(1) The actual or relative potential for abuse of Synthetic Cannabinoids;
(2) if known, scientific evidence of the pharmacological effect of the Synthetic Cannabinoids;
(3) the state of current scientific knowledge regarding the Synthetic Cannabinoids;
(4) the history and current pattern of abuse of Synthetic Cannabinoids;
(5) the scope, duration, and significance of abuse of the Synthetic Cannabinoids;
(6) any risk that Synthetic Cannabinoids pose to the public health;
(7) the ability of Synthetic Cannabinoids to cause psychological or physiological dependence; and
(8) whether Synthetic Cannabinoids are an immediate precursor of a controlled dangerous substance.
In addition, DHMH is seeking comment on this policy question:
(9) Is the current legal framework, requiring listing of specific chemicals, appropriate for Synthetic Cannabinoids, which may contain multiple variants? If not, what type of legal authority could help the Department address this and similar challenges?
These comments will assist the Department with determining next steps. Potential steps include seeking additional legislative authority, monitoring the prevalence and impact of Synthetic Cannabinoids, or determining that specific active compounds in Synthetic Cannabinoids should be added to Schedule I Controlled Dangerous Substances. Such a determination would render the possession, manufacture, distribution and sale of these compounds unlawful.
Comments should be submitted by mail by January 6, 2012 to Michele Phinney, Director, DHMH Office of Regulation and Policy Coordination, 201 W. Preston Street, Room 512, Baltimore, Md. 21201; or by email to firstname.lastname@example.org; or by fax to 410-767-6483.
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