norml23 - Page 56

 f. Risk to the Public Health
 The sixth factor which must be considered is "what, if any, risk
 there is to the public health." Section 2oltc)(6). Tile House Report
 states that "If a drug creates no danger to the public health, it would
 be inappropriate to controi the drug under this bill." H.R. Repo No. 91-
 1444 at pg. 4603. The Senate Report added, S.Rep. No. 91-613 at pg. 16:
 The Attorney General must have the best available
 knowledge of the pharmacologicaJ properties of any
 drug under consideration, if a drug creates _ao
 danger to the public health, it woumd be inappro-
 priate to controt the drug under this act°
 HEW makes a two sentence finding under that factor, but the
 finding appears to have nothing to do with marijuana's risk to the
 pubJic health. HEW states that it is difficult to study the effects of
 marijuana, because the THC content of natura_ plant materiaJs varies.
 HEW concludes that the variability in the THC results {n a "lack of
 accepted safety .... under medical supervision." 44 Fed. Rego at 36126
 Col. 2.
 These findings are inappropriate and irrelevant to this criteria.
 First, they do not address the risk to the "public health" through the
 use of marijuana. Second, while it is true that the THC content of
 marijuana varies, aH marijuana distributed by the federal government
 for research and medical uses -- whether naturaJ marijuana in the form
 of cigarettes, or synthetic THC in the form of pills, etc. -- is
 carefully monitored and dose qualified for THC. There is never a
 mystery about the amount of THC a patient or research subject consumes.
 See, e.g., Ninutes of the National Cancer Institute meeting held on Nay
 9, 1978, on the "Current Status of Research with Tetrahydrocannabinol
 (THC) and Nabilone for the Control of Cancer Chemotherapy-Induced
 Vomiting."
 g. Dependence Liability
 The seventh factor which must be considered is the substance's
 "psychic or physiological dependence _iability." Section 201(c)(7). The
 House and Senate Reports use identical language in describing this
 factor: "There must be an assessment of the extent to which a drug is