From Allan Frankel, MD, April 13:   I was asked to either attend a City Council meeting in San Diego or write a letter. The city is looking to ban edibles and virtually all oil extraction.  I am in the process of moving, so going down Wednesday was just not possible. So, attached is the draft of a letter.

This is a very bad move on the part of SD and others could follow. I THINK it was triggered by the sad foolish college student last week who had the “first marijuana death.”  In actuality, he was eating brownies [containing a cannabis extract] and ended up jumping out of a window and dying.  I  wonder what else he was taking? So sad and no unnecessary, but certainly no reason to BAN edibles.

My name is Allan I Frankel, MD. I am a practicing Internal Medicine and Cannabis specialist practicing in the Santa Monica area of Los Angeles since 1979. I am board certified and was trained at UCLA. In addition, I spent 15 years on their clinical faculty, teaching residents. So, my roots, so to speak, are deep in traditional Allopathic or Western Medicine.

 I came to understand the benefits of cannabis in the 1970’s while still at UCLA dealing with glaucoma patients and cancer patients. I have always viewed it primarily as a medicine. I began doing full time clinical and lab research in 2007 and over the years I have learned much about this confusing industry and medicine. For one thing, I have learned that it is truly a great source of terrific medications, but has been left overly un-regulated.

In making any good cannabis medicine, knowing the precise dosing of the cannabinoids present in the dose is critical. This applies whether the medicine is smoked, vaporized, ingested or used as a tincture. In general, I favor dosed tinctures, but all methods have clinical value WHEN THEY ARE MEASURED AND DOSED. 

It is always much easier to ban than to regulate, but in part I believe this occurs because nobody has set forth reasonable standards.

Using cannabis oils to create medicines is critical; else there is no possible dosing. The problem is that restricting oil production will encourage smoking and vaporizing which are ok but cannot be dosed in the manner that NON SMOKING patients wish to use the medicine. This would punish the majority of citizens as they begin using more CBD or Cannabidiol based medicines. These will all be “oil based” and will be dosed by the mg and taken both orally, under the tongue as well as by other methods of administration.

Eliminating cannabis oil extraction, thereby ending the possibility of having predictable and dosed medicine would place San Diego years behind and force their citizens to use out of city supply for their medicines. They are already coming to LA and will be getting more and more dosed-non-smoked medicine from Los Angeles. It is an exploding business. Does San Diego want to remain behind?  

It is paramount to know, that without safe plant oil extraction, which is very possible with both CO2, alcohol and other methods, there can be no possible true mg dosing. It is true that many patients can smoke their medicine, but the vast majority of patients will be patients who do not smoke. They are the people out there, the majority of your citizens. All these dosed and wonderful medicines are safely extracted using CO2 Extraction techniques, which are basically evaporating dry ice and the resulting oils diluted to 15 mg/ml. 

The volume of revenue to be lost at this time with CBD extracts exploding on the scene might be considered before making any final decisions with regard to banning oil.

 So, what should be done?

 I think that the time has come for reasonable regulation rather than shutting down facilities and making somewhat arbitrary decisions on what is good and what is bad medicine.

 I have been working in the field of Internal Medicine for 35 years and the Cannabis field for nearly eight years. I know that dosing is everything and I believe that anything that is using in the cannabis product field needs testing and regulation. I believe reasonable regulations can be rapidly formed and adopted as we know have knowledge and the technology to do it. I would be more than happy to help create these standards and separate the wheat from the chaff.

How about instead of banning oils, they are regulated and tested?

How about dosed “oral buccal” extracts just as Pharmaceutical companies are doing in Europe and many product makers are doing throughout California. 

 We now know what reasonable dosing is for patients and what is just not reasonable. Frankly, there are some products out there that just should not be out there. This can be solved and the City and many patients will benefit.

Legalization is coming – probably in 2016 and with it will come regulation of recreational cannabis greater than medical cannabis is now being regulated. It is very clear what sorts of regulations need to be in place and it is possible to do so.

I wish I could have been at this meeting in person, but my patient demand is too great. By the way, all my patients are using dosed extracts or tinctures by the mg under the tongue. If we had no ability to extract cannabis and measure dosing, my patients would all be experimenting at home. 

This does not have to happen.

Again, at my own expense, I would be happy to meet with any group in San Diego to discuss this in much greater detail as well as putting together sane regulations. It is not that difficult. We can do it together. Let’s just be careful to not exclude safe oil creation, as it will punish the most critically ill patients the most and leave more casual patient users with smoking options that most patients do not want. 

Allan I Frankel MD