The Canadian Pharmacists Association (CPhA) recently announced its revised policy position, suggesting that pharmacists should “become full partners in the dispensing of medical marijuana in order to improve patient safety and access.” The Globe and Mail published an editorial May 23 by Phil Emberley, CPhA’s director of professional affairs, expanding upon the reasons the CPhA reconsidered and reversed its previous ‘hands-off marijuana’ position.
The most important aspect of CPhA’s position, according to investment consultant and chairman and CEO of The Wile Group, Anthony Wile, is that, as Emberley wrote, the many patients for whom medical marijuana is a third- or fourth-line treatment and who are often on numerous other medicines “may be at risk by not receiving the same counsel and oversight provided for other drugs.”
Wile expanded, “People need to remember that medical marijuana is medicine. The CPhA is not talking about recreational-use marijuana. Individuals using marijuana to treat their – or their children’s – health conditions are medical patients. As such, they have a right to be assured their medicine is of high quality, as well as have access to trained professionals to guide them in the use of that medicine – just like every other patient using any other medicine.”
Currently, patients with a physician recommendation for medical marijuana are required by Health Canada regulations to purchase their medicine only from licensed producers that meet stringent security requirements. Delivery is only allowed through direct provider-to-end user mail delivery in order to tightly control distribution. Customers are not allowed to physically visit the producers’ sites and must have any questions about their medication answered via phone conversation with producer representatives.
Anthony Wile is concerned this constitutes a serious problem for many patients. “The licensed producers’ customer service providers are just that – they are not trained healthcare professionals with detailed knowledge about the plethora of pharmaceutical products patients may be taking,” Wile added.
In a situation that creates similar concerns, Toronto has recently experienced an explosion of illegal storefront shops – more than 100 – distributing “medical marijuana,” a situation the City vowed to crack down on. As reported May 26, “Project Claudia” is already underway, as police have begun raiding these storefront distributors.
These shops are both out of compliance with federal marijuana distribution laws and in violation of Toronto zoning laws.
“What’s more important than the zoning violations the City’s concerned with is the lack of training and staff expertise needed to guide sick people in making wise, safe medication decisions. These dispensaries may well be staffed with goodhearted marijuana proponents and passionate small-business owners, but those behind the counters answering questions and offering suggestions are ill-prepared to address patients’ needs for professional medication guidance.”
Wile offered a comparison. “Again, the key point here is that medical marijuana is medicine. It is not a ‘wellness product,’ but a psychoactive drug. While we might choose to discuss the potential benefits of a given nutritional supplement with a store clerk at the local health market, no one would expect that clerk to be an expert on dosing, contraindications or possible drug interactions when it comes to epilepsy or multiple sclerosis or HIV/AIDS meds.”
Pharmacists, on the other hand, have the training and breadth of experience across the pharmaceutical spectrum that puts them in a uniquely trustworthy position to prudently counsel patients on their medicines. In fact, a poll commissioned by CPhA found that 77% of respondents felt “patient safety and oversight would be improved if medical marijuana was available only through a pharmacy.” Given the increasingly broad scope of services pharmacists are now providing across Canada in their role as patient “medication manager,” this is not a surprising result.
In addition, the pharmaceutical industry has in place the infrastructure needed to securely manage the distribution, storage and dissemination of drugs, including the mandated record-keeping, reporting systems, high security and other factors required by Health Canada’s MMPR regulatory structure.
The goal of the now-shifting global policies on drugs, discussed during the recent UNGASS 2016, is to bring about an end to the socially destructive, violent black market that came about as a response to prohibition. To do so requires putting into place safe and legal cultivation, processing and distribution methods for medical marijuana, as well as recreational marijuana and other drugs. In light of Emberley’s assertion that only 8% of Canadians are now accessing their medical marijuana through legal channels, this point takes on greater urgency.
Black marketers are not concerned with the quality of the drugs being distributed nor for the safety of their customers, let alone the improvement of their buyers’ medical conditions. Their goal is simply to grow their markets, selling drugs to people who demand them, but who are unable to procure them safely from a white market source.
Pharmacies, on the other hand, are in the business of providing high-quality drugs via regulated, carefully controlled mechanisms. Not only do pharmacies procure and distribute only quality-controlled products and counsel consumers on how to safely use those medicines, but professional pharmacists provide another important resource to society in addressing drug problems: They have training and experience in identifying and monitoring drug abuse. Pharmacists constitute a built-in early-warning system, so to speak, thus enabling more timely and effective intervention when needed.
Public policy becomes clear only after laws are passed and the ensuing regulations take shape. As reported in April at UNGASS, the Trudeau government – which announced during its first week in office it would legalize adult-use recreational marijuana – expects to roll out its proposed policy next spring, nearly a year and a half after taking office. Regulations take time to develop.
That’s why, as Anthony Wile suggested last November in an editorial in The Globe and Mail, that investors may want to slow down and “take a deep breath” before investing wholeheartedly in this fledgling industry as currently configured. Industries also take time to shake out and begin to resemble what they will ultimately look like when fully developed. “An apparently wise investment in what currently is may not turn out to be so wise when regulations veer off in a different direction,” he cautions.
Existing medical marijuana producers and distributors in Canada, Wile says, “are likely to take a bit (or maybe a lot) of a beating as regulations change and the Canadian industry continues to develop. Until the final settling of the dust, regional investments in indoor growing operations are likely to cause some headaches, as the current distribution scheme approved by Health Canada – which will almost assuredly look very different in the near future – is built into these producers’ business model.”
Anthony Wile expects existing companies are going to lose a substantial part of their current market projected revenue stream – “likely upwards of 50%,” he said – when pharmacies enter into the fray. As most producers are barely able to float even now, most will fail under a new regime. In that event, shareholders are likely to experience a significant reduction in their investments with a drawdown on valuations in the market on those holdings.
“This is the nature of why I wrote what I wrote previously cautioning investors against running in too early to this admittedly exciting new market,” explained Wile. “The current state of the industry has proven to be highly immature, especially as evidenced by the cottage storefronts peddling these products as medicines without quality controls on either the products or the providers/advisors.”
“Again, I would caution investors to take a deep breath and let the regulatory environment play out in Canada before jumping in aggressively,” Wile concluded.