Global Ganja Report

Among the ambiguous areas in the state medical marijuana laws from coast to coast is the status of cannabis and its derivatives as veterinary medications. Now, a new non-profit has been launched to advocate for legal standards and clarity on the question.

The Veterinary Cannabis Society defines its mission as "to create lasting solutions that ensure the safe use of cannabis in pets through education, advocacy, and promoting product standards." 

Education and advocacy for industry standards 
Dr. Gary Richter of Holistic Veterinary Care in Oakland, Calif., is vice president and co-founder of VCS. He describes his practice, which he began in 1998, as "integrative medicine" — incorporating both the conventional Western model but also "alternative" treatments such as acupuncture, chiropractic, and herbal applications. 

This includes cannabis. "I have been seeing patients for years that have benefited from medical cannabis," he tells Project CBD. He says he has discussed cannabis as a treatment with his patients' owners, as is now permitted by California law.

In a 2019 interview with Project CBD Richter named gastrointestinal issues, pain and inflammation as conditions that cannabis appears effective for in animals.

Richter describes his new organization as "a forum for pet owners and vets to get involved in advocacy efforts, to get things sorted out on a state-by-state basis. We want to make sure products are put together properly, by developing a certification process."

He foresees that soon companies "can put the VCS seal of approval on their products — assuring that they were made in a facility that meets standards, that they are properly analyzed, and labeled accurately for content. We want to make sure companies in their labelling and advertizing are doing it right, and not making inappropriate claims, not promising things they shouldn't promise, and so on."

He hopes to see such standards adopted uniformly nationwide through a three-pronged strategy of "education, advocacy and working with the industry." 

The VCS was launched with members in multiple states, and will be reaching out to more people through a panel discussion the group will be hosting at the annual conference of the American Holistic Veterinary Medical Association (AHVMA), to be held in Reno this October.

Current state of the law in California
While cannabis or (at least) cannabis extracts are permitted for medical use in nearly all states now, California is one of the few states that has taken the first tentative steps toward providing some legal clarity on the status of cannabis and cannabinoids for veterinary use.

The impetus came in February 2017, when the California Veterinary Medical Board (VMB), a body of the state government, sent a memo to every vet in the state entitled "Current Laws and Policies Regarding Marijuana, Hemp, and Animals." It stated: "There is nothing in California law that would allow a veterinarian to prescribe, recommend, or approve marijuana for treating animals. Veterinarians are in violation of California law if they are incorporating cannabis into their practices."

The memo closed with these foreboding words: "From an enforcement perspective, if the Veterinary Medical Board were to receive a complaint related to a Board licensee’s involvement in the treatment of an animal with a marijuana or hemp-related product, the Board would be obligated to conduct an investigation and take appropriate disciplinary action if the findings so warranted."

This led to passage of Assembly Bill 2215 that year, written by Ash Kalra of San Jose, which allows vets to discuss cannabis with their clients without fear of disciplinary or legal action — but not to actually "recommend" it. The VMB ultimately supported its passage, with a caveat raising "concerns regarding the need for cannabis research."

Richter was more enthused by an alternative legislation, Senate Bill 627, authored by Sen. Cathleen Galgiani of the Central Valley, which would have amended the state Health & Safety Code to allow vets to explicitly recommend cannabis (for pets, not livestock). This was supported by the AHVMA but not the VMB — and failed to pass last year after a tortuous year-long journey through the legislative process. "That would have sorted out all our problems," Richter laments.

The VMB did not actually oppose SB 627, but took a position of "support if amended." In a May 22, 2020 letter to Galgiani, the VMB wrote: "[T]he Board acknowledges that medicinal cannabis and medical cannabis products may have potential health benefits to animals." But it called for "amendments to the bill to address funding for animal cannabis research."

However, it was other factors that ultimately led to the defeat of SB 627. It passed the Senate unanimously in May 2019. But when it moved to the Assembly, the Business & Professions Committee added amendments allowing veterinary cannabis products to be sold freely without formal recommendation at either medical dispensaries or adult-use retail outlets. These proved a poison pill for the Appropriations Committee, which nixed it in 2020.

A new bill introduced this year, AB 384, again by Ash Kalra, is a weaker legal remedy — it would prevent the VMB from disciplining a vet for recommending cannabis, but does not actually define cannabis products for animals as medicine, as SB 627 did.

Michelle M. Cave, public information officer with the California Department of Consumer Affairs, the VMB's parent body, tells Project CBD that the Board "does not have a position on AB 384. The VMB is watching it closely and will continue to discuss it at future meetings."

California Veterinary Medical Association (CVMA), which represents the industry in the state, opposed AB 627 on the grounds that its provisions for "continuing education" in cannabis medicine for vets were too weak. It also objected to the bill's proposed creation of a "qualified veterinarian" category to recommend cannabis. The CVMA notes that California law "does not create a qualifying professional designation like this for any other drug that is prescribed by a licensed veterinarian."

The CVMA now supports AB 384, stating: "The CVMA is working closely with Mr. Kalra and his staff to represent the veterinary profession on this issue."

California NORML also supports AB 384.

Keeping pets safe
Richter sees AB 384's failure to formally designate cannabis as medicine as a serious flaw in the legislation. In his view, the imperative for standards and oversight is actually augmented by the loosening of strictures on cannabis under California's adult-use legalization, in effect since 2018.

"Recreational availability allows people to circumvent the process," Richter says, "which means animals could be dosed improperly, or be given cannabis when something else might be more appropriate. We want medical dispensaries to be able to sell cannabis products for veterinary use. And I'm optimistic we can get that done. With more support from the public and the profession, we can get legislators to take action to keep these guys safe."

While CBD products are being marketed openly for pets in California, with the firm VetCBD a leader in the sector, Richter thinks the real regulatory imperative is for psychoactive products.

"Regulation is much less of an imperative for CBD. The legislation in California concerns THC. Anything with a significant amount of THC we think should be sold with a medical recommendation to prevent toxicity or accidental overdose," he says.

Richter has already had to deal in his practice with pets that have overdone it. "The large majority of cases of toxicity are accidental — the dog ate something that was intended for humans," he relates. "Usually the dogs are fine on their own, but sometimes medical intervention is necessary — such as intravenous to speed the excretion process and get everything out. In rare cases, it can be fatal."

This echoes the findings of a study by European researchers published this March in the Germany-based journal Animals and posted to the US National Institutes of Health website. The abstract states: "As cannabis-derived products have become more available, veterinarians are seeing more cases of toxicosis. In addition, animal owners are having an increasing interest in using these products for their pets."

A 'dangerous situation' 
Lovingly & Legally is a registered "social purpose corporation" based in the Mendocino County town of Laytonville, which formally sponsored AB 627 in the Assembly. Its co-directors Paul Hansbury and Susan Tibbon have years of experience in the local cannabis industry, and now say they are working for "the very best health and welfare for human and animal patients." 

"All 2215 did was reaffirm veterinarians' First Amendment rights," Hansbury tells Project CBD.  

And AB 384, he points out, would change the Veterinary Medical Practices Act to allow veterinarians to recommend cannabis — but would not explicitly bring vets under the regulatory framework of MAUCRSA. That's the Medicinal & Adult-Use Cannabis Regulatory Safety Act, the enabling legislation for the 2016 cannabis legalization initiative Proposition 16, which came into force at the start of 2018, creating a regulatory framework for both medical and recreational cannabis. Even if 384 becomes law, there will be "no guardrails, no safety precautions," Hansbury says.

"Treating animals with Dr. Facebook or Dr. Google, or whatever the budtender has to say about it — that's no way to treat a sick animal," he says. He states that since the passage of Prop 64, there has been a "substantial increase in veterinary emergency room visits for cannabis toxicity."

"It's usually because a pet got into an edible," Tibbon clarifies. "But a portion is due to an error of omission or commission when a product was discussed. There's a lot of aggressive advertising, creating a craze for what happens to the be pet product du jour."

"It's a dangerous situation," she adds. "If a dog is suffering from hyperthyroidism, they could be subject to organ failure if they don't get professional diagnosis.  We have agency that animals don't have. That's why it says 'keep away from children and animals" on everything in your medicine cabinet. There's a reason for that." 

Hansbury points to another shortcoming in AB 384. "Vets want to recommend medical marijuana to pet parents," he says. "But this would be useless in a county like Napa that doesn't allow recreational dispensaries. Nothing will change in those counties unless we can alter MAUCRSA by changing the definition of physicians to include vets and patients to include animals." 

Industry influence?
Hansbury and Tibbon point to the lobbying efforts of VetCBD as critical to the failure of any measure to pass that would bring veterinary cannabis products under state oversight. It should be noted that because their CBD products are derived from what California state law calls "cannabis" (rather than "hemp"), they too would be subject to regulation. 

Reached for comment, VetCBD founder and CEO Dr. Tim Shu says that his company "supported AB 2215, which allows veterinarians to discuss cannabis with clients, but not recommend it. Because many veterinarians are not clear where the boundary lies between discussion and recommendation, many are still uncomfortable discussing cannabis with their clients in any capacity. That’s where VetCBD’s support of AB 384 comes in. The passage of AB 384 would allow veterinarians to recommend the use of cannabis as a therapeutic without fear of legal reprisal. Additionally, AB 384 will create a category of pet cannabis products tested and regulated under the standards of MAUCRSA, California’s cannabis framework."

He says that VetCBD "supported SB 627 as it was amended, but it never made it out of the Assembly Appropriations Committee." 

Asked about VetCBD’s relationship with lobbying, Shu said only: "VetCBD has been bolstering awareness efforts for AB-384 by asking the public to join in supporting the measure by writing letters to the California Legislature." He pointed to the website launched for this effort, PetCannabis.org.

Veterinary medicine and New York's MTRA
Other states around the country are also beginning to broach this question. Andy Fleming of Rochester, NY, is a founding member of the Veterinary Cannabis Society and former president of the New York State Veterinary Society. He is encouraged that the Empire State's new cannabis legalization statute at least implicitly recognizes veterinary uses. 

In its expansion of New York's medical marijuana program, the Marijuana Regulation & Taxation Act (MRTA) lists veterinarians as “providers” of healthcare under the heading “definitions” — although they are not mentioned anywhere else. “It doesn't carve us out in terms of use of cannabis in therapy, but doesn't carve us in either," says Fleming. "We’ll see what happens in regulations. We hope to have a definitive plan for veterinary cannabis use. We might have a chance at getting our voices heard. We want to be able to use the full gamut of cannabinoids. We're hoping New York state will take the lead."  

Fleming formerly ran Rochester's Cats Exclusively hospital, and still maintains a multi-disciplinary practice, incorporating Chinese herbal medicine and acupuncture to treat conditions such as paresis in cats and dogs. He studied Chinese medicine at Chi University in Reddick, Fla, the veterinary school founded by Husing Xie — who was trained in China, where veterinary herbology is widely taught and practiced. Fleming says cannabis was not mentioned in his coursework, but when CBD became widely available, he began to inform himself, and followed up with a University of Colorado online course in use of medical cannabis in humans. 

While he sees potential in veterinary CBD products such as HempRX in treatment of ailments such as osteo-arthiris in dogs, Fleming believes much more research needs to be done in veterinary use THC. "This could be key to phasing out opioids in veterinary medicine," he says. 

Other states
A turning point for Fleming was when he attended a presentation entitled "The Endocannabinoid System & its Clinical Relevance" at a September 2019 Northeast regional meeting of the American Veterinary Medical Association (AVMA) in Portland, Me. This was led by Dr. Kasara Andre of the Colorado School of Animal Massage, based in the Denver suburb of Wheat Ridge. "Massachusetts had just legalized, so there was a lot of interest and enthusiasm," she recalls.

Andre, also a founding member of the VCS, calls herself an "integrative holistic practitioner," but started her veterinary career working with dogs in the military, including at North Carolina's Fort Bragg. She was trained at Virginia Tech's veterinary school on Uncle Sam's dime in exchange for 10 years of service as a commissioned officer. Her commission ended in 2016.

Andre notes that in 2016, the Colorado Veterinary Medical Association (CVMA) issued a memo, "CVMA Position Statement on Marijuana and Marijuana-derived Products in Companion Animals," which states: "Veterinarians have an obligation to provide companion animal owners with complete education in regard to the potential risks and benefits of marijuana products in animals." She also notes that Michigan this January passed a law allowing veterinarians to discuss use of cannabis products with pet owners — or, in the terminology increasingly preferred by vets, "pet parents."   

But a fundamental gap in the law remains. "Cannabis is either Schedule 1 on the marijuana side or not scheduled at all on the hemp side," Casara says. "So you can't prescribe either way. And there are currently no laws that allow a veterinarian to recommend, in the sense of actually giving an animal a medical card that allows something to be purchased from a dispensary specifically for them. The pet parent has to buy it for themselves and then decide ‘Oh, I want to use this on my dog.’ We are lacking precise terminology, so everyone winds up getting very confused."

Before the law is clarified, Andre says, she hopes the VCS and responsible vets can provide guidance, making sure pet parents review and understand the certificate of analysis for cannabis products — the label required by California and other states, assuring that the product has passed muster in a licensed laboratory and meets standards.

"We need to make sure the product is not dangerous for animals," Andre says. "Some edibles are made with chocolate — but chocolate is quite bad for animals, especially dogs. The sweetener xylotol is used in some cannabis products, and a very small amount of that will cause renal failure in dogs. Cannaboinds and terpenes themselves are really safe to work with, we find, but products that have been processed for humans can be trouble."

Opening space for research 
Another VCS founding member is Dr. Trina Hazzah of Long Beach, Calif., who serves as the organization's president. She was also certified at the Chi Institute, and recently left her veterinary oncology practice to start a cannabis consulting service, to be called Green Nile. 

While she believes the anti-inflammatory, anti-pain and anti-seizure properties of cannabis products demand attention, "lack of knowledge and fear of disciplinary action by the Veterinary Board are holding us back. We need a society where vets can feel comfortable discussing cannabis — a non-judgmental space for sharing information. And a process to tighten up veterinary cannabis medicine and develop standards."  

She does see greater scientific clarity emerging. "If a pet parent has a particular set of needs, we are starting to know which molecules are most effective. CBDA, for instance is COX-2 inhibitor. COX-2 is an enzyme involved in inflammation, so CBDA might be good to include in the profile of molecules were looking for to treat that." 

Research on CBD to treat arthritis in dogs has recently been undertaken at Cornell and at Colorado State University, and been found promising. "Research shows CBD is very safe in both dogs and cats," Gary Richter says. "But there has been precious little research done regarding animals and THC." 

Cross-post to Project CBD

Graphic by Americans for Safe Access

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