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 chemotherapy patients around the country. Another 500,000 wi[[
 be released by the end of the year. De[ta-9-THC is the principal
 psychoactive ingredient in marijuana. This special program,
 approved by the FDA's Oncologic Advisory on June 26, 1 980,
 required participating physicians to register with both the
 NationaE Cancer Institute and the Drug Enforcement
 Despite these important actions by federal agencies,
 marijuana and THC are often difficult for doctors and patients to
 obtain because marijuana is still cJassified as a Schedule [
 substances in the federal CSAo This classification imposes
 severe restrictions and "red tape" which significantly impede
 access to marijuana for medical purposes.
 3. Marijuana Can Be Safely Used "Under Medical
 The third and fina_ criterion for placement in Schedule [is
 that "there is a lack of accepted safety for use of the drug or
 other substance under medical supervision°" 21 LI.SoC.
 Even if we would concede that marijuana satisfied this
 criterion when the CSA was passed in 1970, we believe that it is
 obvious that marijuana does not satisfy this criterion today.
 The studies and reports cited in the previous sections of the
 memorandum documents marijuana's low potential for abuse, and
 indicate that there is no "lack of safety" attendant to the use
 of marijuana with or without medical supervision.
 In addition, the experience of the states which have aiBowed
 the use of marijuana as medicine documents the safety of the
 substance when used under medical supervision.
 The classification of marijuana in Scheduee i must therefore
 be deemed to be arbitrary and irrational, because current
 information shows that marijuana satisfied none of the three
 criteria for p_acement in Schedule 1.
 4. Marijuana is Classified with Dissimilar and
 Much More Dangerous Substances
 The classification of marijuana is Schedule [is also
 arbitrary and irrational because marijuana is a much less

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