to establish guidelines for its appropriate administration and use. See California Health & Safety Code 11362.9.
If research confirms the medical value of marijuana, it could help treat and save the lives of many of our members patients. For that reason, we believe that the medical use of marijuana is an issue that should be resolved through scientific research. Without that research, marijuanas medical efficacy and safety will simply be an issue for prolonged and loud debate. And, without that research, we believe there is little likelihood that marijuana could ever be tested appropriately to determine whether it is a medicine that should be approved by the FDA for prescription use.
We believe that marijuana should be treated like any other potential therapeutic medicine, with researchers having the ability to obtain it and test it, within federally-approved scientific research protocols. To date, it has generally not been treated that way, causing significant problems in the research into marijuana as a potential medicine. It is in the public interest to allow the scientific process to determine whether marijuana should be available as a medicine for sick patients who may need it, and DEA licensing of appropriate and qualified researchers is crucial to facilitate that process.
Respectfully submitted,
John C. Lewin, M.D.
CEO/EVP, California Medical Association