Comment Letter

COGR Submits Letter to DEA in Regard to Federal Register Notice, "Controls to Enhance the Cultivation of Marihuana for Research in the United States

The Council on Governmental Relations (COGR), representing 187 major U.S. research institutions, submitted comments to the DEA regarding the proposed controls to enhance the cultivation of marijuana for research purposes. COGR expressed appreciation for the DEA’s steps toward expanding the pool of authorized cannabis manufacturers beyond the current single supplier, highlighting the necessity for researchers to access a diverse array of cannabis seeds and cultivars. This diversity is crucial to reflect the range of cannabis products used publicly and to accurately assess their effects, including studies on contamination with substances like heavy metals and pesticides. The group echoed support from federal agencies such as the FDA and NIH for increased diversity in cannabis sources for research.

COGR also urged the DEA to expedite the review of pending applications from potential new manufacturers, noting a lengthy delay since the agency’s 2016 call for applications. Additionally, the organization raised concerns about the DEA’s proposed approach to possession and control of cannabis crops, asking for clarification on issues of physical versus legal possession, associated liabilities, and quality control responsibilities. The letter also questioned the appropriateness of passing administrative fees for compliance onto researchers, warning that such costs could further discourage essential cannabis research given current funding limitations. COGR concluded by commending the DEA for its efforts to facilitate research and welcomed further dialogue on the proposed regulatory changes.

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