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Document Number

TRINA K. FRASER
Ext. 232
tfraser@brazeauseller.com

May 7, 2015
BY EMAIL
College of Physicians and Surgeons of British Columbia
300-669 Howe Street
Vancouver, British Columbia V6C 0B4
ATTN: Dr. Heidi M. Oetter, Registrar
Dear Dr. Oetter:
Re:

Marijuana For Medical Purposes Standard


Our File No.: 35-21986

I am counsel for the Canadian National Medical Marijuana Association


(CNMMA).
The CNMMA has reviewed the new Marijuana for Medical Purposes
Standard which was posted on the Colleges website yesterday, and has
noticed an interpretation error in the following portion of the Questions
and Answers section:
How much marijuana for medical purposes can be dispensed to
a patient at a time?
The new Regulation limits the total amount of marijuana that can
be administered (dispensed) to a patient in a 30-day period to no
more than 30 times the daily quantity specified in the medical
document or 150 grams, whichever is less.

This appears to be a reference to s.5 of the Marihuana for Medical


Purposes Regulations (MMPR) which states:
An individual who obtains dried marihuana for their own medical
purposesmust not possess a quantity of dried marihuana that
exceeds the least of the following amountsin the case of dried
marihuana obtained from a licensed producer, 30 times the daily
quantity referred to in paragraph 129(1)(d)and 150g.

www.brazeauseller.com

t. 613.237.4000
f. 613.237.4001
55 Metcalfe Street, Suite 750
Ottawa, Ontario,
Canada K1P 6L5

The purpose of s.5 of the MMPR is to limit the amount of marijuana that
a patient may possess at a given point in time. It does not limit the
amount of marijuana that can be sold/dispensed to the patient in a given
30-day period. In fact, any patient whose medical document authorizes
them to consume more than five grams per day will be required to order
their medicine from their licensed producer more than once per month.
This is permissible, so long as the total amount shipped throughout the
month does not exceed the total monthly amount authorized by the
medical document (and so long as any one shipment does not exceed
the prescribed limit in s.5).
The CNMMA believes that it would be in the public interest to revise this
portion of the Q&A section to clarify this point. You may wish to refer to
Health Canadas FAQ page in this regard:
http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/faq-eng.php

Document Number
The CNMMA would appreciate the opportunity to discuss the new
Standard with you further, and you may feel free to directly contact Mr.
Deepak
Anand,
Executive
Director
of
the
CNMMA
(deepaka@cnmma.ca) in this regard.
If you have any questions with respect to the above please do not
hesitate to contact me.

Yours very truly,

Trina K. Fraser
cc: Deepak Anand, CNMMA

www.brazeauseller.com

t. 613.237.4000
f. 613.237.4001
55 Metcalfe Street, Suite 750
Ottawa, Ontario,
Canada K1P 6L5

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