As the legal market for cannabis looks continues to look into new avenues, so does the interest in the different product forms and potential therapeutic uses. Areas such as pain relief for both human and animal use are now being reviewed by Health Canada with the purpose of establishing a viable pathway for therapeutic cannabis that would not require the need for practitioner oversight.
Under the current Cannabis Regulations, cannabis and products that contain cannabis are restricted from making any sort of health or cosmetic claims. Part of this is to restrict youth appeal and concerns regarding the unpredictability of the effects, such as those seen with edible products. But another major reason is that the therapeutic effects of cannabis and its constituents have not been sufficiently studied to determine the safety and efficacy for different indications.
In the public consultation put out by Health Canada between June 19 and September 3, 2019, feedback was garnered on what kinds of Cannabis Health Products (CHPs) Canadians would be interested in if such products were made legally available. Of the 1104 respondents to the public consultation, 62% identified as consumers, 23% were industry interested in manufacturing or selling, and 15% were other interested parties. Of these groups, there was a majority interest in CHPs for both human use and use in animals.
When asked if they would be interested in purchasing a product approved by Health Canada that contains cannabis and is intended to treat minor ailments, 95% of the group had a positive level of interest in purchasing these types of products, or learning more about how they could be used to treat minor ailments. This interest was significantly fueled by those who consider cannabis (especially its component cannabidiol, or CBD) as a natural remedy, and wish to have more access as a complement or alternative to some pharmaceutical drugs. These respondents were in favour of Health Canada’s approval in order to ensure that these types of products would be safe and effective, allowing them more choice and increased access without the need for practitioner oversight.
Regarding the minor ailments that consumers are looking to address, there were a wide range of indications. The top three were pain relief and inflammation, mental health issues, and sleep aids, followed by gastrointestinal issues, skin conditions, and muscle recovery/relaxation, among others. This data shows that there may be specific subpopulations that could benefit from having access to approved products that target these types of conditions, such as seniors, athletes, veterans, or pets. Health Canada is proposing an evidence-based approach linking the cannabis or its constituents to a specific condition in order to allow these types of specific health claims, in order to avoid promoting or normalizing cannabis consumption.
In opening up the market to these new types of products, cannabis retail stores would also be able to benefit by expanding the variety of product that they are allowed to sell in order to meet the evident consumer demand for therapeutic cannabis products. The proposal would allow retail stores to sell the CHPs in the same way as the current classes of cannabis products. However, due to the lack of health training among retail store employees and risk of confusion between non-medical cannabis products and CHPs, public feedback suggests the inclusion of CHPs in pharmacies, veterinary clinics, or health stores. All existing regulations regarding the promotion, packaging and labelling prohibitions on being appealing to youth will still be maintained for CHPs.
Regarding the delivery method of these proposed products, it was found that consumers would prefer oral ingestion (such as oils, capsules, or edibles) and topical application as the means of delivery. Inhalation via vaping or smoking scored lower, which does appear to indicate a shift in consumer perception of cannabis from the common recreational methods of delivery.
There are some exciting shifts that are happening in the cannabis industry, and new regulatory pathways are being explored as more research and knowledge is gained with this versatile ingredient. At the forefront will be the need for products to be proven as safe and effective. Health Canada intends to create a scientific advisory committee in 2020 to provide advice on the appropriate safety, efficacy, and quality standards for health products containing cannabis that would be safe for use without practitioner oversight.
dicentra is actively monitoring the government updates regarding CHPs, and is preparing to meet the industry’s need for regulatory and quality oversight on the innovative formulations that will emerge. Along with our Clinical Research Organization to provide the trials and evidence needed to approve these proposed products, we are here to ensure that you are well-prepared to make your mark in this next proposed phase of legalization.
For more information, please contact dicentra today for a quote.
- Cannabis Act & Regulations
- Food & Drugs Act & Regulations
- Consumer Packaging & Labelling Act and Regulations
- Summary report: Consultation on the potential market for health products containing cannabis that would not require practitioner oversight