Thank you for letter dated Feb. 17th, 2004 in response to our facsimile regarding CSA participation in the OCMA multi-stakeholder meeting of February 18th, 2004.
Although it was a pleasure to be able to meet with Beth Pieterson and Valerie Lasher, it is clear that many of the concerns expressed by the courts as well as compassion societies and medicinal cannabis users are not being addressed by the proposed changes to the MMAR.
Canada's compassion societies remain the main source of supply for most of Canada's legally registered medicinal cannabis users. Compassion societies are currently serving over 7000 legitimate medicinal users - nearly 10 times the number of users registered with Health Canada. The OCMA has used this fact in court to justify the MMAR.
Compassion societies are currently the main source of legitimate cannabis research in the nation, participating in studies with the University of British Columbia, The University of California, San Francisco, and with the Canadian Center for Addiction and Mental Health. All of this research has been peer-reviewed and approved, and is taking place without financial assistance from Health Canada or taxpayer funds.
In your response to our fax, you state "compassion clubs are unregulated and operate outside of Canadian laws". Since the inception of the MMAR, compassion societies have willingly engaged with Health Canada, sharing valuable experience and expertise, as well as proposing models for their regulation and licensing. Although many clubs currently operate as registered non-profit societies and are well-integrated into their local communities and network of social/welfare organizations, they remain illegal and unregulated at the discretion of the Health Minister, who - according to the CDSA- has it in his power to license the distribution of cannabis (or any other narcotic drug) at any time and for any reason.
With both the Senate Special Committee on Illegal Drugs and the Ontario Appelate Court (Hitzig) recently recommending a formalization of the relationship between the federal government and the clubs, Health Canada's intransigence in this matter is inexplicable unjustified. Is it not sensible that the OCMA might benefit from a more established relationship with the only Canadian organizations currently engaged in the large-scale cultivation, distribution and research of medicinal cannabis? Is it not in the best interest of Canada's critically and chronically ill to have Health Canada explore the possibility of a more formal and regulated relationship with the clubs? There is simply no good reason to keep ignoring this incredible resource of information, experience and relevant research.
In this regard, we have included some documents with this missive for your review (will be included in hard copy of this document):
Concerns Stemming From the February 18th Health Canada Consultation and the Proposed Changes to the MMAR.
"Operational Standards for the Distribution of Medicinal Cannabis" are guidelines for the community-based cultivation and distribution of medicinal cannabis prepared by the British Colombia Compassion Club Society, Canada's oldest and largest compassion society (2700+ members, 7 years in operation).
"Roadmap to Compassion" is a 12-month timeline to an effective medicinal cannabis program focusing on the continued decentralization of the federal OCMA.
Outlines of several active research projects currently being undertaken by compassion clubs.
It is the hope of Canadians for Safe Access that Health Canada will finally address the many concerns of our nation's critically and chronically ill, and will see the wisdom in working more closely with Canada's non-profit compassion societies which continue to serve as Canada's main resource for cannabis medications and information.
We look forward to hearing back from you.
Sincerely,
Philippe Lucas & Rielle Capler
Canadians for Safe Access www.safeaccess.ca
250-884-9821
P.S. This document has been CC'd to Minister of Health Pierre Pettigrew and the Office of Cannabis Medical Access.
