Tell the FDA WTF Is Up with CBD (As Long as You Do It Nicely)
April 12, 2019 | Geoffrey Marshall
By Josh Jardine for The Stranger
I wish we could sway federal policy with patient stories—and, to a degree, we can on Capitol Hill—but with a regulatory body like the FDA, they’re looking for very specific answers to very specific questions. It’s not like an up/down vote on how many comments in favor and how many comments against [CBD products]. It’s based off the quality and content of the comments.” -David Mangone
Since the Farm Bill passed earlier this year—and with it the legalization of hemp—CBD has become the white-hot next big thing, and it's showing up everywhere, in everything. The Food and Drug Administration has begun a crackdown on CBD when added to food and beverages, or whenever health claims are made. ("If you want to cure your cancer and regrow your hair while adding inches to your manhood, you need our CBD!")
Before establishing new policies surrounding CBD, the FDA is holding hearings and soliciting input, meaning that it's time once again be proactive and make your voice heard. However, equally as important as weighing in is the manner is which you do so. This means using our indoor writing voice, and recognizing the FDA isn't a friend to THC/CBD (yet).
To help you submit something that has the greatest impact while staying on topic (something many stoners struggle with at times), Marijuana Moment spoke with David Mangone, the government affairs director for Americans for Safe Access, a nonprofit that works to support advancement in medical cannabis access and research.
Mangone shares some insightful and valuable guidelines in deciding what you want to share with the FDA. Turns out what might feel therapeutic ("you are so stupid for hating on CBD, so stop it, jerks!") doesn't really help the cause. You dowant to help the cause, right? Great, because the cause needs your help.
While you have until July 2 to submit your views to the FDA, you should do it ASAP, because you will forget. Yeah, you will, weed lover, we both know it. So finish reading this piece, and then log on to submit your well-researched and thought out input.
As Marijuana Moment puts it, "Broadly, the FDA wants to see information concerning the notion that hemp-derived CBD is safe to consume in food, what kind of standards need to be put into place to ensure product quality and consistency, and what information needs to be included on labels to ensure consumers know exactly what risks they’re taking, if any."
While sharing your story about how CBD helped you or a loved one, or simply typing in "I love Mary Jane!!" counts, Mangone explains that won't actually do any good, and when talking about the FDA, never has. "That’s not really what the FDA is ever looking for," Mangone told Marijuana Moment. "I wish we could sway federal policy with patient stories—and, to a degree, we can on Capitol Hill—but with a regulatory body like the FDA, they’re looking for very specific answers to very specific questions. It’s not like an up/down vote on how many comments in favor and how many comments against [CBD products],” he explained. “It’s based off the quality and content of the comments.”
The questions Mangone refers to are very specific, so your submission should be in response to one or more of the FDA's specific questions. There are plenty to select from, and they're listed under the header III. Issues for Consideration and Request for Data and Information. (Examples include "Are there particular safety concerns that FDA should consider regarding its regulatory oversight and monitoring of these products?" and "What are the characteristics of a successful system to collect representative safety information at the national or State level about products containing cannabis and cannabis-derived compounds?")
When you've found a question you want to answer, Mangone suggests backing up your submission with legit sources for studies and data. In addition to a collection of peer-reviewed information the ADA has compiled, he also suggests Health Affairs, PubMED, and other medical journals. These carry more weight than stories about your mom's CBD arthritis cream, even though your mom is great.
If this seems like a chore, that's because it is. But it's important that on the rare occasions federal regulatory agencies actually ask for public input on cannabis and hemp, anyone using cannabis speaks up, and loudly. Change is incremental, and it's made through tasks such as these, even if they may seem like homework. Step up.
Here's the FDA's proposed rule document, where you can leave your intelligent, thought-out and well-researched public comment.