I am writing this email to provide feedback for the attached testing proposal. Implementing testing standards in a medical cannabis program that has existed for over 20 years without them is a tremendous challenge involving the interests of a variety of stakeholders. I very much appreciate OCP staff's time and efforts in producing such a balanced approach. This approach moves the program toward patient safety in a timeframe that allows industry participants to adjust their business models accordingly.
As a patient representative in this workgroup, my primary concerns are patient safety and medicinal efficacy. From that perspective, I would obviously prefer stricter standards implemented more quickly, but I understand the need for moderate compromise and transitional periods when implementing significant change. Again, I applaud the thoughtful process behind this proposal.
My only suggestion for improvement would be for the labeling requirements. Patient education is a key component of patient safety. Informed patients are increasingly able to protect their own safety and health interests in any medically-related situation, and labels are an opportunity for a teachable moment with patients. Many do not know the gamut of problematic elements commonly associated with cannabis and cannabis products.
If the labels were to read: Passed Mandatory Testing For (include analytes); not yet required to test for other analytes, patients would be more inclined to learn about what might be in their medicine. People can't ask questions they don't know to ask, and as I have discussed in the workgroup, I frequently hear and read about people assuming medical cannabis products are tested at least to the same standards as adult use. The phrase "Passed Mandatory Testing" may confuse patients who would assume that testing meets the same standards found in the adult use program. Further, a similar level of possible analyte disclosure on the "Not Tested" labels used by exempt participants would encourage patients to ask their providers about growing and harvesting practices, etc.
Thank you for the opportunity to offer this feedback, as well as the time spent preparing this proposal and hosting this workgroup.