New ACMPR Rules Fall Short According to Cannabis Industry Pioneer Hilary Black

Hilary Black
Taking Care of Patients In the Wake of the ACMPR

Guest Post by Hilary Black, Director, Patient and Community Services, Bedrocan and Founder, BC Compassion Club Society

The newly revised medical cannabis legislation has breathed new life into personal and designated production licenses and paved a pathway for new patients to grow for themselves.  This long awaited progress granting patients this right is a cause for celebration.

However there are some shortcomings to this policy, likely a result of the short time period the government had to respond to the courts. Limiting square footage rather than setting arbitrary plant limits is a far more effective method for limiting personal production, a greater concern is the continued lack of oversight.

As a patient advocate I think of the many patients I spoke with during the MMAR years (the government’s first foray into medical marijuana production, which preceded the MMPR) that were being wildly under supplied as their designated growers sold the cannabis grown under their names, something that was and continues to be illegal. Patients were often passed to growers through brokers for a fee who also failed to provide any oversight.

We must ensure these new production regulations benefit critically and chronically ill patients.

The regulatory framework will likely evolve again within a year and I am hopeful about what improved access will look like in the long term. As the country is focused on the legalization of cannabis for non-medical use, it is imperative the cannabis industry keep a collective eye on the needs of Canada’s medical patients.

It is the patients and their advocates who have laid the groundwork and pioneered the path towards the existing industry flourishing before us. The slow acceptance and understanding of cannabis as a medicine has neutralized stigma and fear and created a tsunami of support propelling us to the end of prohibition. As stakeholders from all corners of this space clamour for their position in our shared future, we must keep patients’ needs top of mind. Those needs are currently not fully met, regardless of the introduction of home production.

It is our responsibility as advocates, researchers, lawyers, physicians, educators, producers, regulators, and distributors to ensure we take care of patients at this key turning point in the history of cannabis in Canada.  Patients are not merely a key in the lock of prohibition, but are the heart and roots of the cannabis industry: they deserve and want our on-going commitment and care.

At Bedrocan / Canopy – the vanguard of legal medical cannabis production and distribution – we strive to set the standard for patient care, education and advocacy. We produce standardized reliable products. We fund clinical trials, safe driving campaigns, physician education, advocate to remove GST from medical cannabis, fund an insurance initiative, and offer True Compassionate Pricing, $5/gr for everyone for all of our dried cannabis varieties.

The dispensary I founded, the BC Compassion Club, is the root of medical cannabis access in Canada. There, patients are provided subsidized non-cannabis holistic therapies and thorough education, and have been for 20 years.

I joined Bedrocan Canada to be able to participate in a medical cannabis regime to break down barriers to access for patients across the country, expanding the market as we serve patients in need of relief. I work with our team to provide valuable products and services to people in need. In turn, providing value to the people who choose to invest in us.

At this critical juncture in the evolution of cannabis regulation, keeping patient needs top of mind for the public and policy makers is critical.

To that end, I’d like to share with you some recommendations that, if heeded, would greatly improve access and understanding of cannabis for medical purposes. These recommendations were originally developed collaboratively by a group* of medical cannabis experts working with The Arthritis Society, Canadians for Safe Access and The Canadian AIDS Society and presented on Parliament Hill.

When discussing legalization with our communities, elected officials and in the public sphere, echoing their messages will help to ensure patients’ needs are taken care of as we move forward into a new era of cannabis regulation.

Please read the full version of the recommendations with supporting rationale here.


Recommendation #1: Sales Tax. The federal sales tax should be removed from medical cannabis in order to increase affordability. Medical cannabis should be zero-rated like other medical necessities and prescription medicines.

Recommendation #2: Insurance Coverage. Create a pathway for Health Canada to approve cannabis as a drug or medicine. An approved drug status would facilitate cost coverage by both public and private insurance plans. As with other prescription medicines, medical cannabis should be covered by healthcare insurance.


Recommendation #3: Access to All Products. Ensure legal access to medical cannabis products in all of its forms and various potencies, including but not limited to: herbal cannabis, capsules, tinctures, topicals, edible extracts and finished products, and inhaled extracts. This move would bring federal policy into conformity with the recent Supreme Court ruling, R vs. Smith 2015.

Recommendation #4: Distribution Options. Regulations should ensure that patients have access to medical cannabis through a wide range of distribution options – including on-site dispensing, mail order, and self-production.

Recommendation #5: Increase the scope of practice for regulated healthcare practitioners to authorize access to cannabis. We encourage the federal ministry of health to work with national and provincial regulatory bodies to increase the scope of practice for regulated healthcare professionals who treat common medical conditions that medical cannabis may benefit. These professions include both nurse practitioners and naturopathic physicians.

Recommendation #6: Promote Research. Expand the evidence base on medical use of cannabis through increased funding from federal granting bodies and the creation of new funding programs and by modernizing research-licensing policies.

In the coming months, the Task Force and government will determine what legal non-medical cannabis production and distribution will look like. It is imperative that together we ensure these recommendations are echoed from as many stakeholders as possible. In a landscape that is often rife with acrimonious discourse we have a rare opportunity, and responsibility, to present a unified message.

True Compassion must be remembered in the wake of legalization and entrepreneurialism.

*Contributing Authors of the Recommendations:

  • Jonathan Zaid, Canadians for Fair Access to Medical Marijuana (CFAMM)
  • Rielle Capler, MHA, PhD(c) Researcher, Educator
  • Lynne Belle Isle, PhD, Canadian AIDS Society
  • Jonathan Page, PhD, Anadia Labs
  • Danial Schecter, MD, Cannabinoid Medical Clinic
  • Hilary Black, Bedocan, BC Compassion Club Society

About the author:

Hilary Black is a currently the Director of Patient and Community Services for Bedrocan Canada. She provides her expertise on patient care, education, outreach, advocacy and physician education initiatives. She continues to be committed to breaking down the barriers to access for all Canadian patients.

Hilary pioneered the first medical cannabis dispensary in Canada, British Columbia Compassion Club Society (BCCCS), in 1997, she has been dedicated to serving patients for over 19 years.  In addition to providing medical cannabis therapies, the BCCCS offers subsidized natural healthcare services in its Wellness Centre, dramatically improving the health, and quality of life, of thousands of critically and chronically ill Canadians.

She has extensive experience working with: patients, medical cannabis producers, healthcare professionals, legal authorities, researchers and government.

Hilary is a recipient of the Queen Elizabeth Diamond Jubilee Award, acknowledging her for making a significant contribution to Canadian society for her work with medical cannabis.

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Published by NCV Newswire
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