Organisations in Favour of Bill

Submission 2: The Don Medicinal Cannabis

Small Australian producer of medicinal cannabis oil. Concerned big pharma will dominate market with standardised product. Company criticised by recreational cannabis users forum Oz Stoners for not delivering goods and likewise the Sunday Telegraph which later fully apologised. Owner featured in Vice (online publication) as possibly ‘last person to face court over medical weed’. for 2 pages.


Submission 3: New South Wales Bar Association

Concerned with legal aspects of medical cannabis. Wishes to regulate ALL drugs including for recreational use to destroy black market. 3 pages.



Submission 8: Phytotech Medical Ltd 

ASX-lised Israeli / Canadian cannabis growing business also known as MMJ Phytotech.  Presents wide-ranging slideshow arguing for amendments to UN convention on medical cannabis & what overseas countries are doing, particularly Holland, Canada, Israel, Uruguay and where relevant, their medical access programmes. Cost issues discussed. 36 slides.

Attachment 1 

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Submission 26: Public Health Association of Australia (PHAA)

Organisation is ‘recognised as the principal non-government organisation for public health in Australia and works to promote the health and well-being of all Australians….comprising around 1900 individual members and representing over 40 professional groups concerned with the promotion of health at a population level.’ Position Statement of 2014 also attached with submission. PHAA strongly supports idea of new Regulator because research indicated benefits of medicinal cannabis and: ‘We do not have available, at present, an adequate range of cannabis-based therapeutic products that meet the TGA standards for registration. As an interim measure, until such time as the full range of TGA approved products are available, it is imperative that people are able to gain lawful access to cannabis in situations where it is likely that they will be able to benefit from the drug’. 6 pages.

Additional Information 


Submission 30: Australian Federation of AIDS Organisations, the National Association of People With HIV Australia, ACON and Positive Life NSW 

National Association of People With HIV Australia (NAPWHA) is Australia’s peak non-government organisation representing community-based groups of people living with HIV. Notes ‘the submissions…made by Ms Debra Cliff (Submission 1) and The Don Medicinal Cannabis (above). Our organisations agree with their call for broadening the purview of the Bill beyond a single oil extract, to ensure that patients can access optimal cannabis treatment.’ Provides links to scholarly articles pertinent to organisations’ area. Wishes ‘ individuals with certified medical conditions to (be permitted to) cultivate a limited number of marijuana plants for personal use and/or to purchase from certified growers and producers.’ 3 pages.


Submission 31: Epilepsy Action Australia

Australia’s national provider of education and support services for people with epilepsy, their families, professional and the community. ‘Strongly supports this initiative.’ 2 pages.


Submission 36: Australian Drug Law Reform Initiative 

Describes itself as academics, visiting fellows, students and former students in the UNSW School of Law and associated UNSW entities. The purpose of ADLaRI is to provide a legal perspective on drug policy issues. Says: ‘Overall the Regulator of Medicinal Cannabis Bill 2014 is very promising and if implemented would be a significant step forward in allowing doctors to use their expertise to prescribe cannabis to patients who may benefit from it’. Gives background to steps in NSW then discusses role of Commonwealth, giving opinion that: ‘States should be left free to trial various forms of schemes for medical cannabis as their Parliaments see fit.’ Notes: ‘The Bill’s clear intention is to remove medical cannabis from the TGA and the scheme that legislation implements’. If the Bill is enacted it ‘will be a very positive step for the Commonwealth and would be welcome progress in allowing medical cannabis.’ 4 pages.


Submission 38: Joynt Venture

Small chain of stores selling drug and other paraphanalia. Supports Bill. Says Government has ‘unnatural fear of cannabis’. 3 pages.


Submission 39: Eros Association 

Adult Industry trade association. Favours Bill & recommends amalgamating proposed Medicinal Cannabis Regulator with National Cannabis Prevention and Information Centre (NCPIC – earmarked by Government to close in December 2016). Questions how medicinal cannabis would be distributed ‘Ensuring that the supply chain effectively meets demand ought to be one of the top priorities of the regulator to avoid market failures’. Letter by Nick Wallis, the Associations ‘Social Tonics Manager’. 1 page.


Submission 43: Cannabis Policy Project 

A ‘new organisation formed with the goal of providing coherent and sound legislative, regulatory and policy advice to both the Federal and State governments of Australia.’ Broadly supports Bill but discusses concerns with: definition of Responsible Minister; transparency and good governance; eligible patients; medicinal cannabis products and medical practitioners; fees & cost recovery; method of distribution. Makes recommendations in relation to above. Authors Craig Ellis & Ivan Ross Vrána. 7 pages.


Submission 28: Australian Lawful Use of Cannabis Alliance

Long, highly researched, finely referenced document ‘wholeheartedly supporting Bill’ and providing much background information, legal, historical & medical. 31 pages.


Submission 48: Bedrocan

Official licensed supplier of medicinal cannabis to Dutch and Canadian Governments now with presence in Australia.  ‘One of the world’s few sources of research-grade cannabis’. Does not offer comment on merits of medicinal cannabis but contributes to to discussion around it. Explores regulatory positions in Netherlands and Canada including product quality, distribution, communication and marketing. Explores some of Bill’s ‘fine print’ & lists studies of harms associated with contaminated cannabis as well as other research. 18 pages.


Submission 53: Bar Association of Queensland 

Association generally supports Bill, emphasises need to distinguish between medical /non-medical use. Discusses international ‘instruments’ (such as Single Convention on Drugs) to which Australia is bound and how other countries deal with this. Says Bill is unclear as to how new Regulator would work alongside TGA. 3 pages.


Submission 55: Australian Lawyers Alliance

A ‘national association of lawyers, academics and other professionals dedicated to protecting and promoting justice, freedom and the rights of the individual.’ Supports Bill. Discusses Single Convention on Narcotic Drugs, cross-jurisdictional differences, calls for community education and greater clarity of Bill in certain respects. 16 pages.


Submission 57: Fagron Compounding Supplies Australia

Specialist chemist equipment supplier allowing clients to create bespoke medications/types of medication for patients. Supplies to 200,000 pharmacies in 60 countries and is ‘the exclusive distributor of cannabis in The Netherlands’, under Government contract. Urges Committee to include a pharmacist in new Regulatory body. Says company would be the ‘best partner’ for Government regarding import and distribution of medicinal cannabis. Also provides ‘Production & Distribution Model’ of Dutch Office of Medical Cannabis (OMC). 3 pages.


Submission 60: Queensland Council for Civil Liberties

Eight-page submission together with additional 24 pages of appendices. Written on behalf of organisation by John E. Ransley, an Executive Member. Author has twice made formal submissions about cannabis to Queensland Government and discloses his late wife (and also, previously, a cousin) used cannabis for medicinal purposes the latter discovering the drug ‘was the only effective and immediate-acting remedy for her chemotherapy- and radiotherapy-induced nausea….despite having access to the best available anti-nausea medications at that time, including the then-new and enormously expensive drug Zofran‘. Discusses medical cannabis science, asserting ‘medicinal cannabis is not an ‘alternative therapy’’s content. Extensive references also appended. 34 pages.


Submission 62: Happy Herb Company 

Company is ‘a prominent establishment in the Australian phytomedicinal industry.’ Welcomes ‘any compassionate and rational approach to the issue of medicinal cannabis.’ Says ‘cannabis is a ‘pharmacologically complex medicinal plant‘ therefore ‘cannabinoids cannot easily be isolated and evaluated on an individual basis using the same criteria that apply to most pharmaceutical drugs; thus provision must be made for patients’ use of the whole plant,’ adding ‘scope’ of pharmaceutical industry should be ‘curtailed’ and patients allowed to ‘grow their own medicine.’ 3 pages.


Submission 65: Elixinol LLC

Author, Peter Benhaim, is ‘CEO of the largest industrial hemp food manufacturing facility in the Southern Hemisphere‘, manufactures, packs and distributes products for Australia and export throughout the world. Is also CEO of Elixinol LLC – a US based company that manufactures and legally distributes non-psychoactive medicinal cannabis oil from industrial hemp – low THC plants’ and holds licence to import cannabis products into Australia from various countries. Believes ‘the psychoactive ingredient THC should be included, yet differentiated from all other cannabinoids and limited to new licensing methods‘. Author makes a number of points he believes the Committee should consider, including that ‘significant knowledge’ of medicinal cannabis exists (says he has over 1000 pages of clinical research himself, that cannabis a good source of tax revenue, removal of criminal penalties of benefit to individuals and society, absence of deaths as a direct result of cannabis use, and medical benefits supported by large body of anecdotal evidence. Includes (as attachment) testimonials about the product Elixinol and wishes to share information with proposed Regulator. 4 pages + attachment.



Submission 69: Victorian Government

Says State recognises people with certain illnesses wish to use medical cannabis but are legally prevented from doing so and is ‘committed to investigating legislative reform options’ to allow use ‘in exceptional circumstances.’ Adds: ‘The use of medicinal cannabis is a matter of high sensitivity and complexity‘, and describes how the State’s Attorney General referred matter to the Victorian Law Reform Society, tasking it to review and report on the Drugs, Poisons and Controlled Substances Act 1981 and associated Regulations and acts so as to enable necessary amendments which would allow treatment with medical cannabis in exceptional circumstances. At time of writing VLRC was conducting its Public Consultation. Concludes ‘If the Regulator of Medicinal Cannabis Bill 2014 progresses, the Victorian Government will seek to further engage with the Commonwealth Government regarding issues raised in the Bill. In particular, consideration will need to be given to the scope of the Regulator’s proposed functions and the interaction between the operation of Victoria’s legislation and any new proposed national regulatory framework.‘ 1 page.


Submission 73: Penington Institute

Author John Ryan on behalf of Institute. Believes ‘Australia should allow access for therapeutic purposes and ensure that safeguards are put in place to mitigate the risks associated with the use of cannabis in the general population, while simultaneously reaping the therapeutic benefits for those who are receiving it for medical reasons‘. Believes assertion that cannabis is highly addictive ‘ignores firm evidence’ and that ‘the removal of legal action and possible imprisonment for possession and use of cannabis in Australia and United States found that it made no difference to cannabis consumption‘. Argues that ‘a medical practitioner is not going to be aware of the composition and potency of the cannabis accessed by the patient, and should therefore not have to bear the responsibility inherent in making a recommendation. Therefore it should be sufficient that access to a medicinal cannabis scheme be open to patients who have been diagnosed with a prescribed medical condition; with the patient bearing responsibility for her/his choice to access cannabis,’ and that access to the drug by young (15-25 year-old) people should be restricted because of evidence of mental and behavioural problems among users. Numerous learned papers cited at end of submission. 4 pages.


Submission 82: Families and Friends for Drug Law Reform (ACT) 

Organisation formed around group of people in the ACT who had a child, relative or friend who had died from a drug overdose with membership now across Australia. Supports Bill, notes ‘the illegal status of cannabis and accompanying grossly exaggerated and alarmist propaganda has long impeded the objective scientific assessment of the drug.‘ Provide some ‘guiding principles’, including on rights of patient, they believe should be considered, discussed in more detail within submission. Conclude: ‘The perfect should never be allowed to be the enemy of the good.’ 18 pages.


Submission 85: Ecofibre Industry Operations 

Author Phil Warner, the company owner, has been ‘instrumental in developing the Industrial Hemp (cannabis) Industry within Australia and in other countries for nearly 20 years‘. Supports Bill, believes ‘TGA stance (on scheduling of cannabis) is completely out of step with the rest of the modern world and causes flow-on issues for those who are legitimately undertaking research to either provide materials and/or clinically analyse its benefits, but ‘on the other hand, I do understand the need for the TGA to quickly address the wholesale exploitation of the public by unscrupulous retailers selling unregulated CBD products‘, and that ‘CBD has unwittingly been included with THC in the broad definition given to Cannabis Extracts‘. 2 pages.


Submission 145: Medical Cannabis Users Association 

Organisation is ‘a growing collective of over 6000 Australian refugees from a broken health ‘care’ system that has run out of options for safe treatment for their terminal, baffling, hidden and rare illnesses‘ and a a member organisation the new International Medical Cannabis Coalition. Say it wishes to see cannabis ‘given its rightful place in our medical arsenal against cancer and all other cannabinoid deficient illnesses that baffle our modern doctors,’ and Bill a first step towards. Members biggest concern however  ‘is the potential cost and quality of any pharmaceutical one-size-fits-all or single-molecule chemical imitations created in a laboratory‘. Want reassurance that products are full plant extract of the best species for their illness. Cite various studies, give historical background and say current laws and treaties based on lies. Give details of misdeeds and critical of pharmaceutical industry and those working for it, with examples given and says governments ‘buckle’ to it. Say current situation mirrors that of a decade ago and mentions 2000 NSW Drug Summit. Says NSW leading the charge again but carers charged and arrested for cultivating medical cannabis despite being on NSW TICS register (now Compassionate Use Scheme). Cites seven studies about cannabis from overseas and asks who benefits from keeping cannabis banned in Australia, adding: ‘The health system in this country is not a safe place. Trust is gone’. Discusses cannabis as a preventative medicine and explores stance of Australian Medical Association (see Submission 44) citing (and differing with) AMA President Dr Stephen Hamblin. Also discuss the United in Compassion Symposia quoting Dr G. Edward Griffin who says ‘today more people are making a living from cancer than are dying of it.’ Provide statistics about cannabis use in Australia, and cost to police public relations as  to society and public opinion as well as safety concerns. Conclude with: ‘Even though we applaud the efforts of what this legislation is attempting to achieve yet again, it still remains far too over complicated and burdened with yet more cost‘. 18 pages.


Submission 147: ACT Government

ACT Government believes a national approach to the regulation of the medicinal use of cannabis is required and supports the compassionate intent behind the Bill. Discusses clinical need and says has consulted with clinicians specialising in pain, general practice, neurology, sexual health, oncology, anaesthetics and addiction medicine. Finds a general reluctance among clinicians to recommend cannabis use mainly because of quality controlled supply and dosing standards. Government concerned about ensuring safety of young people, intersection with existing legislation, limited detail of Bill (i.e. on matters like law enforcement) and supply and distribution. Concludes ‘if Bill enacted ACT Government would be eager to participate in development of rules.’ 5 pages.


Submission 210: Medicann Pty Ltd

Companywas established 2015 by two enthusiastic brothers who have been watching the medicinal cannabis industries movements for the last 10 years‘ with ambitions to become one of the county’s most trusted medicinal cannabis companies. Provides first a glossary of definitions and key words then information about medicinal cannabis, strains for different medicinal purposes and potential conditions it can treat. Company does not believe the drug should ‘be regulated by the current system (TGA) (because it is) a natural product and should be treated as such when it comes to the regulating of its use as a medicine or therapeutic good.  6 pages.