From: Benson Hausman
Sent: Friday, September 08, 2017 1:10 PM
Subject: Required Laboratory Testing
I am the Chief Science Officer for Elemental Wellness Center in San Jose. I recently received a copy of the draft CEQA document that has been offered for public comment.
I wish to express my concern about section 3.5.2, Substances Requiring Analysis, Terpenes and Terpenoids. While Prop 64 and previous State laws on medical cannabis, required testing for “The terpenes described in the most current version of the cannabis inflorescence monograph published by the American Herbal Pharmacopoeia” (section 26101 (E)), it appears that this requirement has been dropped. In my opinion, this is a big mistake that requires reinstatement in the regulations. I say this because it has become increasingly clear that terpenoids have a major role in the identification and confirmation of cannabis strains, but more importantly have synergistic effects on cannabinoid therapeutic effects (see: Taming THC: potential cannabis synergy and phytocannabinoid-terpenoid entourage effects. Russo, Ethan B., British Journal of Pharmacology. 2011, 163: 1344-1364).
Without requiring testing for terpenoids, the information and understanding of cannabis will be significantly handicapped. Adult use and medical use will not be able to sufficiently confirm that the product they are getting is indeed what it is labeled. The science surrounding cannabis is rapidly developing whereby understanding the chemical profile (cannabinoids and terpenoids) is considered essential to strain identification and expected effects (both adult use and medical). In addition, costs of laboratory testing for terpenoids has decreased significantly in the last few years and should not be seen as a large financial burden.
As a physician, I can also attest to the need on the part of doctors making recommendations, that if the terpenoid profile is not known, patient treatment will suffer. It has long been know that terpenoids have their own therapeutic effects and they need to be matched with cannabinoid therapeutic effects to maximize cannabis’s therapeutic benefits. This fact of terpenoids’ therapeutic benefits is completely missing in the CEQA document and needs to be part of its considerations.
Please reinstate the original testing requirements for terpenoids. Consumers, patients, and doctors need this information. In my opinion, it should not be seen as an option, but as part and parcel of our rights as California citizens to be well informed and safe.
Benson Hausman, MD, MPH