The Medicinal Cannabis Control Scheme, consultation paper was released on 10 July and closes on 7th August 2019.
We support in principal the objectives of the scheme, to improve patient access to affordable medicinal cannabis products, providing prescribers with confidence about the quality of the medicinal cannabis products. Therefore supporting equitable health outcomes and access to the economic benefits of a medicinal cannabis industry, while supporting NZ trade and economic objectives.
The Ministry of Health have an opportunity to develop a world class medicinal cannabis agency to administer the Medicinal Cannabis Scheme. By following the Keep It Simply approach used during the development of the Industrial Hemp regulations (2006), they can achieve the above objectives and show the world what a great system looks like.
New Zealand can show the world how to correctly use cannabis, foremost as a functional food and for health and wellness, allowing New Zealanders access to phyto-cannabinoids – which can supplement our own endocannabinoid system – and this starts with allowing medicinal cannabis products and making CBD products available to a wider local market – New Zealanders want to get healthy not high.
The simple approach focuses on what needs to be controlled, which is the psychotropic cannabinoid THC. THC is what triggers the need for government control, as only high THC plants need to be reported under our international reporting requirements (i.e. UN single convention on Narcotic Drugs) and only high THC plants have a risk of diversion.
The industrial hemp industry has shown over many years that low THC crops have little risk of diversion, and this is reflected in the requirements for a safe location under our iHemp Licences. This is in contrast to a Misuse of Drugs Act licence, for higher THC crops which must be kept both safe and secure.
New Zealand can remind the world that hemp has traditionally been used as a functional food and source of fiber, and only with its prohibition in the 20th Century has it been used as an illicit recreational drug.
We encourage all individuals and business to make a submission, by using the document which can be down loaded here. To get you started our draft submission is attached here. Questions 1 and 2 cover most of the relevant points we wish to make on behalf of the iHemp industry.
The NZ Hemp Industries Association will be submitting on areas of interest to the industry, such as:
1) Allowing the use of industrial hemp biomass to be extracted for non-medicinal export markets for food, dietary supplements, nutraceuticals, and natural health products. Allowing access to the export market will help us to get up to speed quicker, so we can compete with imported products from suppliers who are already manufacturing to the required medical standards.
2) Allowing low THC industrial hemp, grown under a iHemp licence to be used to make medicinal cannabis products for the local and export market; this will allow cannabis medicines to be made available more quickly and more affordably to New Zealanders, whilst the regulatory environment is changed to allow access to the border non-medical market, as detailed in 1) above.
3) Banning the use of synthetics cannabinoids, as they are less effective than those derived from nature and are the main cause of problems in overseas markets.
NZ companies that produce medicine will need to be GMP approved (Good Manufacturing Practices) – this will delay the availability of products from local sources. To create a level playing field which gives NZ companies the opportunity to be part of the economic benefit of a medicinal cannabis industry, we will need access to the international markets immediately.
We can comply with the requirements of these offshore markets as they range from medical (GMP standard) through to markets who can accept a lower level of compliance such as the Canadian GPP (Good Processing Practices). Both provide a high level of quality assurance, which meets the buyers’ specifications. The cash flow from these international markets will support the development of the GMP facilities and the economies of scale required to make medicinal products affordable in New Zealand.