CADFY’s Statement to the Commission on Narcotic Drugs General Session – Vienna 2020
Regarding The World Health Organization’s recommendation 5.5
Recommendation 5.5: A footnote should be added to Schedule I of the 1961 Single Convention on Narcotic Drugs to read: “Preparations containing predominantly Cannabidiol (CBD) and not more than 0.2% of delta-9-THC are not under international control.
Thank you for giving me this time to speak before this distinguished body.
It is important to understand that CADFY has grave concerns regarding the World Health Organizations Recommendation 5.5
“In Recommendation 5.5, The Word Health Organization (WHO) and its Expert Committee on Drug Dependence (ECDD) have recommended that “preparations” containing predominantly CBD and not more than 0.2% THC be excluded from international control. The use of the term “preparation” will cause significant confusion, since, under the Single Convention, that term can apply to finished products. If WHO/ECDD had intended for their recommendation to apply only to drug substances or Active Pharmaceutical Ingredients, not to finished products, they had other terminology choices (such as the term “drug”) that would have caused less confusion, or they could have clearly explained their intention in the surrounding text. On the other hand, if WHO/ECDD did intend for their recommendation to apply to finished products, then the scientific justification on which they based the recommendation is mistaken. They relied almost exclusively on the abuse potential data from the Epidiolex studies (Epidiolex is the only purified CBD product to be approved as a prescription medication in the US and the EU.) However, in Epidiolex the finished product, the THC content is only 0.01% . By contrast, in the crystalline CBD drug substance or Active Pharmaceutical Ingredient of Epidiolex (before it is dissolved in sesame oil), the THC content is not more than 0.1% THC. So WHO/ECDD are potentially recommending the de-scheduling of products having 20 times more THC than Epidiolex. As you will see in the presentations, this can be a lot of THC. In addition, in light of the poor quality control of the CBD products currently being marketed, there is no reliable way to ensure that products purporting to be pure CBD actually do not contain concerning levels of THC. For these reasons, CADFY believes that Recommendation 5.5 should not be adopted in its current form. “
John Redman
Executive Director
Community Alliances for Drug Free Youth
