The Administration has initiated a Notice of Proposed Rulemaking (NPRM) which means the public now has the opportunity to comment: This form will allow you to directly submit your comment to the federal register. 

Important things to know: 

This form will allow you to directly submit your comment to the federal register. The comment you submit will be a part of the public record and will be visible to the public. Do not include any personally identifiable information in the comment that you do not want made public. 

All comments must be submitted by July 22, 2024. 

If you would like to submit a comment anonymously, you may do so on the regulations.gov website. 

The Drug Enforcement Administration (DEA) has asked for specific feedback that we have integrated into a sample comment for you. We strongly encourage you to include your own comments in addition to what we have provided. We have included some optional data points below to integrate into your comment. Many of these points are from our Myths and Facts document and our Legalization Impact Report; feel free to copy-paste any relevant points from either document into your comment:

• Poison control data in legalized states: The widespread availability and accessibility of high-potency marijuana due to legalization has resulted in an increasing number of marijuana-related poison control calls, hospitalizations, and ER visits. Nationally, marijuana edible-related poison control calls among children 0-12 increased 3,311% from 2016 to 2022. After legalization, every state sees an increase in THC-related poison control calls, particularly in young children under 6. 
• Drugged driving in legalized states; see the SAM Drugged Driving toolkit for more information. Increased use and normalization of marijuana makes our roads less safe. Marijuana has been implicated in 25% of road deaths in Colorado (CO Division of Criminal Justice, 2020). If marijuana were legalized nationwide, the U.S. would suffer an additional 6,800 excess fatal crashes every year. 
• Increased potency: Marijuana potency has increased significantly and rapidly. Marijuana in the 1970s had an average of 2% THC (the psychoactive component in marijuana), but today the average potency ranges from 18-35% and products as high as 99% are produced and sold by the industry. There is much we do not yet know about high-potency THC products, but what we do know is alarming. These products are more addictive and result in worse health outcomes for users, especially teens and young adults. 
• IQ loss: Multiple scientific studies have now also linked THC to IQ Loss, psychosis, schizophrenia, depression and suicidality. Research shows that marijuana use changes the structure of the brain and heavy, lifelong use can result in IQ loss (Hill & Hsu, 2022).
• ER visits: Marijuana users are 25% more likely to need emergency care and hospitalization. (Vozoris et al., 2022) Between 2011 and 2021, marijuana-related emergency department visits increased by 77% to over 800,000 ED visits. (DAWN, 2011&2021) . Among teenagers in Colorado, emergency department visits were 71% for psychiatric events. (Dr. Ken Finn, 2019) 
• Cannabis Hyperemesis Syndrome (CHS): Though it is true that marijuana misuse does not result in the same kind of immediate overdose that other drugs may cause, cases of Cannabinoid Hyperemesis Syndrome (CHS) have increased significantly since legalization. CHS is a disease that presents as episodes of screaming and vomiting, dubbed “scromiting,” and the only effective treatment is the immediate stoppage of marijuana use. The disease primarily affects heavy, daily users of marijuana.

The comments submitted are considered part of the official record and the Administration is supposed to take public comments into account before issuing a final rule. After the public comment period is over, the Administration will examine the comments and issue a final rule. If the Administration decides to move marijuana to Schedule III, then SAM is prepared to pursue legal action. There is no doubt the other side will flood this rule with positive comments, so please spread this far and wide to anyone you know who is opposed to the normalization of marijuana!