A CLEAR Response To the Liberal Democrats’ Proposals For Cannabis Regulation.
CLEAR welcomes the Liberal Democrats’ proposals which can be seen here. We set out below a few comments which we intend to be constructive.
We represent more than 600,000 people who support cannabis law reform. Our own publication, ‘How to Regulate Cannabis in Britain’ is now in its second edition.
It is based on independent, expert research which we commissioned from the Independent Drug Monitoring Unit, published as ‘Taxing the UK Cannabis Market’.
Comments on ‘A framework for a regulated market for cannabis in the UK’
1. We support a cautious approach and agree that it is better to start with stricter regulation that could, based on experience, be relaxed at a later date if appropriate.
Spectrum of Cannabis Policy
We reject the diagram ‘Exploring a spectrum of options for regulating cannabis’ which paints an inaccurate picture of the effects of a legal market. Evidence from all jurisdictions that have implemented reform does not support the equivalence of ‘social and health harms’ with ‘ultra prohibition’ and ‘commercial production’. It is absolutely clear that legally regulated commercial production is far less harmful than prohibition.
Essentially, instead of a ‘U’ shaped curve, we consider an ‘L’ shaped curve is more accurate.
2. The diagram indicates a fundamental objection to the commercial model implemented in Colorado, Washington and Oregon and the report explicitly rejects the Colorado model in favour of the Uruguay model.
We disagree with this. The Colorado model is a proven success with virtually no downsides. The Uruguay model is still a theory which is yet to be proven in practice. This conclusion in the report is therefore not evidence-based. This suggests that wider political or philosophical considerations have been allowed to trump existing evidence.
3. We are concerned about the undue weight given to restricting commercial enterprise. The UK is not a socialist economy and there is a danger of a ‘nanny-state’ attitude which we cannot support. We repeat the point that it seems wider political or philosophical considerations have been allowed to prevail over actual evidence. There needs to be a balance between a ‘cautious approach’ as in 1. above and over-regulation which will only result in a continuing criminal market. The UK is a market economy and if the legal market is too strict and rigid, the illegal market will flourish.
4. We have very grave concerns about the cannabis social club (CSC) model which provides significant opportunity for the corruption of those involved into major criminal enterprises with exploitation of both workers and customers. The establishment of such ‘clubs’ is entirely unnecessary given the other more controllable methods of supply and will only lead to diversion and perhaps active marketing of excessive production through criminal networks. In other words, CSCs are a golden opportunity for the emergence of ‘drug pushers’ and they undermine the whole purpose of cautious regulation.
5. We regard the recommendation not to permit the production and marketing of ‘edibles’ as an error. If the other recommendations making raw herbal cannabis legally available are implemented then this will inevitably lead to the production and marketing of unregulated ‘edibles’, undermining the whole purpose of regulation. Far better to learn from the mistakes already made in excessively potent ‘edible’ products and introduce appropriate regulations with reduced dosages.
If anything, ‘edibles’ need regulation far more urgently than the raw product because of the potential for very unpleasant overdosing. To abrogate responsibility for this is an extremely unwise proposal and inconsistent with the whole basis for a regulated market.
6. We would encourage a more positive and supportive approach to enable producer countries such as Morocco, the Lebanon, Pakistan and Afghanistan to supply varieties of cannabis resin and hashish. Encouraging such trade under strict regulation will further undermine criminal activity and offers great potential for better relations and positive ‘soft power’ influence on these countries. We recognise the difficulties involved in this with regard to the UN conventions but consider it is a prize worth working towards.
7. For the same reasons set out above we consider that a refusal to regulate concentrates and vapouriser products undermines the whole purpose of a regulated market. Vapouriser products are almost certainly going to be an important component of the medical cannabis market. These nettles must be grasped. To avoid them is irresponsible.
8. We would argue for far more emphasis on harm reduction information, particularly about smoking and avoiding mixing cannabis with tobacco. As in 7. above, we would actively promote the choice of vapouriser products.
9. In principle we agree with the proposal for three levels of THC content and for minimum CBD content. However, there is no evidence to support the necessity for CBD content as high as 4%. The evidence suggests that levels of 1% or 2% adequately meet the desirable ‘entourage’ effects of CBD. Furthermore, at these levels, existing strains are available. Little consideration has been given to the practicalities of developing three new strains to meet the THC:CBD ratios proposed. To develop such strains and ensure they are stable and consistent is the work of several years, requiring significant investment and so undermines the ability to implement these proposals in timely fashion.
10. We consider that the ‘plain packaging’ proposal is unnecessarily restrictive in the UK’s market economy. We agree with child proof containers but would recommend that far more emphasis is given to content and harm reduction labelling. There is nothing to be gained from restricting the marketing and commercial enterprise of companies wishing to develop brands and packaging styles within strict regulations.
11. For reasons already set out we consider that the restrictions on exterior and interior retailer environments are oppressive and will be self-defeating. The UK is not accustomed to such overbearing and anti-business regulation. Existing pharmacies do not operate under such heavy restrictions and they make significant use of point-of-sale and merchandising techniques.
Overall, we welcome this document and the proposals it contains. One final point that is of significance is that clearly there was no ‘consumer’ representation on the panel and this is obvious in some of the tone and detail of the report. We recommend that account should be taken of consumer opinion in any future development of the proposals.
Email To My MP On Conduct Of Tory MPs At PMQs.
From: Peter Reynolds
Sent: 09 March 2016 15:00
To: Oliver Letwin
Subject: Conduct of Tory MPs at PMQs
Dear Oliver,
The disgusting behaviour of your colleagues in the House today was shameful. They demean Parliament and our entire political system, not to mention the elected government and, most important of all, our nation.
The spectacle of these pompous buffoons conducting themselves in a manner that would be unacceptable from primary school children is just too much. It appalls me and, I am sure, all decent people throughout the UK. They are pigs rooting in a trough of self-indulgent hypocrisy. Each one of them could do with 24 hours in a cell to contemplate their behaviour which is far worse than some drunken yobbo vomiting in the gutter after a binge drinking session.
That all Cameron can do is smirk makes the whole matter worse. His failure to act makes him the most culpable oaf of all.
Please ensure that my views are communicated to the prime minister, your colleagues in cabinet and other Tory MPs.
This must stop.
Kind regards,
Peter Reynolds
Tim Farron. Another Politician Displays Total Ignorance About Cannabis.
Tim Farron on BBC’s Victoria Derbyshire show
It is truly pathetic to see. Farron clearly understands the huge harm caused by cannabis prohibition but doesn’t have the knowledge, the courage or the integrity to speak the truth. Instead he panders to to the scaremongers and says:
“Cannabis causes psychosis”
“Cannabis is dangerous”
“People who use cannabis have a health problem”
“Cannabis is a bad thing”
The Liberal Democrat’s report ‘A framework for a regulated market for cannabis in the UK: Recommendations from an expert panel’ is a re-hash of Transform’s ‘Blueprint’ and its work on a socialist model of cannabis regulation in Uruguay. It denigrates the highly successful commercial model introduced in Colorado and follows Transform’s evidence-free exaggeration of the harms of cannabis and its determination to impose anti-business controls on a legal cannabis market.
There is no evidence that cannabis causes psychosis. The most that can be said is that in a very small number of genetically-vulnerable people, it may be one of many ‘component causes’.
There is no evidence that cannabis is dangerous. The most that can be said is that it does have the potential for harm if used by children, to excess, irresponsibly or by a tiny group of people who may have an allergic reaction. If you describe cannabis as dangerous then you have to describe peanuts, aspirin and hay fever remedies as more dangerous. That’s without even considering comparison with the two most dangerous drugs of all: tobacco and alcohol.
Some people who use cannabis have a health problem and they use cannabis for its remarkable properties to relieve pain and other symptoms. For most people, in moderation, cannabis is actually beneficial, helping to protect against autoimmune conditions, cancer, dementia and other diseases of aging.
For at least 95% of people who use cannabis they do so safely, without any negative consequences and it is a very good thing for their health and wellbeing.
IPCC Upholds CLEAR Appeal Against Avon and Somerset Police.
PC Adge Secker
In January, a cocky, self-publicising cop from Bath published a typically ignorant piece of anti-cannabis scaremongering in his local paper.
PC Adge Secker wrote, amongst other nonsense, that “on average” cannabis plants are worth £1000 each, that “kids as young as 10 get hooked” and that it “…causes psychotic episodes so terrible that people throw themselves off buildings”.
CLEAR submitted a formal complaint to the Professional Standards department of Avon and Somerset Police. We described the article as “full of exaggeration, falsehood and distortion” and said “it is wholly wrong and unprofessional for any police officer to engage in this political debate and amounts to misconduct”.
Avon and Somerset Police rejected our complaint, described it as “fanciful” and refused to record it or investigate it any further. Another article was published in the same local newspaper headlined “Bath police officer’s views on cannabis backed by Avon and Somerset Police”. The editor of the Bath Chronicle, Alex Brown, had already taken sides and supported this police misconduct writing that “any suggestion that he shouldn’t have an opinion and shouldn’t speak out is ridiculous”. But the fact is that police officers are prohibited from engaging in politics for very good reason.
The Independent Police Complaints Commission (IPCC) has now upheld our appeal. Avon and Somerset Police must now record and investigate the complaint.
The IPCC’s decision states “a reasonable person could share your general view that the officer has used his position to publish inaccurate information and enter into a political debate”.
It doesn’t mean we have won but it does mean we have forced this police force to take us seriously. Now PC Secker’s misconduct in telling porkies to support his political opinion will have to be investigated. The rules of evidence will apply and we have a very strong case.
Most important of all, making complaints like this deters other police officers from engaging in such propaganda exercises. CLEAR followers will recall that in 2013 we ran a series of similar complaints against Sir Bernard Hogan-Howe, Commissioner of the Metropolitan Police. In the end our complaints weren’t upheld but Sir Bernard has never since voiced his jaundiced opinions or pushed his anti-cannabis agenda. That is the result we wanted.
CLEAR Evidence For the APPG Medicinal Cannabis Inquiry.
Roland Gyallay-Pap, Peter Reynolds
Yesterday, 2nd March 2016, Roland Gyallay-Pap and Peter Reynolds were called to give evidence at the All Party Parliamentary Group for Drug Policy Reform Inquiry into Regulation of Cannabis for Medicinal Use.
We have already submitted a 15 page written response. Yesterday’s oral hearing was to enable the inquiry to question us in more detail. We cannot publish our written response or go into great detail about yesterday’s hearing until the inquiry has published its own report which is some weeks away yet.
As we arrived at the hearing, Tom Lloyd, ex-chief constable of Cambridgeshire, was waiting to go in so we sat at the back of the committee room and listened to his contribution. Later, after our session, we adjourned to the Westminster Arms for some legal recreational drug use and to swop notes. Tom is a great asset to the campaign and we were able to update each other on the work we are involved in.
The inquiry panel consisted of three MPs and five members of the House of Lords. Roland opened our session with an account of how cannabis oil had helped in the last months of his mother’s life before she died from pancreatic cancer. The whole panel was visibly moved. Baroness Meacher explained that this was not the only such testimony they had heard. Everyone was extremely receptive. A lot of detailed questions were asked about CLEAR’s work and our knowledge of the science, law and best practice involved in medicinal cannabis.
The inquiry’s report will undoubtedly support some reform of the law around medicinal cannabis. Let us hope it will provoke real action from government.
Top Jersey Doctor Misinforms and Misleads On Medicinal Cannabis.
Dr Nigel Minihane
Dr Nigel Minihane is the head of Jersey Primary Care Trust which represents all GPs on the island. Recently he contributed supposedly ‘expert opinion’ to an article in the Jersey Evening Post about someone who had been juicing raw cannabis for therapeutic reasons. His comments demonstrate an ignorance and lack of knowledge which is unacceptable in a doctor in such a senior position. In conjunction with CLEAR members in Jersey, we have submitted a formal complaint.
Jersey Evening Post, 13th February 2016
Dear Sirs,
On behalf of our members in Jersey, we wish to bring a complaint of misconduct against Dr. Nigel Minihane concerning comments attributed to him and published in the Jersey Evening Post on 13th February 2016.
The article in question is attached to this email. The passage we are concerned about is at the very end of the article where Dr Minihane gives false information about a recent drug trial in France which resulted in one death and several people suffered brain damage.
The trial to which Dr Minhane refers was not “of a cannabinoid substance”, it was of an FAAH inhibitor, known as BIA 10-2474. This drug is designed to inhibit the natural degradation of endocannabinoids, leading, it was hoped, to pain relief through modulation of the CB receptor network. It was therefore neither a cannabinoid substance nor cannabis. See: http://www.nature.com/news/scientists-in-the-dark-after-french-clinical-trial-proves-fatal-1.19189
Dr Minihane’s words were therefore inaccurate and misleading and contribute to the prejudice and misunderstanding around the use of cannabis and cannabinoids as medicine. Dr Minihane is, of course, entitled to his opinion but based on his other comments in the article he is clearly very poorly informed on the subject. There is a vast amount of peer reviewed, published evidence which supports the safety and efficacy of cannabis and cannabinoids as medicine. See attached paper ‘Medicinal Cannabis: The Evidence’. Furthermore, it is well established in the evidence that cannabis is physically addictive, with about 9% of regular users developing dependence which is characterised by physical withdrawal symptoms including insomnia, lack of appetite and headache.
We understand that Dr Minihane is head of the Jersey Primary Care Trust and the Jersey Evening Post will have asked him to provide an expert opinion. The information he provided was inaccurate, misleading and reckless. In our view it falls well below the professional standard that one is entitled to expect from any doctor. It is woefully inadequate in the case of a doctor in such a senior position who holds himself out as an expert yet communicates false information to the public through the media.
We would be grateful if you would consider this complaint at your earliest opportunity. We are able to provide oral evidence in support and to suggest witnesses resident in Jersey who endure unnecessary pain and suffering due to medicinal conditions that coud be treated by cannabis if the PCT was properly assessing and considering the evidence.
Yours faithfully
Peter Reynolds
President
The Next Prime Minster Of The UK?
Michael Gove is a decent Tory, a man of principle, extraordinary intelligence and integrity. He is also a master of the media and a man I would vote for.
His decision to campaign for the UK to leave the EU is the right one. Cameron’s self-serving charade of negotiation is at last over. Now we can get on with making the decision. It will be all scaremongering, fear and dire warnings from the ‘In’ campaign but in Michael Gove we have a leader who can inspire the nation towards the courageus and correct decision.
Sadly, he is the sort of man now rare in the Conservative Party but after the chaos and shameful equivocation of the Cameron years, Gove could be the man to rescue Britain.
His values are well demonstrated by the way he has dismantled the authoritarian and brutal jackboot rule imposed by Chris Grayling as Lord Chancellor at the ministry of justice but, in my view, he has a proud record in education as well.
Michael Gove, the libertarian, could be the man to persuade me away from the floundering Liberal Democrats. Now led by a quasi-socialist and more concerned with political correctness than liberalism, I am reluctant to renew my membership. Get us out of the EU, replace Cameron with Gove and I will consider rejoining a liberal, one nation Tory party.
GW Founder And Chairman, Geoffrey Guy, Explains Sativex.
“Most people in our industry said it was impossible to turn cannabis into a prescription medicine. We had to rewrite the rule book. We have the first approval of a plant extract drug in modern history. It has 420 molecules, whereas every other drug has just one.”
Fast Moving Consumer Goods.
Commercialisation Is The Only Sustainable Route To Legalisation.
Talking Cannabis In Parliament.
Norman Lamb MP, Peter Reynolds
Today, 8th February 2016, Peter Reynolds, president of CLEAR, met with Norman Lamb MP, Liberal Democrat spokesperson for health, for an update on the cannabis campaign.
Independent Panel of Experts on Cannabis Regulation.
The Liberal Democrats have set up an independent panel of experts to establish how a legalised market for cannabis could work in the United Kingdom. Norman Lamb wants the panel to look at evidence from Colorado, Washington State and Uruguay, where cannabis has been legalised and to make recommendations for the party to consider in the spring.
As a contribution to the panel’s work, CLEAR has provided the independent study it commissioned in 2011, ‘Taxing the UK Cannabis Market’ which establishes the most comprehensive database on the reality of cannabis in the UK. In addition, The CLEAR Plan, ‘How To Regulate Cannabis in Britain’, builds on this data to propose detailed regulations for exactly how the market could work and contribute a £6.7 billion net gain to the UK exchequer.
Imminent Launch of New Medicinal Cannabis Campaign.
Within the next few days, CLEAR, along with other cannabis law reform groups, will co-operate in the launch of probably the largest campaign for access to medicinal cannabis ever seen in the UK. The time has come when people who are suffering must be given the opportunity to stop their pain with a safe, non-toxic, proven alternative to expensive and debilitating pharmaceutical products. The intransigence of successive UK governments must be overcome and this time a strategy is in place which will work.
The CLEAR publication ‘Medicinal Cannabis:The Evidence’ has received international acclaim and is the most comprehensive and up to date review of the scientific evidence supporting the use of cannabis.
Further Development of Liberal Democrat Drugs Policy.
In 1971, when the Misuse of Drugs Act came into force there were approximately 3,000 problematic drug users in the UK. Today, 45 years on, that figure has risen to around 350,000. Norman Lamb describes this as “one of the greatest public policy disasters of all time”. Today, in a speech about the prison service, David Cameron talked of the need to tackle the most difficult social problems facing Britain. Drug crime and drug addiction is probably the single biggest factor in our prison problems and the consequences of 45 years of failed drugs policy pervades our society. As the Liberal Democrats consider this difficult issue, tackling reform of cannabis policy is the first step.
Peter Reynolds 