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 [I]ntroduction of a drug into the body by..
 smoking is a very efficient method of
 administration .... Persons who have
 recreationally smoked marijuana, who know how
 to titrate themselves, would probably have
 little difficulty in
 emck_ the drug for
 medical treatment ....
 Many witnesses have testified that patients exercise
 very fine control overthe i_nalation of marijuana. _-_/ This
 fact haml be_n demonstrated in numerous studieso _/ While DEA and
 other federal agencies promoted a _standardized smoking x regimen_
 the state-authorized treatment programs quickly abandoned this
 inflexible approach. Georgia found patients compelled to smoke
 in a rigid, pre-determined or Nstandardized" way were less
 likely to benefit from the therapy. _-Q/ Both New York and
 California first adopted the govelnlment_s _standardized smoking _
 regimen, then abandoned this approach and altered their INDs to
 permit patient _self-titrationo w_ul/
 __Z/ Affidavit of Raphael Mechoulam_ Ph.D., _ 12.
 _/ ACT Brief at i08, 109.
 49/ Cross-examination of Dr. Norman Zinberg Tr° 11-199-203o
 Drs. Sallan and Zinberg found patients abandoned their 1974_75
 oral THC study to smoke marijuana because it was more con-
 trollable. Affidavit of Dr. Norman Zinberg, Exhibit 3; Cross
 Examination of Madelyn Brazis, R.N. Tr. 7-212 Affidavit of Rona_
 Stephens_ _ 17; Cross=examination of Dr. J_ Thomas Ungerleider_
 Tr. 4-117; $e9_ al_ ACT Brief at 108-09.
 __q/ ACT Official State Reports_ Vol_ II_ Exhibit 8 at Table 2 =
 C. See _il_q ACT Brief at 57.
 51/ ACT Official State Reports, VOlo iI_ Exhibit 16. Governor
 and Legislature on the Antonio G. Olivieri Controlled Substances
 Therapeutic Research Program, September i, 1982, at 5. See_!l__2
 ACT Brief at 71.
 The Consensus among experienced investigators
 [is] that patients should smoke [marijuana]

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