vol1 - Page 347

 but also-includes marijuana. I_4/ Chang concluded that smoked
 marijuana resulted in a lower incidence of nausea and vomiting
 than oral THC. if-x/
 Furthere DEApoints out thai'Chang discussed some
 drawbacks to marijuana_s route of administration which would
 hinder Łtswide clinical acceptability_ Howevers Chang was
 referrinq most importantly to oral THCo In facts Chang remarked
 that the inhalation method avoided the _ineffective _ route of
 oral drug administration in a nauseated or vomiting patient. I!_/
 Clearly the Chang study suggests that the inhalation route,
 although having some drawbacks_ is more effective than the oral
 route. It is difficult to see what point DEA intends to
 formulate by raising these drawbacks other than to require
 marijuana to be a-perfect drug. The evident drawbacks in oral
 o
 THC's route of administration did not preclude its rescheduling.
 And, most importantly, DEA overlooks the significant conclusions
 reached by Chang on marijuana's efficacy in a double-blind,
 randomized study: NThe data show that _al or smoked THC
 [marijuana] is an effective antiemetic in patients receiving
 high-dose methotrexate chemotherapy. NIl//
 Finally, DEA points out that Chang concluded additional
 studies were needed to confirm.the correctness, of his conclu=
 sions. The state-authorized studies conducted in New Mexico,
 ii_/ I d. at 819
 i_15_/ I__. at 823_
 _/ _. (emphasis added) Q_ .... z