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 to conclude that marijuana is safe and effective for use as
 Marijuana is not recognized as medicine in generally
 accepted pharmacopeia_ 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
 (S) (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 oncologists and
 antiemetic researchers reject marijuana for use in
 controlling nausea and vomiting_ 54 FR 5377, that experts
 experienced in researching glaucoma medications reject
 marijuana for use in treating glaucoma, 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. [ take this to mean my
 predecessor found no national consensus of qualified experts
 accepts marijuana's value as medicine.
 Certainly i cannot know my predecessor's unstated
 reasonings However_ I have reviewed the entire record de
 novo, 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 cu_rently accepted medical

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