The Florida Department of Health recently issued a new proposed rule making workshop for September 17th at 9am in Tallahassee. This workshop is for the dosing guidelines the Office of Medical Marijuana Use will adopt and put into law. The full text of the notice can be found below. The purpose of this proceeding is to address daily dose amounts and equivalent dose amounts for each allowable form of medical marijuana in Florida. What this means is the OMMU is looking for input into what the limits on dosing should be. They are looking for feedback from a variety of organizations and groups to determine the maximum allowable daily dose per patient and maximum allowable daily dose per modality of administration.
Patients are going to suffer as a result. All existing data proves that medical cannabis is a user specific experience. The same medicine will affect ten people differently. The same dose of medicine will affect ten people differently. Patients with a metabolic issue may require 20-50 times as much medical cannabis as a patient with a normal metabolic function. Science does not have answers for why there is a huge variance in the amount of cannabis that a patient must consume for desired effects. The end result of the OMMU setting dosing guidelines will be a further restriction on access to medical cannabis. The only fair way to treat dosing, is to leave it up to the physician to determine what the patient needs are.
Contact your legislator and voice your concerns about limitations on patient access to medical cannabis. Tell them that dosing limits will cause harm to patients.
Please read the full version of the Rulemaking notice below.
Notice of Development of Rulemaking
DEPARTMENT OF HEALTH
Office of Medical Marijuana Use
RULE NO.:RULE TITLE:
64-4.015Dosing for Low-THC Cannabis and Medical Marijuana
PURPOSE AND EFFECT: The Department of Health announces the convening of a negotiated rulemaking proceeding to address daily dose amounts and equivalent dose amounts for each allowable form of marijuana dispensed by a medical marijuana treatment center. The purpose of the negotiated rulemaking is to draft a mutually acceptable proposed rule.
SUBJECT TO BE ADDRESSED: The subject and scope of the rule to be developed through negotiated rulemaking will be the regulatory structure for daily dose amountsand equivalent dose amounts for each allowable form of marijuana.
RULEMAKING AUTHORITY: 381.986(4)(c) and (h), FS.
LAW IMPLEMENTED: 381.986(4)(c), FS.
NEGOTIATED RULEMAKING COMMITTEE: The negotiated rulemaking committee members will be selected from the following representative groups:
1. A member of the Florida Medical Association;
2. A member of the Florida Osteopathic Medical Association;
3. A member of the Florida Board of Medicine;
4. A member of the Florida Board of Osteopathic Medicine;
5. A representative of qualified physicians who meet the criteria of section 381.986(1)(m), Florida Statutes;
6. A representative of qualified patients who meet the criteria of section 381.986(1)(l), Florida Statutes;
7. A representative of the Coalition for Medical Marijuana Research and Education
8. A representative of the Department of Health.
If you believe that your interests are not adequately represented by the committee members listed above, you may apply to participate within 30 days of the date of publication of this notice. Your application must contain the following information: your name, business address, and telephone number; the name of any organization you are representing; a description of the organization or the members of the organization; a description of how the proposed rulemaking proceedings will affect you or the parties that you represent; a statement identifying the reasons why you believe the representative groups listed above will not adequately represent your interests; and a statement that you are willing to negotiate in good faith and can attend the scheduled meeting. Please submit your application to Courtney Coppola, Department of Health, 4052 Bald Cypress Way, Bin M-01, Tallahassee, Florida 32399, email address: Courtney.Coppola@flhealth.gov.
NEGOTIATED RULEMAKING COMMITTEE MEETING:
The committee will meet at the following date, time, and place to discuss rule development: September 17, 2018, 9:00 a.m. -5:00 p.m. or until concluded, the, Department of Health, Room 301, 4052 Bald Cypress Way, Tallahassee, FL 32399.
Pursuant to provisions of the Americans with Disabilities Act, any person requiring special accommodations to participate in this meeting is asked to advise the agency at least 7 days before the meeting by contacting Courtney Coppola, Department of Health, (850)245-4274, Courtney.Coppola@flhealth.gov. If you are hearing or speech impaired, please contact the agency using the Florida Relay Service, 1(800)955-8771 (TDD) or 1(800)955-9770 (Voice).
THE PERSON TO BE CONTACTED REGARDING THE PROPOSED RULE DEVELOPMENT AND A COPY OF THE PRELIMINARY DRAFT, IF AVAILABLE IS: Courtney Coppola,Email address: Courtney.Coppola@flhealth.gov