Comment Letter

COGR Submits Joint Association Letter in Support of HR 5485

The document is a formal letter dated April 19, 2018, sent by leading academic and research associations—the Council on Governmental Relations (COGR), the Association of American Universities (AAU), and the Association of Public and Land-grant Universities (APLU)—to senior Congressional leaders and relevant federal agencies. The letter expresses concern that, despite legislative efforts such as the 2014 Farm Bill intended to facilitate research on industrial hemp, researchers at higher education institutions continue to face significant legal and regulatory obstacles. These barriers arise from conflicting federal definitions of "industrial hemp" and "marihuana" and ambiguous guidance from federal agencies like the DEA, which create uncertainty over whether legitimate industrial hemp research could be deemed a violation of the Controlled Substances Act, thereby potentially subjecting researchers to criminal liability without a Schedule I DEA registration.

The letter urges Congress and federal agencies to resolve these ambiguities by providing clear and consistent federal guidance that distinguishes industrial hemp and its derivatives from marijuana, as well as by exempting research activities involving industrial hemp from overly restrictive controls. The associations advocate for specific legislative actions, including clarifying language in the upcoming Farm Bill and support for the bipartisan Hemp Farming Act of 2018, to permanently remove industrial hemp from Schedule I of the Controlled Substances Act and facilitate research and commerce in hemp products. The document underscores the need for streamlined processes for researchers to access and transfer hemp materials without additional DEA licensing, and highlights the broader public interest in enabling robust scientific study of cannabis sativa and its derivatives. The signatory organizations emphasize their commitment to supporting regulatory improvements that advance scientific knowledge and public policy.

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Posted April 19, 2018