Pages tagged "public comment"

  • ASA/PFC Submit Comments to USDA for the Establishment of a Domestic Hemp Program

    The United States Department of Agriculture closed its comment period after requesting information on the establishment of a domestic hemp program. ASA/PFC submitted comments for the 12 questions being asked, which included additional requirements for measurement uncertainty and requiring the use of sound scientific methodology when quantitatively determining THC content.

    This is the second set of comments submitted to USDA by ASA/PFC and we look forward to results of this comment period in order to continue to improve the PFC program so that certification clients know they are getting the most up to date assessment.

    Review the comments we submitted to the USDA.

    Take a look at all the comments submitted to the USDA.

  • ASA offers solution to DOJ research block: Our comments on the DEA’s proposed rules

    On March 23, the Drug Enforcement Administraction (DEA) published a proposed rulemaking—“Controls to Enhance the Cultivation of Marihuana for Research in the United States”—in the Federal Register (85 FR 16292), involving who can grow cannabis in bulk for research purposes.  Americans for Safe Access (ASA) submitted comments which suggested several amendments to the provisions of these regulations governing the bulk marijuana manufacturers program. In the comments, we suggest to federal legislators and the DEA that a new agency be established that has no history in prosecution of the activities of which the DEA seeks to become the sole enforcer. This new agency, the Office of Medical Cannabis Control (OMCC), would be tasked with overseeing not only the requirements of the research program, but would also enable cultivators that are already licensed in medical cannabis states to provide high quality medical cannabis to researchers, thereby increasing the diversity of products that can be used in research studies and clinical trials.

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  • Submitting Comments That Will Make A Difference

    Americans for Safe Access Wants to Help You Navigate the Federal Regulatory Process

    Earlier this spring, the Food and Drug Administration (FDA) issued a notice in the Federal Register that invited the public to submit scientific information and comments on cannabis and cannabis products. This is not the first time that the FDA has called for comments. In 2018, the FDA solicited public comments to help determine the United States’ position on the rescheduling of CBD and other cannabis compounds under international law. Fortunately, in recent years, there has been a shift in the FDA’s attitude about cannabis. Currently, their website acknowledges that states are developing their own programs and that there is medical value to, at a minimum, isolated components of the cannabis plant, marking a shift from previous years when the agency outright ignored the progress being made at the state level.

    Regulatory comments are a good way for activists to make their voices heard. However, unlike typical grassroots campaign activities that rely on building coalitions and generating large scale support, regulatory comments do not benefit from a large number of people saying the same thing. In fact, the FDA itself specifies that the FDA comment process is not a popularity contest in which the agency will adopt the policy position promoted by the greatest number of commenters. What the FDA and other regulatory agencies look for during the commenting process are concise, well-thought-out responses that cite scientific research and make recommendations for sound public policy.

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