SUBMISSION OF THE BEYOND PROHIBITION FOUNDATION IN RESPONSE TO PROPOSED IMPROVEMENTS TO HEALTH CANADA’S MARIHUANA MEDICAL ACCESS PROGRAM
INTRODUCTION
The Beyond Prohibition Foundation was established in 2010 to advocate for the repeal of cannabis prohibition and its replacement with a system of regulated production and distribution. It operates the website www.whyprohibition.ca, Canada's largest dedicated drug policy reform website and host to more than 30,000 members. The Foundation's mission includes advocacy on behalf of safe access to medicinal cannabis and cannabis byproducts for those obtaining therapeutic and medicinal benefit.
This submission responds to Health Canada's consultation document titled "Proposed Improvements to Health Canada's Marihuana Medical Access Program" (the "Consultation Document"). In the Consultation Document, Health Canada foreshadows significant changes to Canada's medical cannabis policies. The Foundation welcomes Health Canada's tacit acknowledgement that the current Marihuana Medical Access Regulation (MMAR) system is deeply flawed and in need of significant reform. That reform is necessary in two primary areas: (1) the need to improve access to the legal protections afforded by the legislative and regulatory scheme; and (2) the need to provide consumers with safe access to an effective supply of medicinal cannabis and cannabis byproducts. This submission lays out the Foundation's view of the proposed changes and offers suggestions for making necessary improvements to the federal program.
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