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Commentary
Counterblast to the I.O.M.
Peter Webster
Copyright 1999 International Journal of Drug Policy
Elsevier Science Publishers
In mid-March of this year, the report of the U.S. Institute of Medicine(Joy
et al., 1999) on the topic of 'medical marijuana' was finallypublished,
having been commissioned by the U.S. Drug Czar and his WhiteHouse Office
of National Drug Control Policy in January 1997. Thewidespread and growing
use of marijuana for medicinal purposes and thepassage of legislation
in several U.S. states recognising patients' rightsto use, and physicians'
rights to recommend marijuana had been countered bythe Drug Czar's denunciation
of medical marijuana as "a cruel hoax,""Cheech and Chong
medicine," and a "Trojan horse" for across-the-boardlegalisation
of drugs. A review of the scientific evidence on marijuana byan organisation
with irreproachable credentials was thus called for,although at the
time - January 1997 - the request to the I.O.M. was widelyseen as merely
a stalling tactic by an unremittingly prohibitionist federalgovernment
pressed to divert attention from the recent successes of thedrug policy
reform movement.
The I.O.M. document, summarising a purportedly scientific and thoroughreview
of all available evidence, left no doubt that marijuana - or atleast
some of its active ingredients - showed significant promise forcertain
conditions: "For [some] patients...cannabinoid drugs might offerbroad
spectrum relief not found in any other single medication." Examinedfrom
the point of view of the U.S. federal government's long-standingprohibitionist
policies, however, the report's findings were not consideredsignificant
enough to justify any change of direction: Even for theterminally ill
and severely afflicted who find marijuana of some use orcomfort, harassment,
arrest, seizure of assets, and imprisonment are stilldeemed appropriate
federal action for 'sending the right message' about the'great danger
to society' posed by the weed, medicinal or not. The stark'message'
that the Feds were sending was unmistakably loud and clear: In1997 there
were three-quarters of a million marijuana arrests in the U.S.,90 percent
of them for simple possession. Even larger figures are expectedfor 1998
and 1999. The I.O.M. study shunned consideration of the largersocial
questions: "Can marijuana relieve health problems? Is it safe formedical
use? Those straightforward questions are embedded in a web ofsocial
concerns, most of which lie outside the scope of this report."
The I.O.M. report went on to recommend further extensive research on
themedical use of cannabis: "Recommendation 1: Research should
continue intothe physiological effects of synthetic and plant-derived
cannabinoids andthe natural function of cannabinoids found in the body."
Publicly, atleast, the U.S. federal government agrees. But marijuana
research,according to some top scientists, has been actively thwarted
by the U.S.government for decades, and there has been little if any
loosening of thestringent requirements for approval of proposed research
projects. As anexample of recent stonewalling, Rick Doblin of the MultidisciplinaryAssociation
for Psychedelic Studies writes,
"Obtaining approval for MAPS-sponsored medical marijuana research
has...been difficult. As reported in the last Bulletin, the NationalInstitutes
of Health (NIH) rejected for the second time the grantapplication of
Dr. Ethan Russo, U. of Montana, for a study of the use ofsmoked marijuana
in people whose migraines are not successfully treated bycurrently available
medicines. The NIH letter explaining the rationale forits decision arrived
well after the news of the rejection of the grant. TheNIH reviewers
focused in large part on an issue that cannot be resolved andthat has
nothing to do with the scientific merit of the protocol design,the supposed
need for preliminary data to supplement extensive historicaland anecdotal
reports. It is difficult to imagine that the NIH reviewersdidn't realize
that it is impossible to obtain permission to conductpreliminary studies,
or didn't know that the NIH Expert Committee on theMedical Uses of Marijuana
recommended full-scale trials. Despite theClinton Administration rhetoric
in favor of medical marijuana research, thereality is continued obstructionism.
In a victory for the opponents ofmedical marijuana, Dr. Russo has decided
that it is futile to reapply toNIH a third time. The Clinton Administration
position that the controversyover the medical use of marijuana should
be resolved through scientificresearch rather than at the ballot box
will remain dishonest and deceptiveuntil good-faith efforts to conduct
research, such as attempted by Dr.Russo and supported by MAPS, are permitted
to proceed." (Doblin, 1999)
Indeed, while marijuana officially remains a schedule I drug "with
highpotential for abuse and no accepted medical use" it is difficult
to see howany U.S. research agenda could attain the necessary freedom
from corruptingpolitical imperatives rooted deep in moralistic and religious
convictions.Under such pressure, what little research as has been allowed
over theyears has been largely directed at supporting prohibitionist
policy andprejudice, and there is little sign that the tendency will
improve in thenear-term, the I.O.M. recommendation notwithstanding.
The lack of adequate research uncontaminated by ideology, especially
withregard to understanding the illegal 'recreational' use of marijuana,
has ofcourse permitted the long-standing demonisation of cannabis and
thedismissal of claims for its utility and safety as mere 'anecdotal
evidence'of little or no use as 'scientific proof.' Thus the I.O.M.
report could'safely ignore' not only sociological concerns but a vast
body of commonknowledge about cannabis that remains 'illegitimate' simply
by virtue ofthe illegality and demonisation of 'the evil weed,' and
use what littlegovernment-approved research as existed to disguise,
more than reveal, thetrue medical and social potentials of cannabis.
The facts that were thusignored or discredited by the report, as well
as the objections to themedical use of whole smoked cannabis presented
there, reveal that to asignificant extent the essential substance of
the I.O.M. report is ideologydressed up as science. When social and
scientific concerns are asinterfused as they are today concerning medical
marijuana and the largerissue of substance prohibition in general -
especially in view of theoverwhelming evidence that prohibitions are
invariably self-defeating andin the long run may amount to crimes against
humanity - no study whichrejects important evidence as 'anecdotal' and
'outside its scope' will betruly objective, nor will it resolve, but
instead perpetuate the problemsit has been commissioned to clarify.
Amid all the calls for exactingscientific evidence for the efficacy
and safety of the medical use ofmarijuana, where are the equally stringent
requirements for scientificevidence which proves the merit of current
repressive prohibitionistpolicy? Much testimony that would lead to wide-ranging
changes inapproaches to drug use is dismissed as "anecdotal",
yet the evidence thatputting drug users in prison has any benefit to
society falls short even ofthe anecdotal, indeed, the entire concept
and practice of drug prohibitionseems based primarily on misplaced moralism,
lies, racism and historicalerrors. Why should science require far more
stringent evidence forrecommending the reversal of bad drug policy than
for supporting its continuation?
Let us evaluate certain aspects of the I.O.M report, and especially
itsstated objections to the use of whole 'crude' smoked marijuana as
amedicinal product, from a position less beholden to U.S. prohibitionistconvictions
than mainstream institutions today appear capable of. To itssmall credit,
the I.O.M. Report did stress the lack of evidence thatmarijuana was
significantly 'addictive,' or a 'gateway' drug that in itselfenticed
users to graduate to 'harder drugs,' ("it is the legal status ofmarijuana
that makes it a gateway drug"), and also found no convincingevidence
that medical availability of cannabis would stimulate illegal'recreational'
use of the drug. These were not revolutionary admissionshowever: considering
the wealth of evidence showing such suspicions asproducts of 'reefer
madness' fanaticism, the I.O.M. would have severelytarnished its credibility
had it stated otherwise. But the superficiallygenerous admission of
the obvious may often be a way to disguise a partisanevaluation of the
controversial.
"Because marijuana is a crude THC delivery system that also deliversharmful
substances, smoked marijuana should generally not be recommendedfor
medical use. Nonetheless, marijuana is widely used by certain patientgroups,
which raises both safety and efficacy issues," states the I.O.M.Report.
"If there is any future for marijuana as a medicine, it lies in
itsisolated components, the cannabinoids and their synthetic derivatives.""Marijuana's
future as a medicine does not involve smoking," insisted Dr.Stanley
Watson, a neuroscientist and substance-abuse researcher from theUniversity
of Michigan and co-author of the report.
Despite the authors' insistence that scientific rigor was their rule,embedded
in the above quotes and in the substance of the Report are valuejudgements
and prejudices, and we can discern the way in which scientificobjectivity
has fallen prey to moralistic conviction by way of thefollowing arguments.
The principal stated and implied conclusions of thereport in objection
to the use of smoked marijuana - which reflect currentmedical and scientific
paradigms - need some careful examination andrebuttal. Among those conclusions
and paradigms are:
o Smoking "delivers harmful substances" and is dangerous to
health andunsuitable as a drug delivery method. No other drugs are smoked.o
An efficient medicinal product should ideally consist of a singlepurified
substance. When herbal remedies or mixtures are found to be ofvalue,
research then isolates the active ingredient and industry produces astandardised
and scientifically-tested pharmacological product.o Whole ('crude')
marijuana contains variable and uncertain amounts ofactive ingredients,
as well as a range of inert and inactive substances.The 'efficiency'
of 'crude' marijuana is thus uncertain.o Certain substances and activities
are 'harmful'. "Marijuana is not acompletely benign substance,"
the report stresses.
Prohibitionists and government spokesmen seized upon the objection tosmoking
as a route for the administration of a therapeutic drug despite thereport's
recommendation that smoking might be an interim solution forcertain
patients and through research a "step towards the possibledevelopment
of nonsmoked, rapid-onset cannabinoid delivery systems."Ideologues
routinely confuse themselves with their own convictions, evenwhen the
facts are imposing, so we might excuse them from parroting theanti-smoking
conclusions of the I.O.M. Report. But scientists should beashamed for
jumping on the anti-smoke bandwagon without a moment ofreflection. True,
in the modern pharmacopoeia, there are no medicinalsubstances delivered
by smoking, and in the absence of evidence to thecontrary such a route
of administration might be avoided. But the argumentthat smoking is
an inappropriate drug delivery method because no otherdrugs are administered
that way is logically weak, at least insofar asuniqueness of method
is concerned. Before the hypodermic syringe wasinvented no drugs were
administered by injection, but with the advent ofthe method there was
no great movement by government and medicalauthorities denouncing injection
merely on the basis of novelty, since thedelivery method was found to
be effective. (And presumably, drug injectionin those days, with the
primitive equipment and minimal understanding ofinfections prevalent,
involved significant risk of complications.)
With marijuana, however, the nature and effects of the drug make itssmoking
far more effective and acceptable for patients than oralpreparations,
for problems of solubility make absorption by the oral routefar too
dependent on the presence of fats. Indeed, for the minority ofmedical
users who are averse to smoking, marijuana may be prepared into'brownies'
or other fatty pastries, and as a starting point in the recipe,the cannabis
is usually heated in butter or other oil to dissolve anddisperse the
active cannabinoids. Absorption in the gut is then far morereliable
and predictable, if still unduly delayed.
In addition, all medical marijuana users stress the importance ofself-titration
of the drug, and insist that smoking is by far the bestexisting route
for implementing this technique, oral ingestion resulting inlittle ability
to control the onset of effect or the size of dose.Presumably, similar
and additional concerns would make an injected cannabispreparation both
impractical and unacceptable to the great majority ofpatients. Obviously,
the primary consideration of a drug/delivery-methodcombination is that
it should work, and if no other delivery method can befound superior,
it would be absurd to reject the 'novel' or unusual solelyon the basis
of its curiosity. And it must be added that in the case ofmarijuana,
the unusual chemical, biological, and medicinal qualities of thedrug
make it unlike any other in the pharmacopoeia, thus the 'novel' routeof
administration must be given much leeway until extensive clinical trialshave
definitively shown that a safer and equally patient-acceptable routeis
in every way equivalent or superior to smoking. Thus, at least for thepresent,
the peculiarities of marijuana and its use for various medicalapplications
leave smoking as the superior route of administration, despiteany drawbacks.
"Although marijuana smoke delivers THC and other cannabinoids to
the body,it also delivers harmful substances, including most of those
found intobacco smoke." The fallacy of believing that 'harm' and
'risk' (and even'safety') are not entirely relative to one's premises
has beenphilosophically explored since time immemorium. Likewise, labelling
asubstance as "not completely benign" tells us nothing. And
calling a meresubstance 'harmful' without reference to how it is used
nor concerns ofrelativity or value judgement should be an intellectual
trap scrupulouslyavoided by scientists, at the least. The contention
that marijuana smokedelivers "most of the harmful [sic] substances...found
in tobacco smoke" isa howler, however, and produces the suspicion
that lapses of scientificrigor by the I.O.M. were intentional, allowing
the report to legitimate thecontinuing and very unscientific status
quo of marijuana prohibition.Paradoxically, even tobacco smoke itself
does not necessarily deliver allthe harmful substances "found in
tobacco smoke," as we can ascertain fromrecent research indicating
that bacteria in tobacco leaf that producenitrosamines - the chemicals
thought to be the biggest cancer hazard intobacco smoke - can easily
be killed to produce a potentially far safertobacco. (Day, 1999) Does
marijuana contain such bacteria-producednitrosamines? The I.O.M. Report
does not say, nor do the references cited.Certainly marijuana does not
contain nicotine, nor does it containtobacco-specific bio-accumulated
radionuclides such as Polonium210, analpha-emitter also suspected of
being highly carcinogenic to lung tissue.And what about other key tobacco
toxins such as 4-aminobiphenyl? Are theyto be found in marijuana?
True, burning one leaf or another is likely to produce hundreds ofpractically
identical combustion products, so that a list of chemicalsfound in tobacco
smoke vs. marijuana smoke might seem superficiallyequivalent. But if
even one or two of the principal disease-producingsubstances in tobacco
smoke are absent, or even significantly reduced inmarijuana smoke, the
contention that the two smokes deliver equivalent'harmful substances'
is merely capitalising on current anti-tobaccohysteria in the attempt
to denounce marijuana smoking when thepreponderance of evidence indicates
that smoked marijuana may not be acarcinogen at all. In fact, a United
Press International article fromJanuary 30, 1997 reports that,
"The U.S. federal government has failed to make public its own
1994 studythat undercuts its position that marijuana is carcinogenic
- a $2 millionstudy by the National Toxicology Program. The program's
deputy director,John Bucher says the study found absolutely no evidence
of cancer. In fact,animals that received THC had fewer cancers."
Certainly I do not propose that smoking is 'harmless' when indulged
in toexcess, and tobacco smoking is renowned for excess. The effect
of nicotineis so short-lived that most tobacco habitu=E9s require a
new dose everyhalf-hour. And surely, marijuana when burned produces
carbon monoxide and afew more or less carcinogenic combustion products
as do cigarettes,fireplace logs, power stations, and barbecue fuel.
But it would not bestretching credulity to argue that mankind has developed
a fairly robustresistance to breathing smoke for at least part of the
day, having livedfor 99% of his time on earth in dwellings with open
hearths. In thesedwellings even the pregnant and the new-born would
breathe all sorts ofcombustion products. Natural selection must certainly
have acted to producesome immunity to smoke inhalation, or it would
now be impossible to live inmany of our major cities.
The comparison of the daily use of a few puffs of medical marijuana
andliving in London or Los Angeles must surely reveal the latter the
moredangerous for the respiratory passages. This must certainly be the
casewhen the quantity and frequency of marijuana use required for a
givenapplication such as anti-nausea is low and the variety of cannabis
employedone of the potent high-quality strains favoured by users, so
that the smokeintake is very modest compared with the round-the-clock
breathing ofpolluted air. There are thousands of deaths yearly in many
major citiesdirectly caused by air polluted with a wide range of carcinogens
andirritants, (in the U.K., microparticulates from diesel exhaust alone
arethought to kill 10,000 people a year), yet no one has identified
a singledeath or cancer caused by marijuana smoking. Why should living
in pollutedair seem an acceptable, even disregarded risk while light
to moderatemedical marijuana smoking be denounced as unconscionable?
Extending the argument into sacred pharmacological territory, it cannot
beignored that all medical preparations have side-effects. Even an aspirinhas
potentially dangerous and common, occasionally fatal side-effects, andin
the case of aspirin as for smoked marijuana and many other drugs, IT
ISTHE ROUTE OF ADMINISTRATION WHICH LEADS TO THE POTENTIALLY THREATENING
SIDEEFFECTS! The oral method of aspirin use leads to possibly severe
and notuncommon gastro-intestinal consequences having nothing to do
with thepurpose of the drug nor its targeted site in the body. The smoked
method ofusing medical marijuana may lead to some as yet unproved harm
to therespiratory passages. There is simply no practical, logical, or
medicalargument which can justify risking stomach lesions taking aspirin
for itsneurological effects while denouncing as prohibitive the risk
of possiblelung damage smoking medical marijuana for effective therapeutic
purposes.Is lung tissue more sacred than the stomach lining? We use
warning labelson the product's package to alert the physician and user
of side-effects,not logical fallacy disguised as medical truth, as is
now being done formarijuana.
To proceed yet further with standard pharmacological tenets, no medicine,even
a totally purified single chemical entity, affects all persons thesame
or to an equal degree, nor will it work equally at all times for thesame
person. Sometimes an aspirin works fine, sometimes even several dosesfail
to deliver any analgesia whatsoever. The idea that a single purifiedsubstance
is the summum bonum in pharmacology, which the IOM reportsupports by
implication, is rendered uncertain both by this non-specificityargument
and the fact that custom mixtures of drugs sometimes prove thebest for
not a few individual cases. In the case of a simple disease orcondition
such as an infection, a single purified substance is oftendesirable,
such as a condition-specific antibiotic. It is no doubt throughthe successes
of the treatment of such well-defined conditions that the'single purified
substance paradigm' has attained its current prominence,but there are
many conditions which are complex, involving several aspectsof health
and multiple bodily systems including psychologicalmanifestations. The
relief of pain and other conditions for which marijuanahas been found
useful fall into the category of being multiple-causation,complex physical
and psychological syndromes, and positing that a singlepharmaceutical
product MUST be the best remedy is an invalid extension ofthe 'simple-disease/simple
cure' paradigm. It is obvious to medicalmarijuana users and to a growing
number of physicians and scientists thatstrict reductionism in medical
treatment is severely limiting, and that thesynergistic effects of a
drug like marijuana on several bodily systems aswell as positive psychological
effects combine to produce a wide-spectrummedicinal potential that we
should in principle not expect of a singlepurified substance.
Objecting to the proven efficacy of marijuana use on the basis that
thedrug contains a complex and varying mixture of substances might be
a validcomplaint if the pharmaceutical houses had already producedcondition-specific
cannabinoid preparations therapeutically equal to wholesmoked cannabis.
The only pharmaceutical preparation that science hasbrought us so far
is Marinol, consisting of only one active ingredient(synthetic THC)
dissolved in sesame oil to be taken orally, a preparationwhich few patients
or physicians find as useful or effective as smokedmarijuana. It is
possible that the chemistry and pharmacology of cannabisis so complex
that it will require decades of research to produce medicinestailor-made
for conditions which are suitable for treatment right now withvarious
strains of whole cannabis, and we can imagine that the price tag ofthose
future researched-for-decades preparations will result in easily- andcheaply-grown
whole cannabis still being the intelligent choice for many.With respect
to cannabis at least, much of the pharmacological argumentagainst 'herbal
medicine' is a symptom of the dollar-signs-in-the-eyessyndrome.
There is a further possible factor complicating the argument against
smokedcannabis: burning the substance in a certain way may actually
producealtered cannabinoids which are therapeutically useful. It is
known, forexample, that cannabinoids in fresh green cannabis are to
some degreecarboxylated and largely inactive, and that curing and drying,
smoking, (orheating in butter as mentioned above) de-carboxylates and
thus activatesthe drug. The hypothesis that smoking itself makes cannabis
moretherapeutically active cannot be ruled out but must be thoroughly
tested.Thus medicinal cannabis preparations taken with yet-to-be-developedinhalers
mentioned in the I.O.M. document may still not completelyreproduce the
effect of smoked whole cannabis. Let research on vaporisersand inhalers
begin in earnest (and here the I.O.M. report notes that suchdelivery
methods might not be perfected for many years). But for the timebeing,
and as has been noted by many, asking patients in need to wait yearsfor
a substitute for what they already have that works, or go to prison
andforfeit their homes for insisting, is a bit extreme!
The argument that whole cannabis supplies unknown and uncertain doses
ofactive products is flawed in another respect, and here it is the smokeddelivery
method itself which supplies the rebuttal. As noted above, medicalmarijuana
users insist on the importance of self-titration foradministering the
drug, so as to obtain the desired level of relief ofsymptoms while avoiding
taking a dose which produces excess psychologicaleffects or renders
them temporarily overwhelmed, a frequent complaint withthe oral preparation
Marinol. The onset of action of the drug when smokedis particularly
rapid, so that no matter what the strength of the wholecannabis, or
its particular blend of active and inert ingredients, a smokermay arrive
at his required dose within a few minutes solely on the basis ofperceived
desired effect. Thus may he also select among varieties of wholecannabis
for the best perceived remedy for his particular condition.
And if there are inert and ineffective substances in the collection
of "400chemicals in marijuana," so what? Read the label of
any medical preparationand see: 'active ingredients,' and then 'inert
ingredients.' No one wouldinsist that the food we eat be completely
analysed and consist only ofingredients 'recognised by science' to have
benefit to the body. Indeed,many foodstuffs contain toxins, carcinogens,
and irrelevant substances. Anda recommendation to eat only purified
vitamins, nutrients, minerals andsterile bulking agents would be considered
absurd by all except thecompanies which intended to market such products.
The pharmaceutical andmedical paradigms which will not allow medicines
to be at all analogous tofoods in their application and benefit is certainly
too narrow, and shouldbe relaxed. And in the case of medical marijuana
and other herbalpreparations whose effectiveness depends on their wide-spectrum
influenceon both body and mind, current pharmaceutical paradigms become
anabsurdity. Let research show which ingredients in natural herbs areeffective,
just as research has shown which nutrients in food are requiredfor various
aspects of health. But let us not get sucked into approving theblinkered
profit motives of pharmaceutical companies by supporting thedictum that
'acceptable medicine' may not be a natural plant or combinationof plants,
especially when the desired effect is relief of pain andpsychological
distress or other objectives for which the subjectiveevaluation of efficacy
by the patient must reign supreme.
The onus is on science, industry and government to improve therapy,
even(need I say it?) at the sacrifice of profits and prestige, and not
toattempt to remove currently effective if imperfect therapy from the
scene(and what therapy has been proved perfect?). Current arguments
againstcannabis are morality dressed up as science, and (to quote the
Drug Czar)"a cruel hoax."
Peter Webstervignes@monaco.mc
ReferencesDay, Michael. The Lesser Of Two Evils: If people can't stop
smoking, the next best thing is to make tobacco less harmful. New Scientist,
May 8, 1999.
Doblin, Rick. Letter from Rick Doblin, MAPS President. MultidisciplinaryAssociation
for Psychedelic Studies, Bulletin 1999, Vol IX, No. 1, p.3.
Joy, J.E., et al. Marijuana and Medicine: Assessing the Science Base.
JanetE. Joy, Stanley J. Watson, Jr., and John A. Benson, Jr., Editors,
Divisionof Neuroscience and Behavioral Health, Institute Of Medicine,
NationalAcademy Press, Washington, D.C. 1999.
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