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Project CBD Speaks to the FDA

There will come a time when CBD is finally place on the approved pharmaceutical list. When this happens, it will be on the FDA to decide how producers of CBD products will be allowed to operate. Project CBD has made the following word for word recommendations to the FDA:

  • Do not make CBD a prescription-only drug. This would only serve the interests of a few pharmaceutical companies while
  • hurting patients who have benefited from CBD-rich food supplements, topicals and other artisanal preparations.
  • Fast track clinical studies designed to compare the efficacy of CBD isolates and whole plant CBD rich extracts. Let’s learn more about the pros and cons of both in order to maximize their benefits and minimize harm.
  • Require safety warnings for CBD isolates regarding drug interactions.
  • While facilitating access to pharmaceutical CBD, don’t impede safe access to artisanal CBD-rich products. We recognize that the FDA is generally not in the business of approving plants as medicine. Nor should the FDA be in the business of undermining plant medicine in general and CBD-rich cannabis therapeutics, in particular.
  • Prohibit the use of toxic thinning agents and flavoring additives in CBD-rich vape oil products.Several additives (propylene glycol and polyethylene glycol, for example) that are commonly found in CBD vape oil cartridges become toxic when heated and inhaled. Most flavoring additives have not been safety tested for inhalation; some are known to be highly toxic when combusted.
  • Publish all FDA test results pertaining to CBD hemp oil products. Artisanal CBD producers have a mixed record thus far with respect to product safety, labeling accuracy, and quality control. The FDA has already documented instances of fraud and product mislabeling when it analyzed the content of several CBD hemp oil items. The bad apples – hemp oil extracts with little or no CBD or excess THC - should not be a pretext for the FDA to prohibit or restrict access to safe, non-pharmaceutical CBD products.
  • Don’t privilege pharmaceutical priorities at the expense of the fledgling, domestic CBD-rich agricultural sector and the CBD food supplement and topical industry. In Denver, Colorado, state law permits wholesale manufacturers of CBD extracts and edibles to source hemp biomass from within and outside Colorado provided that it originates from a farmer who cultivates CBD-rich plants under regulations guided by safe consumption criteria.
  • Implement procedures to harmonize the patchwork of state regulations regarding CBD. Thus far a coherent regulatory framework is lacking. It’s federally illegal to sell food supplements and other products infused with CBD across state lines, but there’s a gap in federal oversight of CBD manufacturing operations.
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