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 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
 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

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