Source: The Gordon and Breach Publishing Group Author: Lester Grinspoon, M.D. Pubdate: Unknown Contact: http://www.gbhap-us.com/top.htm Note: The following is an exception to our policy of not posting web based only articles. I could not identify exactly when this article was first posted on the above website, and found no evidence that it is also in print. The website posting comes in three versions, Omni, Pro and Anti. This is the Omni version. - Richard Lake, Sr. Editor, DrugSense News Service Also note: Dr. Grinspoon's website is at: http://www.rxmarihuana.com/ "MEDICAL MARIHUANA RECONSIDERED" The medical value of marihuana has become increasingly clear to many physicians and patients. There are three reasons for this. First, it is remarkably non-toxic. Unlike most of the medicines in the present pharmacopeia, it has never caused an overdose death. Its short-term and long-term side effects are minimal compared to medicines for which it will be substituted. Second, once patients no longer have to pay the prohibition tariff, it will be much less expensive than the medicines it replaces. Third, it is remarkably versatile, useful in treating a diverse array of symptoms and syndromes.[1] As the number of people who have experience with medical marihuana grows, the discussion is turning away from whether it is effective to how it should be made available. When I first considered this issue in the early 1970s, I thought the main problem was its classification in Schedule I of the Comprehensive Drug Abuse and Control Act of 1970, which describes it as having a high potential for abuse, no accepted medical use in the United States, and lack of accepted safety for use under medical supervision. At that time I naively believed that a change to Schedule II would overcome a major obstacle, because clinical research would be possible and prescriptions would eventually be allowed. I was the first witness at a joint meeting of the Drug Enforcement Administration and the Food and Drug Administration that was convened to consider a petition for rescheduling introduced by the National Organization for the Reform of Marijuana Laws in 1972. At that time I had already come to believe that the greatest harm in recreational use of marihuana came not from the drug itself but from the effects of prohibition. But I saw that as a separate issue; I thought that, like opiates and cocaine, cannabis could be used medically while remaining outlawed for other purposes. I also thought that once it was transferred to Schedule II, research on marihuana would be pursued eagerly, since it had shown such interesting therapeutic properties. From this research we would eventually be able to determine how prescriptions could be provided and who would be responsible for quality control. Now, 25 years later, I have begun to doubt this. Reclassification may turn out to have more symbolic than practical value. It may be only a transitional phase in the process that leads to a workable accommodation for the medical marihuana. It would be highly desirable if marihuana could be approved as a legitimate medicine within the present federal regulatory system, but it now seems to me unlikely. First, I should note that cannabis has already been a legally accepted medicine in the United States several times. Until 1941, when it was dropped after the passage of the Marihuana Tax Act, it was one of the drugs listed in the U.S. Pharmacopeia. If it had not been removed at that time, it would have been grandfathered into the Comprehensive Drug Abuse and Control Act as a prescription drug, just a cocaine and morphine were. Again, in the late 1970s and early 1980s, cannabis was used medically by hundreds of patients (mainly in the form of synthetic tetrahydrocannabinol) in projects conducted by several of the states for the treatment of nausea and vomiting in cancer chemotherapy. This episode ended because each state program had to comply with an enormous federal paperwork burden that was more than the physicians and administrators involved could bear. The federal government itself approved the use of cannabis as a medicine in 1976 by instituting the Compassionate IND program, under which physicians could obtain an individual Investigational New Drug application (IND) for a patient to receive cannabis. This program too was so bureaucratically burdened that in the course of its history only about three dozen patients ever received marihuana, and only eight are still receiving it. When the program was discontinued permanently in 1992, the Chief of the Public Health Service gave the following reason: "If it is perceived that the Public Health Service is going around giving marihuana to folks, there would be a perception that this stuff can't be so bad. It gives a bad signal. I don't mind doing that if there is no other way of helping these people...But there is not a shred of evidence that smoking marihuana assists a person with AIDS." In effect, this action was analogous to the recall of a prescription drug, but without any evidence of toxic effects to support it. Today, even transferring marihuana to Schedule II would not be enough to make it available as a prescription drug. Such drugs must undergo rigorous, expensive, and time-consuming tests before they are approved by the Food and Drug Administration for marketing as medicines. The purpose is to protect the consumer by establishing safety and efficacy. Because no drug is completely safe or always efficacious, an approved drug has presumably satisfied a risk-benefit analysis. When physicians prescribe for individual patients they conduct an informal analysis of a similar kind, taking into account not just the drug's overall safety and efficacy, but its risk and benefits for a given patient with a given condition. The formal drug approval procedures help to provide physicians with the information they need to make this analysis. This system is designed to regulate the commercial distribution of drug company products and protect the public against false or misleading claims about their efficacy and safety. The drug is generally a single synthetic chemical the company has developed and patented. It submits an application to the Food and Drug Administration and tests it first for safety in animals and then for clinical efficacy and safety. The company must present evidence from double-blind controlled studies showing that the drug is more effective than a placebo and as effective as available drugs. Case reports, expert opinion, and clinical experience are not considered sufficient. The standards have been tightened since the present system was established in 1962, and few applications that were approved in the early 1960s would be approved today on the basis of the same evidence. Certainly we need more laboratory and clinical research to improve our understanding of medicinal cannabis. We need to know how many patients and which patients with each symptom or syndrome are likely to find cannabis more effective than existing drugs. We also need to know more about its effects on the immune system in immunologically impaired patients, its interactions with other medicines, and its possible uses for children. But I have come to doubt whether the FDA rules should apply to cannabis. There is no question about its safety. It is one of humanity's oldest medicines, used for thousands of years by millions of people with very little evidence of significant toxic effects. More is known about its adverse effects than about those of most prescription drugs. The American government has conducted a decades-long multimillion dollar research program in a futile attempt to demonstrate toxic effects that would justify the prohibition of cannabis as a nonmedical drug. This is an enormously important consideration in thinking of cannabis as a medicine. One of its uses, for example, is the treatment of chronic pain. This symptom is usually treated with opioid narcotics or synthetic analgesics that are far riskier. Opioids are addictive and tolerance develops; an overdose can be lethal. The most commonly used synthetic analgesics -- aspirin, acetaminophen (Tylenol), and nonsteroidal antiinflammatory drugs (NSAIDs) like ibuprofen and naproxen -- are not addictive, but they are often insufficiently powerful. Furthermore, they have serious side effects. Stomach bleeding and ulcer induced by aspirin and NSAIDs are the most common serious adverse drug reactions reported in the United States, causing an estimated 7,000 deaths each year.[2] Acetaminophen can cause liver damage or kidney failure when used regularly for long periods of time; a recent study suggests it may account for 10% of all cases of end-stage renal disease, a condition that requires dialysis or a kidney transplant.[3] Results of comparisons between cannabis and other drugs are similar, whatever medical use we consider -- anticonvulsant, antispasmodic, antidepressant, antinauseant. Should time and resources be wasted to demonstrate for the FDA what is already so obvious? As for efficacy, some believe that has been proven too, although others disagree. During the 1970s and '80s several of the state-sponsored research projects I mentioned suggested that marihuana had advantages over both oral tetrahydrocannabinol and other medicines in the treatment of nausea and vomiting from cancer chemotherapy. But as long as the imprimatur of science can be given only to rigorous double-blind controlled studies, the case for marihuana has not been made. The assertion that it is a useful medicine rests almost entirely on case reports and clinical experience, just as it did in the late 19th and early 20th centuries. A double-blind controlled study may be the best way to prove the relative value of a new medicine whose advantages over established drugs are not obvious. But it is not the only way to demonstrate efficacy. The focus of controlled trials is usually statistical differences in effects in groups of patients, but medicine has always been concerned mainly with individuals,whose needs can be obscured in such experiments, especially when little effort is made to identify distinctive characteristics that affect their responses. The value of case reports and clinical experience is often underestimated. They are the source of much of our knowledge of synthetic medicines as well as plant derivatives. As Dr. Louis Lasagna has pointed out, controlled experiments were not needed to recognize the therapeutic potential of chloral hydrate, barbiturates, aspirin, curare, or insulin.[4] The therapeutic value of penicillin was widely recognized after it had been given to only six patients. Similar evidence revealed the use of propranolol for hypertension, diazepam for status epilepticus (a state of continuous seizure activity), and imipramine for childhood enuresis (bedwetting). These drugs had originally been approved by regulators for other purposes. As early as 1976 several small and imperfect studies, not widely known in the medical community, had shown that an aspirin a day could prevent a second heart attack. In 1988 a large-scale experiment demonstrated effects so dramatic that the researchers decided to stop the experiment to publish the life-saving results. On one estimate, as many as twenty thousand deaths a year might have been prevented from the mid-1970s to the late-1980s if the medical establishment had been quicker to recognize the value of aspirin. The lesson is suggestive: marihuana, like aspirin, is a substance known to be unusually safe and with enormous potential medical benefits. There is one contrast, however; it was impossible to be sure about the effect of aspirin on heart attacks without a long-term study involving large numbers of patients, but innumerable reports show that cannabis often brings immediate relief of suffering that can be measured in a single person. Case histories are, in a sense, simply the smallest research studies, and the case reports on marihuana are numerous and persuasive. There is an experimental method known as the N-of-1 clinical trial, or the single-patient randomized trial. In this type of experiment, active and placebo treatments are administered randomly in alternation or succession to a patient. The method is often useful when large-scale controlled studies are impossible or inappropriate because the disorder is rare, the patient is atypical, or the response to the treatment is idiosyncratic. [5] Some medical marihuana patients we know of carried out similar experiments on themselves by alternating periods of cannabis use with periods of no use. They had such symptoms as nausea and vomiting, muscle spasms, loss of vision, seizures, and debilitating pruritus (itching). It is certain that cannabis won its reputation as a medicine partly because many other patients around the world have carried out the same kind of experiment. Admittedly, in these experiments cannabis could not be administered completely at random and there was no placebo, but in any case its psychoactive effects are usually unmistakable, and few patients or observers could be deceived by a placebo. Case histories and other reports of clinical experience are sometimes disparagingly dismissed as merely "anecdotal" evidence, which is said to be irrelevant because only apparent successes are counted and failures are ignored. It is true that cannabis may be useful for some people with, say, multiple sclerosis, chronic pain, or depression, and not for others. But cannabis is so safe that if even a few patients with a given symptom could get that kind of relief, they should be allowed access to it. Even if it made sense to put marihuana through the FDA process, there would be other problems in taking the conventional route to medical legitimacy. As I mentioned, FDA procedures are designed for single chemical compounds, but marihuana is a plant material containing many chemicals. Also, it is taken chiefly by smoking, and no other drug in the present pharmacopeia is delivered by this route. Thousands of people are already getting relief from cannabis,and they would not be risking severe penalties if they did not believe that it was more useful than conventional medicines. Can we expect them to put their pain and suffering on hold for years while the established procedures grind away? And where will the money to finance all this come from? New medicines are usually introduced by drug companies, which spend an estimated two hundred million dollars on the development of each product. They are willing to undertake these costs only because they hope for large profits during the 20 years they own the patent. Obviously pharmaceutical companies cannot patent marihuana, and in fact may oppose its acceptance as a medicine because it will compete with their own products. Drug companies may be interested in synthetic cannabinoids and cannabinoid analogs -- individual chemical compounds that do not have to be smoked and might be aimed at specific symptoms with little psychoactive effect. But their patentability and the costs of development would make these drugs expensive, and many patients would understandably prefer to buy or grow their own marihuana and endure (or enjoy) the psychoactive effects. Even now, the minority of cannabis-using patients who find Marinol (dronabinol, or synthetic tetrahydrocannabinol) useful generally prefer whole smoked marihuana because it is not only more effective but often less expensive despite the prohibition tariff. Only the U.S. government has sufficient resources to explore medical marihuana, but its record on the matter is, to put it mildly, not reassuring. The government has opposed any loosening of restrictions on clinical research with cannabis, including the research needed for FDA approval. The government will ultimately provide support for this research, but that will happen only gradually as public pressure increases. A proposed study of marihuana's safety as a treatment for the AIDS wasting syndrome has recently been approved and funded, but only after four years of obstruction -- and not because anything new has been learned about cannabis, but only because the political climate has changed in the wake of the recent California initiative. But just for the sake of argument, let us suppose that government resistance evaporates and marihuana is approved for, say, the relief of nausea and vomiting in cancer chemotherapy. Furthermore, we can leave aside the issue of who would provide the marihuana (the government or marihuana farmers under contract?) and who would distribute it (pharmacies will need special facilities to keep fresh supplies). There are other reasons why making marihuana a Schedule II prescription drug would probably be unworkable in the long run. As a Schedule II drug, marihuana would be classified as having a high potential for abuse and limited medical use. Restrictions on these drugs are becoming tighter. Nine states now require doctors to make out prescriptions for many of them in triplicate so that one copy can be sent to a centralized computer system that tracks every transaction. [6] In 1989 New York state added the benzodiazepines (Valium and related drugs) to the list of substances monitored in this way. Research has shown that since then many patients in New York who have a legitimate need for benzodiazepines are being denied them, and less safe and effective drugs are being substituted. Increased regulation caused by fear of drug abuse has been to the disadvantage rather than the advantage of patients.[7] Obviously, in such situations physicians are often afraid to recommend what they know or suspect to be the best medicine because they might lose their reputations, licenses, and careers. Pharmacies might be reluctant to carry marihuana as a Schedule II drug, and physicians would hesitate to prescribe it. Through computer-based monitoring, the DEA could know who was receiving prescription marihuana and how much. It could hound physicians who by its standards prescribed cannabis too freely or for "off-label" purposes the government considered unacceptable. The potential for harassment would be extremely discouraging. Unlike other Schedule II drugs such as cocaine and morphine, cannabis has many potential medical uses. Many patients might try to persuade their doctors that they had a legitimate claim to a prescription. Doctors would not want the responsibility of making such decisions if they were constantly under threat of discipline by the state. In fact, since the passage of the medical marihuana initiative in California, I have received calls from patients who say their doctors are afraid to recommend (not prescribe) marihuana because of threats from the federal government -- even though those threats have been declared by the courts to be legally baseless. There is actually no case for such restrictions on cannabis -- unless you think that third-party reefer-madness anxiety qualifies as a risk. Cannabis is not accurately described as a Schedule II drug. It does not have a high potential for abuse and, above all, it does not have limited medical uses. For example, a physician might sensibly and safely prescribe it for muscle spasms and chronic pain resulting from a variety of conditions, from paraplegia to premenstrual syndrome. If the government and medical licensing boards insist on tight restrictions, challenging physicians as though cannabis were a dangerous drug every time it is used for any new patient or any new purpose, there will be constant conflict with one of two outcomes: patients do not get all the benefits they should from this medicine, or they get the benefits by abandoning the legal system for the black market or their own gardens. In fact, the range of beneficial uses of marihuana is so broad that it may ultimately be wrong to single out the strictly medical uses for approval. We all know of people who use it to ease everyday discomforts, heighten creativity, or help them in their work. It can serve as an intellectual stimulant, and it can also enhance the appreciation of food, sex, natural beauty, music, and art. It can promote emotional intimacy. Cannabis use simply cannot be made to conform to the boundaries established by present medical institutions. In this case the demand for legal enforcement of a distinction between medical and nonmedical use is incompatible with the realities of human need. I know that to say this is to invite the charge that medical marihuana advocates are only using medicine as a stalking horse for the legalization of nonmedical use. This false accusation is actually a mirror image of the view taken by enemies of marihuana. They are unwilling to admit that it can be a safe and effective medicine largely because they are committed to exaggerating its dangers when used for other purposes. Nevertheless, it would be hypocritical to deny that there is a connection. Tolerance for marihuana use in general is growing as experience of its many medical uses becomes more widespread, because everyone understands that one important aspect of its medical usefulness is its safety. For 26 years I have been urging the legalization of marihuana for general use. That would be desirable for many reasons I cannot go into here. But at one time I thought that medical use could be treated as a distinct issue. Even people who might never see the urgency of legalizing nonmedical use would be willing to respond to medical need. Now I have come to the conclusion that this distinction may be invalid, and that on the contrary, making marihuana fully available as a medicine is another reason for general legalization. Ideally, cannabis should be available under more or less the same rules now applied to alcohol. If the present political and legal system is too ossified to accommodate that change, as I fear it is, we must at least encourage a climate of tolerance for all marihuana use, so that the laws will not be enforced in all their pointless harshness. Doctors must no longer fear that they have something to lose by recommending marihuana, even when the law is uncertain, as in the California example I just mentioned. Patients should no longer have to fear that their motives will be questioned and they will be charged with "improper" use. That will be possible only when it is clear that no one is being arrested or persecuted for any cannabis use. The full potential of this remarkable drug, and its medical potential in particular, will be realized only when, officially or unofficially, the present era of prohibition has ended. References 1.) L. Grinspoon and J. B. Bakalar, Marihuana, the Forbidden Medicine, revised and expanded edition (New Haven: Yale University Press, 1997). 2.) G. Singh, D. R. Ramey, D. Morfeld, H. Shi, H. T. Hatoum, and J. F. Fries, "Gastrointestinal Trace Complications of Nonsteroidal Anti-inflammatory Drug Treatment in Rheumatoid Arthritis," Archives of Internal Medicine 156 (July 22, 1996): 1530-1536. 3.) T. V. Perneger, P. Whelton, and M. J. Klag, "Risk of Kidney Failure Associated With the Use of Acetaminophen, Aspirin, and Nonsteroidal Antiinflammatory Drugs," New England Journal of Medicine 331:25 (December 22, 1994): 1675+1679; P. M. Ronco and A. Flahault, "Drug-induced End-stage Renal Disease," Editorial, New England Journal of Medicine 331:25 (December 22, 1994): 1711-1712. 4.) L. Lasagna, "Clinical Trials in the Natural Environment," in Drugs Between Research and Regulations, ed. C. Steichele, W. Abshagen, and J. Koch-Weser (New York: Springer-Verlag, 1985), 45-49. 5.) E. B. Larson, "N-of-1 Clinical Trials: A Technique for Improving Medical Therapeutics," Western Journal of Medicine 152 (January 1990): 52-56; G. H. Guyatt, J. L. Keller, R. Jaeschke, et al., "The N-of-1 Randomized Controlled Trial: Clinical Usefulness," Annals of Internal Medicine 112 (1990): 293-299. 6.) "State Multiple Prescription Programs," State Health Legislation Report of the American Medical Association 15 (August 1988): 35-339. 7.) H. I. Schwartz, "Negative Clinical Consequences of Triplicate Prescription Regulation of Benzodiazepines," Hospital and Community Psychiatry 43 (April 1992): 382-385; M. Weintraub, S. Singh, L. Byrne, et al., "Consequences of the 1989 New York State Triplicate Benzodiazepine Prescription Regulations," JAMA 266 (1991): 2392-2397; R. S. Hoffman, M. G. Wipfler, M.A. Maddaloni, et al.,"Has the New York State Triplicate Benzodiazepine Prescription Regulation Influenced Sedative-Hypnotic Overdoses?" New York State Journal of Medicine 91 (1991): 436-439. Copyright 1996 -- 1998 OPA (Overseas Publishers Association) N.V. - --- Checked-by: Richard Lake