Health Committee on Sept. 15th, 2017

[Dr. Daniel Vigil]

In our most recent year of data for both poison centre and emergency department visits, we have had a slight decline. We hope that's related to regulation and public education. We can't be certain what the causes are, but we have seen a slight decrease and hope that continues.

[Don Davies, NDP, Vancouver Kingsway, BC]

Mr. Larsen, you sell products. We're talking edibles, and again, all I hear is about brownies and gummi bears. You described a range of products that under Bill C-45 would still be illegal. You mentioned creams, sprays, tinctures, patches, and tablets. These are all forms of cannabis that would remain illegal under Bill C-45.

Can you tell us, in terms of the products you sell: are these products unsafe? Do consumers want them? What percentage of your users prefer these products as opposed to smoking cannabis?

[Dana Larsen]

The ratio of extracts to buds is probably about 60:40. Of course, there are also smokable extracts as well—hash and shatter and things like that—which are also very beneficial but are used in a smoke format. People are more inclined to use edibles when they know it's a safe amount. People do not want to ingest vast amounts of THC and hallucinate. That's not what they're looking for. People tend to smoke because it's easily titrated. You have the amount you need and then you're done. With edibles, it can be a long wait.

Edibles can be very useful for pain relief and for longer-term effects, especially for medical users who don't want to be smoking constantly. They find the right dosage in an edible or suppository, which by the way is an incredible way of using cannabis, with very low psychoactivity and good to get a high dose, medicinally or otherwise. When they talk about legalizing—oh, we're going to sell it in liquor stores—are you going to sell cannabis suppositories in liquor stores?

We sell a cannabis cream called MJ creams. There's no psychoactivity at all; you rub this cream on your skin and it's great for psoriasis, eczema, and topical pain relief. This could be put on a baby or on anybody of any age. I don't see any reason to have an age limit on a cannabis-infused cream that has no psychoactivity.

We have to broaden the range of things that we're looking at. At our dispensary it is very rare for somebody to come back and say I took too much of the edible and I had a bad experience. We tell people, as doctors do with prescription drugs, start up with a lower dose. If that doesn't work, work your way up to a higher dose. Try a little more at a time until you reach the point where you're getting the effect you want, and then you've got enough.

If the government is not going to allow edibles and extracts, we're going to continue to sell them through dispensaries, through the black market. They'll be unregulated, but we do our best to make sure these products are safe and labelled. Given the constraints of legality, we do our best, and I think we do a pretty good job already: a lot of the fearmongering around edibles and extracts simply hasn't materialized in Vancouver, or Toronto, or other cities that have dozens and dozens of dispensaries. We're not really seeing a lot of problems coming out of this, and that's an unregulated, self-regulated market. If we have some proper rules in place, the problems will be minimal.

[Don Davies, NDP, Vancouver Kingsway, BC]

“Mr. Zaid, you put it well.”

He talked about how we want to limit the use, in uncontrolled fashion, of products of unknown providence.

Mr. Vandrey, you refer to it as a crapshoot. Would we prefer to keep this legal and have Canadians cooking their own edibles in their own kitchens, without any control over the concentration of the THC, for instance, in a tray of brownies? I fail to understand how that's a preferable public policy approach to edibles than putting it into the hands of a tightly regulated market where it's sold in retail fashion by people who can be advising the customers, as you just pointed out.

[Dana Larsen]

They're going to make their own edibles anyway, even in a fully legalized market. People enjoy making their own edibles—it's fun. It's like growing your own cannabis. It's an enjoyable activity to grow a plant in your garden, then harvest it and use it. People like that. Tomatoes, or zucchini, or cannabis, people enjoy it. People are going to make their own edibles even under legalization.

Most won't, they'll go buy it in a store because that's easier, but people brew their own wine and make their own beer, and there's nobody coming in and saying we're going to check the alcohol level of that beer and make sure it's at the right level. That doesn't happen, so I think a lot of these concerns are overblown.

I would prefer to see a legally regulated market that's open and accessible for regular Canadians to enter, as it is with other products. Until that day happens, edibles and extracts will continue to be available. We sell pure CBD tincture and pure isolative THC and CBD at dispensaries. We're years and years ahead of where the legal system is going to be, and you have a lot of catching up to do.

[Don Davies, NDP, Vancouver Kingsway, BC]

Bill C-45 legalizes dry flour and oil, but I'm not quite sure what that oil will be used for. What's your understanding, Mr. Larsen, of the oil that will be legal under this bill? How will people use it and can it be vaped?

[Dana Larsen]

My understanding is this legislation is only...3% THC is the limit that licensed producers are able to make for their extracts, and I think this is the same thing. There are going to be a lot of problems with this.

Vaping is very positive too, by the way, if you have concerns with people smoking. Those concerns are often overblown, but vaporizing eliminates most of them. There are no particulates—it's purely just the active ingredients steamed off the plant. You inhale them. It combines the benefits of smoking, which is a quick action, and being able to get your dosage precise without having any smoke involved. I think vaping should actually be encouraged and considered a better way of using it.

Real legalization would mean that Canadian farmers are able to grow high-THC cannabis by the thousands of hectares. That is what we're working towards. When it comes, smoking buds will be less popular, but you'll be able to make extracts of pure THC or CBD or CBG or CBN or the other cannabinoids in any combination you want and vaporize or use those in a way that will be revolutionary and much safer than what we're doing now.

[The Chair, Liberal, Bill Casey]

Ms. Sidhu.

[Sonia Sidhu, Liberal, Brampton South, ON]

Thank you, Mr. Chair, and thanks to all of you all for being here. There is a lot of new learning that I've never heard about before.

My question is for Dr. Vandrey. In your recent study on edible products and labelling, you said that only 17% of edible products had an accurate THC content listed, while 60% were “overlabeled”. What makes accurate labelling of THC content in edible products so challenging? Is it the result of a lack of regulation or of producers not having the resources to accurately provide that labelling?

[Prof. Ryan Vandrey]

I think it's a combination of the manufacturing practices not being careful enough to put a precise amount of product in each package or in each dose, as well as difficulties with the lack of standards for testing those products.

[Sonia Sidhu, Liberal, Brampton South, ON]

You've said “education”. Who should be or who shouldn't be using? You also mentioned cardiovascular stress for cardiovascular patients, so high THC or low THC means something...? What types of education tools do we need to be providing?

[Prof. Ryan Vandrey]

I think broad education needs to be disseminated regardless. In terms of THC content, you have to define a dose, and the dose depends on the individual and the reason they're using it. Right now, we're talking about non-medical use, so my presumption here is that you have people looking to get intoxicated. You're likely talking about doses that are higher than what potentially would be needed for medicinal uses, but as for what level that is, it's still up for debate and in need of more research.

As any good researcher will tell you, we need more research, but the fact of the matter is there are very few controlled studies of edible dosing with cannabis. What we've found in our laboratories is that we can give the same dose to 35 different people and half of them tolerate it very well and the other half get severely impaired. We have some individuals who vomit after a really high dose, and they consistently get sick when we vary the route of administration. It doesn't much matter if they smoke it, vape it, or eat it: at high doses of cannabis, they get the same types of effects. Some people are more sensitive to those effects than others.

Again, drawing a parallel with other things like alcohol, you can say the same thing. Some individuals can drink six beers and be fine, and others would be throwing up in the corner. How you manage this and how you factor it into regulation is that you want a unit dose that's low enough and is not going to make most people sick. Let the people who can tolerate higher doses consume more but do so in a manner such that they know what to expect and so it's consistent across episodes of use. When you go to the liquor store and buy a beer, the beer isn't 5% alcohol one time and 10% the next if you're buying the same beer. There's variety and there are differences in beer, but it's labelled with the alcohol content on it, and you need a similar set-up for cannabis.

[Sonia Sidhu, Liberal, Brampton South, ON]

I've heard that Colorado is using 10 milligrams. Is there any way to ensure the THC doses are evenly distributed?

[Prof. Ryan Vandrey]

Again, Colorado has their system for evaluating and testing those products and they put the ceiling on there. I'll let Mr. Vigil talk about that process, but as long as you get consistent dosing of 10 milligrams there.... We did not do our testing study in Colorado. It was conducted in California and in Washington state. Also, it was conducted only in medical cannabis dispensaries, not in non-medical retail, and it was done several years ago. I don't know where things stand now, but I think there needs to be a quality control regulatory agency in place to monitor this stuff and to make sure things are accurately labelled, the dose is appropriate, and all of that. Quality control is imperative.

[Sonia Sidhu, Liberal, Brampton South, ON]

Thank you.

My next question is for Mr. Vigil. In July 2016, the Denver Post published a report on the fivefold increase in children's admissions to hospital due to the ingestion of edibles. How can we protect our kids? What are the challenges with the packaging so that the kids aren't attracted to the packaging? Also, what about food safety? What do you think about other jurisdictions that combine edible production and food inspection regulations?

[Dr. Daniel Vigil]

First, concerning children and edibles, to answer an earlier question, the hospital data is a mix, I think, of causes. One is likely some increased exposure, but there's also very likely an increase in the willingness to admit to exposure or use. Of course, we've mentioned that childproof packaging is very important, as well as education for parents about how it is not okay to leave this out. It can be dangerous if children are exposed, so keep it in the childproof packaging once you get home.

For the appeal, again, that's not something that I can quickly give you a very clear answer on. I think it's very important to come up with good guidelines and balancing that with the fact that people want these products and want a variety of these products. If restrictions are too limiting, you'll see products that are outside of the regulated system. It's a tough balance. I don't have a clear answer for you on that.

Can you remind me of your last part of the question?

[Sonia Sidhu, Liberal, Brampton South, ON]

It was the food inspection.

[Dr. Daniel Vigil]

I think that varies from state to state. In Colorado, any edibles production falls under the general food inspection that they do for kitchens that produce any products that go on the shelves. They are subject to the food safety inspections. In addition, all marijuana products are required to be tested for content of THC, CBD, and other cannabinoids, and for any microbial contamination, pesticides, and residual solvents.

[The Chair, Liberal, Bill Casey]

That completes our first round. Now we go to our five-minute round, starting with Dr. Carrie.

[Colin Carrie, Conservative, Oshawa, ON]

Thank you, Mr. Chair.

Again, it's a great panel. Thanks to all of you for being here.

I want to get right to my questions, because we know that this is rolling out in 288 days. There's not a lot of time, and I think it's really a really missed opportunity. We had Colorado here earlier saying that, really, before we get this rolled out, we should have our public education program in place, with really good factual information—which we don't see here—and data collection should be in place, along with treatment research and things along those lines. For the last two years, really, the Liberal government hasn't been doing anything, and again, we're jamming all of this into one week.

I want to particularly thank you, Mr. Larsen, for being here. I think you're the first person we've had here who is on the ground and actually integrating with and talking to the public about this very important issue and this transformative piece of legislation.

I'm going to throw out all my questions, and I'm going to throw all of them out to you, because I only have five minutes. I have four main questions that I'd like you to answer.

First of all, there are a lot of questions about cannabis from parents and educators. What do you do for your clientele on education? When they have questions for you, do you have basic scientific pamphlets and things along those lines? Where do you get your product? How do you assure quality control? Also, I'm curious as to what you would say a good age cut-off would be, and I'm not talking about medicinal use. I'm talking about recreational use.

Those are the four questions. I probably only have four minutes left for my time. Would you be able to comment on those four questions, please?

[Dana Larsen]

Sure. Can you give them to me one at a time again so that I don't forget all the questions?

[Colin Carrie, Conservative, Oshawa, ON]

First of all, what do you do for your clientele as far as education is concerned?

[Dana Larsen]

It depends on what they're coming in for, you know, but we try to guide them to the right product.

Sometimes people who are experienced with cannabis come in. They've used it a lot. They're just looking for a particular product. They don't need a lot of guidance.

We also get senior citizens who come in and say that they haven't used cannabis in 50 years but their grandson says it will be good for their arthritis or something. We don't typically stick a joint in their face. We normally give them edible products or CBD-based products or creams or tinctures or things that are going to have less psychoactivity and more of a medicinal effect. We try to guide them based on what they're looking for and what their experience is. Like for other things, we always tell them to start off with a small dose and then work their way up until they get to the point where they're getting the benefits or whatever it is they're seeking. That's the kind of guidance we try to give.

[Colin Carrie, Conservative, Oshawa, ON]

Is that a written type of guidance?

[Dana Larsen]

It's mostly oral. We have some written information and pamphlets and things like that too. It depends. A lot of it is just personal conversations with people in one-on-one discussions like you'd have with a pharmacist or a doctor in looking for guidance on cannabis. Sometimes they have a doctor's advice going in, but Canadian doctors don't really know a lot about cannabis or the endocannabinoid system, which is the part of our body's system that the cannabis interacts with, so mostly—