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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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