2005N-0479 International Drug Scheduling; Convention on Psychotropic Substances; Single Convention on Narcotic Drugs; Butorphanol; Delta-9-tetrahydrocannabinol (Dronabinol); Gamma-Hydroxybutyric Acid; Ketamine;
FDA Comment Number : EC3
Submitter : Ms. Melissa Osterhoudt Date & Time: 12/19/2005 01:12:00
Organization : Ms. Melissa Osterhoudt
Category : International Public Citizen
Issue Areas/Comments
Thank you for taking public ommentary on this topic.
Regarding delta-9-tetrahycrocannabinal or dronabinol otherwise known as marinol: this substance has been shown to be less effective than naturally occuring cannabis for the treatment of currently approved health disorders. In addition, cannabis is making headlines internationally in its effectiveness with RA, Parkinson's, Alzheimers and other diseases. It is time to delete this from schedule III. Marinol has it's own problems: it causes drowsiness and mental fog, whereas naturally occuring cannabis can be administered in more minute doses to allow the effective dose for treattment while preventing too large of a dose which causes the above mentioned symptoms. This allows for greater integration into activities of daily living, which is of utmost importance to those who are currently prescribed Marinol.
Lastly, all prescription drugs are abused, including aspirin. There is no way to prevent, fully, the abuse and misuse of drugs of any kind (even non-psychotropic). Abuse is known to stem from greater societal problems which need to be addressed in order to really get tot he root of the problem. In addition, cannabis in general has been proven to be non-habit forming, it is not physically addictive (unlike non- schedule 3 drugs such as prednisone and others and freely used/abused non-theraputic mind altering substances such as nicotine and alcohol). People abuse food and sex as well. It is really time to get real about this substance for its theraputic effects and non-addictive nature far outweigh the long standing stigma that has shrouded it for so many decades. If we look at Europe's stance of decriminalization we will find far less instances of abuse/addiction and criminal activity around this substance (either as natural cannabis or Marinol). Much of our problems lie in prohibition of this substance in general. People are drawn to that which is denied, like moths to the flame. When this substance (in every form) is no longer demonized and people are no longer presented with 1) factual scientific studies that clearly refute the propaganda 2) factual circumstansial evidence from other countries' successful decriminalization efforts 3) overt PR efforts to continue the ridiculous "war on drugs" which substantially focuses on cannabis despite the above facts; then the glamor of this supposed demon will be reduced and abuse will decrease (as it has in Europe).

Marinol is a step in the right direction, but it is a small and insufficient step. It has side effects that consumers find unpleasant while they are already dealing with horribly unpleasant symptoms. Only those folks who are suffering pretty horribly are prescribed this medication, which is like pulling teeth to get, and then they have to deal with the side effects while the naturally occuring substance is better controlled for administration of the drug and has little to no side effects. This is just plain silly to continue this substance as a Schedule III, it is contributing to untold human suffering and is a huge waste of taxpayer's money.