Public Comment on MCC Cannabis Cultivation Guidelines

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This is the Executive Summary of the Full Public Comment in reply to the MCC’s Medical Cannabis Cultivation Guidelines.

PLEASE NOTE: To view the full Public Comment on the MCC’s Medical Cannabis Cultivation Guidelines [please click here]

The MCC has sought to clarify the rules and regulations around medical cannabis, this is a response to the call for public comment to their draft “MCC Cultivation Of Cannabis And Manufacture Of Cannabis-related Pharmaceutical Products For Medicinal And Research Purposes” guidelines.  The MCC failed to seek experienced local input on their journey to draft adequate guidelines that are ‘Made in South Africa’.

This is evidenced by the vacillating proposals put forward by the MCC. On Nov 23 2016 the MCC put forward the Victoria Australian model for medical cannabis, and then within 3 months introduce a set of guidelines based on Dutch guidelines, with some Australian appendices.

Despite the press releases that these rules and regulation were “developed” with DAFF, they were NOT! They were in actual fact mostly copied verbatim from the Dutch “Guidelines for cultivating cannabis for medical purposes” (Voorschriften voor de Verbouw van Cannabis voor Medicinale Doeleinden) of 2003, without putting any thought into how the application of these guidelines would suit the South African environment.

Problems with these guidelines:

  • Excessively unattainable application restrictions
  • Illogical Security, Personnel, Equipment and Cultivation requirements
  • No Home Cultivation, Co-op or Social-club models considered
  • No Primary Care Giving or Compassionate Care model
  • No clarity on different forms of cannabis administration
  • Lack appropriate cannabis dispensing models.
  • Unsubstantiated INCB restrictions and quotas
  • No affordable patient access to medical cannabis discussed

As a top cannabis producing country, South Africa has extremely talented and well informed citizens that will work together to achieve a more pragmatic goal for cannabis; in a global context. The MCC’s failure to provide a working solution, after it has ceased to exist and SAHPRA take over, would see a cottage industry erupt sooner than later.

These MCC guidelines fail to acknowledge the historic use of cannabis in South Africa, by doing so they are excluding those with knowledge, and enforcing a stricter version of prohibition on the unlicensed. In no way should the South African citizens accept this poor application of intellect at a  governing body level.

We reject the MCC Medical Cultivation Guidelines until interested and affected parties become involved in the guideline creation process.

According to these guidelines, Mario Ambrosini would be unfit to apply for a licence.

To view the full Public Comment on the MCC’s Medical Cannabis Cultivation Guidelines [please click here]

Endorse this communication by signing below:

This petition is now closed.

End date: Apr 30, 2017

Signatures collected: 1369

1,369 signatures

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