Section 8) Related or Precursor Chemicals
DEA maintains that the presence of numerous cannabinoid substances in marijuana makes it impossible to generalize about marijuana on the basis of cannabinoid research, and that marijuana and its constituent parts are more dangerous to use than THC, the principle psychoactive ingredient in marijuana.
Modern research firmly establishes the interrelationship of the cannabinoid family of chemicals unique to marijuana, bound together both by chemical similarity and by a common mechanism of action in the human body.
There are no significant reports of abuse of the synthetic THC pill approved by the DEA in the late 1980’s for nausea associated with chemotherapy.
Modern cannabinoid research, including research on marijuana, is based on the validity of assertions based on scientific research on marijuana’s separate cannabinoid constituents.
DEA is not authorized under the Controlled Substances Act to make scientific or medical determinations, and must accept the paradigms and conventions of the scientific community.
The scientific community recognizes the treatment of cannabinoids as a group for classification purposes. This relationship is explicit in all cannabinoid research, and is the basis for the development of new therapeutic drugs.
There is no scientific basis for an assertion that marijuana had a greater dependence liability than D9-THC.
There is no scientific basis for an assertion that any cannabinoid compound has a greater dependence liability than D9-THC.
There is no basis for distinguishing between the scheduling of marijuana, cannabinoids, and D9-THC on the basis of dependence liability or potential for abuse.
References Cited in Section 8.
Fan, F., Compton, D.R., et al., Development of Cross-Tolerance between D9-Tetrahydrocannabinol, CP 55,940 and WIN 55,212. Journal of Pharmacology and Experimental Therapeutics. 271:1383-1390, 1994.
ElSohly, M.A. and Ross, S.A., “Quarterly Report, Potency Monitoring Project, Report #50” (Washington, D.C.: NIDA,) 1994.
Institute of Medicine, Marihuana and Health. (Washington, D.C., National Academy Press,) 1982.
Koob, G.B. and Bloom, F.E., “Cellular and molecular mechanisms of drug dependence.” Science, 242:715-723, 1988. Cited in Oviedo, et al. (1993) and in Pratt (1992).
Melvin, L.S., and Johnson, M.R., “Structure-activity relationships of tricyclic and nonclassical bicyclic cannabinoids.” In: Rapaka, R.S., and Makriyannis, A., (eds.) Structure-Activity Relationships of the Cannabinoids. National Institute on Drug Abuse Research Monograph 79, (Washington, D.C.: U.S. Govt. Print. Off.,) 1987. pp. 31-47. Cited in HHS (1991).
Nahas, G. Marihuana-Deceptive Weed. (New York: Raven Press.) 1973.
Oviedo, A., Glowa, J, and Herkenham, M., “Chronic cannabinoid administration alters cannabinoid receptor binding in rat brain: a quantitative autoradiographic study.” Brain Research, 616:293-302. 1993.
Razdan, R., “Structure-Activity Relationships in Cannabinoids.” Pharmacological Reviews. 38(1):75 – 149, 1986.
U.S. Department of Health and Human Services, (1987) Drug Abuse and Drug Abuse Research, the Second Triennial Report to Congress From the Secretary, Department of Health and Human Services. (Washington, D.C.: U.S. Govt. Print. Off.,) 1987. (DHHS Publication No. (ADM)87-1486) pg. 76.
U.S. Department of Health and Human Services, (1991) Drug Abuse and Drug Abuse Research, the Third Triennial Report to Congress From the Secretary, Department of Health and Human Services. (Washington, D.C.: U.S. Govt. Print. Off.,) 1991. (DHHS Publication No. (ADM)91-1704)
U.S. Department of Justice, Drug Enforcement Administration, Docket No. 86-22. Marijuana Scheduling Petition, Denial of Petition. 54 Fed. Reg. 53,787 (1989)
U.S. Department of Justice, Drug Enforcement Administration, Docket No. 86-22. Marijuana Scheduling Petition, Denial of Petition; Remand. 57 Fed. Reg. 10,499 (1992)
U.S. Department of Justice, Drug Enforcement Administration, Docket No. 86-22. Schedules of Controlled Substances; Hearing on Petition to Reschedule Marijuana and its Components. 51 Fed. Reg. 22,946 (1986)
United States Pharmacopeial Convention, Inc. Volume I – Drug Information for the Health Care Professional. (Taunton, MA: Rand McNally,) 1995. pg. 1185.