Sunday
Aug032008

Dosing

Dosing medical cannabis is one of the most controversial and mysterious aspects of this modern herbal medication. Although the medical use of cannabis has been approved in 12 states, marijuana remains illegal for all uses under US federal law. Due to the extensive laws surrounding the federal prohibition, doctors are limited to recommending marijuana when it might provide relief for a certain patient suffering from a certain ailment, but physicians are not allowed to actually prescribe medical marijuana. Thus, while a doctor may specify that the health benefits of using marijuana outweigh the risks, the management of a patient's use of cannabis, including dosing, is not allowed by law.

Cannabis is known to be one of the safest medicines used in medical practice. Remarkably, no deaths have ever been recorded over the course of 27,000 thousand years that cannabis has been used by humans, so the open-ended titration question is not a threat to health, and doctors may recommend the herb without much concern. Indeed, physicians frequently shy away from further discussion of cannabis with a concern for legal ramifications. The recommendation of a treatment without detailed follow-up management is an anomaly in medical practice that should be eliminated with the federal rescheduling of cannabis from its current legal definition of having "no medical value".

Noted AIDS and cannabis researcher Donald Abrams disagrees with the archaic federal position on medical cannabis. Not only is there ample research on the safety of medical marijuana, Abrams has also determined some medical value of cannabis in human studies. Dosing of medical cannabis has been determined through elaborate scientific analysis of the most prominent cannabinoid, THC. Ina 1999 lecture at the Lindesmith Center in San Francisco, Dr. Abrams noted:

“When taken by mouth, delta-9 THC has a very low 6 to 20 percent absorption, and it’s very variable from one person to another. Peak plasma concentrations of delta-9 THC, when taken by mouth, occur within one to six hours and may remain elevated for several hours with a half-life of 20-30 hours. So it sticks around for a long time. It takes a long time to reach a peak concentration. Similarly, when taken by mouth, delta-9 THC is broken down into the liver to a by-product of 11 hydroxyl THC, it’s called, which in and of itself, this metabolite, has potent psychoactive effects. You get less of it when you smoke it… The 11 hydroxyl, which in and of itself is a potent metabolite, and when smoked you produce less of the 11 hydroxyl. Smoking THC, the THC is rapidly absorbed into the blood stream and redistributed with a considerable amount of it destroyed by combustion. Peak plasma levels are achieved at the very end of smoking and decline rapidly over 30 minutes, as if it were given intravenously, for example, whereas, if taken by mouth, it’s slow and doesn’t reach very high peaks and takes a long time to disappear. The amount of THC one is exposed to might be the same, but certainly the effects are different."

The only authoritative text on cannabis dosing was written by Gregory T. Carter, MD. That paper titled, "Rational Guidelines for Dosing". That paper is included in full in the Abstracts and Studies section linked at the bottom of the list of chapters on this website.

The following paper was prepared for the WA State Department of Health in determining the state's "60 day supply limit.

MARIJUANA PATIENT DOSAGE AND CULTIVATION LIMITS

By Martin Martinez, October 2007

MARIJUANA DOSAGE LIMITS

Cannabis medications are unique in several ways. Marijuana patients may precisely self-administer their required dose, a benefit not available with standardized pharmaceutical medications. Marijuana smokers and vaporizer users are able to ingest the exact amount required for immediate relief. In medical terminology this is called "self-titration" for relief of symptoms "as needed".

Cannabis is known to enter the bloodstream and produce psychoactive stimulation almost immediately following inhalation, peaking in effect within about 20 minutes and beginning to diminish in effect after about 40 minutes. Residual effects may remain at work for hours after a large dose, but immediate therapeutic effects generally begin to fade after the first hour or two for most users. Many patients exercise a repetitive medicinal schedule for continued symptomatic relief. A few puffs or more per hour is common.

Medical marijuana is also consumed orally, especially by long-term medical users with acute chronic conditions. In general, marijuana that is eaten takes several hours to absorb with full effectiveness, but once digested, cannabis compounds may remain active in the body for an entire day or night. Eating marijuana can be more effective than smoking or vaporizing, but usually requires consumption of greater amounts. For some marijuana patients, the slightly different effects of eating marijuana can be overwhelming. For others, oral ingestion may be less effective in immediate symptomatic relief than inhalation.

Cannabis medicines are most often an adjunctive treatment. Concurrent use of pharmaceutical drugs may adversely affect the bioavailability of cannabis. Powerful drugs can also reduce physiological responses, creating the need for higher-than-average dose levels. Some patients depend on medical marijuana to keep from vomiting their oral medications so their need for a specific dose of cannabis compounds may fluctuate with day-to-day reactions to those nauseating pharmaceutical drugs.

Washington State law allows doctors to recommend medical marijuana under at least ten separate categories of illness. The variety of medicinal features of marijuana includes a broad range of dose- related applications. For some patients, a few puffs of a cannabis cigarette can restore their appetite and they may need no more until the next meal time, or perhaps until the next chemotherapy session. Then again, for others, say a long-term Crohn's patient with severe hardening of intestinal tissues, instilling a healthy appetite may require a much larger amount. Quelling intractable pain usually depends upon a far greater dose threshold than is typically required for GI stimulation. One argument used against marijuana in the treatment of Glaucoma is that effective therapy depends on continued intermittent dosing--about every 3 or 4 hours to continually relieve intraocular pressure. Due to that frequency of administration, the American Ophthalmology Association has opposed the use of medical marijuana, though many Glaucoma patients rely on cannabis to maintain their vision and to halt progression of the disease.

Perhaps the most important consideration in assessing amounts of marijuana required as medicine is the tolerance factor. Long-term marijuana patients may ingest relatively huge amounts of the herb because they develop a tolerance to the psychotropic effects.

Medical research has shown that the more one uses medical marijuana, the less one feels "high", thereby allowing a greater dose range and greater medical effectiveness. As noted by the National Institute on Health:

"After repeated smoked or oral marijuana doses, marked tolerance is rapidly acquired (after a day or two) to many marijuana effects, e.g., cardiovascular, autonomic, and many subjective effects. After exposure is stopped, tolerance is lost with similar rapidity (Jones et al. 1981). Measurable tolerance or tachyphalaxis is evident for some hours after smoking even a single marijuana cigarette."

Also published by the National Institute on Health:

"THC bioavailability, i.e., the actual absorbed dose as measured in blood, from smoked marijuana varies greatly among individuals. Bioavailability can range from 1 percent to 24 percent with the fraction absorbed rarely exceeding 10 percent to 20 percent of the THC in a marijuana cigarette or pipe (Agurell et al. 1986; Hollister 1988a). This relatively low and quite variable bioavailability results from significant loss of THC in sidestream smoke, from variation in individual smoking behaviors, from incomplete absorption from inhaled smoke, and from metabolism in lung and cannabinoid pyrolysis. A smoker's experience is probably an important determinant of dose actually absorbed (Herning 1986; Johansson et al. 1989)."

See NIH report online at:

www.nih.gov/news/medmarijuana/MedicalMarijuana.htm#EXECUTIVE

Along with basic differences in individual metabolisms, various degrees of disease development, and even discounting the tolerance factor, there are distinct pharmacological differences among the many strains of cannabis in use today. THC is one of the active substances found in the resin of marijuana flowers. A handful of compounds called "cannabinoids" work together in a synergy of effects. Cannabis is one of the most diverse plant species cultivated, and there are subtle differences in the medicinal properties in use today. Such differences in medical effectiveness of various types of marijuana certainly alter the amounts required. It is also clear that potency is partially determined by cultivation techniques, which is another important variable in the range of quantities needed for various medical uses.

California NORML (National Association for Reform of Marijuana Laws) published the only reputable assay of medical marijuana in 1999. Those test results show a wide disparity in potency.

"The study, consisting of three rounds of testing by two different DEA-licensed laboratories, measured the concentrations of THC, the primary active ingredient of marijuana, and its two commonest chemical relatives, known as cannabinoids, CBD and CBN. In all, 49 samples of medicinal cannabis were analyzed for potency by standard gas chromatograph mass spectrometry.

The sample showing the lowest THC (less than or equal to 3.9%) was the government's own marijuana, grown for the National Institute on Drug Abuse (NIDA) to supply researchers and eight legal medical marijuana patients. Nearly all other samples tested over 8%, with averages in the range of 12.8% -15.4%, and many samples above 20%. One sample of hashish (concentrated resin) tested above 44%."

See: http://www.cannabismd.org/foundation/excessivesmoke.php or: www.canorml.org

Some legal authorities might like to impose an exact and standardized dose limit that would apply universally in every case. Yet medical facts indicate that such a precise understanding may never be attained. Some patients use vastly greater amounts than others, and patients often develop patterns of use that may change with time due to numerous individual factors. Cannabis is non-toxic and there are no serious health risks associated with overdose, so the determination of dose limitations is primarily a concern of law enforcement. However, there has been inadequate scientific study of cannabis to firmly establish exact quantity limits for effective medical use at this time.

California State Legislators have arrived at this same conclusion. In the words of California Attorney General Bill Lockyer:

"Senate Bill 848 did not include 'guidelines' or 'standards' addressing the quantity of marijuana a person with a valid recommendation could possess. The issue was discussed and debated many times within the task force before the final legislative recommendations were drafted. However, the strong consensus of the task force was that the amount of marijuana a patient may possess might well depend on the type of illness, and is, in any event, ultimately a medical question more appropriately analyzed and decided by medical professionals."

See: www.cannabismd.org/foundation/alameda.php

Exact dose requirements for medical marijuana patients have not been established. But there are some general ranges in use by reputable medical and legal authorities. In Washington State, accurate identification of a 60 day supply must reflect the amounts prescribed by modern medical scientists, as well as in long-standing federal regulations.

Dr. Donald Abrams conducted the first clinical trials of medical marijuana with AIDS patients at San Francisco General Hospital. During the initial 21 day study, Dr. Abrams prescribed three marijuana cigarettes per day--one .joint before each mealtime. Abrams determined that marijuana use does not interfere with retroviral AIDS drugs, and that medical marijuana smokers gained more weight than control groups taking either a placebo or Marinol, the standardized THC pill. Marijuana cigarettes used in the study were obtained from the National Institute on Drug Abuse, the same as the FDA's Compassionate Use IND Program.

South of San Francisco, in San Mateo County, the first State-sponsored medical marijuana trials are conducted at the Cannabis Research Center. Doctors there are also tracking the use of medical marijuana by people with AIDS. And as with the Donald Abrams study, researchers are dispensing marijuana from the US government grown in Mississippi under the direction of the Food and Drug Administration and the National Institute on Drug Abuse (NIDA). Researchers at the San Mateo center limit their subjects to 30 joints per week, or slightly more than 4 per day.

Three or four 1 gram marijuana cigarettes per day, every day, might seem like a tremendous amount compared to the consumption typical of non-medical pot smokers. However, the two reputable research teams that dispensed those amounts were careful and conservative in their prescriptions. Medical marijuana patients who receive this same marijuana from the same federal government cannabis plantation in Mississippi consume two to three times the amount allowed in these current research studies.

The federal government's Compassionate Use Investigational New Drug Program has supplied a handful of patients with federally-grown marijuana for almost 3 decades. Those patients receive 300 pre-rolled joints per month. Patients with chronic pain conditions receive 50% more than others. 450 joints per month. The weight of those joints equals approximately 0.9 grams each, not including the paper. 0.9 grams of cannabis multiplied 300 times equals 250 grams, more than one half-pound (8 ounces) per month. The US government has established a medical marijuana dose range of between one half and three quarters of a pound per month.

See: www.cannabismd.org/reports/russo2.php

Even marijuana advocates agree that the dose range established by the Compassionate Use IND Program is higher than average, which is fortunate for those patients, considering the low quality of government-grown marijuana. The City of Oakland California pioneered patient protections soon after enactment of California's Compassionate Use Act of 1996. After reviewing the dose range established by the US federal government, Oakland set a similar limit of 6 pounds per year. However, after further review, the Oakland City Council adopted a revised limit of 3 pounds per year per patient.

According to the Drug Enforcement Administration:

In California there is no state regulation or standard of the cultivation and/or distribution of medical marijuana. California leaves the establishment of any guidelines to local jurisdictions, which can widely vary. For example, Marin County allows up to six mature plants, and/or a half-pound dried marijuana. Its neighbor, Sonoma County permits possession of three pounds of marijuana, and allows cultivation up to 99 plants, and physicians may recommend more for exceptional patients."

See: www.dea.gov/ongoing/calimarijuana.html

The DEA website report is not entirely correct. California's landmark law, Prop. 215, was amended by Senate Bill 420, but aside from those statewide guidelines, an increasing number of communities have found common ground on legal marijuana gardens. The Sonoma County Office of the Prosecuting Attorney originally adopted an upper limit identical to that of Oakland, but both communities have revised their limits in recent years. Patients in Sonoma County are now allowed to possess up to 3 pounds per year--less than half of the lowest amount currently distributed to patients by the US IND Program.

See: www.cannabismd.org/foundation/sonomaguidelines.php

Oakland California has been a leader in assessing the needs of marijuana patients and the gardens required to supply them. The following text is taken from the 2001 City Council Resolutions:

"The Medical Marijuana Working Group met 4 times in preparation for this report. The Group reached easy consensus that a three month supply was a reasonable amount for a patient to possess. The Group wrestled with difficulty of defining what would be a reasonable amount of marijuana for a 3 month supply. The difficulty in determining this amount comes from interplay of a variety of factors. The nature of a patient's illness bears strongly on the amount of marijuana they need to relieve symptoms. Some illnesses will require daily medication. Others may only require occasional medication. The type of marijuana available to the patient is another factor. Some types are stronger than others are. Some can only be baked in other foods. That requires more marijuana than the type that can be smoked. Even within the same types of marijuana, there are qualitative differences in separate harvests."

See: www.cannabismd.org/foundation/oakland2.php and

www.cannabismd.org/foundation/oakland1.php

Below are listed the current medical cannabis limits set by CA communities:

Arcata: 8 ounces pound dried marijuana per patient Berkeley: ordinance allows 10 plants and 2.5 lbs per patient, or up to 50 plants, 12.5 lbs total for collectives Butte Co.: County guidelines : 6 mature or 12 immature plants, 1 pound processed Calaveras Co.: Board of Supervisors approved: 6 plants and 2 pounds Colusa Co.: case by case review; has permitted 1.5 pounds processed marijuana Del Norte Co.: County adopted Sonoma cultivation guidelines with maximum 100 square feet cultivation area and 99 plants or fewer; one pound possession limit El Dorado Co.: Sheriff & DA policy: Indoors: 10 flowering plants + 10 vegetative + 1 mother; Outdoors: 20 starters or 10 mature plants, 1 -2 lb processed marijuana depending on season of year Humboldt Co.: County guidelines allow patients 100 square feet and 3 lbs w/ no plant number limit. City of Eureka PD and CHP enforce SB 420 limits (6 mature/12 immature plants, 1/2 lb processed) Inyo Co.: Up to 1/2 pound dried marijuana Mendocino Co.: 25 plants & 2 lbs. processed marijuana per patient Nevada Co.: New policy June 2007: Cultivation: 6 mature female plants or 75 square feet of plant canopy. Possession: 2 lbs processed marijuana Oakland: Indoors -72 plants in maximum 32 sq. ft growing area. Outdoors -20 plants, no area limit, weight limit 3 lbs dried marijuana per patient, collective gardens limited to 3 patients, dispensaries serving four or more patients allowed 6 mature and 12 immature plants and 1/2 pound per patient San Diego (also Chula Vista): City Council guidelines allow up to 1 lb of marijuana, 24 plants in 64 square feet indoors; no outdoor growing allowed except in enclosed greenhouses San Francisco: Patients allowed up to 24 plants or 25 square feet of canopy; dispensary gardens capped at 99 plants in 100 square feet, possession limit 8 oz. dried cannabis per patient Santa Cruz: cultivation to 100 sq feet canopy and 3 lbs processed Sonoma Co.: guidelines permit 3 lbs for possession; maximum 100 square feet cultivation area with 30 plants or fewer (approved Sept 2006) Trinity Co.: guidelines permit 3 lbs for possession; 12 mature and/or 24 immature plants (up to 36 total)

(SOURCES: CANORML.org and CA AG Lockyer)

Communities NOT listed above are subject to California state guidelines set by Senate Bill 420 in 2004: patients may possess 6 mature plants, 12 immature plants, and 8 ounces of dried marijuana.

North of Washington State, medical marijuana is regulated by Health Canada.. Utilizing complicated equations for estimating the needs of marijuana patients, Health Canada has established one important provision: patients are allowed to possess up to 5 grams per day with the standard medical authorization. Patients are not prohibited from possessing larger amounts, but in such a case a physician must sign an additional form to register their greater-than-average medical requirements.

From the Health Canada website:

Health Canada's examination of the current available information suggests most individuals use an average daily amount of 1 gram to 3 grams of dried marihuana for medical purposes, whether it is taken orally, or inhaled or a combination of both. Based on the World Health Organization (1997), a typical joint contains between 0.5 and 1.0 gram of cannabis plant matter. Accordingly, a daily amount of 3 grams will result in approximately 3 to 6 joints. Actual dose of THC absorbed when smoked is not easily quantified. It has been estimated that 20-70% of the actual THC level is delivered in the smoke.

It is reported that an elevated daily dosage of more than 5 grams may increase risks with respect to the effect on cardiovascular, pulmonary and immune systems and psychomotor performance, as well as potential drug dependency. An authorized patient can choose to order marihuana from Health Canada. With that option he/she can access a standardized and tested source of supply produced under contract for Health Canada. It is comprised of flowering heads and female plants with a tetrahydrocannabinol (THC) level of 12.5 ± 1.5%. Authorized patients also have the option of cultivating marihuana for themselves or having a person designated to cultivate for them. The number of marihuana plants they can cultivate is based on the daily amount identified in the application. For instance, a daily amount of 3 grams is approved for indoor production of 15 plants and a storage quantity of 675 grams of marihuana.

Extensive Information for Health Care Professionals Online: http://www.hc-sc.gc.ca/dhp-mps/marihuana/how-comment/medpract/infoprof/index_rev_e.html

To our immediate south, Washington has another appropriate example. The Evergreen State initially led the Pacific Northwest in medical marijuana statutes, but Oregon has been faster to implement some much-needed updates to their public initiative. Oregon's Medical Marijuana Act was effectively amended on January 1, 2006. Senate Bill 1085 raised the quantity of cannabis that authorized patients may possess from 7 plants (with no more than 3 mature) and 3 ounces of cannabis to 6 mature cannabis plants, 18 immature seedlings, and 24 ounces of dry, processed medicine.

In NIDA-sanctioned research studies, medical marijuana is prescribed by physicians at approximately 3.6 grams per day, a rate equal to almost 8 ounces in a 60 day period. The US federal medical marijuana program, a 60 day supply equals at least 8, and up to 12 ounces of processed marijuana. In California, the legal limit is again at least 8, but up to 48 ounces in some communities. Canada's marijuana patients may possess 675 grams, approximately 24 ounces. Oregon, in an environment similar to that of Washington, the allowable limit coincides with Canada's limit of 24 ounces of usable medicine. In a voluntary survey of over 200 legally qualified long-term medical marijuana patients in Western Washington conducted from 2001 through 2003, respondents reported an average usage of 15 grams per week, with the highest reported data at about twice that amount, 1 ounce per week, or about 8 ounces per 60 days. In the 1996 medical necessity defense of Martin Martinez, a physician testified that the use of 3.5 grams per day (about 8 ounces over a 60 day period) was reasonable in his professional medical opinion. (More than ten years later, the chronic pain patient's use has more than doubled to at least 7 grams per day-about 16 ounces per 60 days.)

Available data from credible sources recognizes that the majority of medical marijuana users consume up to about 1 ounce per week. Many anecdotal reports indicate that a small percentage of severely ill patients may use twice that amount, up to two ounces per week, though the greater share of patients definitely use less.

MARIJUANA CULTIVATION LIMITS

The most important distinction of a marijuana garden is its location. Most areas of California offer extraordinary outdoor growing conditions, and legal limits of garden area are fixed accordingly. California regulations often designate canopy size rather than numbers of plants as the means of determination. Comparing cannabis cultivation in The Golden State with cannabis cultivation in The Evergreen State is very much like comparing oranges and apples. Not only is the weather generally less beneficial, Washington law specifically prohibits "public display", a provision that limits medical marijuana cultivation to indoor gardens for most growers. Also, marijuana patients are generally aware of the great likelihood that an outdoor marijuana garden may be eradicated by police regardless of a medical recommendation.

Law enforcement agencies would like to set a precise number of marijuana plants as a definition of the 60 day supply for all marijuana patients in Washington State. In fact, many other states have already fixed a certain number of plants allowable per patient. However, without a scientific basis, such designations are arbitrary, capricious, and may be subject to a legal challenge by qualified patients acting within the spirit of the statute.

Officially, the sole source of information on typical yield of marijuana plants is the June 1992 study published by the US Drug Enforcement Agency titled Cannabis Yields. Law enforcement policies and provisions governing marijuana cultivation in the United States are determined by that single study of outdoor marijuana plants. Albeit useful to law enforcement, the DEA study of outdoor marijuana farming has very little relation to the cultivation of medical marijuana under artificial lighting in basements or other interior environments. According to Cannabis Yields by the DEA, various types of outdoor cannabis plants under various outdoor planting conditions may yield averages of 236 grams, or about one half pound, to 846 grams, or nearly two pounds. In addition, the study notes data from outdoor marijuana eradication programs:

"The total number of cultivated outdoor cannabis plants eradicated in 1991 was 5,257,486. The number of sensemilla plants was 2,251,735, or 42.8% of the total, and the number of non-sensemilla plants was 3,005,751, or 57.2% of the total. A weighed average using the yields reported in Table 4 results in an average domestic plant yield of 448 grams, or approximately 1 pound per plant." (Cannabis Yields, June 1992, Drug Enforcement Administration) These DEA estimates are not disputed. Cannabis plants may reach as high as 16 feet tall or more under ideal outdoor conditions. But the best possible yield of indoor plants does not compare with the potential yield of outdoor plants on a one-to-one ratio. Indoor growers cannot possibly create the huge outdoor plants studied in Cannabis Yields by the DEA.

Indoor ceiling height and floor-area limitations demand a completely different approach to cannabis cultivation. Washingtonians labor under high-voltage lighting with industrial venting and other technologies. In California, many patients grow a four or six month supply outdoors, two or three times per year, which is why many California guidelines allow relatively large amounts of processed medicine and relatively fewer live plants. A single outdoor plant might yield 16 ounces of finished product. Indoor gardens consist of much smaller plants due to height restrictions and limitations of stationary lighting. In Washington, our 60 day supply clause effectively prohibits the traditional outdoor growing season with its bountiful harvest. In Washington, a small group of medical marijuana plants must be harvested every two months in order to comply with the 60 day supply limitation. Indoor cultivators must maintain a constant cycle of plants in at least two stages of development in order to meet legal as well as botanical limitations.

Cannabis plants begin to flower when their daily light cycle is cut in half. 12 hours of darkness triggers hormonal development that produces cannabinoid-rich flowers over a two-month period. Thus, the youngest possible cannabis plants one might consume must be grown for at least three month, one month for vegetative growth followed by a two-month flowering (budding) period. A larger harvest is gained through an extended vegetative period prior to the two month bloom cycle. This botanical feature of cannabis is the reason why many of the limits covered earlier in this paper specify the state of maturity of cannabis plants. The amount of vegetative plants allowed is typically three times the amount of mature plants allowed.

It is important to mention that police officers are not trained in botany and should not be burdened with the specialized task of examining amorphous stages of plant development. Certainly it is true that the two-month flower cycle cannot be distinguished by a novice during the first two weeks while there are no visible signs to observe. The rapid leaf development of vegetative plants morphs into the slower development of small white hairs that swell into resinous buds in several weeks. A simple plant-count limit may suffice in most examples, but precise plant-stage determinations by untrained officers would likely become a source of conflict over time.

The limitations of Senate Bill 1085 in Oregon offer a parallel to the comparable needs of marijuana patients in Washington. Oregon allows 6 mature plants and 18 vegetative plants. It is known that the Office of the Prosecutor has already set a flat 36 plant limit in King County. Although it is this author's opinion that the most capable marijuana farmers can learn to subsist on only 24 plants if they have sufficient equipment and floor area available, there are many growers who simply cannot conform to those rules. 24 is an ample number for collective p-patch marijuana gardens. (Even large groups shy away from the federal threshold of 100 plants, as most know that this number invokes the 5-year mandatory minimum sentence.) However, in my experience as Washington’s court- qualified expert in the use and cultivation of medical marijuana, I am certain that this range of limits will definitely not suffice for growers who have limited resources.

In one case in which I was deposed as expert witness, State of WA v. Mark Mariano Reyes, from Thurston County, Cause No. 03-1-196-5, the defendant had only one room and only one light available. Hence, there was no possibility the patient could conduct the two-cycle pattern (requiring two separate rooms with two separate lights) allowed under the regulations observed in Oregon.

With only one light-station, it is simply not possible to maintain a constant 60 day supply because medical marijuana plants must develop through a lifetime of at least three months. This is one example of what has become a classic conundrum: the most seriously ill patients who have the greatest medicinal needs and the poorest marijuana patients with the least ability to cope with their difficult circumstances are the ones subject to the greatest peril of interdiction.

Another fine point that must be recognized is the germination and sexing of seeds. Any group of seeds tends to be about 50 percent males, and those are usually destroyed after weeks or even months of growth. Clearly, the germination of seeds and the culling of males out of a sensimilla (seedless) crop may require a substantial time span wherein a large number of plants must be possessed, yet have absolutely no medicinal value.

Three photographs are provided to illustrate a range of yields from indoor cultivation.

The plant on the top is 26 inches tall, including its container. This small plant is about three months old and yields approximately one half ounce of usable medicine. The center plant is 41 inches tall, including its container. The center plant is about four months old and yields approximately one and one half ounces of usable medicine. The large plant on the bottom measures 44 inches tall, including its wider-than-average container. The large plant is about six months old and yields approximately four and one half ounces of usable medicine. Left to right, each plant yields three times more medicine than the previous plant, even though they were grown under similar conditions.

This series of photographs indicates that the largest of typical indoor plants might yield about one quarter of the average outdoor plant yield cited by the DEA in 1992. Secondly, these pictures show that indoor marijuana gardens cannot be accurately assessed purely on the basis of the number of plants in possession. Many plants may be replaced by a few, but those few might have far greater yield per square foot of lighted area. Assessing light-area (canopy size) is an alternative method to a simple plant-count restriction currently utilized in several California communities. Note that the middle plant shown above is in the range of average-sized plants grown indoors in Dutch marijuana gardens. The following abstract is from the only reputable study of indoor yields known:

ABSTRACT: To obtain a reliable estimation on the yield of illicit indoor cannabis cultivation in The Netherlands, cannabis plants confiscated by the police were used to determine the yield of dried female flower buds. The developmental stage of flower buds of the seized plants was described on a scale from 1 to 10 where the value of 10 indicates a fully developed flower bud ready for harvesting. Using eight additional characteristics describing the grow room and cultivation parameters, regression analysis with subset selection was carried out to develop two models for the yield of indoor cannabis cultivation. The median Dutch illicit grow room consists of 259 cannabis plants, has a plant density of 15 plants/m², and 510 W of growth lamps per m². For the median Dutch grow room, the predicted yield of female flower buds at the harvestable developmental stage (stage 10) was 33.7 g/plant or 505 g/m². Yield of Illicit Indoor Cannabis Cultivation in the Netherlands

Journal of Forensic Sciences, Volume 51 Issue 5 Page 1050-1054, September 2006

www.blackwell-synergy.com/doi/abs/10.1111/j.1556-4029.2006.00228.x

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ABOUT THE AUTHOR

Martin Martinez presented Seattle's first medical necessity defense in 1996, eight months prior to the passage of Proposition 215 in California. Two years of legal battles with the State of Washington that included a trial and two arrests finally ended the same week that Washington adopted The Medical Use of Marijuana Act of 1998, a popular measure initially filed by Martin's physician in 1997. Martinez relocated to Oakland, California for four years. During that time he was one of the 14 marijuana patients who petitioned the US Supreme Court for the use of medical marijuana in the OCBC vs. Ashcroft case litigated by attorney Robert Raisch for Jeff Jones and Bay Area supporters. During this time Martinez also wrote The New Prescription--Marijuana as Medicine, a compendium of scientific studies on medical marijuana published by Quick American Archives (Ed Rosenthal) of Oakland. Martin's science-based website, www.Cannabis MD.org, was launched near the turn of the century. The site remains a valuable resource for marijuana patients and activists throughout the world, generating over one million hits per year. Martinez has spent many years petitioning the Washington State Legislature for reforms to the existing medical marijuana statutes, personally representing hundreds of patients, members of Lifevine, the medicinal collective designed to conform to state statutes. Martin Martinez has also represented facts of medical and botanical science in courtrooms around The Evergreen State as Washington’s only court-appointed expert witness on the use and cultivation of cannabis. Martinez produced a short documentary entitled The Miracles of Marijuana that has been viewed by many government officials in Washington. The crippled chronic pain patient recently spent many long hours in draft and lobby efforts that eventually resulted in the passage of Senate Bill 6032, a much-needed update of the original citizen's initiative. A key feature of those legislative revisions is the Department of Health determination of the 60 day supply clause which has been the source of numerous legal battles. This paper, Marijuana Patient Dosage and Cultivation Limits, was specifically written to help Department of Health administrators understand some important facets of medicinal cannabis, the most powerful herbal medicine known to mankind.