On Monday, April 9, 2018, the U.S. Food and Drug Administration (“FDA”) published a notice in the Federal Register seeking public comment from interested persons on the scheduling status of cannabis, under international agreements, in a number of forms, including cannabis extracts, THC and CBD. FDA is seeking comments on cannabis to inform the Agency’s final testimony for the World Health Organization (“WHO”) later this year. WHO’s Expert Committee on Drug Dependence will use FDA’s testimony to aid in WHO’s analysis of the current status of cannabis on its potential to cause dependence, abuse and harm to health, as well as its medical and therapeutic uses. WHO will then make recommendations to the United Nations on whether there is a need for international control of these substances.
FDA is accepting comments through April 23, 2018, and all interested persons, including hemp and marijuana businesses, have an opportunity to contribute to the Agency’s cannabis analysis. The Firm’s clients are encouraged to submit comments in an effort to change the scheduling status of cannabis and highlight the medical and therapeutic benefits of cannabis derived treatments. Commenters on this matter will also be able to challenge any FDA rule governing cannabis that may stem from this process. McAllister Garfield has extensive experience participating in agency rulemaking and is happy to submit comments on behalf of clients. Time is of the essence in this matter, so do not hesitate to contact the Firm so that we may begin drafting comments on behalf of your entity.