norml09 - Page 43
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use in treatment in the United Stazeso Therefore_ I adopt
in their entirety the findings of facts and conclusions of
law reached by the former Administrator in his final order
of December 21, 1989, 54 FR 53767.
Pursuant to the remand of the Court of Appeals, I have
condensed and clarified the initial standard into a five-
point test. My application of the refined, five-point test
to this record is set out briefly below.
Firsts marijuana_s chemistry is neither fully known,
nor reproducible. Thus far_ over 400 different chemicals
have been identified in the plant° The proportions and
concentrations differ from plant to plant, depending on
growing conditions, age of the plant5 harvesting and storage
factors. THC levels can vary from less than 0°2% to over
i0%. It is not known how smoking or burning the plant
material affects the composition of all these chemicals, it
is not possible to reproduce the drug in dosages which can
be considered standardized by any currently accepted
scientific criteria. Marijuana is not recognized in any
current edition of the official compendia. 21 U°SoC.
21(j) o
Seccnd, adequate safety studies have not been done°
All reasonably applicable pharmacological and toxicological
studies have not been carried out° Most of the chronic
animal studies have been conducted with oral or intravenous
THC, not with marijuana. Pharmacological data on
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