Document 2 - OPH specific recommendations pertaining to the five (5) themes
outlined in the task force discussion paper
One: Minimizing harms of use
Advertising and marketing restrictions recommendations:


Prohibit advertising, marketing, and sponsorship through federal legislation, similar
to that of the Tobacco Act and include language that addresses volume and content
restrictions1,2,3,4,5



Develop a supporting infrastructure to ensure accountability for these restrictions



Adopt plain packaging measures6,7

Taxation and pricing recommendations:


Regulate base prices (including minimum prices) on THC content8,9,10



Index prices to inflation to ensure prices do not decrease relative to other goods over
time

Restrictions on marijuana products (potency) recommendations:


Commission research to determine maximum THC limits11,12



Establish regulations that mandate clear and visible labelling of THC content in
products, accompanied by evidence-based health warnings

Restrictions on marijuana products (edibles) recommendation:


Regulate maximum dosage for edible products and distribution of dosage per
serving size



Set regulations that mandate clear and visible labelling of THC content and dose per
serving size, with visible warning statements



Prohibit production and sale of products that are attractive to children and youth as
well as product content and combinations with other substances



Require child-resistant containers to protect against the risk for unintended overdose



Monitor lessons learned from Colorado13

1

 Limitations on quantities for personal possession recommendation:


Limit quantities for personal possession as a means to reduce opportunities for
resale to youth

Minimum age for purchasing and possessing marijuana recommendation:


The minimum age for purchasing and possessing marijuana should be 25. The
regulations for purchasing and possessing marijuana must be coupled with rigorous
enforcement and penalties for violations in order to be effective14,15,16,17,18,19

Consistency of a minimum age across Canada recommendation:


Develop a federal legislative framework that sets a minimum age for sale or
provision that is consistent across all provinces and territories20,21

Two: Establishing a safe and responsible production system
In response to this section, OPH presented key principles and some recommendations
that the federal government should consider when developing a production model.
Principles:


A production model that provides a safe, consumable product and exposes the
individual to the least amount of harm



A model that has strict government oversight, inspection, regulation and
enforcement is preferred



Regulate marijuana in a way that recognizes its psychoactive properties

Recommendations regarding the production, packaging, storage and distribution
of marijuana:


Develop national standards for production, packaging, storage, distribution and
testing of cannabis products, based on public health principles of prevention and
protection



Expand regulation to a wider variety of cannabis products (e.g., edibles,
concentrates, and tinctures), so that all forms of cannabis are regulated



Provide government resources for inspection and other accountability and regulatory
functions

2

 

Ensure that food safety regulations are followed regarding the manufacturing of
edible products and that food safety training be offered as needed

Three: Designing an appropriate distribution system
Distribution model recommendations:


Adopt a government owned and controlled store front system for distribution22,23,24



Regulate the sale of cannabis paraphernalia



Ensure compliance with requirements through inspections and test-purchasing with
under-age clients



Develop a uniform distribution model consistent across Canada25,26,

Four: Enforcing public safety and protection
Designing laws recommendations:


Set clear minimum standards that all provinces and territories must follow, including
a minimum age for sale, clear regulations for provision/sale , and a clear
enforcement infrastructure to safeguard these new regulations27



Place onus of youth possession of cannabis on the supplier



Provide mandatory labeling or markings that easily identify regulated products

Enforcement measure to protect public health and safety for impaired driving
recommendations:


Develop a comprehensive framework which includes prevention, education, and
enforcement to address and prevent cannabis impaired driving with a focus on
groups at higher risk of harm, such as youth



Strengthen Graduated Licensing System programs and enhance components
related to drug impairment to deter youth usage28



Apply criminal charges for cannabis impaired driving and open products in vehicles
to all offenders regardless of age

3

 Consumption of marijuana in publicly-accessible spaces recommendations:


Apply a comprehensive ban of the consumption of marijuana in workplaces and
indoor and outdoor public spaces at the federal level29,30,31



Explore options to include multi-unit dwellings in legislation to reduce exposure of
second hand smoke

Five: Accessing marijuana for medical purposes
Appropriate access to medically authorized persons recommendations:


Support persons who require marijuana for medical purposes through accessibility
measures such as price



Health professionals should continue to have a role in informing patients of the
health risk as well as the potential benefits of using marijuana for medical purposes
as well as regular health monitoring

1

Government of Canada. 2016. Towards the legalization, regulation and restriction of access to
marijuana: discussion paper. Task force on marijuana legalization and regulation. Canada
2

Lovato C., Linn G., Stead L., Best A. Impact of tobacco advertising and promotion on increasing
adolescent smoking behaviours. Cochrane Database Syst Rev 2011;
DOI: 10.1002/14651858.CD003439.pub2 . Available at:
http://onlinelibrary.wiley.com/wol1/doi/10.1002/14651858.CD003439.pub2/citedby
3

Robertson, L., McGee, R., Marsh L, Hoek J. (2015). A systematic review on the impact of point-of-sale
tobacco promotion on smoking. Nicotine Tob Res. 17(1):2-17
4

Anderson P, de Bruijn A, Angus K, Gordon R, Hastings G. Impact of alcohol advertising and media
exposure on adolescent alcohol use: a systematic review of longitudinal studies. Alcohol 2009; 44:229–
43.
5

World Health Organization. (2015). WHO Framework Convention on Tobacco Control. World Health
Organization. Geneva, Switzerland
6

Australian Office of Best Practice Regulation. Tobacco plain packaging post-implementation review,
February 2016
7

Canadian Centre on Substance Abuse. (2016). Lessons Learned in Colorado and Washington State
Tobacco plain packaging post-implementation review. Ottawa:ON.
8

Thomas, G. Price policies to reduce alcohol-related harm in Canada. (2012). Alcohol Price Policy
Series: Report 3. Ottawa, ON: Canadian Centre on Substance Abuse. Retrieved from:

4

 http://www.ccsa.ca/Resource%20Library/CCSA-Price-Policies-Reduce-Alcohol-Harm-Canada-2012en.pdf
9

Non-Smokers’ Rights Association/Smoking and Health Action Foundation (2015). Retrieved from
http://www.nsra-adnf.ca/cms/file/files/SHAF_Prohibitive_pricing_fact_sheet_March_2015(1).pdf
10

Haden, M and Emerson, B. 2014. A vision for cannabis regulation: a public health approach based on
lesson learned from alcohol and tobacco. Open Medicine, 8 (2) e73.
11

Schlossarek, S., Kempkensteffen, J., Reimer, J. & Verthein, U. (2016). Psyschosocial determinants of
cannabis dependence: A systematic review of literature. European Addiction Research 22:131-144.
12

Canadian Centre on Substance Abuse. Cannabis Regulation: Lessons Learned In Colorado and
Washington State. [Report online]. Ottawa: Canadian Centre on Substance Abuse, 2015 [Last accessed
2016 Jul 27]. Available from: http://www.ccsa.ca/Resource%20Library/CCSA-Cannabis-RegulationLessons-Learned-Report-2015-en.pdf
13

Sam Wang, G. et al (2016) Unintentional Pediatric Exposures to Marijuana in Colorado, 2009-2015

14

Canadian Centre on Substance Abuse. Substance Abuse in Canada: The Effects of Cannabis Use
during Adolescence. [Report online]. Ottawa: Canadian Centre on Substance Abuse, 2015. Available
from: http://www.ccsa.ca/Resource%20Library/CCSA-Effects-of-Cannabis-Use-during-AdolescenceReport-2015-en.pdf
15

Haden, M and Emerson, B. 2014. A vision for cannabis regulation: a public health approach based on
lesson learned from alcohol and tobacco. Open Medicine, 8 (2)e73. Babor. T, et al. Alcohol no ordinary
commodity research and public policy second edition. 2010. New York.
DOI:10.1093/acprof:oso/9780199551149.001.0001
16

Babor. T, et al. Alcohol no ordinary commodity research and public policy second edition. 2010. New
York. DOI:10.1093/acprof:oso/9780199551149.001.0001
17

Giesbrecht N, Wettlaufer A, April, N, Asbridge M, Cukier S, Mann R, McAllister J, Murie A, Plamondon
L, Stockwell T, Thomas G, Thompson K, Vallance K. Strategies to Reduce Alcohol-Related Harms and
Costs in Canada: A Comparison of Provincial Policies. [Report online]. Toronto: Centre for Addiction and
Mental Health, 2013 [Last accessed 2016 Aug 15]. Available from:
https://www.camh.ca/en/research/news_and_publications/reports_and_books/Documents/Strategies%20t
o%20Reduce%20Alcohol%20Related%20Harms%20and%20Costs%202013.pdf
18

Lopez‐Quintero C, Pérez de los Cobos J, Hasin DS, Okuda M, Wang S, et al. (2011). Probability and
predictors of transition from first use to dependence on nicotine, alcohol, cannabis, and cocaine: Results
of the National Epidemiologic Survey on Alcohol and Related Conditions (NESARC). Drug and Alcohol
Dependence 115: 120‐130, as cited in Centre for Addiction and Mental Health. (2014). Cannabis Policy
Framework. Toronto: ON.

5

 19

Schlossarek, S., Kempkensteffen, J., Reimer, J. & Verthein, U. (2016). Psychosocial Determinants of
Cannabis Dependence: A Systematic Review of the Literature. European Addiction Research 22: 131144.
20

Giesbrecht, N., et al (2013). Strategies to Reduce Alcohol-Related Harms and Costs in Canada: A
Comparison of Provincial Policies. Toronto: Centre for Addiction and Mental Health.
21

Callaghan, Russell C et al. (2014). Impacts of drinking-age laws on mortality in Canada, 1980-2009.
Drug and Alcohol Dependence. 138(2014) 137-145.
22

Alcohol No Ordinary Commodity: Research and Public Policy, 2

nd

Edition 2010

23

Regulating Commercially Legalized Marijuana as a Public Health Priority. American Public Health
Association 2016
24

Tilson, Melodie. Non-Smokers’ Rights Association. Reducing the Availability of Tobacco Products at
Retail: Policy Analysis. April 2011.
25

Alcohol No Ordinary Commodity: Research and Public Policy, 2

nd

26

R v Comeau, 2016 NBPC 3 (CanLII), found at http://canlii.ca/t/gpr3f, retrieved on 2016-08-23

Edition

27

Health Canada and the Public Health Agency of Canada. 2012. The Federal Tobacco Control Strategy
2001-2011 Horizontal Evaluation Final Report. Found at http://www.hc-sc.gc.ca/ahcasc/performance/eval/ftcs-evaluation-sflt-eng.php#a7 retrieved on August 23, 2016 at 16:00
28

Mayhew et al,. 1999. Impact of the Graduated Driver Licensing System in Nova Scotia. Ottawa,
Ontario: Traffic Injury Research Foundation.
29

Moir, D., Rickert, W.S., Levasseur, G., Larose, Y. & Maertens, R. (2008). A Comparison of Mainstream
and Sidestream Marijuana and Tobacco Cigarette Smoke Produced under Two Machine Smoking
Conditions. Chemical Research in Toxicology 21, 494–502.
30

Maertens, R.M., White, P.A. Rickert,W., Levasseur, G. & Douglas, G.R. (2009). The Genotoxicity of
Mainstream and Sidestream Marijuana and Tobacco Smoke Condensates. Chemical Research
Toxicology. 22, 1406–1414.
31

Moir, D., W.S. Rickert, G. Levasseur, Y. Larose, R. Maertens, P. White, S. Desjardins, 2008.“A
comparison of mainstream and sidestream marijuana and tobacco cigarette smoke produced under two
machine smoking conditions”. Chem Res Toxicol.;21 (2): 494-502.

6