Pathway for Licensing Natural Health Products under Law in Virginia

More direction regarding claims qualifications is found in the annex text, as well as Section 2.6.4 in the Guidance Document, The Natural Health Product Licensing Pathway to Make Current Claims. The medical ingredients(s) supporting traditional claims(s) must comply with traditional use claims requirements under the Pathway for Licensing Natural Health Products Used as Traditional Medicines. This guidance describes risk-based levels of evidence of the safety and effectiveness of Natural Health Products (NHPs) making contemporary health claims. This guidance provides information to assist applicants for product licenses in determining the evidence (types and amounts of data) that should be submitted in the application for a product license in order to support safety (risk) and effectiveness (benefits) of natural health products (NHPs) that make modern health claims.

It is the responsibility of the Natural and Non-Prescription Health Product Directorate (NNHPD) to consider the information provided as part of the product licence application in order to evaluate the safety, effectiveness, and quality of a natural health product (NHP), ensure benefits are greater than risks, and to clearly record product licensure decisions. Information on all NHPs that have been granted a Product License (NPN) from Health Canada, such as the medicine ingredients, dosage, and recommended uses. Further information and help may be obtained by contacting one of the resources for Substance Use Disorders at the University of Virginia listed under Resources for Alcohol and Other Drugs in this Policy. University functions involving alcohol occurring in appropriately licensed state-licensed food service facilities located outside University property are not required to go through review by a university alcohol-approval office.

Natural Health Products

Any alcohol consumption at University Functions or on University Property should be approved by the proper alcohol approval authority a minimum of five working days in advance using the required University of Virginia Form. The presence of minors family members, employees, or guests does not prevent alcohol from being served in residences which are on University property, provided the proper family member of the appropriate legal age and/or the host is willing to accept the legal responsibility of compliance with Virginia state law and federal laws, as well as university policies. The City of Alexandria cannot regulate the sound of trains because of the rules set forth by the Occupational Safety and Health Administration (OSHA) and Federal Railroad Administration (FRA).

CBD products produced under a legal, medical, or adult-use cannabis program in the State are also illegal products under Federal law, whether in-state or crossing state lines. Every single state-legal cannabis program is illegal under federal law, with no exceptions, and the Farm Bill does nothing to change this.

There are only 11 currently in operation in Virginia, and one of the VAs medical services areas–a wide swath of which includes Winchester and Charlottesville–has no licensed processors, a result of a continuing legal fight. Physician enrollment in VAs medical marijuana program has traditionally been slow, and several of the states largest hospital systems, including Bon Secours, Sentara, and UVA Health, have remained outright prohibited by many of the systems primary providers from offering certifications, or allow marijuana in limited circumstances, like clinical trials or seizures resistant to medical treatments.

Virginia does indeed require pharmacists to supervise cannabis manufacturing and sales, and dispensaries are required to have them on-site to talk to patients about products (another requirement, which has added to high costs, according to some processing facilities). Products often cost twice as much in Virginia as in other markets, including D.C., a fact that some processors attributed to extensive regulation by the state. A small tub of cannabis-infused salves by one Virginia-based processor, for instance, costs $75 online.

Earlier this year, Virginia lawmakers approved a bill requested by the board, which eliminated patient registration requirements, allowing medical marijuana patients to buy products at dispensaries once they have received written verification of their eligibility to use medicinal marijuana from their provider. While provisions are in place to strictly regulate hemp, and concerns have been raised by law enforcement – fair or not – about marijuana plants used for cannabis production being mixed in with hemp plants, the legislation makes hemp the primary crop. Hemp will be a highly regulated crop in the U.S., both for personal and industrial manufacturing.

As climate changes, and as farmers become used to growing this new product, these protections will be essential. This will help farmers that, during normal farm production, they will experience acrobatics (crop losses). Second, significant, shared, State-Federal regulatory authority over the growing and manufacturing of hemp will exist.

It specifically allows for cross-state transfers of hemp-derived products for commercial or other purposes. It also places no restrictions on the sale, transportation, or possession of hemp-derived products, so long as these items are produced consistent with law. Penalties can include seizure of property, including vehicles used for possession, transportation, or concealment of controlled substances, and the denial of occupational licenses or federal benefits, such as student loans.

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