The public commentary closed Friday March 10th on the draft rules prepared by the Ohio Pharmacy board on Medical Marijuana Forms & Methods of Administration. These rules also defined what constituted a 90 day supply of Medical Marijuana. The Ohio Pharmacy board is the most conservative of the three administrative agencies involved in writing these rules. Ohio Patient Network has sent in a series of comments to the Ohio Pharmacy Board on their proposed draft rules. Below is a summary of our comments.
Limiting the addition of flavors
The draft rules allowed flavors to be added such as menthol and other flavors to mimic various strains. OPN’s submitted rule change read as follows:
Natural terpenes are acceptable in naturally occurring levels, but any artificial flavors, including menthols and any other flavors intended to mimic marijuana strains, are prohibited from all products intended for use in the vaporization of medical marijuana or other products
Someday marijuana medical products will be regulated by the FDA, then added flavors may be acceptable assuming adequate product testing. But not today.
Expnsion on use of vaporization devices
While it is well understood and supported that products like e-cigarettes should not be used by youth, vaporization is a perfectly acceptable method of delivery for children and should not be prohibited. Our suggested rule revision read as follows:
“Vaporization devices must be controlled by parent or guardian of a registered patients under the age of eighteen”.
Expansion of methods of delivery
In a discussion with members of the Pharmacy Board, the use of a nasal spray was brought up and rejected. Marijuana nasal sprays are a very effective means of delivery for young children with seizures conditions. In addition to nasal spray the use of a rectal suppository was suggested. This form may make some culturally uneasy but it has a very high bioavailability or means of transmission of cannabis molecules. OPN suggested adding spray and suppository to the draft rule as follows:
Pursuant to section 3796.06 of the Revised Code approved medical marijuana products include the following forms and routes of administration:
1. Oil, tincture, capsule, tablet, spray, suppository or edible form for oral administration;
(Note plant material was included in the draft rules)
90 Day Supply
The longest and most involved comment involved the limitation on the 90 day supply of plant mater. A series of comparisons was presented using the various state medical marijuana programs. Also included in the comparison was how much the Federal Government is still supplying to the remaining IND Federal patients from the 1990s on a monthly basis. Our recommendation was the following:
Tier I product 90 day limits to be increased to 12 ounces.
We intend to continue pushing for better rules in a patient meeting with the Pharmacy Board soon. Below are links to the Ohio Pharmacy rules as drafted.