The following could not easily be placed into any of the other groups created to break down and classify the Submissions.
The Government’s leading think-tank on drug policy in Australia. Scholarly, wide-ranging submission 20 pages in length, reviewing background, overseas experiences, positions of other organisations, problems of definitions of medicinal cannabis, possible blurring between medical and recreational use, different regulatory options. Cites many papers, articles and studies. Raises issue of problems ensuring product is consistently of same, high (medical) grade. Concludes: ‘DPMP believes that any medicinal cannabis debate in Australia should be informed by the experience of different regulatory regimes abroad,’ and this based on fact that ‘the tightness of the model will depend on the extent to which it is desirable to draw clear distinctions between medicinal and recreational use, with the attendant risk of creating a false dichotomy and valorising medicinal use at the expense of marginalising recreational use and nonrecognised medical use‘. 20 pages.
Industry lobbying body representing cannabis growers in Australia, including of industrial hemp. Against new regulator but also against TGA type regulation. Cites ‘Canadian Marijuana For Medical Purpose Regulations‘, a slightly modified version of which it feels should serve as exemplar/model of how Australia should proceed. 15 pages.
Clinical Oncology Society of Australia (COSA) is the peak national body representing health professionals from all disciplines whose work involves the care of cancer patients. Cancer Council Australia is Australia’s peak national non-government cancer control organisation and advises the Australian Government and other bodies on evidence-based practices and policies to help prevent, detect and treat cancer. Concerned that ‘By not requiring registration by the TGA, a product cannot apply to the Pharmaceutical Benefits Advisory Committee‘ and my thus be unaffordable. Also concerned clinical trials of medicinal cannabis adhere to Australian Code for the Responsible Conduct of Research and the National Statement on Ethical Conduct in Human Research, including approval from a Human Research Ethics Committee. Say no evidence exists of cannabis as a treatment for cancer, but may be useful for side effects of chemotherapy. Believe ‘evidence to support the medicinal use of cannabis remains limited‘. 13 pages.
Organisation offers no opinion on Bill but draws attention to its widely cited National Drug Strategy Household Survey which, in 2013 showed that 75% of people aged 14 or over supported trials of medicinal cannabis and 69% supported change of legislation permitting medicinal use (only around a quater – 26% – believed the drug should be legal for recreational use however). 5 pages.
AusCann Group Holdings Pty Ltd (AusCann) ‘aims to of cultivate high quality, medicinal-grade cannabis for export’. Uses Canadian model of MMPR (see Submission 34 – above) to outline good practice among growers advising against patients or carers being able to ‘grow their own’. Discusses cannabis as a plant, various strains and conditions it has been used to treat. ‘Good Practice’ discussed fully, covering all aspects of cannabis cultivation, harvesting, quality assurance, distribution, security etc. 22 pages.
College advises caution because ‘cannabis is a substance that may cause significant psychiatric morbidity and can alter the trajectory of a person’s mental illness for the worse.’ Suggests provision in Bill for registering patients with ‘psychiatric sequelae (condition as a consequence) of cannabis use‘. Without such a Register it would be possible to prescribe a drug that, in essence could do more harm than good. College considers that ‘if legitimate medical uses are established‘ (through research) then it is appropriate for cannabis to be used,’ but ‘no new drug enters the lawful pharmacopeia without rigorous scientific testing‘ and that under the present law such testing is difficult, so ‘no scientifically valid claim concerning the efficacy of cannabis derivatives in any condition can be made‘. Concerned the availability of medicinal cannabis is likely to increase demand and that access to medicinal cannabis should not be a ‘slippery slope’ to full legalisation because of ‘accumulating evidence that cannabis use, at least in adolescence, is associated with an increased risk of developing schizophrenia‘ and exacerbates symptoms of existing schizophrenia as well as increasing the risk of rod accidents. 6 pages.
Company offering security & safety services, event management services and training solutions to various sectors. Notes that Bill ‘does not specifically address security measures‘ in relation to cannabis production & distribution. Believes security is ‘a key focal point of any future regulation of medicinal cannabis‘ and proposes a basic framework of 15 points for developing security regulations using best practice and policy from ‘a range of sources’. 10 pages.
US-based organisation promoting drug policies that are ‘grounded in science, compassion, health, and human rights‘. Mentions 23 States + Washington DC and the territory of Guam have enacted medical marijuana laws and an additional twelve other states have ‘recently passed laws protecting patients’ use of CBD2-rich oil for medical purposes. Hence, 35 out of 50 states have now passed laws granting patients access to marijuana or marijuana-based products for medical use,’ the organisation says. Goes on to describe ‘lessons learned’ with implementation of these laws, including patient access, consumer protection, caregiver provisions, doctors’ discretion and concludes ‘these programs can help Australia create legislation that will help ill patients obtain marijuana for medical use while maintaining public and consumer safety‘. 6 pages.
Institute raises possible legal ramifications of Bill and says organisation ‘supports debate’, that Committee should be ‘supported to complete its enquiry’ and that ‘consideration of the Bill should be informed by (the Committee’s) report on the complex legislative regime which currently regulates medicinal cannabis‘. 2 pages.
Founded by ‘Ellomo Medical Cannabis Pty Ltd Australia’s oldest registered medical cannabis company‘ organisation is ‘a group of cannabis researchers, providers, patients and caregivers..dedicated to helping the sick and informing people about the amazing healing powers and the therapeutic benefits of medical cannabis‘. Believes laws about the drug should be reviewed so that medical cannabis users are not criminalised. Believe ‘medical cannabis in Australia is currently seen as a potential money pot by many business people‘ and that ‘people must come before profits.’ Feels ‘Australian cannabis carers need an amnesty period in order to move from operating clandestinely to under a open legal framework‘, and that NCPIC and others only publish negative information about the herb. 2 pages.
Author suffers from over-active Thyroid they believe caused by anti-depressants. Also has chronic bone pain and a slight disability affecting brain ‘like a stroke.’ Cannabis has helped and believes Bill in this form too limited since would not include patients such as themselves. 1 page.
Is a regular cannabis user now prescribed anti-depressants. Author feels these would not be needed if they could use cannabis but instead has to submit to urine tests as a result of obtaining a criminal record after being caught growing plants. Believes arguments about cannabis and psychosis are ‘shallow’ and calls for immediate legalisation of herb. 1 page.
Authors represent ‘a Melbourne based boutique manufacturer of what’s commonly known as herbal incense or synthetic marijuana‘. Has now stopped producing since main compound has been banned. Submission includes emails from customers with various difficulties who have benefited from product. 2 pages.
Author has lobbied on issue of cannabis since 1980s and believes ‘this submission should be unnecessary’ due to volume of material available about cannabis prohibition. Refers to UN Single Treaty (and others), Baume Report of 1977, South Australian Royal Commission into the Non-Medical Use of Drugs, 1979. Writes ‘on behalf of 1000’s of Australians currently forced to risk criminal prosecution to treat themselves or their family with a proven medicine‘, and those wishing to use substance for medicinal or recreational purposes. 3 pages.
Writes on behalf of Medical Cannabis Tasmania. Believes Bill ‘fatally flawed’ and does not support it, believes cannabis should be removed from ‘poisons list’ and regulated by TGA as a complimentary medicine. Makes suggestions in relation to implementation of cannabis legal reform, including: exemption form prosecution for those using or growing medical cannabis; creation of an ‘Australian Cannabis Council’; patient register; creating a government regulated supply line; quality assurance and other matters. 4 pages + 1 attachment with supporting/background material. 4 pages.
Believes Bill un-necessary since ‘cannabis use has been shown to be 114 times more safe than alcohol‘ in a 2015 medical paper linked to. Author says they have been ‘self-medicating psychologically and physically, as a preventative measure for 29 years with absolutely no ill-effects apart from an empty wallet‘. Provides lengthy quotes from articles formerly archived on safechoice website covering moral issues, safety, health costs of alcohol vs cannabis, and the various injuries / damage caused by alcohol as against cannabis, including anti-social behaviour. 4 pages.
Author is concerned about allowing for special precautions for people who do not wish to be exposed to the drus and asserts ‘it should only be allowed with the informed consent of the patient (and) never be forced on patients, nor should neighbours, family and friends be subjected to non-consensual, second hand exposure.’ Discusses in turn the following: involuntary and incapacitated exposure; third party exposure (with special emphasis on children). Makes several recommendations, including limiting treatment to voluntary patients with special protections for mental health patients; prohibition of general smoking of cannabis; strengthening of criminal and child endangerment laws; strengthening of penalties which should be the same for medical and recreational use where third party exposure is concerned; tenancy laws reviewed so landlords can evict tenants who expose third parties to unwanted smoke in apartment blocks; public and patient education campaigns with emphasis on respect for those who wish to be drug-free. Concludes ‘a more compassionate approach to the terminally ill is welcome but it should not come at the expense of people who wish to avoid drugs.’ 2 pages.
Makes a proposal aiming to prevent cannabis consumers from being involved in illegal activities and that requirements concerning public health and safety are being met ‘by establishing regulated licensed ‘clubs’ and ‘government approved cannabis collectives‘ as seen overseas, enabling members to use drug ‘for medical and recreational purposes‘. Describes criteria for membership (including age, prohibition of other drugs in such establishments). Clubs would be concerned with public health, quality control, have dialogue with authorities and describes benefits of such premises and organisations. Then provides as appendix background information about the plant, its properties, effects and forms cannabis can take as well as notes on cannabis consumption, safety issues and use of a ‘cannabis log.’ 22 pages.