Someone Needs To Do Their Job
In this week’s blog, we are going to try to shed some light
of the current FDA position regarding cannabis and hemp related products. We
are not in any way making a statement as to the effectiveness of these
compounds but are merely attempting to call attention to what we feel is the
need for a more comprehensive study and controls in hopes that the products
that are being released to the public are consistent and safe for use.
In December 2018, the 2018 Farm Bill was signed into law
under President Donald J. Trump. In essence what this did was to legalize the
growing and processing of hemp related crops by licensed farmers provided the
plant contained less than 0.3% THC. This bill also preserved the FDA’s
authority over hemp products in the Agricultural Improvement act of 2018 (2018
Farm Bill, PL 115-334). Before a meeting of the Committee on Agriculture,
Nutrition and Forestry, D. Amy Abernethy, Principal Deputy Commissioner of the
Food and Drug Administration stated “we recognize the substantial potential
that hemp has for our nation’s farmers and agriculture sector. FDA’s approach to cannabis and cannabis
derived products just like we do any other. FDA is committed to advancing hemp
products through the Agency’s existing regulatory pathway’s and we are further exploring whether it would
be appropriate to make additional pathways available to hemp products such as
those containing cannabidiol (CBD). FDA believes this approach protects
patients and the public health, fosters innovation for safe and appropriate
products and promotes consumer confidence.”
Some of you may remember that in June of 2018, the FDA
approved the drug Epidiolex for the treatment of two sever forms of childhood
seizures Lennox-Gastrault syndrome and Dravit syndrome in patients two years of
age and older. While this was certainly groundbreaking, it clearly shows the
need to further develop programs to properly evaluate the active ingredients in
marijuana and hemp related products to determine their effectiveness in
treating a variety of maladies from anxiety, to sleep and stress disorders,
opioid addiction and the list goes on.
Unfortunately, the FDA’s role in moving forward with
additional study has become somewhat bogged down by special interests and
remains the same as it was originally, which was to protect and promote public
health. So far, it appears, the FDA’s biggest concern has been to halt the
marketing of products that make unsubstantiated claims to prevent, mitigate,
treat or cure diseases without the support of FDA analysis. In addition, the
FDA recognized other concerns such as review of some products showed they did
not contain the amount of CBD noted on the products label and in fact contained
materials not mentioned on the label such as THC, heavy metals and other contaminants.
While this is certainly concerning, part of this could be very well attributed
to the lack of a qualified drug approval process that would establish
consistent policies and guidelines that would help halt the production of
inferior products and ensure public safety. How is it then that the FDA can
hold manufacturers accountable for not meeting the guidelines that they are
responsible for developing?
While the FDA agrees that there has been an explosion of
interest in products that contain CBD, there is still much they do not know
about it. That seems a little odd since they are claiming to have little
knowledge about a compound that has been in existence for close to 5000 years.
The first documented use of a cannabis derived medicine
dates back to 2737 B.C. when the Chinese Emperor, Sheng Nung used cannabis
infused tea to aid with a variety of reported ailments including memory loss,
malaria, rheumatism and gout.
In 1839, Irish physician and researcher William B.
O’Shaughnessey published a study which investigated the plants therapeutic
effects and started to consider it for possible medical applications. In his
study, which was then considered quite controversial, O’Shaughnessey explored
the effects of cannabis and described its potential as an anesthetic. This also
opened the door to an unknown compound that would later be known as
cannabinoids which were discovered almost a hundred years later in 1940 by
British Chemist Robert S. Cahn.
In 1992, at the Hebrew University in Jerusalem, Dr. Lumir Hanus
along with American researcher Dr. William Devane discovered the
endocannabinoid anandamide. The same team later discovered a second major
endocannabinoid 2-anachidonoyglycerol (2-AG) and in addition a less known one
known as endocannabinoids, homo-gamma-lineleoul ethanolamide, docosatetraenoul
ethanolamide (DEA) and noladen ether (2-AGE). These are a handful of
endocannabinoids that have been identified along with G-coupled protein
receptors that interact with these cannabinoids in the creation of metabolic
pathways of phyto-cannabinoids and endocannabinoids which are a molecular
signaling system within the body that regulates a variety of biological
functions. The “system” was named the endocannabinoid system and is responsible
for maintaining a stable environment, in spite of the external environment,
thereby maintaining the body’s homeostasis or balance. The thought being that,
by stimulating and supporting your endocannabinoid system, one can experience
relief from a variety of illnesses and conditions.
So now, you have a little better idea as to how long these
compounds have been in use and tested by a broad range of scientists and
researchers throughout the world. By that it begs to question why the FDA would
say they are reluctant to recognize CBD’s healing properties because there has
still been very little formal testing conducted. How do they consider 5000
years of study a little?
What we are asking is the FDA to do is to accelerate the
development of a serious program to help manage the CBD “craze” by establishing
the testing guidelines and minimum criteria to which all manufacturers must
adhere. You have a flood of CBD products being released into the marketplace
and all sorts of claims being made by those trying to sell them. Simply issuing
warning letters and expecting banks and social media to act as the “gate
keepers” does little to solve the problem and may in fact be hindering the
progression of drugs and supplements which could not only improve people’s
quality of life but may be a solution to the ever worsening opioid crisis in
our country. The thing is how will we ever know if the governing body, tasked
with the authority of setting the guidelines, appears to be under the control
of those that are in a position to benefit most by their inaction?
These are some of the questions that need to be asked and
answered by those responsible for moving this potential “miracle” from the
wild-west to the future. Please, get the word out to your representatives in
congress and implore them to put pressure on the FDA to do their job.
With that, thanks for reading this week’s blog and stay
healthy…CBD Doc.
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