OHA/OLCC Joint Public Comment on DEA Rescheduling

As two State of Oregon agencies that work together to regulate medical and recreational marijuana, the Oregon Health Authority and the Oregon Liquor and Cannabis Commission support rescheduling marijuana from Schedule I to Schedule III. In 1998 Oregon voters approved Oregon Measure 67 permitting the medical use of marijuana. Since 1998, the State of Oregon has found marijuana to be an effective treatment for suffering caused by debilitating medical conditions and, therefore, the State of Oregon requires that marijuana must be treated like other medicines (ORS 475C.770). The rescheduling of marijuana from Schedule I to Schedule III will allow for additional research of marijuana which could provide a better understanding of marijuana’s safety and efficacy in treating medical conditions. Currently Oregon has more than 23,000 participants registered in the Oregon Medical Marijuana Program (OMMP) and 1,362 health care providers who have recommended the use of medical marijuana to their patients. Rescheduling marijuana from a Schedule I drug, that is defined as a drug with no currently accepted medical use and a high potential for abuse, to a Schedule III drug would better align federal regulation of marijuana with the intent of the Oregon Legislature to allow Oregonians with debilitating medical conditions to benefit from the medical use of marijuana.  (ORS 475C.770 – ORS 475C.919).

In 2014, Oregon voters legalized the use of marijuana for adults over the age of 21. By allowing legal access to marijuana, Oregon is ensuring all patients and consumers have access to marijuana that is packaged, labeled, and tested so that people are aware of what the are consuming and have confidence marijuana they purchased at licensed retailers does not contain harmful levels of substances like pesticides, heavy metals, and solvents.

The tax collected on the retail sale of marijuana items has provided over $100 million to fund drug treatment and recovery, prevention, and mental health, as well as funding for schools, police and local governments. Oregon’s legal marijuana industry has proven to be a large economic driver even though businesses do not have access to traditional banking services and are significantly burdened by being taxed through the inability to deduct IRS 280E expenses.

By legalizing and regulating marijuana, Oregon has been able to protect the public from the problems related to illicit manufacturing and distribution of marijuana items, including sales to minors and the presence of contaminants such as pesticides, heavy metals, and solvents. State agencies that oversee the regulation of marijuana also work closely with other agencies and law enforcement to ensure compliance with all state laws and levy fines when state laws or administrative rules aren’t followed. This ensures public health and safety standards are met across Oregon. In addition, regulation has taken an industry that was completely illegal and turned it into a legitimate industry that brings many benefits to all Oregonians through the generation of retail sales on marijuana flower and marijuana products.

This proposed change in the federal status of marijuana will benefit individuals and businesses in Oregon and reduce barriers to research to benefit an already thriving industry throughout the nation.

Signed:

Cara Biddlecom, MPH,

Interim Public Health Director Public Health Division,

Oregon Health Authority

Craig Prins, Executive Director

Oregon Liquor and Cannabis Commission

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