norml08 - Page 42

 to conclude that marijuana is safe and effective for use as
 medicine_
 Marijuana is not recognized as medicine in generally
 accepted pharmacopeias medical references and textbooks_ as
 noted by my predecessor. 54 FR 53784° I take this to mean,
 under initial factor (5)_ that he determined that
 marijuana_s chemistry is neither known, nor reproducible, as
 evidenced by its absence from the official pharmacopeia.
 Finally, my predecessor concluded_ under initial factor
 (8) (a)_ that the vast majority of physicians does not accept
 marijuana as having medical use. 54 FR 53784_ Along the
 way, he found that highly respected onco!ogists and
 antiemetic researchers reject marijuana for use in
 controlling nausea and vomiting, 54 FR 5377, that experts
 experienced in researching glaucoma medicaZions reject
 marijuana for use in treating glaucomas 54 FR 53779, and
 that noted neurologists who specialize in treating and
 conducting research in spasticity reject marijuana for use
 by MS patients, 54 FR 53780. I take this to mean my
 predecessor found no national consensus of qualified experts
 accepts marijuana_s value as medicines
 Certainly I cannot know my predecessor's unstated
 reasoning. However, I have reviewed the entire record de
 Dovo, and I am convinced that his application of the initial
 eight_point test to this record correctly resulted in the
 / ....... conclusion that marijuana has no currently accepted medical
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