Consultation on the medicinal cannabis scheme: NORML’s advice for patients

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The government is working on setting up New Zealand’s medicinal cannabis framework. Now is the final moment for all of us to have a say in what that will look like.

The Ministry of Health has put out a very long document outlining their proposals. There’s a lot in there. You don’t have to read every word of it. But if you care about the future of medicinal cannabis access in this country, it’s important to make comments in the Ministry of Health’s public consultation, which is open online now through 7th August.

Below are summaries of some of the key issues – and some guidance on how to have your say.

What’s good

What the government is proposing is far from perfect. But let’s start with the things that ARE good, just to be clear that progress is happening:

  • We will have a NZ-based medicinal cannabis industry.
  • A range of products will be available, including dried herbal cannabis and oral medicines.
  • Cannabis could be prescribed for any health condition.
  • Prescriptions will no longer need to be signed off by the Ministry of Health.

What’s not happening

  • There is no provision for patients to grow their own, or for ‘green fairies’ to provide cannabis in the community. If you want to grow your own, help make sure the referendum for full legalisation passes in 2020!

Issues we’re concerned about

Here are some of the key issues the Ministry of Health is raising for consultation right now.

Who prescribes? This is one of the most controversial issues that remains to be decided. Currently the Ministry is proposing that all cannabis prescriptions would have to be signed off by a ‘specialist’. It’s not clear exactly how they are defining ‘specialist’, and exactly how this process would work. Will patients have to travel to see a medical specialist in person? What about chronic pain, considering that there is a shortage of chronic pain specialists in New Zealand? We’re already hearing a lot of concern from patients and caregivers about this. If you have concerns about having to go through a medical specialist, it’s important to communicate these in your submission in section E of the consultation.

What’s it going to cost? There’s a lot of nice language in the government’s proposals about ‘equity’. But they don’t seem to have done any work yet on how to ensure that cannabis products are affordable for all. We’d like to see the government work out ways to keep costs down for patients. Again, if this is important to you, mention it in your comments.

What’s the production standard? There are a lot of acronyms in the air at the moment! The Ministry is asking for feedback on what standard cannabis products should meet. One proposal is for GMP (Good Manufacturing Practice), a global certification system which is basically pharmaceutical-grade. The other option is GPP (Good Production Practices), a Canadian model which is slightly more flexible and is more of a near-pharmaceutical standard.

Both GPP and GMP medicines should present good enough quality for patients. GMP will be a harder standard for some manufacturers to reach, so it could mean there will be a smaller number of companies, operating at pharmaceutical-level quality. It’s hard to predict how this would affect the cost of products.

Who can enter the industry? Currently the government is proposing that anyone can work in the medicinal cannabis industry. But they’re also proposing that having a past drug conviction could stop someone from being a company director, licence holder or responsible person in the industry.

One of the other big issues will be the licence fees. Currently the Ministry is proposing to set the fees quite high, which could make it hard for small growers to participate.

Have your say

There are plenty more technical issues in the Ministry of Health’s proposal. Don’t worry if you don’t have time to fully analyse the whole 109 pages. What matters most is that you go online and send the government some feedback. You don’t have to answer every question; you can just answer the questions where you want to give input.

It’s also really important that there are submissions from medical professionals who support broad access to cannabis products. So if you have a supportive doctor, please encourage them to make a submission as well.

The deadline to comment is August 7th. Your comments could help us have a more fair and accessible medicinal cannabis industry in New Zealand.

Here’s where to do it – click on the “online survey”: https://consult.health.govt.nz/medsafe/medicinal-cannabis-scheme-consultation/

More info

If you are having trouble making your submission and would like some support, contact us on medical@norml.org.nz.