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Debunking the ONDCP's Scott Burns

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Scott M. Burns, Deputy Director of the White House Office of National Drug Policy (ONDCP), wrote an open letter to prosecutors, which was distributed by the National District Attorneys Assocation on November 1, 2002 (Full text of letter - pdf). As is so often the case with the ONDCP, the letter was full of half-truths, exaggerations, and outright falsehoods.

In this article, I point out some of these claims with my responses (note: emphasis in quoted material is original in Scott Burns' letter):


Scott M. Burns:

"60% of teenagers in treatment have a primary marijuana diagnosis. This means that addiction to marijuana by our youth exceeds their addiction rates for alcohol, cocaine, heroine, methamphetamine, ecstasy and all other illegal drugs combined."

Response:

The ONDCP continually mixes terms like "treatment," "dependency," "addiction," and "abuse," even though these terms have distinctly different meanings. The data used in this statement (which is still overstated from the study referenced) refers to young people who have been "enrolled" in treatment programs, and gives absolutely no support to any statements about addiction.

Some of those enrolled in treatment are dependent on marijuana. Others are there simply as a condition of testing positive for use through school testing programs or are enrolled through criminal justice referrals. These people may or may not be dependent. They may also be taking up treatment slots that could be better used by the millions of those addicted to harder drugs on waiting lists for treatment.

The numbers in the study quoted point to the fact that teenagers are often given the option to enroll in treatment to avoid criminal prosecution or school expulsion. This inflates treatment numbers for that age group. The overall numbers of treatment admissions (including teenagers) point this out fairly dramatically:

"Primary marijuana abuse accounted for 14% of TEDS admissions in 1999...More than half (57 percent) of marijuana admissions were referred to treatment through the criminal justice system... Secondary abuse of alcohol was reported by 57 percent of admissions for primary marijuana abuse" (Department of Health and Human Services: Office of Applied Studies: Treatment Episode Data Set (TEDS) 1994-1999: National Admissions to Substance Abuse Treatment Services http://wwwdasis.samhsa.gov/teds99/1999_teds_rpt.pdf p. 25)

In fact, when it comes to the truth about marijuana dependence, the ONDCP should look to the US Government's own study commissioned through the National Institute of Medicine, which states: "Although few users of marijuana develop dependence, some do. But they appear to be less likely to do so than users of other drugs (including alcohol and nicotine), and marijuana dependence appears to be less severe than dependence on other drugs." (National Institute of Medicine (IOM). Marijuana and Medicine: Assessing the Science Base. National Academy Press. Washington DC, 1999.)


Scott M. Burns:

"As a factor in emergency room visits, marijuana has risen 176% since 1974, and now surpasses heroin.

Response:

The Drug Abuse Warning Network (DAWN) study used here relates to "mentions," not "factors." The study reports emergency room visits that have a connection to drugs, including recreational use, health problems, etc. and records are inspected to determine if any drugs have been "mentioned" or showed up on tests (regardless of their impact on the emergency room visit). Up to four drugs can be mentioned, in addition to alcohol. In 17.4% of the cases where drugs are mentioned, marijuana is one of the drugs mentioned. This is remarkably low considering that most who use harder drugs also use marijuana (the reverse is not true). The DAWN web site warns: "DAWN does not measure prevalence of drug abuse in a community or in the U.S." (http://www.dawninfo.net/about/myths.asp)


Scott M. Burns:

"One recent study involving a roadside check of reckless drivers (not impaired by alcohol) showed that 45% tested positive for marijuana."

Response:

The citation of this study (Brookoff, D.; et al., New England Journal of Medicine, 331:518-522) is extremely misleading for a number of reasons: 1. Data on reckless driving which eliminates alcohol as a factor is questionable. No information was given as to the percentage of those eliminated from that sample, only that after eliminating alcohol-related reckless driving, there were 150 subjects who were tested. 2. Information on positive marijuana testing is meaningless as a factor in reckless driving, since marijuana gives positive tests for up to two weeks after use, and the data did not say that any of the drivers were impaired as a result of the use of marijuana. 3. The letter neglects to mention that a significant number of those who tested positive for marijuana also tested positive for cocaine. 4. The letter fails to mention that fewer of that group of reckless drivers tested positive for marijuana alone than those that tested negative for drugs. [actual percentages of the 150 individuals tested: 41% no drugs, 14% cocaine alone, 12% cocaine and marijuana, 33% marijuana alone. No other drugs were tested.)

The ONDCP is using poor data in a misleading way to imply that marijuana use causes reckless driving. However, according to the National Highway Traffic Safety Administration study titled "Marijuana and Actual Driving Performance" (published November, 1993): "THC's adverse effects on driving performance appear relatively small." and "Evidence from the present and previous studies strongly suggests that alcohol encourages risky driving whereas THC encourages greater caution."


Scott M. Burns:

"The truth is that marijuana is addictive. Average THC levels rose from less than 1% in the late 1970s to more than 7% in 2001... Marijuana users have an addiction rate of about 10%, and of the 5.6 million drug users who are suffering from illegal drug dependency or abuse, 62% are dependent on or are abusing marijuana."

Response:

Once again, the ONDCP mixes terms like "addiction," "dependency," and "abuse." The definition of abuse used in that particular study includes those who used marijuana on 6 or more days in the past year and had some other factor that caused problems for them, such as being late, or the fact that the drug is illegal.

The Institute of Medicine cautions against the misuse of these terms. "Tolerance, dependence, and withdrawal are often presumed to imply abuse or addiction, but this is not the case. Tolerance and dependence are normal physiological adaptations to repeated use of any drug."

As a matter of fact, dependency rates for marijuana use are dramatically lower than those for tobacco and alcohol (which are legal), and "marijuana dependence appears to be less severe than dependence on other drugs." (National Institute of Medicine (IOM). Marijuana and Medicine: Assessing the Science Base. National Academy Press. Washington DC, 1999.)

The mention of rising THC levels in this paragraph is also meant to mislead, seemingly connecting a higher THC level with addiction, which is not supported. It is true that potency has increased, but unlikely that it has increased by the levels claimed by the ONDCP. According to the federal government's own Potency Monitoring Project at the University of Mississippi, 1999's average was 4.56 percent. (http://www.mpp.org/USA/news_2824.html) The 1% figure for 1970s is highly disputed as that level would not result in much of a marijuana high.

Potency increase does not mean an increase in individual consumption, as smokers are likely to self-regulate use to get a desired "high," thereby using less of the more potent product.

Potency increase is also a factor of prohibition. Richard Cowan calls this the "Iron Law of Prohibition" (Richard Cowan, "How the Narcs Created Crack," National Review, December 5, 1986, pp. 30-31). The law states that the more intense the law enforcement, the more potent the prohibited substance becomes. When drugs or alcoholic beverages are prohibited, they will become more potent, will have greater variability in potency, will be adulterated with unknown or dangerous substances, and will not be produced and consumed under normal market constraints. (see Mark Thornton, "The Potency of Illegal Drugs," Auburn University working paper, 1986; and Thornton, "The Economics of Prohibition")

"During alcohol prohibition the underground economy swiftly moved from the production of beer to the production of the more potent form of alcohol, spirits. Prohibition made it more difficult to supply weaker, bulkier products, such as beer, than stronger, compact products, such as whiskey, because the largest cost of selling an illegal product is avoiding detection." ("Alcohol Prohibition Was a Failure" by Mark Thornton, The Cato Institute July 17, 1991 http://www.cato.org/pubs/pas/pa-157es.html)


Scott M. Burns:

The truth is that marijuana and violence are linked.

Response:

An association between drug dependence and antisocial personality or its precursor, conduct disorder, is widely reported in children and adults. Robins recently concluded that it is more likely that conduct disorders generally lead to substance abuse than the reverse. (Robins LN. 1998. The intimate connection between antisocial personality and substance abuse. Social Psychiatry and Psychiatric Epidemiology 33:393--399.)


Scott M. Burns:

The truth is that marijuana is a gateway drug for many people.

Response:

As the Rand report states: "the harms of marijuana use can no longer be viewed as necessarily including an expansion of hard-drug use and its associated harms. This shift in perspective ought to change the overall balance between the harms and benefits of different marijuana policies." ("Using Marijuana May Not Raise the Risk of Using Harder Drugs" http://www.rand.org/publications/RB/RB6010/RB6010.pdf )


Scott M. Burns:

The truth is that marijuana legalization would be a nightmare in America.

Response:

The ONDCP likes to paint the Dutch policies as a failure, but that viewpoint is not supported by the facts:

Last month use of cannabis (marijuana) by high school seniors:
18.1% in the Netherlands (1996);
23.7% in the U.S. (1997).
(Sources: The Trimbos Institute, Amsterdam, the Netherlands; Monitoring the Future Survey, University of Michigan and White House Office of National Drug Control Policy)

Any lifetime use (prevalence) of cannabis by older teens (1994):
30% in the Netherlands;
38% in the U.S.
(Sources: Center for Drug Research, University of Amsterdam; Monitoring the Future Survey, University of Michigan and White House Office of National Drug Control Policy)

Recent (last month) use of cannabis by 15 year olds (in 1995):
15% in the Netherlands;
16% in the U.S.;
(Sources: Trimbos Institute, Amsterdam, the Netherlands; Monitoring the Future Survey, University of Michigan and White House Office of National Drug Control Policy)

Any lifetime use of cannabis by 15 year olds (in 1995):
29% in the Netherlands;
34% in the U.S.;
(Sources: Netherlands Institute of Health and Addiction, U.S. National Institute for Drug Abuse)

Heroin addicts as a percentage of population (in 1995):
160 per 100,000 in the Netherlands;
430 per 100,000 in the U.S.
(Sources: Netherlands Ministry of Health, Welfare and Sport; White House Office of National Drug Control Policy)

Murder rate as a percentage of population (in 1996):
1.8 per 100,000 in the Netherlands;
8.22 per 100,000 in the U.S.
(Sources: Netherlands Bureau of Statistics; White House Office of National Drug Control Policy)

Incarceration rate as a percentage of population (1997):
73 per 100,000 in the Netherlands;
645 per 100,000 in the U.S.
(Sources: Netherlands Ministry of Justice; White House Office of National Drug Control Strategy)

Crime-related deaths as a percentage of population:
1.2 per 100,000 in the Netherlands (1994);
8.2 per 100,000 in the U.S. (1995).
(Sources: World Health Organization; Uniform Crime Reports, U.S. Federal Bureau of Investigation)

Per capita spending on drug-related law enforcement:
$27 per capita in the Netherlands;
$81 per capita in the U.S.
(Sources: Netherlands Ministry of Justice; White House Office of National Drug Control Strategy)


Scott M. Burns:

The truth is that marijuana is not a medicine, and no credible research suggests that it is.

Response:

This is one of the most outrageous statements that the ONDCP continues to make. Despite the fact that the government has repressed research in marijuana as medicine through difficult approval procedures for researchers, there is a huge body of evidence supporting medical marijuana. You might try reviewing some of the references supplied by drugscience.org:

Abrahamov A, Abrahamov A, Mechoulam R. An efficient new cannabinoid antiemetic in pediatric oncology. Life Sci 1995;56(23-24):2097-102.

Barsch, G.: Zur therapeutischen Anwendung von Cannabis - Ergebnisse einer Pilotstudie unter HIV-positiven und Aids-kranken Männern und Frauen. In: Deutsche Aids Hilfe (Hrsg.): Cannabis als Medizin. Beiträge auf einer Fachtagung zu einem drängenden Thema. Berlin, Aids-Forrum D.A.H., 1996.

Brady CM, DasGupta R, Wiseman OJ, Berkley KJ, Fowler CL. Acute and chronic effects of cannabis based medicinal extract on refractory lower urinary tract dysfunction in patients with advanced multiple sclerosis - early results. 2001 Congress on Cannabis and the Cannabinoids, Cologne, Germany: International Aaasociation for Cannabis as Medicine, p. 9,

Carter GT, Rosen BS. Marijuana in the management of amyotrophic lateral sclerosis. Am J Hosp Palliat Care 2001;18(4):264-70.

Clifford DB. Tetrahydrocannabinol for tremor in multiple sclerosis. Annals of Neurology 1983;13:669-671.

Consroe P, et al: Reported marijuana effects in patients with spinal cord injury. 1998 Symposium on the Cannabinoids, Burlington, Vermont, International Cannabinoid Research Society, p 64.

Consroe P, Musty R, Rein J, Tillery W, Pertwee R. The perceived effects of smoked cannabis on patients with multiple sclerosis. Eur Neurol 1997;38(1):44-8.

Dansak DA. As an antiemetic and appetite stimulant in cancer patients. In: Mathre ML, ed. Cannabis in medical practice: A legal, historical and pharmacological overview of the therapeutic use of marijuana. Jefferson/NC: McFarland & Co, 1997, pp. 69-83.

Elsner F, Radbruch L, Sabatowski R. Tetrahydrocannabinol for treatment of chronic pain [published in German]. Schmerz 2001;15(3):200-4.

Fortissimo 1, March 2002, Journal of the Swiss Multiple Sclerosis Society.

Fride E. Cannabinoids and cystic fibrosis: a novel approach to etiology and therapy. J Cannabis Ther 2002;2(1);59-71.

Gieringer D. Cannabis "vaporization": a promising strategy for smoke harm reduction. J Cannabis Ther 2001;1(3-4):153-170.

Gieringer D. Medical Use of Cannabis: Experience in California. In Cannabis and Cannabinoids. Pharmacology, Toxicology, and Therapeutic Potential, edited by F. Grotenhermen and E. Russo. Bing?hamton (NY): Haworth Press, 2002.

Grotenhermen F. Harm reduction associated with inhalation and oral administration of cannabis and THC. J Cannabis Ther 2001;1(3-4):133-152.

Grotenhermen F. The medical use of cannabis in Germany. J Drug Issues 2002, in press.

Hagenbach U, Ghafoor N, Brenneisen R, Luz S, Maeder M. Clinical investigation of D9-tetrahydrocannabinol (THC) as an alternative therapy for overactive bladders in spinal cord injury (SCI) patients. 2001 Congress on Cannabis and the Cannabinoids, Cologne, Germany: International Aaasociation for Cannabis as Medicine, p. 10.

Hampson A. Cannabinoids as neuroprotectants against ischemia. In: Grotenhermen F, Russo E, editors. Cannabis and cannabinoids. Pharmacology, toxicology, and therapeutic potential. Bing?hamton (NY): Haworth Press, 2002: 101-10.

Helliwell, D.: GPs are key informants in medicinal cannabis survey. GP Speak, Newsletter of the Northern Rivers Division of General Practice, April 1999, S.4.

Holdcroft A, Smith M, Jacklin A, Hodgson H, Smith B, Newton M, Evans F. Pain relief with oral cannabinoids in familial Mediterranean fever. Anaesthesia 1997;52:483-488.

House of Lords Select Committee on Science and Technology. Cannabis. The scientific and medical evidence. London: The Stationery Office, 1998.

Jatoi A, Windschitl HE, Loprinzi CL, Sloan JA, Dakhil SR, Mailliard JA, Pundaleeka S, Kardinal CG, Fitch TR, Krook JE, Novotny PJ, Christensen B. Dronabinol versus megestrol acetate versus combination therapy for cancer-associated anorexia: a North Central Cancer Treatment Group study. J Clin Oncol 2002;20(2):567-73.

Joy JE, Watson SJ, Benson JA, eds. Marijuana and medicine: Assessing the science base. Institute of Medicine. Washington DC: National Academy Press, 1999.

Killestein J, Hoogervorst EL, Reif M, Kalkers NF, Van Loenen AC, Staats PG, Gorter RW, Uitdehaag BM, Polman CH. Safety, tolerability, and efficacy of orally administered cannabinoids in MS. Neurology. 2002;58(9):1323-4.

Knoller N, Levi L, Shoshan I, Reichenthal E, Razon N, Rappaport ZH, Biegon A. Dexanabinol (HU-211) in the treatment of severe closed head injury: a randomized, placebo-controlled, phase II clinical trial. Crit Care Med 2002;30(3):710-1.

Martyn CN, Illis LS, Thom J. Nabilone in the treatment of multiple sclerosis. Lancet 1995; 345(8949):579.

Maurer M, Henn V, Dittrich A, Hofmann A. Delta-9-tetrahydrocannabinol shows antispastic and analgesic effects in a single case double-blind trial. European Archives of Psychiatry and Clinical Neuroscience 1990;240:1-4.

Meinck HM, Schönle PWA, Conrad B. Effect of cannabinoids on spasticity and ataxia in multiple sclerosis. Journal of Neurology 1989;236:120-122.

Mueller-Vahl KR, Kolbe H, Schneider U, Emrich H M: Cannabis in Movement Disorders. In: Grotenhermen F, Saller R (eds): Cannabis und Cannabinoide in der Medizin [Cannabis and Cannabinoids in Medicine]. Research in Complementary Medicine 6, Supplement 3, 1999b.

Mueller-Vahl KR, Schneider U, Koblenz A, Jobges M, Kolbe H, Daldrup T, Emrich HM. Treatment of Tourette-Syndrome with delta-9-tetrahydrocannabinol (THC): a randomized crossover trial. Pharmacopsychiatry 2002;35(2):57-61.

Mueller-Vahl KR, Schneider U, Kolbe H, Emrich HM: Treatment of Tourette's syndrome with delta-9-tetrahydrocannabinol. Am J Psychiatry 156:3, 1999a.

Mueller-Vahl, K.R., Kolbe, H., Dengler, R.: Gilles de la Tourette-Syndrom. Einfluß von Nikotin, Alkohol und Marihuana auf die klinische Symptomatik. Nervenarzt 1997;68:985-989.

Musty RE, Rossi R. Effects of smoked cannabis and oral D9-tetrahydrocannabinol on nausea and emesis after cancer chemotherapy: a review of state clinical trials. J Cannabis Ther 2001;1(1):29-42.

Nofziger L. Foreword. In: Marijuana RX - The Patients Fight for Medicinal Pot, edited by Robert C Randall and Alice M O'Leary, 1999.

Notcutt W, Price M, Miller R, Newport S, Sansom C, Simmonds S. Medicinal cannabis extracts in chronic pain: (4) cannabidiol modification of psycho-active effects in D9-THC. 2001d Congress on Cannabis and the Cannabinoids, Cologne, Germany: International Aaasociation for Cannabis as Medicine, p. 25

Notcutt W, Price M, Miller R, Newport S, Sansom C, Simmonds S. Medicinal cannabis extracts in chronic pain: (5) cognitive function and blood cannabinoid levels. 2001c Noyes R, Baram DA. Cannabis analgesia. Comprehensive Psychiatry 1974;15:531-535.

Notcutt W, Price M, Miller R, Newport S, Sansom C, Simmonds S. Medicinal cannabis extracts in chronic pain: (2) comparison of two patients with back pain and sciatica. 2001a Congress on Cannabis and the Cannabinoids, Cologne, Germany: International Aaasociation for Cannabis as Medicine, p. 25

Notcutt W, Price M, Miller R, Newport S, Sansom C, Simmonds S. Medicinal cannabis extracts in chronic pain: (3) comparison of two patients with multiple sclerosis. 2001b Congress on Cannabis and the Cannabinoids, Cologne, Germany: International Aaasociation for Cannabis as Medicine, p. 26

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Pertwee RG. Prescribing cannabinoids for multiple sclerosis. CNS Drugs 1999;11(5):327-334.

Plasse TF, Gorter RW, Krasnow SH, Lane M, Shepard KV, Wadleigh RG. Recent clinical experience with dronabinol. Pharmacology, Biochemistry and Behavior 1991;40:695-700.

Porcella A, Maxia C, Gessa GL, Pani L. The synthetic cannabinoid WIN55212-2 decreases the intraocular pressure in human glaucoma resistant to conventional therapies. Eur J Neurosci 2001;13(2):409-12.

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Russo E, Mathre ML, Byrne A, Velin R, Bach PJ, Sanchez-Ramos J, Kirlin KA. Chronic Cannabis Use in the Compassionate Investigational New Drug Program: An Examination of Benefits and Adverse Effects of Legal Clinical Cannabis. J Cannabis Ther 2002;2(1):3-58.

Schnelle M, Grotenhermen F, Reif M, Gorter RW. Results of a standardized survey on the medical use of cannabis products in the German-speaking area. Forsch Komplementarmed 1999 Oct;6 Suppl 3:28-36

Siegling A, Hofmann HA, Denzer D, Mauler F, De Vry J. Cannabinoid CB(1) receptor upregulation in a rat model of chronic neuropathic pain. Eur J Pharmacol 2001; 415(1): R5-R7

Sieradzan KA, Fox SH, Hill M, Dick JP, Crossman AR, Brotchie JM. Cannabinoids reduce levodopa-induced dyskinesia in Parkinson's disease: a pilot study. Neurology 2001;57(11):2108-11.

Soderpalm AH, Schuster A, de Wit H. Antiemetic efficacy of smoked marijuana: subjective and behavioral effects on nausea induced by syrup of ipecac. Pharmacol Biochem Behav 2001;69(3-4):343-50.

Stinchcomb A, Challapalli P, Harris K, Browe J. Optimization of in vitro experimental conditions for measuring the percutaneous absorption of D9-THC, cannabidiol, and WIN55,212-2. 2001 Symposium on the Cannabinoids. Burlington Vermont: International Cannabinoid Research Society, 2001, abstr. 161.

TNO Preventie en Gezondheid: Aard en omvang van Cannabis gebruik bij mensen met Multiple Sclerose. 1998, ISBN 9067435171.

Ungerleider JT, Andyrsiak T, Fairbanks L, Ellison GW, Myers LW. Delta-9-THC in the treatment of spasticity associated with multiple sclerosis. Adv Alcohol Subst Abuse 1987;7(1):39-50.

Vinciguerra V, Moore T, Brennan E. Inhalation marijuana as an antiemetic for cancer chemotherapy. New York State Journal of Medicine 1988;88:525-527.

Warms CA, Turner JA, Marshall HM, Cardenas DD. Treatments for chronic pain associated with spinal cord injuries: many are tried, few are helpful. Clin J Pain 2002;18(3):154-63






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