Re: Recent coverage of Prairie Plant Systems and CanniMed
[“Prairie Plant Plant Systems’ Medical Marijuana Monopoly is Back”, “Companies Ready To Cash In On Canada’s New Medical Marijuana Program”, “CanniMed Not Ready To Sell Medical Marijuana”]
Dear Mr. Vandermeer,
I sincerely understand and appreciate your concerns raised in the articles you have posted since our press release hit the wire on September 23rd that Prairie Plant Systems and CanniMed were awarded the first two licenses under the new Marihuana for Medical Purposes Regulations.
This is a new and evolving time for everyone involved in the medical marijuana landscape — including patients, the government and producers.
At Prairie Plant Systems, we welcome the new regulations and the fact that a commercial industry will greatly expedite the scientific research that is required to close the gap between the anecdotal benefit of medical marijuana and evidenced-based scientific research. Our goal is to provide improved access for Canadians who rely on medical marijuana through scientific collaboration with academic institutions and healthcare professionals.
At a conference I attended last week in Germany I was blown away by the future of cannabis, and I have been working with the product for 13 years! Science has revealed that there are now 104 identified and confirmed phytocannabinoids present in cannabis plants (obviously in varying ratios). With some hard work and science, just think about what we can offer patients in the future.
But at this stage we are just appreciative that Health Canada has removed the constraints against us and have opened up the medical marijuana market. As you may or may not know, under our agreement with Health Canada, we were limited in our ability to provide only one type of marijuana. As with other medications, we know that one type doesn’t work for everyone.
Under the new regulations, we will be able to offer patients and physicians choice. We are committed to providing two products, CanniMed 12•0 and CanniMed 17•1 by the end of this year as well as CanniMed 9•9 early in 2014. We are also committed to further research and development of new varieties to continue to support patients’ needs.
I do, however, want to take this opportunity to clear up a few facts about Prairie Plant Systems and CanniMed that you may not know.
Our patients are satisfied with our product
There are thousands of Health Canada patients that use medical marijuana purchased through Health Canada and respond very favorably towards the product. It is hard for us to comment on the actual numbers of patients because we are bound by confidentiality through our agreement with Health Canada, I can tell you that historically we have had a return rate of 0.3% – divided between wrong addresses, deceased patients and product rejection. What this means is that we also have a 99.7% acceptance rate of the product.
There is no question that some patients didn’t find our product effective for their condition. As mentioned above, where we were limited in the past was our ability to only offer one strain of medical marijuana to Health Canada. The new regulations will allow this to happen.
We no longer grow our marijuana in the Flin Flon, Manitoba mine
As of 2009, Prairie Plant Systems moved our medical marijuana production site to an undisclosed location above ground in Canada. And with the new requirements imposed by Health Canada, we have undertaken a $24 million retrofit and expansion of our current facility which will provide us with the growing capacity of 5 times our current capacity.
There are no quality discrepancies with our marijuana
After more than 13 years producing medical marijuana for Health Canada, we have refined and strengthened our standards and practices into 281 points of quality control. These quality control points include: sampling, specifications, testing, documentation and approval for release. The use of validated laboratory methodology provides accuracy, reliability and repeatability in these measures.
Our products are tested to pharmacopeia standards including: potency, metals analysis, microbiology purity & mycotoxins. Each major area has a number of items for which the products are tested.
Using appropriate standards leads to safety for patients. Our products are tested before and after they are packaged to ensure safety as well as consistency of the product all of which is released by lot numbers and associated documentation for traceability.
At Prairie Plant Systems we are the only licensed producer to mill our cannabis plant prior to shipment, what this does is create a homogeneous product that further ensure consistency of dose. In this uncertain time, dose consistency gives both the patients and their healthcare professionals the confidence in the level of THC and CBD the patient is receiving.
Our products are irradiated for patient benefit
Extensive research and testing has shown that irradiation is a safe method for eliminating harmful bacteria and mild. By eliminating the potentially harmful bacteria or mold (if any had been present), the process provides assurance for immunocompromised patients that the product is safe. During development of the standards established for quality control, a number of immunologists were consulted as to acceptable microbial counts (Colony Forming Units or CFU/g) for people who have health challenges, whose conditions could be worsened if molds (and their by-products) were in with the medical marijuana product. It was highly recommended by the doctors that patients should only be exposed to mold counts of less than 100 CFU/g. Since this product cannot be heat sterilized given the concerns with vaporisation and heat-induced degradation of the cannabinoids, it was determined that this medical marijuana product should be sterilized in the same manner as other pharmaceutical drugs and even spices. That process is gamma irradiation. This is an acceptable method for sterilizing products that Canadians consume every day.
I have also provided a reference from one of the papers that was used in your article by Canadians for Safe Access, which adds balance to the reference they provided in the article:
“The relevancy of these results for the risk assessment of human consumption of irradiated food remains to be elucidated. It must be emphasized that the daily amount of pure 2-ACB administered to rats corresponds to a pharmacological dose (3.2mg/kg body wt.), which is not comparable to the amount ingested by humans eating irradiated food products, which can be estimated to be ?5-10 ?g/kg body wt. In addition, these food products may also contain several components that may reduce the bioavailability of 2-ACBs. The benefits of food irradiation to protect public health against food-borne pathogenic bacteria are becoming increasingly recognized”
I sincerely hope that this overview has helped to clear up some of the questions you and your staff might have about Prairie Plant Systems or CanniMed. I welcome you to call me directly if you have any further questions.
And please let Matt Mernagh know that our applications forms are now finalized and available on our website (www.cannimed.ca). We welcome the opportunity to count on Matt as one of our clients.
Brent H. Zettl
President and CEO
Prairie Plant Systems Inc. and CanniMed Ltd.