Letter to the Editor: Proposed Rule Changes Could Cripple Medical Cannabis Program

Los Alamos

New Mexico’s Medical Cannabis Program permits people who suffer from certain debilitating medical conditions, and who otherwise qualify, to legally possess and use marijuana (cannabis).

These debilitating conditions include cancer, multiple sclerosis, epilepsy, and post-traumatic stress disorder (PTSD)–a condition that hits veterans especially often. (The VA estimates that PTSD afflicts almost 31 percent of Vietnam veterans, 10 percent of Desert Storm veterans, 11 percent of Afghan war veterans, and 20 percent of Iraqi war veterans.)

The Medical Cannabis Program (MCP) is administered and regulated by the New Mexico Department of Health (DOH). DOH recently proposed changing the rules that govern the program. The proposed changes are extensive; some are very restrictive; some are impossible to comply with. They will cripple the program, or kill it. DOH plans to implement the new regulations next month.

Why is the DOH making these proposals? The department says that the changes will improve and strengthen the program, and some do sound positive. Nevertheless, the proposals as actually written are highly negative. They must be stopped.

Here is an example. DOH proposes to change the rules and fees that apply to licensed growers of medical cannabis. The department says this will increase supply. This certainly sounds good, as the current supply is chronically inadequate, but the proposed regulations will only make the shortage worse. DOH says that supply will increase because growers will be permitted to keep more productive plants than they can now. Let’s see.

Suppose, under the proposed regulations, a grower decides to keep the maximum permitted number of productive plants. The grower’s annual license fee will double or triple from its current amount, but the maximum permitted number of productive plants will increase by only perhaps 50 percent.

Would a grower choose to double or triple a significant cost of production in order to increase the productive agent by only a fraction? It seems unlikely. DOH’s proposal is poorly conceived, grounded perhaps on an uninformed view of how growers actually work. It is likely to disrupt the current system of production and reduce supply yet further.

Here is another example. DOH proposes mandatory testing of all medical cannabis products. On its face this seems highly desirable. Unfortunately, DOH proposes tests and protocols that are vastly excessive. They are far beyond what is necessary to assure product safety and quality. They are so demanding and expensive that growers will be unable to comply.

DOH proposes a great many changes in addition to these two. These changes threaten to disrupt or destroy a program that works well already. Thanks to the MCP, many of our veterans and thousands of other New Mexicans can find some relief from their constant suffering. These people are not helped by other medications. They have nowhere else to turn.


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