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C-45 Quality Association Cautions New Study's Conclusions May Not be Supported by Limited Data

A new study from researchers in Canada is calling for greater regulatory measures to be placed on cannabis edibles, but some in the country's legal industry are questioning the authors’ conclusions.

The study, Unintentional Pediatric Cannabis Exposures After Legalization of Recreational Cannabis in Canada, looks at emergency department hospital visits for young people in Ontario up to the age of nine, between January 1, 2016, and March 31, 2021.

Dividing the results into three categories - prior to legalization in Canada, after legalization but prior to edibles becoming legal, and then after edibles were introduced - the study shows 522 emergency room visits for young people due to cannabis exposure. While there were 81 visits documented prior to the legalization of cannabis (September 2018), the number increased to 124 from October 2018-January 2020 (when edibles were not yet available in the legal market), and 317 from February 2020-March 2021.

Edibles and other non-flower cannabis products become legal in Canada on October 17, 2019, with products beginning to make it to shelves several months later.

“These findings suggest that the introduction of legal commercial edible cannabis products was a key factor associated with changes in ED (Emergency Department) visit frequency and severity,” notes the study. “Rates of pediatric cannabis ED exposures found in this study were seven-fold higher than rates reported in Colorado after recreational cannabis legalization.”

The study also notes that it was unable to determine exactly what types of products had sent these young people to the emergency room, or the origin of the products (whether licit market or illicit market), noting it’s possible that illicit sources and non-edible products could have contributed to the increase in visits, as well.

Nonetheless, the study concludes that “Further regulatory measures, such as limiting formulations and appearance of commercial edibles, combined with education for parents and caregivers, may be required to decrease pediatric cannabis exposures.”

One member of the C-45 Quality Association, argues that the results of the study could not show an actual increase in incidents of young people consuming cannabis, accidentally or otherwise. “It is entirely possible that prior to legalization people were unwilling to take someone to emergency due to accidental exposure of cannabis (unless life-threatening presumably) due to the presumed scrutiny of a child accessing an illegal drug,” they noted. “Post legalization and more so, post edible-legalization, the presumed scrutiny likely evaporated and therefore a greater willingness to take someone into emergency even if the exposure was from the illicit market.”

In addition, the study’s authors argue there is a greater need for public education around cannabis products to ensure parents and other adults understand the importance of keeping them away from young people. However, the Canadian federal government already committed to spending $100 million on ongoing public education campaigns to help Canadians better understand issues like the potential health effects of cannabis in the first six years of cannabis legalization.

Anuraga Mandava, a Quality Assurance and Regulatory Affairs consultant in the Canadian cannabis industry and member of C-45’s Regulatory Committee agrees that although continued education is important, the effectiveness of even greater restrictions to edible cannabis products is questionable.

“I agree that more education is necessary, but that is not just limited to parents or caregivers,” says Anuraga. “The health care professionals and the general public must be well informed, as well. Bringing more restrictions is certainly not the answer.”

The C-45 Quality Association advocates for reasonable cannabis regulations in Canada on behalf of its members, and certainly welcomes continued consumer and public education to minimize any potential harms associated with cannabis use, particularly as it relates to the accidental exposure or ingestion of cannabis by young persons.

However, the conclusions of this study - namely that the legalization of edible cannabis products in Canada is the likely principal cause of increased accidental cannabis exposures by children under the age of nine - is not supported by the data, since the source of the cannabis cannot be confirmed, as noted in the paper.

The current Cannabis Regulations in Canada already prevent companies from marketing cannabis products to children and young persons, and all cannabis products including edibles are required to be packaged in certified child-resistant packaging and clearly labelled to prevent accidental ingestion. Further, there are already extensive restrictions on packaging and labelling to reduce appeal to minors, on the potency and number of edibles able to be packaged to reduce the risk of over-consumption, and cannabis products can only be marketed and sold to adults over the age of majority in their respective province or territory. Combined, these types of regulations protect children from accidental exposure to commercially-produced and licitly-sourced cannabis, assuming that the adults living in the same household as children continue to store their products in their original packaging.

The Cannabis Regulations also allow for most Canadians to grow their own cannabis and produce their own edibles and extracts at home for personal consumption. Further, the illicit market continues to supply a significant amount of cannabis products to Canadians, absent of any packaging or dosage restrictions. Without any concrete data on the source of the cannabis, it is simply not possible to determine with great certainty the source of the cannabis exposures presented in the study. The C-45 Quality Association supports evidence-based regulations as they pertain to cannabis in Canada, particularly those that protect public health, but we strongly caution policymakers to consider the significant limitations of this study and its conclusions, which heavily rely on correlation rather than causation.

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