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Drug Free Kids Canada Position Regarding Legalization of Recreational Cannabis
Background
DFK’s mission is and has always been to help reduce the use of illicit and inherently dangerous drugs and to reduce/eliminate the use of prescribed drugs for non-‐medicinal purposes.
The key landscape change that bears on DFK’s mission is the Canadian government’s stated commitment to deliver on an election promise to legalize the use of marijuana. This promise appears to extend beyond the medical use of marijuana and will likely include personal consumption. Legalization of marijuana use should, under no circumstances, be regarded as an invitation to use marijuana. The risks from the consumption or use of marijuana remain and may well be increased, if public consumption expands. Legalization of marijuana is simply recognition that the current laws prohibiting such use have failed to accomplish their purpose, have proven to be ruinously burdensome and expensive, and have enabled organized crime to generate enormous profits.
While not retreating from its mission, such legalization will have an impact on the manner in which the use of marijuana should be assessed by DFK, since the legalization of marijuana effectively moves it from an illicit substance to one that is/will be regulated, not unlike tobacco and alcohol, both of which also have proven negative health and dependency impacts on Canadians.
DFK is not a lobbying organization. It does, however, have an influential and informed platform from which to speak and disseminate facts regarding the use of marijuana that may be of interest to governments, the public at large, media and, in particular, the parents of young Canadians.
Specifically, its mission includes provision of evidence-‐based messages on the risks of drug use and the benefits of a drug-‐free lifestyle – a mission that remains valid under both current law and any future laws that might make recreational use of marijuana legal.
In this respect, DFK has two principal positions: a responsible framework for legalized availability and use of recreational marijuana, and increased emphasis on the need for educational resources for parents who have teenagers who may be at risk. DFK believes that the regulatory framework should be established in a responsible and thorough manner prior to its release, rather than proceeding to publish something that is known in advance to require modification.
Responsible Regulatory Framework
DFK has reviewed the ongoing developing regulatory frameworks in the United States, examined publications prepared by the Canadian Centre on Substance Abuse and has consulted its Advisory Council, which includes medical experts (such as clinicians and researchers), law enforcement, adolescent addiction counsellors, family health counsellors, psychologists, pharmacists and other NGOs.
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Based on this review, DFK considers that a responsible regulatory framework for legalized marijuana should include at least the following elements:
• Evidence-‐based independent research on
o the impact of marijuana use on the developing brain for purposes of determining the minimum age for use of marijuana
o the impact of potency levels of THC for purposes of understanding risks associated with certain THC concentrations in order to inform regulations on levels
o the effects and extent of the use of marijuana, along with trends in the use of other drugs (e.g., cocaine, heroin, ecstasy, etc.)
o national annual consumption studies that include the student population o drug-‐impaired driving and other criminal behaviours o addiction trajectories o baseline data to be established for all population segments involving the legalization of
recreational use of marijuana o establishing appropriate limits (including consideration of zero tolerance) for the
presence of a drug while driving
• Channels of distribution
o restriction of Big Industries (e.g., tobacco, alcohol) o equal or greater restriction of advertising and promotion of use, as in the case of
tobacco o restriction (or elimination) of personal cultivation o distribution to be limited to government or licenced outlets o regulation of permissible quantities to be purchased (e.g., >1 oz.)
• Penalties and controls
o minimum age limits for consumption and possession to be established on the basis of scientific research, as opposed to simply following age limits established for alcohol/tobacco
o clear requirements for producers and distributors of marijuana with respect to maximum THC content, other components, quality control, product testing, record keeping, etc.
o once appropriate impairment levels are set, same penalties as for alcohol-‐impaired driving
o controls for sale or supply to those younger than the minimum age limits to be established, combined with severe penalties for non-‐licensed distributors
o regulation of packaging, advertising, internet and mail order sales
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o public consumption to be prohibited, more than for tobacco and alcohol, including significant penalties for public consumption
o edible product should not be permitted, unless there are strict controls on production (THC levels), plus childproof packaging
o equivalent or greater product testing and risk assessment requirements for medical use marijuana/marijuana products as with other medicines made available to and approved for use by Canadians
o equivalent or greater product testing and risk assessment requirements for personal use marijuana/marijuana products as with other consumer products made available to Canadians
o explicit product liability legislation for marijuana, placing product health impact liability on producers and distributors of marijuana
o significant penalties for illicit sales
Drug and Addiction Treatment Education Programs
Legalization of marijuana use will add increased risk of usage, damage and addiction by kids whose brains are still developing. Informing youth (and their parents) of the risks of marijuana use will require the development of education programs and teaching materials that will be easily available and targeted to the special circumstances surrounding marijuana use, such as
o special emphasis on children and those under the legal age limit established for marijuana, as well as their parents
o smoking in the presence of kids to be discouraged o consumption of edibles o implementation of a levy on all marijuana sales (similar to the GST or other value-‐added
taxes and levies) which is ear-‐marked for drug education and long-‐term addiction treatment programs/facilities, both publicly and privately run
o further investment in drugged driving education (similar to what DFK has already started)
o education on acceptable social use of marijuana products