To whom it may concern,
I have reviewed the proposed amendments to 105 CMR 725.000 and oppose two changes. The following bodies explain why I do not support 105 CMR 725.010(I) and 105 CMR 725.032(H).
Under 725.010’s title, “Written Certification of a Debilitating Medical Condition for a Qualifying Patient,” amendment (I) states that “A certifiying healthcare provider may determine and certify that a qualifying patient requires an amount of marijuana other than +10 ounces as a 60-day supply and shall document the amount and the rationale in the medical record and in the written certification.”
- First, I will state my opposition. Then, I ask for clarification of this amendment.*(X)
- If this amendment states that a healthcare provider may determine and certify that a qualifying patient requires an amount less than the current (patient) possession limit (of “No more than 10 ounces every two months”), then I oppose it.
- I oppose it, because currently, adults 21 or over may legally and without a medical license possess up to 10 ounces of pot (inside the home). Patients deserve at least the same legal freedom, so they should continue to be able to purchase up to 10 ounces every two months from a dispensary.
- Additionally, to my knowledge, there currently lacks the scientific evidence a healthcare provider would need to be able to determine and certify that a patient requires less than 10 ounces as a 60-day supply. Simply put, there lacks even the scientific proof that 1 gram of (strain-y) cannabis at 50% THC offers the same effects as 1 gram of (strain-z) cannabis at 50% THC.
- *(X) Finally, if this amendment is merely stating that a certifying healthcare provider may determine and legally certify that a qualifying patient requires more than the current limit of 10 ounces as a 60-day supply, then I agree with it, because as was just stated, there is no scientific evidence suggesting that an average of 5 grams a day is sufficient for every qualifying medical patient, which is nearly what 10 ounces over the course of 60-days ends up averaging out to.
Under 725.032’s title, “Registration of Independent Testing Laboratory Agents,” amendment (H) states that “Laboratory agents may only test marijuana and marijuana products from a RMD in good standing with the Department.”
- First, I will state my opposition.
- As it stands, to my knowledge, any person may submit water or even alcohol to a testing laboratory. Restricting laboratory agents willing to help all to testing only marijuana and marijuana products from a RMD in good standing with the Department I believe violates my civil liberties.
- Currently without a medical marijuana license, I believe that if I desire to test the legal cannabis I consume in order to better understand its properties and components, and if a laboratory is willing to assist me in this process, then I and the laboratory agents should be able to do so.
- Likewise, if a patient with a medical marijuana license desires to test marijuana and/or marijuana products, and a laboratory is willing to assist them in this process, then they and the laboratory agents should be able to do so.
- The bottom line is that insufficient recognized scientific research is one of the main reasons why cannabis remains illegal at the federal level. Amendment (H) proposes to prevent data which may be discovered through testing marijuana and marijuana products submitted by non-RMD’s (in good standing with the Department) for no justifiable reason.
- Finally, I propose that 105 CMR 725.032(H) be amended to “Laboratory agents may only test marijuana and marijuana products from a RMD in good standing with the Department or adults age 21 or over.”
In closing, I want to thank the Department of Public Health for listening to my testimony.
Sincerely,
Jonathan Michael Hammond, who resides at 47 Holten St., Peabody MA, 01960, U.S.A.