RESPONSE TO MCC GUIDELINES FOR CANNABIS MEDICINE MARCH 2017
ISSUED ON AN
ENTIRELY WITHOUT PREJUDICE OR ADMISSION OF ANY GUILT OR LIABILITY BASIS
Firstly ii do give thanks for this opportunity to engage
in discussion about the future of Cannabis Medicine in South Africa.
- AUTHORISED
PRESCRIBERS/MEDICAL PRACTITIONERS
Registered doctors may now apply to MCC for permission to
access and prescribe Cannabis Medicine.
This is a positive step in the right direction because as
we know this legal medical provision has actually been in place for some time,
but as we also know that only a very few people were actually able to get such
a prescription.
The very first question the public would wish to know is
how will our Medical Practitioners’ become educated in psychopharmacology and
Cannabis Medicine in order to make conscious medical decisions?
So we are concerned as to whether doctors’ higher education is a
consideration?
Many of us have long believed that doctors will
eventually learn about Cannabis Medicine from their patients so now we see the
law making provision for sick people to pay steep fees for the privilege of
being prescribed a herbal remedy which they could easily grow themselves by a
doctor who has possibly and likely never studied Cannabis Medicine or
psychopharmacology.
The reality of this medicine is that for the majority of
conditions proven and accepted to be treated with Cannabis for over 5000 years like
pain, inflammation, menstrual pain, anxiety, depression, insomnia, anorexia, nausea
and vomiting it is most effective when smoked and this is the delivery system
which doctors will most likely have a moral and ethical issue with.
These conditions also affect the majority of our
population especially women from as young as 12 years old.
“Cannabis products
intended for medicinal use may thus be made available:
In exceptional circumstances
In conditions where other treatments have failed
To specific patients under medical supervision “
This reminds of a press statement issued by the Italian
Minister of Health a few years ago where he stated proudly that they “would decide who was sick enough to get
this medicine.”
We pray that we will not be like the US and keep a
limited and unrealistic list of conditions which may ONLY be treated with
Cannabis Medicine. To this day the US has still not added Autism to their list
yet around the world we know that this medicine is both suitable and
appropriate for this condition and further it actually gives positive results.
We do appreciate “In conditions
where other treatments have failed” as most prescription
medicines do fail and this is because most of these drugs in fact inhibit our
Vitamin D uptake and inhibit our Endocannabinoid Systems not to mention long
term liver damage and other nasty side effects.
Around the world we can see that the only way the people
will be able to legally access this medicine is via the pharmaceutical industry
and strictly controlled and expensive.
Even today we are witnessing some US states with Cannabis
Medicine Dispensaries operating for years already now having to deal with their
own federal people who insist on raiding them regularly, but now having to face
the reality that they may have to fight a new government system which does not
necessarily agree upon legal Cannabis Medicine as ludicrous as this sounds it
must surely be ‘fake news’ or else it seems these governments have something to
lose in ‘legal’ Cannabis Medicine. When
a story doesn’t make sense you might as well just follow the money so here were
look at their massive drug cartels which carry Cannabis far and wide for
massive revenue.
“Authorisation to prescribe is dependent on the submission of
an:
Appropriate dosage regimen
Acceptable justification for the proposed use
Regular reporting to MCC”
What will happen with patients who for example have been
cancer free for say 20 years?
For many patients over the years they have discovered
that when they discontinue their Cannabis Medicine often times their condition
and symptoms will return. So for many people this is like a death sentence.
Has the MCC considered maintenance dosing of Cannabis Medicine
as a viable supplement to our preventative health care system?
Cannabis should be the first port of call in any illness instead
of leaving a patient to wait to deteriorate before considering Cannabis as a
last resort.
It is hard to believe that the average medical
practitioner has sufficient knowledge or experience to work with Cannabis Medicine
because they have never studied it unless they themselves have been consuming
same in which case ii understand that they would not qualify for the permit,
although this is not mentioned in the document.
Perhaps it is a foregone conclusion that medical doctors do not smoke
Cannabis.
I have heard many stories of patients having to succumb
to their medical practitioners ‘googling’ symptoms and remedies and we pray
this is not a taste of the future of Cannabis Medicine.
We are pleased to see that veterinarians have been
included as some other countries have not considered this in the first world.
“Only registered, authorised prescribers may apply for
authorisation to prescribe a medicine for a patient”
This appears to exclude all Traditional Healers, Traditional
Herbalists and Natural Health Care Providers who are not registered with the authorities
but who have been working with this herb for hundreds of years especially the
Rastafari Bush Doctor and Medicine Woman.
It is massive concern that even today in South Africa we
still officially have an oppressed minority group which currently is around 3
million strong and which has a solid foundation both in the Bible and in our
constitution and again this is why we are in court at the moment to fight for
our constitutional rights to continue to carry this medicine without being
properly persecuted for doing so in terms of our faith and unconstitutional
laws of the land.
It is a sensitive matter to exclude the role of the
Traditional Healer in Africa.
- LEGAL STATUS OF CANNABIS
According to the Medicines Act NO ONE is allowed to grow this plant without a permit. And if you
read the clarification to this 32 page document you will see that NO ONE is getting any permits in the
very near future.
“UN Single Convention on Narcotics Drugs (1961)
Cultivation, production, manufacture and use may only occur
through a licence issued by MCC and a permit by Department of Health.
MCC allows for the acquisition, use, possession, manufacture and
supply of medicinal Cannabis in order to provide a medical practitioner,
analyst, researcher or veterinarian therewith for the treatment or prevention
of a medical condition in a particular patient, or for the purposes of
education, analysis, or research provided a permit is obtained”
“Cannabis is a prohibited substance listed under Schedule 7
however products approved by MCC may be rescheduled to 6”
“Cannabis is a prohibited narcotic substance in South Africa.
Cultivation for any purpose other than allowed is a criminal offence.
Cultivation by non-licensees remains a criminal offence”
We have two important high profile court cases pending
for decriminalisation which creates a lot of paper work in applying for stay of
prosecutions by people arrested while these cases are pending. Reference the
Dagga Couple (Gauteng) and Dagga Party (Cape Town) cases.
Many of us feel that the two main reasons this plant
remains illegal are revenue and recreation.
If this plant did not possess psychedelic properties we
might now not even be spending time on this document. On a spiritual level Cannabis opens our
chakras and our consciousness to the deceit on this planet. As do other
psychedelic substances found in nature such as sacred mushrooms.
Cannabis also reveals a person to themselves and for a
lot of people this could be quite intense and this is why people who use
Cannabis are more conscious of their behaviour.
Cannabis must only be consumed in its pure whole herbal
form.
To legalize for recreational purposes and even medicinal
is a real challenge to world leaders
The story of alcohol versus Cannabis is an old one and a
real one…if alcohol had psychedelic properties it would still be illegal. Alcohol is under fire in “The Trial of The Plant”.
It seems at this stage around the world that any
substance which opens the mind to truth and spiritual enlightment will not be
tolerated by world leaders.
So at the very least Cannabis should be decriminalised
and treated exactly the same way as alcohol. In the future ii can see a lot of
‘silly court cases’ having to be endured, because truly it is ridiculous to
persecute a person for using a herb which the government itself is prescribing
but only to certain people under certain conditions. Truly there ought to be a
moratorium on Cannabis laws.
“Making people criminals for taking
psychoactive substances is in itself criminal, for one is dealing with, at
worst, a vice but not a crime.” – JP van Niekerk, Managing Editor – South
African Medical Journal.
All plants have consciousness but this particular herb
has a consciousness all of its own and this is because of the way in which this
plant and its humans have been persecuted over the ages.
This persecution was even anticipated in the scriptures…
Ezekiel 34 vs 29
“And I will raise up for them a plant of renown, and they shall be no
more consumed with hunger in the land, neither bear the shame of the heathen
anymore.”
Section 10 of
our Bill of Rights states “Everyone has
inherent dignity and the right to have their dignity respected and protected.”
So for people like myself,
in the eyes of the law and in the eyes of our families we are criminals for a
plant and a medicine even though we are saving people’s lives daily we still
have to live in fear as we heal, and surely this is not dignity. This of course
also affects our chances of gaining employment in the work force and other
scenarios where a criminal record is unacceptable.
- LICENCE HOLDERS, EMPLOYEES AND PERSONELL
“The applicant for licence/permit should not have a history of
illicit drug use or a conviction for an illicit drug-related offence.
UNSUITABLE EMPLOYEES
- Under
18
- Convicted
of a serious offence
- Has
a drug addiction or has had treatment or rehab
- Has
a history of illicit drug use or a conviction”
Under legal status we are informed that Cannabis remains
a Schedule 7 prohibited narcotic drug.
So the message is that no persons who consume Cannabis or
who have Cannabis related convictions will ever be allowed to work in the
Cannabis industry.
These employees will surely have to wear extreme
protective gear, to ensure barrier planting, to prevent the resin from getting
into contact with their skin and activating their Endocannabinoid Systems
because drug testing for employees is guaranteed so employers must guarantee
that the resin won’t seep through protective clothing.
This motion therefore excludes the majority of the people
who carry the wisdoms, passion, skills and grow experience required to work
with this plant. We do not doubt that any botanist or horticulturist will
eventually figure out how to grow Cannabis but we are just saying that there is
a lot to learn especially with regards to pest control.
For this reason ii am extremely concerned about the use
of pesticides as we have already seen in our food production and we are
noticing from overseas markets that a lot of Cannabis is recalled due to
pesticide problems.
So many people who consume Cannabis have been fighting
and looking forward to a positive experience working in the Cannabis industry
only to now be totally excluded unless they stop consuming.
- SECURITY MEASURES
It is prudent to be so security conscious because we
believe that the way in which access is denied to the majority will result in
an increase of Cannabis crimes which in turn will boost the security industry.
- SEEDS AND LABELLING MATERIAL
This is a huge concern and seems to be in line with
corporates like Monsanto who insist that we may only use their seeds in food
production. Seed which have been altered
in any way is simply not natural and not acceptable for our health. People
should be able to grow their own known strains which work for them personally.
“Specific Provision for the production of Cannabis intended for
the processing into a standardised herbal medicine “chemically
defined isolated constituents or their mixtures are not considered herbal
medicine preparations.
Herbal medicine preparations may contain other components
such as solvents, dilutents and preservatives.”
Despite successful CBD isolation in Israeli research
there is sufficient evidence to prove that Cannabinoids simply do not work as
well when isolated and some cease to occur when others are isolated.
So ii am deeply concerned about nature, which is perfect
beyond any man’s comprehension being altered and synthetic Cannabinoids being presented
to people as natural herbal medicine.
- TESTING AND QUALITY CONTROL
Personally ii believe that testing and quality control
are the two most important aspects of the pharmaceutical and now the Cannabis
Medicine industry. We pray that this new
industry will be more concerned with the production and supply of quality
Cannabis Medicines not like the pharmaceutical industry which clearly continues
to produce unsafe medicines with radical side effects. Usually the side effects
are the very symptoms they are designed to cure. For example epileptic drugs can cause
seizures, osteoporosis drugs can cause more fractures and so on.
Initially the medicines which will be made available will
be imported from overseas markets, as it has been for some years now such as
Dronabinol, Marinol and Sativex for instance, and if you do your homework you
will see that many batches of these products, specifically Dronabinol, and
other synthetic Cannabinoid medicines have been recalled over the years mostly
due to pesticide levels, bacterial formation and inducing of suicidal thoughts
especially when used in conjunction with alcohol or other narcotics like
cocaine for instance.
The MCC confirms that it has already registered ONE
Cannabis medicine as a Schedule 6 and we give thanks for forward thinking in
this regard.
So we are concerned about the quality of some of these medicines
which will now land on our shores in larger quantities.
Also we are concerned that these medicines are not produced from
whole herbal plant and have therefore been altered through dilution which has
serious pharmacological effects when working with this plant.
Most people are aware of global trends in molecular
sieving, gas chromatography, mass spectrometer testing and other Cannabinoid
isolation techniques so we can see that people are really trying to look at the
pharmacological science of the plant.
Most efforts to alter the components of this plant are to
reduce or eliminate the psychedelic components clearly showing that there is a
shortage of scientific psychopharmacological and biological research and
knowledge when working with the over 800 chemical components of the Cannabis
plant.
- FEES
We simply cannot see how the average South African would
be able to afford these fees even the fees required to just be paid by the
patient for application for prescription.
This places this medicine out of the reach of the majority of our people
and into the hands of the rich and corporates.
This is unacceptable on so many levels because this plant
should be free for everyone to use who might need it.
What about the private individual who heals themselves or uses
Traditional and Natural Healers? What about the Healer?
Personally ii do agree with Julian and Myrtle that the
only paperwork which should be required to work in this industry is a tax
number.
- RESEARCH
“All studies involving medicinal Cannabis for clinical or scientific
research require a permit issued by the Director General of Health in terms of
Section 22A(9)(a)(i) and prior approval by MCC.
Approval by an independent research ethics committee may be
required”
Our constitution clearly states that we have the right to
engage in research.
Chapter 2 of our
constitution Section 16 of The Bill of Rights contains detailed provisions with
regard to freedom of expression, stating
“Everyone has
the right to freedom of expression, which includes freedom of the press and
other media; freedom to receive or impart information or ideas; freedom of
artistic creativity; and academic freedom and freedom of scientific
research.”
Section 16
contains the following limitations to freedom of expression “The right in
subsection (1) does not extend to propaganda for war; incitement of imminent
violence; or advocacy of hatred that is based on race, ethnicity, gender or
religion, and that constitutes incitement to cause harm.”
Average people have been researching Cannabis medicine
for more than 30 years now in South Africa and indeed many medical
practitioners have started to educate themselves and this is a positive step
forward.
CONCLUSION AND FINAL MOTIVATION
Personally ii never ever imagined that ii would have the opportunity
of writing a response to my government’s guidelines for Cannabis Medicine in my
own life time, so truly this is a wonderful occasion especially the fact that
public opinion has been sought for comment to these guidelines.
It is only through the teachings of my Elders and Masters that ii have
known since a young girl that we have “THC Receptors” and that Cannabis cures
cancer and we have all now seen how Cannabinoid treatment can be used to treat
a wide variety of disorders and health conditions also eliminating many
age-related conditions like cell degradation.
We have all become
more educated from research studies being released through the emerging science
of Cannabis Chemistry and Cannabis Medicine, and one thing is very clear, a
fully functional Endocannabinoid System is essential for health.
All evidence
indicates that the Endocannabinoid System and the Cannabis plant both have a
very profound effect on the human body.
The very fact that we
have this system proves that we are in fact intended to consume Cannabinoids
not only as a medicine but as a supplement to maintain our Endocannabinoid
Systems because it has been scientifically proven that Cannabinoid deficiency
leads to illness.
So truly if you
really think about it Cannabis has gone from dangerous narcotic drug to a
healing medicine to a vital vegetable in just 99 years in our country under
prohibition.
With all this
scientific evidence it is really hard to understand and to explain to our
children why this plant is still illegal.
GENESIS 1
VERSE 29
Especially when we
also know that scientists and medical professionals around the world now agree
that the psychedelic effects of Cannabis’ active pharmacological component THC
are only short lived and pose no negative side effects and no one has ever died
from Cannabis use and overdose is virtually impossible and that in fact
Cannabis is a remarkably tranquil and calming medicine unlike alcohol which
alters the mind negatively and this is why we constantly see such terrible
behaviour which people then claim that they cannot even recall. Perhaps this is why they call it ‘spirits’
because it makes you unconscious and it has been scientifically proven that the
human vibrates at the lowest possible frequency when under the influence of
alcohol and this is why they tend to react to aggression so much.
This is why we are in
court now over the legitimacy of criminalisation of Cannabis and alcohol is under
hot debate.
These same
professionals also agree that addiction is alike to that of coffee or
chocolate. Many recovering addicts can testify how Cannabis has helped them in
their recovery especially from alcohol and other drug addictions and in fact
has helped to keep them off these dangerous drugs and alcohol is by far the
most dangerous drug on the planet yet it remains legal.
Governments around
the world including the USA accept that “Cannabis is the
least toxic plant known to mankind”.
So for world
governments to still try and convince us that this plant is a dangerous drug is
truly becoming more and more unacceptable to more and more people. Pretty soon there will be more people
consuming Cannabis than do not and this will be interesting times in terms of
law making as we have seen around the world in a short space of time.
At this time more
than 80 controlled clinical trials on humans have been published as well as
more than 15 000 peer reviewed scientific articles on the chemistry and
pharmacology of Cannabis and Cannabinoids as well as more than 2000 articles on
the body’s natural Endocannabinoids so really no one can say that the research
has not been done or that we need more research.
Section 11 of our
Bill of Rights states that
“Everyone has the
right to life”
Consuming a natural herb which contains the vital
chemicals we need to maintain our health is equivalent to life in the same way
as being denied this herb is dangerous and threatening to our health and lives.
There is currently an explosion of scientific research on
the therapeutic potential of Cannabis, with no lack of evidence, and in fact more
evidence than you can find on some of the most popular remedies of conventional
medicine. You could say this is the most researched plant on the planet.
In my mind Cannabis Medicine is the single most useful
herbal remedy in the treatment of the widest range of medical disorders and
diseases.
Cannabis Medicine has already been proven to be the vital
element of preventative health care and the natural source of an adaptive
support and defence mechanism in our ever increasing toxic, carcinogenic
environment which we find ourselves today.
It is my personal belief that the average person in the
street should be permitted to grow a limited number of plants for personal
medicinal consumption. Not everyone wants to grow Cannabis or even their own
food, so there will always be a need to dispense this medicine.
It is therefore unacceptable for this plant to be denied
to the majority of our people by rigid financial and legal barriers and
everyone should be free to grow this God given herb in their back gardens.
Again we give thanks for the opportunity to express our
opinion on this platform and look forward to positive healing of the nations in
the future.
Sister
Vee Nohombile Bush
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