The federal government plans to legalize recreational cannabis in July 2018. On September 25, 2017, the government of British Columbia announced a public engagement process on the distribution and sale of small amounts of recreational cannabis.
So far, the federal government has indicated it will maintain two separate channels for cannabis: one for medical use and one for recreational use. The BC Pharmacy Association is pleased the government is moving in this direction. We continue to believe all medical cannabis should be regulated by Health Canada like any other controlled substance or natural health product, which means it should undergo the drug review process to ensure the safety, efficacy and quality of the medication.
We recognize that the federal government’s decision to delay further discussion and decision-making on the distribution and sale on medical cannabis beyond the current regime has led provincial governments to believe the policy discussion and decisions about recreational and medicinal cannabis should be separated and dealt with under different timelines.
We respectfully disagree that it is in the public interest to separate the public policy debate and decision-making process on recreational and medical cannabis and encourage the province of British Columbia to move forward in addressing the issue of safe dispensing of medical cannabis in tandem with the implementation of the sales of recreational cannabis.
B.C. is in a unique position regarding the entrenched and far-reaching presence of “medicinal” cannabis retailers. Unlike other provinces, where the appearance of cannabis “dispensaries” has been relatively recent, B.C. has had pot retailers for many years and in significant numbers. In all instances these retailers masquerade as businesses selling “medicines” to their “patients”. While there is no actual connection between these retail outlets and legitimate licensed producers, we believe there is a public view that these “dispensaries” sell medical marijuana. As such, we believe B.C. can’t wait to address the distribution and sale of medicinal cannabis to a later date.
Regardless of the new business model for recreational cannabis, we believe it is imperative to protect patients by making legal, quality controlled medicinal cannabis available with the oversight of a pharmacist.
The BC Pharmacy Association has had a long-standing concern about the many illegal cannabis retailers in B.C. positioning themselves as purveyors of medicinal products by using terms like dispensary and “farmacy” to market their products to consumers. There can be no doubt that these retailers use the term dispensary to associate themselves with legitimate pharmacy dispensaries.
These storefront retailers make false medical claims and the “dispensary” staff have no health care training. They do not “prescribe” based on any established guidelines or protocols and do not have training related to drug interactions. Every transaction carried out in an illegal cannabis store has the potential to put a consumer at risk of a serious medical complication. All efforts must be made to remove any aura of legitimacy these operations have as being a facility that has a role to play in the delivery of health care services. Therefore, we recommend that the provincial government take the approach of only allowing individuals governed under the Health Professions Act (HPA) to designate their businesses as “dispensaries”. Making this public policy decision will provide municipalities with the authority they need to disallow non-medical retailers of cannabis trying to assume a degree of unfounded legitimacy by calling their businesses dispensaries.
This move will provide important public protection, particularly considering the upcoming legalization of recreational cannabis. Legitimate medical cannabis, available for legitimate producers and dispensed by trained professionals, must be easily identified as such. Only pharmacists should be able to dispense prescribed medications in a pharmacy and dispensary setting.
Community pharmacists believe that medicinal cannabis should be available to patients when prescribed by a physician as a prescription narcotic. This would require medical cannabis to be included in the drugs listed in the Schedule to the Narcotic Control Regulations. It should be treated as a behind-the-counter narcotic drug in pharmacies. Just like other Schedule 1 drugs, medicinal cannabis would be stored with other narcotics. In B.C. that would require them to be stored in a time-locked safe.
Pharmacists believe that medical cannabis should be distributed like any other narcotic requiring a chain of signatures from manufacturer to pharmacist, with scheduled regular inventory checks. In B.C. all medicinal cannabis prescriptions would be logged in a patient’s PharmaNet record. This would ensure prescribers, pharmacists and emergency workers would have ready access to the patient’s complete medication history. This allows for important monitoring of drug interactions and potential overuse of cannabis by patients allowing for early intervention by the health care team.
B.C.’s community pharmacists foresee cannabis being obtained only from Health Canada licensed producers. Inventory would be closely tracked, and like other narcotics, discrepancies would be reported to Health Canada and authorities as appropriate. The BCPhA would work closely with the College of Pharmacists of BC and the Ministry of Health to ensure the appropriate practice standards are in place, and pharmacists receive the needed training to counsel patients appropriately.
Cost and convenience can be key motivators for how patients access marijuana. Therefore, we encourage the government of British Columbia to ensure the price of recreational cannabis is not lower than the price of medical cannabis, which would encourage patients to seek medical cannabis from the recreational market. If this happens, patients would be removed from the oversight of their health-care providers.
Like other health-care professionals, pharmacists believe there remain health and safety questions around cannabis that must be answered. The Association strongly urges the government to support more research in the form of appropriately structured clinical trials to determine the safety and effectiveness of cannabis as a drug for various medical conditions. This will help prescribers and pharmacists make safer and more effective decisions when providing medical cannabis to patients in the province.
Approved by the BC Pharmacy Association Board of Directors, November 17, 2017