vol1 - Page 327
Page 327
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In sum, DEA's _standardization # argument is little mort
than a diversion. The government's position is not even
supported by DEA witnesses. Richard Hawks, Ph.D.s head of the
NXDA Research Technologies Branch, testified NIDA_grownmarijuana
is nstandardized_ and #authentic° # NIDA_s Marijuana Drug Master
File satisfies FDAns IND/NDA requirements for information on
marijuana'mcheanistry, pharmacology, toxicology and product
description. Even DEA defines marijuana by code°
DEASs Nvariability# argument also lacks credible
support. DEA witnesses Keith Green, PhoD., Raphael Mechoulam,
Ph.D., and CRAP, admit marijuana is superior to synthetic THC in
terms of bioavailability. The National Cancer Institute deter-
mined that, "the [marijuana_ cigarette is the best means of
delivering the drug. m Finally, physicians and patients, nin
....... treatment _ have found self-titration (patient control over drug
delivery) actually improves the drug's therapeutic utility and
reduces potential side effects, a fact clearly demonstrated by
several large-scale Phase Ill state-authorized treatment
programs.
The scientific quest for the _Holy Grail u -- a perfect
drug -- should continue. But this scientific quest should not
preclude marijuana's medical availability for therapeutic use _i_
treatment N where needs are immediate and perfect solutions are
nonexistent.
__i/ (...continued)
until comfort is achieved.
ACT Official State Reports Vol. I_ Exhibit 4, Thirteenth Annual
Report, CRAP, San Francisco, 1983 at ii.
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