We submit this statement in support of moving the prescription drug, Marinol, from Schedule II to Schedule III, but with grave concerns that this move not be an attempt to frustrate the needs of hundreds of thousands of patients who desire to use whole marijuana for medical purposes, or an attempt to thwart the will of the voters in the states named above who have decided by overwhelming majorities that whole marijuana should be available for medical purposes to legitimate patients under their state laws.

Current regulations require that Marinol only be prescribed for patients suffering from the extreme nausea associated with cancer chemotherapy and for patients suffering from the wasting syndrome associated with AIDS. There is ample scientific evidence in numerous peer-reviewed medical and scientific journals, as well as controlled studies performed by state governments, indicating that such patients experience greater symptom relief from whole marijuana than from Marinol. As a result, considering only the patient population which currently enjoys prescription access to Marinol, moving it to Schedule III is not a sufficient solution, given the available scientific evidence that more effective relief can be obtained from marijuana.

However, an even greater problem exists with respect to the huge patient population seeking symptomatic relief from conditions that go beyond cancer chemotherapy and AIDS wasting. There is a clear and convincing body of scientific evidence that whole marijuana is an effective remedy for patients with glaucoma, seizures disorders like epilepsy, and spasticity disorders like multiple sclerosis. Indeed these three syndromes, along with the nausea associated with chemotherapy and AIDS wasting, were the five conditions for which 1998 voters in the states named above approved the medical use of whole marijuana. These five syndromes are also the basis for a preliminary injunction awarded by Judge Fern Smith in Federal District Court in San Francisco which blocks officials of the federal government from interfering with any California doctors recommending marijuana to their patients for relief from these syndromes.

Beyond these five syndromes, there is a growing body of scientific and medical evidence indicating that whole marijuana is more effective than any traditional pharmaceutical agent in the relief of pain and suffering associated with migraine, asthma, arthritis, Crohn’s Disease, spinal cord injury, and several other conditions. For a review of this evidence, see my recently published book, "Is Marijuana The Right Medicine For You?" (Keats Publishing, New Canaan CT, 1998).

The New England Journal of Medicine, one the most highly respected medical and scientific publications in the world, has endorsed the medical use of marijuana. So has a recent and exhaustive review by a special commission of the British House of Lords. Francis Young, an Administrative Law Judge for our own Drug Enforcement Administration, concluded in 1988 after presiding over a two-year study of marijuana that it was, "the safest therapeutically active substance known to man." Laws regarding the medical use of marijuana have recently been eased both in Britain and in Canada. The American Medical Association and the American Bar Association have both called for additional research on this promising medicine.

Thus, Americans for Medical Rights endorses the rescheduling of Marinol, but cautions all involved that scientific evidence proves beyond doubt that whole marijuana provides more effective relief than Marinol for a wide variety of disease syndromes, and as a result, the latter’s rescheduling should in no way serve as a substitute for making whole marijuana legally available to those patients for whom it would be beneficial.

Bill Zimmerman, Ph.D.
Americans for Medical Rights
1250 Sixth Street, #202
Santa Monica CA 90401