To whom it may concern,
725.032: Registration of Independent Testing Laboratory Agents
(H) Laboratory agents may only test marijuana and marijuana products from a RMD in good standing with the Department.
This amendment limits patient access to an independent testing facility. If a patient purchases product from a dispensary and they feel it is contaminated, you are removing the option to safely test their medicine. If a patient is growing at home, you are removing the option for them to test their own medicine for contamination and potency which also provides them the information they need for dosing just like a patient purchasing from a dispensary knows. It is of the utmost importance that a patient has these options available to them. The variance in cannabis is too broad for a patient to “trust” a product sold at a dispensary and to some that can be putting their life at stake. Contaminants like mold come in spores and propagate, meaning even though product tested can pass, there is still a chance contaminated product gets to a dispensary. Smoking contaminated product such as mold can cause a lung infection or other negative side effects from the mycotoxins mold carries and releases. A patient who is immunodeficient cannot fight off a lung infection as easily and it could be fatal. Independent testing facilities should not be limited to RMD’s as this would restrict public health concerning cannabis testing for quality and accurate dosing information for safe and responsible use.
725.010: Certifying Physician’s Written Certification of a Debilitating Medical Condition for a Qualifying Patient
(I)A certifying healthcare provider physician may determine and certify that a qualifying patient requires an amount of marijuana exceeding other than 110 ounces as a 60-day supply and shall document the amount and the rationale in the medical record and in the written certification. For that qualifying patient, that amount of marijuana constitutes a 60-day supply.
This indicates the supply can be lessened by the healthcare provider. We are already seeing limits at the medical dispensaries. Limiting the amount in any way will push patients into the black market and force them to purchase recreationally where they will be taxed for purchasing medicine because they were limited by the medical marijuana program’s regulations.
From the DEA drug info data sheets:
“Overdose effects
No death from overdose of marijuana has been reported” (
Massachusetts Department of Public Health data:
“In 2015, the estimated rate of unintentional opioid-related overdose deaths was 25.8 deaths per 100,000 residents. The 2015 rate is the highest ever for unintentional opioid overdoses and represents a 32% increase from the rate of 19.5 deaths per 100,000 residents in 2014.” (
Why is cannabis so scrutinized with these facts while the current system is clearly overflowing with bigger problems? When looking at things we are concerned with, opioid overdose deaths are decreasing in states where cannabis is regulated.
National Institute on Drug Abuse:
“They found that the policies, despite their common motivation, have had varied, and sometimes offsetting, indirect effects on substance use and related problems. The most striking finding was that legally protected marijuana dispensaries (LMDs) were associated with lower rates of dependence on prescription opioids, and deaths due to opioid overdose, than would have been expected based on prior trends.” (
Why are we are putting such restrictions on cannabis and putting patients through a system that is complicated and expensive? Cannabis is the safest substance. We have tried the pharmaceuticals. We have tried it and it doesn’t work or the side effects are too great. Cannabis works and is safe and can be used responsibly to improve quality of life when it comes to public health specifically the patients in the medical marijuana program.
We fear what we do not understand, but we have the numbers, we have statistics, and we have facts. We are choosing laziness to say we do not have the data. It is regressive. When considering additions to regulating the medical marijuana program team, I would personally like to see the DPH seek out a cannabis expert from Massachusetts fluid in cannabis the plant. Thank you for your time.
Maggie Kinsella