An open letter to Dr Stewart Jessamine, GM of MedSafe and NZ representative to the WHO

An open letter to Dr Stewart Jessamine, GM of MedSafe and NZ representative to the WHO

Old bottle of Parke Davis cannabis pills. Photo: Wikimedia Commons

Dear Stewart,

Greetings, I hope that you are well.

I am nervous that you are representing NZ at the June WHO meeting in Geneva re: Cannabis.

I am nervous because I believe you may have misled the health select committee last year regarding cannabis. I hope it was unintentional, but it just doesn't stack up.

As you and I both know, our bodies use a 'wi-fi system' to maintain our health and protect us from injury. This ‘wi fi’ system connects all of our organ and tissue systems. These connections enable our health to be maintained through 'on demand' regulation. Obviously this wifi system doesn’t use radio, it uses fatty molecules called cannabinoids. That’s why it is called our cannabinoid system.

Strangely only 11% of NZ GPs have heard of it, and MoH isn’t telling anyone about the medical potential of this unique system. In fact it has hidden it’s own reports on the subject. Every animal on earth has a cannabinoid system. It is a masterpiece of Mother Nature, and is 600,000,000 years old.

That is why cannabis is so much more effective than pharmaceuticals. It contains the 'magic' molecules our bodies use to maintain and regulate our wellbeing.

That is also why cannabis became 50% of all medicines in the USA and Europe very quickly, because it optimises our bodies’ self-regulating abilities. That is why it can treat such confusingly diverse conditions. That is why people make such ridiculous seeming health claims.

Fact: Cannabis contains essential elements of our own health regulating system.

That is why cannabis was a staple of the world pharmacopoeia for more than fifty years.

In those fifty years of common use, Britain imported 100 tons of cannabis a year as medicine. Several million doses were prescribed every year in the US alone, until its prohibition via stealth, lies, and taxes. The American Medical Association valued it so much that they fought to keep cannabis for five years, until finally defeated by their own government.

So when you told the Select Committee, in 2017, that cannabis has “never been actively promoted as a drug in the way that it currently is…putting aside going back to the 1920s, when it was being promoted as a treatment for asthma,” You were telling them a very partial truth, and one that you should really know is false.

That is because this is all well documented, and the benefits of cannabis are clearly outlined in a report that OIAs show was commissioned, approved, and subsequently suppressed, by the National Drug Policy Unit in 2008.

In plain English, this report, Cannabis Therapeutics: a Novel Approach to Pain and other Chronic Disease State Management tells us that humans rely on a unique, powerful, physiological system for health protection and regulation. It is known as the endogenous cannabinoid system (ECS), and was discovered in 1990. Plant cannabis is a unique source of these precious molecules.

This report, known as the Woodbridge report, noted that cannabis is "a legitimate advance in therapeutic option...safer than alcohol...and a potential panacea for general health maintenance and protection." Because our cannabinoid system is "critical to the bodies overall homeostasis, and influences all of our main organ and tissue systems. This is a unique biological system, its mechanisms are responsive and capable of adaptation, and thus allows for a biological response to system demand or environmental conditions."

A unique, responsive, health regulating system that is capable of adaptation and responsive to both system demand and environmental conditions? That sounds promising.

So the question is, why did the Ministry of Health bury it? The reports section on 'pharmaco-economics' offers some clues.

Sadly, OIAs show that this report has NEVER been used to inform MoH policy on cannabis. Furthermore, the Ministry has no intention of ever doing so. This seems odd, given the government’s stated intention to make therapeutic cannabis more widely available. Strangely, the authors’ subsequent reports were negatively framed and never again addressed cannabis’ therapeutic potential.

These are unethical actions. In 2011 The Catholic Institute of Bio Ethics and Jesuit Community (USA) wrote that patients have a right to all beneficial treatments, including cannabis. In Medicinal Marijuana: Medical Necessity versus Political Agenda, they argue that "patients have a right to all beneficial treatments, and to deny them this right violates their basic human rights." Those words aren't coming from a radical. They are coming from the conservative Jesuit intellectuals of the Catholic Church.

Under this same rationale, you and your staff could potentially be considered to be violating New Zealanders’ human rights Dr Jessamine.

So what is really going on Stewart? In 2013, Dr Sanjay Gupta wrote "We have been terribly and systematically misled for nearly 70 years in the United States, and I apologise for my own role in that." That is bold language for a neurosurgeon/CNNs Chief Medical reporter to use. Are you systematically misleading us?

Questions have to be asked. Why did you not publish Cannabis Therapeutics? Why has it never informed policy? Why are you still misleading us? Why does the Ministry talk about imaginary and exaggerated harms? Why won’t you investigate this new therapeutic option? Why are you fighting legal hemp? Why have you suppressed this report? Why do you refuse to acknowledge its’ evidence and the published research since then? Who benefits from this continued denial?

It is of concern that the National Drug Policy Unit acknowledged "the useful overview of safety and efficacy of cannabis" contained in this report ten years ago. OIAs show that it was accepted, respected, kept for internal reference and "not intended for an audience other than the team."

As the Rt Hon. Helen Clark says "this 2008 report is useful in outlining that there is a good case to be made for enabling access to cannabis for therapeutic purposes. It could have been the basis for pursuing evidence based policy on the issue. It is important that it is made public now as a select committee is examining medicinal cannabis legislation" These are very diplomatic words given that this report was hidden during her government’s last term, and could have provided an issue to win another.

The Rt Hon. Paul East is also dismayed by these censoring actions, saying "I am happy to join Helen in saying that the paper should have been published".

Despite knowing about this report since 2008, you told select committee in 2017 that cannabinoids have been discredited in the marketplace. This is not true. Synthetic pharmaceutical cannabinoids have been discredited, and its synthetic cannabis that is killing New Zealanders today. Real natural cannabis cannot kill anyone, and moderate smoking of cannabis can be described as beneficial in effect. Eating raw cannabis IS beneficial in effect. Smoking seems to treat symptoms, eating it seems to treat the condition.

That is because the raw plant is 50% more therapeutic than commercial 'medicinal cannabis' products (according to patents owned by GW Pharma of Sativex), yet you persist in misrepresenting its’ harms while knowing better; and while Kiwis are dying from synthetics and meth. I think that is unethical too.

You also falsely attempted to conflate cannabis with psychosis. Cannabis use has gone through the roof in the western world since the 1960s, schizophrenia has not. Specific cannabinoids such as CBD are as good an anti-psychotic as the standard meds; but without the severe adverse side effects.

Finally, your position that we don’t know how to use it was false. India reserved the right to use the raw leaf in 1961, because it is a traditional medicine. Cannabis is a functional food and a herbal remedy, and its use as an intoxicant is its least valuable use. Even though 70% of the public supports access to cannabis, you appear to be working to prevent access. The question must be asked, why? Why are you so keen to keep it from patients and the market?

In your own words, you told the Committee that cannabis is a danger because “of what it’s actually being used for...the danger is by calling it medicinal cannabis, if you don’t have control around it, do you end up that the average medicinal use is for a minor illness that has other treatments available.”

That position seems at odds with your mandate to investigate new therapeutic uses, and your moral responsibility to ensure that they are cost effective. It also seems a very weak reason to oppose a new and more effective therapy.

Furthermore, many medical professionals and medical bodies in New Zealand and worldwide, believe cannabis should be regulated as a herbal remedy. Potentially this could make it accessible to patients and clinicians, and put Kiwi businesses at the front of global export markets before they are monopolised by larger forces. But your own words display only concern for established commercial products.

If you were serious about improving public health outcomes, I would think you might have followed your reports conclusions and run a campaign to educate the profession as to the possibilities of cannabis therapeutics and reclassified cannabis as a herbal remedy. Instead The Hemp Foundation has had to self-fund this critical work, and dig through the OIAs that show how your stance has continued the situation that prevents chronically ill children from accessing safe effective medicines.

Shame on you. The 'banality of evil' that Hannah Arendt wrote about seems to run through your Ministry. It seems to me like you have no care for the human consequences of your actions.

We both know neither hemp nor cannabis are dangerous enough to be controlled as a medicine. Yet Medicines Control has forbidden NZ’s legal hemp farmers from harvesting CBD, despite the Hemp Act specifically exempting them from MoDA. Barring farmers from harvesting CBD is what Canada did, at a cost of $52 billion Canadian dollars in lost revenues. Why are we repeating that foolish error? Who benefits? Are you just a prisoner of regulation? Surely not, you're supposed to investigate new uses.

Our survey data shows that 70% of doctors think cannabis should be removed from the Misuse of Drugs Act, and 81% think it is a health issue, not a criminal one. 75% of NZ think it should be available, and yet your argument against it is based in concern for other products in the market; and you are misleading the public and the politicians re: the facts of this "legitimate advance in therapeutic option?"

Seriously? Our health system is in crisis; the boomers are retiring, 44% of our doctors are retiring, we are a low wage economy with a declining workforce, and our health system is already in crisis. What happened to ‘investigating new uses’ that can improve public health and reduce our crippling health costs/improve efficiencies? There are also very serious conditions for which cannabis is safest, best, and sometimes only, treatment. Furthermore, it will be an economic windfall in revenues and savings.

Cannabis Therapeutics was commissioned and completed during the cannabis sympathetic Clark government. Why was its evidence, and the international research done since, ignored by MoH, MedSafe, and Medicines Control? We could have improved our health outcomes and reduced our social harms while adding to our economic development and environmental sustainability. Except our bureaucrats unilaterally withheld this vital information; with the consequence of countless human suffering, death, and expense.

It can't be the harms either, because in 2016 the Dunedin Longitudinal Study confirmed that twenty years of smoking cannabis was only associated with poorer gum health. So it must be what you said to select committee, that it could displace existing products from the market.

That is right, it will; and people will be healthier, our health costs will be reduced, our taxes could be reduced, and our revenues will be greater. Why do you oppose those outcomes?

The Hemp Foundation agrees that smoking is not to be recommended. It is the least therapeutic way to use cannabis, and tars are inevitably inhaled.

But given that non-smokers get more cancer than cannabis smokers, it is not a major health threat. "Moderate use (of smoked cannabis) can be considered beneficial in nature", said the British Crown in the most comprehensive investigation of cannabis ever done.

So I struggle to understand your perspective, until I ask "who benefits?"

Most medical schools do not teach the major (diet based) physiological system that creates and relies on cannabinoids for health regulation. Coincidentally, this ensures customers, not cures.

Today, not many people realise that Britain grows 45% of the world’s legal cannabis. Whereas once it imported 100 tons a year, in the 21st century it exports 100 tons annually as 'medicine'. Confusingly, cannabis remains illegal in Britain because it has "no therapeutic value and a high risk of abuse."

Cannabis was the single most safe and useful part of the international pharmacopoeia until its prohibition on false grounds. When you say "all things are poisonous, its just a matter of dose" you're also being misleading, because cannabis CANNOT KILL and was recognised by the DEA in 1988 as being "safer than most foods we eat on a daily basis...(and having) a therapeutic value that is without measure."

Dr Keith Bedford, (the Governments Chief Forensic Scientist and a founding member of the Expert Advisory Committee on Drugs) and NZs ESR found it "necessary to defend the integrity of the criminal justice system" by opposing the illogical and unethical arguments advanced by MoH to restrict public access (eg. by falsely making CBD an isomer of THC). Sadly MoH’s control of the territory won it the day.

The respected political commentator Colin James told me that "I do hear round the traps -- and have heard for well over a decade -- that the Ministry of Health is broken, which I think goes to your point." So it would be great if you could clarify why MedSafe is writing policies that ensure 1. poor health outcomes for NZ, 2. high health costs, and 3. reduced economic opportunities.

It would also be nice to know why you appear to have misled our House of Representatives on the subject. I'd love to think you just don't know the facts, like most other doctors. But your comments, your knowledge of the Woodbridge report, and the actions of MoH/MedSafe suggest otherwise.

Our OIAs show that, even though CBD was patented by the US Dept of Health and Human Services in 2003 as a safe and effective treatment; in 2015 you were following a strategy that has continued to deny the parents of intractably epileptic children access to CBD.

MoH has also worked relentlessly, (arguably beyond the remit of its powers; and based upon anonymous legal advice) to disable the NZ Hemp Industry by preventing it from exercising its legal rights to harvest CBD. This strategy has cost Canadian hemp farmers $52 billion dollars over the last 20 years. It is costing us both in dollars and in suffering.

Harvard Medical School says that we have a broken pharmaceutical model, and that it is characterised by "anti competitive practices, fraudulent marketing, and lax regulators." That is your industry we are talking about, you are in charge of regulating it, and you are in charge of "investigating new uses." So whose side are you on?

We are presenting at an international medical conference in July. Our paper is called Pharmaceutical Colonisation: the Appropriation, Prohibition, and Privatisation of Traditional Medicine. The title sums up the issue really.

As one of your slideshows says, you are supposed to be transparent and accountable. As our OIAs show, you and your Ministry have been anything but on this issue. Something is not right.

At Monday’s WHO meeting the pre-review documents were not comprehensive and were partial, and misleading. There was no mention of the raw acid forms of cannabis compounds (eg CBDa and THCa). The original plant cannabinoids were omitted. Instead 99% of the content appeared to be about THC and its isomers. There was scant mention of the human endocannabinoid system, which is bizarre, as the experts on that section are from a privately owned university/hospital group (US$600m+) that is building the largest 'medical marijuana patient database in the world'. Presumably they understand that cannabis has more therapeutic potential than their documents indicate. Presumably they also understand why. It is curious that they, like you and your Ministry, do not seem to want anyone else to know.

Uniquely in the world of plants, cannabis is both a functional, non-intoxicating food, and an essential medicine because its’ compounds play an essential part in human and animal health regulation. The WHO should treat it as one, and so should we.

You appear to be on the wrong side of history Sir. But it is not too late to change your approach and in doing so improve things for the patients of New Zealand who you are supposed to serve.

Yours sincerely,

T Stopford,

The Hemp Foundation

The Hemp Foundation is a non-profit education organisation dedicated to improving NZs health and wealth.

The hemp foundation is NZs first provider of Medical education in cannabis. GPs that attend our course are eligible for professional development points from the RNZCGZP on completing a reflection form. This course has educated over three hundred GPs so far.

www.thehempfoundation.org.nz

OIAs available here:

Full OIA response letter

MOH OIA 1

MOH OIA 2

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