Thoughts on the Proposal to Change Marijuana to Schedule 3

I’ve had a lot of folks ask my thoughts about the push to change marijuana to Schedule 3, given the recent release of the HHS document.? Here are some quick thoughts – I’ll keep it concise as I can, although this will be a meatier post.? Would love to discuss respectfully in the comments if you agree or disagree!

For time’s sake I’m going to skip the links to references/citations here, but if there are any points here that anyone would like background on feel free to DM me and I’ll provide sources.

Also - before I dive into the central question, I just need to say that a 253-page document like the one that was released represents a TON of labor-hours and tax dollars spent on making this argument.? This is an aside, but I feel like there’s a lot of other issues facing the USA today that I would have put at a much higher priority for both HHS and our tax dollars than a back-end classification change to marijuana that essentially would just serve to make it easier for people to invest in into cannabis companies.? If we want to open up more avenues for research on different THC products, there are other ways to do that (and bills that have already been proposed).

The definition of Schedule 1 is that the items on the list are “drugs with no currently accepted medical use and a high potential for abuse.”? The definition of Schedule 3 drugs are that they are “drugs with a moderate to low potential for physical and psychological dependence” and have accepted medical use.? My understanding is that, at this point in time, every Schedule 3 drug has been FDA-approved for at least one condition.

• ?In regards to medical use, “marijuana” is not currently FDA-approved for anything.? “Marijuana” is a type of plant and thus highly heterogenous, meaning that even if certain strains had certain approved medical uses, other strains of “marijuana” as a category might not.? It also has highly variable concentrations of THC, from around 3%-to 35% (just referring to flower here).? “Marijuana” as a construct has a hard time fitting the definition of medicine, because “marijuana” is not a consistent product.
• Also of note, we do have actual FDA-approved cannabinoid medications: Marinol and Epidiolex.? Marinol (essentially a synthetic version of THC called dronabinol) is categorized as Schedule 3.? Epidiolex is plant-derived CBD, and it is not a controlled substance (because it is CBD).?

• In regards to addictive potential, the two most recent studies I’ve seen on population dependence/use disorder rates for adults who use THC were around 20% - 1 in 5 users reports having a use disorder (Here’s one of them: https://www.kuow.org/stories/new-study-1-in-5-washington-cannabis-users-show-signs-of-addiction ).? Historically it’s been lower, around 10%, but it makes sense that this number would increase as the average THC content in marijuana has increased over time.? But a 20% cannabis use disorder rate amongst users seems like an objectively high number to me, and quite a bit higher than other Schedule 3 drugs like testosterone and ketamine.?
• In terms of riskiness and adverse outcomes (other than addiction), marijuana has been consistently associated in the medical literature with the development or exacerbation of psychosis, depression, and suicidal behaviors.? It’s not going to directly kill you like an opioid can, but in terms of risk I’d say it’s definitely higher than testosterone or ketamine.? We could talk a lot more about details re: risk here, but these are the most salient ones for me.

?So to sum it up, my personal opinion is that “marijuana” is not a fit for Schedule 3 because:

1. ?It’s not a consistent product that you can categorically claim has an accepted medical use
2. Unlike all other Schedule 3 drugs it’s not FDA-approved for any condition (as opposed to dronabinol, which is a medication, FDA-approved, and already is Schedule 3)
3. It does have significant physiological addictive potential, particularly when compared to other Schedule 3 medications.
4. Its risk profile seems higher to me than other Schedule 3 drugs

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Just my 2 cents!? I'd love to hear yours – it’s a fascinating topic.? I’ll also put out there that I think that there’s a lot of room here to talk about potentially reforming the Scheduling system as a whole so that it’s more nuanced…but given the system we have today, where even most Schedule 2 drugs have accepted medical use, I don’t think “marijuana” (as a category) can be moved outside of Schedule 1.? Perhaps you could make a case for schedule 2, as cocaine is there now (although there is a nasal spray that is FDA-approved and has cocaine).? But Schedule 3 seems like a massive stretch to me.

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#marijuana #drugpolicy #publicpolicy