Reform in Canada Pretense & Perils

were not included in the formulation of regulations addressing the use of pesticides. The
authors also suggest that the problems they encountered in Oregon would likely exist in
other states as well.
Analysis of medical cannabis samples have also revealed inconsistent product strength
resulting in both insufficient and dangerous dosing, with particular concern expressed
around edibles which have been found to be inconsistent in ingredients and inaccurately
labelled (Thomas et al., 2015).
There is also potential for similar problems to arise in the ever-expanding legal
recreational market in the United States. The problems of under-reported THC levels,
along with the detection of dangerously high levels of pesticides draws attention to yet
another troubling aspect of the US legalization experiment – the introduction of
cannabis edibles for retail, often sold in a form (eg. cookies) that would be attractive to
children. The edibles are associated with increased hospitalization of children for
treatment of toxic reactions from inadvertent ingestion (RMHIDTA, 2014, p.60; Wang et
al., 2016). According to Dr. Patricia Daly, the Chief Medical Health Officer for Coastal
Health, THC ingestion, in very young children can depress respiration and lead to coma
(CBC, 2016a). The prospect of children ingesting potentially toxic pesticides as well as
high levels of THC should be a serious concern for government regulators and other
health authorities.
Given that legalization would not mark the demise of the contraband industry, and that
the current status of drug industry regulation provides inadequate consumer protection,
it is not clear that a legal, government-regulated regime, in its current state of practice,
would result in a significant overall improvement in product safety relative to the current
prohibition regime or to a decriminalized regime.
It must be acknowledged that regulation may better allow for detection of pesticides and
irregularities in concentration, providing a clear advantage for legal commercial regimes.
However, the finding that dangerous levels of contaminants are indeed found in legal
product is disturbing and should be a significant concern for government regulators,
public health authorities and the general public who are being wooed by the promise of
product safety in a legal regime. As noted by Voelker & Holmes (2015), it is important
for government to include duly-qualified scientists in the development of regulations for
issues like pesticide use. If government is concerned about the quality and safety of
contraband product and confident that a legal industry will produce safer product, it
should encourage the legal industry to compete with contraband supply on that aspect.
Most people will pay more for a safer product to protect their health and well-being,
particularly if they can be assured that the legal product is, in fact, a safer purchase.
But consumer confidence can be achieved only if government transparently
acknowledges the problem of contaminated legal product in the first place.
It should be noted that evidence of contaminated product from legal cannabis producers
in both Canada and the US was submitted to the Task Force by this author near the end
of August 2016. The Task Force Report’s subsequent offering of its seemingly
gratuitous accolades, without justified qualification, provides cause for concern.
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