The Science Advisory Committee on Health Products Containing Cannabis released their long-awaited report on July 28. Of the information presented, Diplomat Consulting (hereafter referred to as DIplomat) has the following comments:
Other cannabinoids and compounds
Diplomat would have liked to see this report include compounds other than CBD. All non-psychoactive cannabinoids, terpenes, flavonoids, etc. should be reviewed and included in a comprehensive Cannabis Health Product (CHP). In addition, single cannabinoid usage is anecdotally known to be less effective. A review of the entourage effect of compounds is missing. Multiple international jurisdictions have created a more comprehensive minor cannabinoid review and implementation in the last year. Canada should utilize the evolving worldwide regulatory frameworks that have changed since the completion of the Science Advisory Committee work in March 2021, for example, New Zealand’s CHP program and the United States.
Non-prescription availability, age-gating, and pharmacist consultation
While Diplomat commends the recommendation for non-prescription availability of CBD, the recommendation is limited in potency and term length and falls short on specifics. In pharmacies, information on over-the-counter (OTC) vs. behind-the-counter (BTC) availability is missing. Additionally, how products will be age gated and how pharmacist consultations will occur is not available in the report.
Extra labelling and insert requirements
Several of the report recommendations call for extra statements, instructions, warnings, and leaflets specifically related to CBD products. This is a lot of additional information on the existing labelling requirements for cannabis products. This has the potential to keep consumers away from legal avenues if CBD products become overladen with health warnings and statements. Clarity on how this extra information should be presented is key to fully understanding these recommendations.
Consumer education and pharmacist training
We at Diplomat agree with the recommendations for consumer education and pharmacist training. However, the information surrounding education and training is unclear – where funding will come from, how consumers will be educated, and how pharmacists will be trained. The lack of standardized education under development and being implemented, funding for research and innovation, and education of key stakeholders (E.g., College of Family Physicians, Canadian Medical Association, and Canadian Pharmacist Association) has been wanting for cannabis, and the same concerns remain for CBD and CHPs.
Existing research
While this report addresses afflictions in dogs and cats and utilizes that as part of its basis for recommending veterinary access to CBD products, there is no counterpart to that for human afflictions. Diplomat would have liked to see a review on how cannabinoids affect, modulate, or treat human medical conditions.
Future research
Diplomat is very happy to see a recommendation on continued research efforts. We would like to see research dollars currently being collected from the taxation regimes at the Federal and Provincial level to be allocated to Canadian businesses, post-secondary institutions, and researchers to meet and exceed this recommendation. This is a significant failing in the current cannabis regime. Diplomat recommends significant efforts to allocate research to position Canadian CHPs partners and providers for worldwide leadership.
Diplomat will send these comments and more to Health Canada through their consultation period, ending October 6. If you would like to learn more about our further comments and what we intend to submit through consultation, or if you would like to participate and submit comments alongside Diplomat, please reach out to us at hello@diplomatconsulting.com.
