Regulating Cannabis Manufacturing: Applying Public Health Best Practices from Tobacco Control

ABSTRACT

State legalization and regulation of cannabis, despite continued federal illegality, is a massive shift in regulatory approach. Manufactured cannabis, including concentrates, extracts, edibles, tinctures, topicals and other products, has received less attention than more commonly used dried flower, but represents emerging regulatory challenges due to additives, potency, consumption methods, and abuse and misuse potential. In November 2017, the California Department of Public Health (CDPH) released initial cannabis manufacturing regulations as part of a new state regulatory structure. As the largest U.S. medical cannabis market (and largest legal adult use market in the world beginning in 2018), California’s regulatory approach will potentially influence national and global policy. Comparing CDPH’s initial regulations to tobacco control best practices reveals that, while the regulations recognize the need to protect public health, prioritizing public health over business interests requires stronger approaches to labeling, packaging, and product formulations. Based on tobacco best practices, we recommend that cannabis regulations incorporate large and proportionately sized informational labels, a prominent universal cannabis symbol, rotating and pictorial health warnings, mandatory plain packaging, a comprehensive ban on characterizing flavors and addictive additives, and strict limits on the potency of inhalable products and those easily confused with non-cannabis products.

KEYWORDS:

• Cannabis
• marijuana concentrates
• marijuana edibles
• marijuana extracts
• marijuana labeling
• marijuana legalization

Acknowledgments

The authors wish to thank Dharma Bhatta, Candice Bowling, Eric Crosbie, Catherine Egbe, Minji Kim, Margarete Kulik, Lauren Lempert, Danielle Ramo, Yvette van der Eijk, and Tanner Wakefield for their guidance and feedback.

Additional information

Funding

This research was supported in part by National Institute of Drug Abuse grant DA-043950. The funder had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript.