Proposed Rules on Medical Marijuana are Illegal, "Cruel and Unreasonable," Says Valley Doctor

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Proposed restrictions on Arizona's voter-approved medical marijuana law are worse than illegal, says one Valley doc -- they're "cruel and unreasonable."

Edgar Suter, a Mesa doctor of nuclear medicine, writes in an a lengthy call-to-arms today that the state Department of Health Services' suggested rules concerning Proposition 203 probably violate the 1998 Voter Protection Act.

We came to the same conclusion last month after reading the draft rules and sitting in on a DHS news conference.

Suter's criticisms are broad, but he's particularly troubled by the bureacrats' attempts to make patients jump through hoops to get state approval to possess pot. He points out that a doctor in Arizona can prescribe Adderall to a kindergartener after one visit, but the proposed rules would require four doctor visits prior to obtaining a marijuana recommendation. Patients would suffer during the four-visit system, he writes.

We could summarize his other points, or we could simply post his bulletin. So, without further ado, here's what Dr. Suter e-mailed us this morning, in its entirety:

Written comments on the Arizona DHS draft regulations on medical marijuana must be received before January 7. There will be public hearings Feb 16-18 to receive verbal comments. I have attached both the Arizona Medical Marijuana Act and the AzDHS draft regulations. You are welcome to use my objections or compose your own, but PLEASE OBJECT!


ARS 36-2803.4 of the Arizona Medical Marijuana Act requires that the Arizona Department of Health Services rulemaking be "without imposing an undue burden on nonprofit medical marijuana dispensaries...."
ARS 28.1 Section 2 "Findings" of the Arizona Medical Marijuana Act requires the department to take notice of the numerous studies demonstrating the safety and effectiveness of medical marijuana. Arizona's pharmacies and physician offices dispense addictive, dangerous, and toxic drugs that, unlike marijuana, are potentially deadly, yet Arizona's pharmacies and physician offices are not required to have 12 foot walls, constant on-site transmission of video surveillance, residency requirements for principals, or any of the other cruel, arbitrary, and unreasonable regulations proposed by the department.
R 9-17-101.10 is an undue and unreasonable burden. 9 foot high chain link fencing, open above, constitutes reasonable security for outdoor cultivation.
R 9-17-101.15 is unreasonable and usurps authority denied to the department. It violates the 1998 Arizona Voter Protection Act. The department does not have the authority to deny the involvement of naturopathic and homeopathic physicians as defined by ARS 36-2806.12.
R 9-17-101.16, R 9-17-101.17, R9-17-202.F.5(e)i-ii , R9-17-202.F.5(h), R9-17-202.G.13(e)I , R9-17-202.G.13(e)iii , R9-17-204.A.4(e)i-ii, R9-17-204.A.4(h), R9-17-204.B , R9-17-204.B.4(f)I, and R9-17-204.B.4(f)Iii are cruel, arbitrary, unreasonable, and usurp authority denied to the department. Those sections violate the 1998 Arizona Voter Protection Act. ARS 36-2801. 18(b) defines an assessment, singular, as sufficient. The Arizona Medical Marijuana Act does not give the department authority and the 1998 Arizona Voter Protection Act denies the department authority to require multiple assessments, require "ongoing" care, or redefine the patient-physician in any way, much less to promulgate a relationship among patient, physician, and specialist that is found nowhere in the practice of medicine. Nowhere in medicine is a specialist required to assume primary responsibility for a patient's care. Nowhere else in the practice of medicine does Arizona require a one-year relationship or multiple visits for the prescription or recommendation of any therapy, including therapies with potentially deadly outcomes. Marijuana is not lethal, but the department usurps authority to treat it with cruel and unreasonable stringency far beyond the stringency imposed upon drugs that are deadly. Plainly, it is dangerous and arbitrary for the department to suggest that a cannabis specialist assume primary care of cancer, HIV/AIDS, ALS, multiple sclerosis, Hepatitis C, and other potentially terminal qualifying conditions when the cannabis specialist may not have the requisite training or experience to do so. The department's regulations are a cruel, unreasonable, and arbitrary usurpation of authority and denial of patients' rights of choice, including their rights to choose other medical providers, other sources of care or information, or even to choose not to seek (or cannot afford to seek) other medical care at all (whether prior or subsequent to application).
R9-17-102.3, R9-17-102.4, R9-17-102.7, R9-17-102.8, R9-17-104.5 , R9-17-105.4, R9-17-203.A.3, R9-17-203.B.8, R9-17-203.C.5, R9-17-304.A.11 usurp authority denied to the department. ARS 36-2803.5 only gives authority to the department for application and renewal fees, not for changes of location or amending or replacing cards.
R9-17-103, R9-17-202.F.1(h), R9-17-202.G.1(i), and R9-17-204.B.1(m) are cruel, arbitrary, and unreasonable. Though many qualifying patients, qualifying patients' parents, and their caregivers suffer financial and medical hardship, the sections make little or no provision for patients, parents, and caregivers without internet skills or internet access.
R9-17-106.A(2) is cruel, arbitrary, and unreasonable. The regulation does not allow for addition of medical conditions that cause suffering, but do not impair the ability of suffering patients to accomplish their activities of daily living. For example, conditions such as Post-Traumatic Stress Disorder (PTSD), Anxiety, Depression, and other conditions may cause considerable suffering, yet still allow patients to accomplish their activities of daily living.
R9-17-106.C is cruel, arbitrary, and unreasonable. The regulation only allows suffering patients of Arizona to submit requests for the addition of medical conditions to the list of qualifying medical conditions during two months of every year.
R9-17-202.B is cruel, arbitrary, and unreasonable. Qualifying patients may need more than one caregiver to ensure an uninterrupted supply of medicine.
R9-17-202.F.5(e)i-ii , R9-17-202.F.5(h) cruel, arbitrary, unreasonable, and usurps patients' rights to choose other providers or sources of information
R9-17-202.F.6(k)ii, R9-17-204.A.5(k)ii , R9-17-204.C.1(j)ii , R9-17-302.B.3(c)ii, R9-17-308.7(b), R9-17-308.7(b), and R9-17-309.5(b), are arbitrary and unreasonable. If a caregiver already has a valid caregiver or dispensary agent registry card, no additional fingerprints need to be submitted.
R9-17-205.C.2 and R9-17-320.A.3 are arbitrary and unreasonable. A registry card should not be revoked for trivial or unknowing errors. Revocation of a card should not be allowed unless the applicant knowingly provided substantive misinformation.
R9-17-302.A, R9-17-302.B.1(f)ii, R9-17-302.B.1(g), R9-17-302.B.3(b) , R9-17-302.B.3(d)i-ix, R9-17-302.B.4(c), R9-17-302.B.4(d), R9-17-302.B.15(a), R9-17-302.B.15(b), R9-17-302.B.15(d), R9-17-306.B, R9-17-307.A.1(e), R9-17-307.A.3, R9-17-307.C, R9-17-308.5, R9-17-319.A.2.(a), R9-17-319.B are arbitrary, unreasonable and usurp authority denied to the department. These sections violate the 1998 Arizona Voter Protection Act. The department does not have the authority to establish residency requirements, control the occupation of the principal officers or board members, require surety bonds, require a medical director, require security measures that are an undue burden (security measures for non-toxic marijuana that exceed security measures required for toxic potentially lethal medications stored at and dispensed from Arizona pharmacies and physician offices), require educational materials beyond what the law requires, require an on-site pharmacist, require constant, intrusive, or warrantless surveillance, or regulate the portion of medicine cultivated, legally acquired by a dispensary, or transferred to another dispensary or caregivers.
R9-17-310 is arbitrary, unreasonable and usurps authority denied to the department. These sections violate the 1998 Arizona Voter Protection Act. The department has no authority to require a medical director, much less to define or restrict a physician's professional practice.
R9-17-313.B.3 is arbitrary, unreasonable and usurps authority denied to the department. This section violates the 1998 Arizona Voter Protection Act. The department has no authority to place an undue burden on recordkeeping for cultivation or to require the use of soil, rather than hydroponics or aeroponics, in cultivation of medicine.
R9-17-313.B.6 is arbitrary, unreasonable and usurps authority denied to the department. This section violates the 1998 Arizona Voter Protection Act. The department has no authority to place an undue burden on recordkeeping by requiring the recording of weight of each cookie, beverage, or other bite or swallow of infused food.
R9-17-314.B.2 is arbitrary, unreasonable and usurps authority denied to the department. This section violates the 1998 Arizona Voter Protection Act. Especially in the absence of peer-reviewed evidence, the department has no authority to require a statement that a product may represent a health risk.
R9-17-315 is arbitrary, unreasonable and usurps authority denied to the department. This section violates the 1998 Arizona Voter Protection Act. The department has no authority to place an unreasonable or undue burden by requiring security practices to monitor a safe product, medical marijuana, that is not required for toxic, even lethal, products.
R9-17-317.A.2 is arbitrary, unreasonable and usurps authority denied to the department. This section violates the 1998 Arizona Voter Protection Act. The department has no authority to require the daily removal of non-toxic refuse.


Attorneys are already preparing legal action against these cruel and unreasonable draft regulations.

If you are happy with such an outcome, do nothing. If you want to reduce your suffering and your costs, you must speak out now and also at the public meetings I have listed below.

The good news: As best I can tell, the AzDHS does NOT have the authority to enact the cruel and unreasonable package of regulations they propose. Obviously, I am not an attorney, so we are soliciting the input of qualified attorneys. Because I am a physician, I am restricting my comments here to the matter of patient-physician relationship. Others with expertise in dispensary and caregiver matters will share similar analysis and commentary concerning the draft regulations for dispensaries and caregivers. I have attached the AzDHS Timeline.


Please familiarize yourself with the Arizona Medical Marijuana Act (AzMMA):
http://stoparrestingpatients.org/home/initiative


If you pay special attention to Section 36-2803 "rulemaking," you will notice that the AzMMA does NOT give authority to the Arizona Department of Health Services to define-or redefine-the patient-physician relationship and does NOT give the authority to amend the AzMMA language, e.g., adding "ongoing" to "patient-physician relationship." The Arizona Voter Protection Act specifically DENIES authority for such usurpations.


Please note that even the Director of AzDHS questioned his own authority to do what he proposes:
http://directorsblog.health.azdhs.gov/?p=810
See also: http://blogs.phoenixnewtimes.com/valleyfever/2010/11/prop_203_legal_weed_will_be_av.php

Next please familiarize yourself with the draft regulations:
http://www.azdhs.gov/prop203/documents/Medical-Marijuana-Draft-Rules.pdf


Then please participate in the public comments online and in person:
http://azdhs.gov/news/2010-Alll/101217_ADHS-Med-Marijuana-Release-and-FAQ.pdf


Please plan to testify. Please also mobilize other suffering patients to comment online, in writing, and to testify at the Public Meetings:


Phoenix, February 15, 2011, 1PM, 250 N. 17th Avenue
Tucson, February 16, 2011, 1PM, 400 W. Congress, Room 222
Phoenix, February 17, 2011, 1PM, 250 N. 17th Avenue


Some specifics.


The AzMMA requires this:


18. "WRITTEN CERTIFICATION" MEANS A DOCUMENT DATED AND SIGNED BY A PHYSICIAN, STATING THAT IN THE PHYSICIAN'S PROFESSIONAL OPINION THE PATIENT IS LIKELY TO RECEIVE THERAPEUTIC OR PALLIATIVE BENEFIT FROM THE MEDICAL USE OF MARIJUANA TO TREAT OR ALLEVIATE THE PATIENT'S DEBILITATING MEDICAL CONDITION OR SYMPTOMS ASSOCIATED WITH THE DEBILITATING MEDICAL CONDITION. THE PHYSICIAN MUST:
(a) SPECIFY THE QUALIFYING PATIENT'S DEBILITATING MEDICAL CONDITION IN THE WRITTEN CERTIFICATION.
(b) SIGN AND DATE THE WRITTEN CERTIFICATION ONLY IN THE COURSE OF A PHYSICIAN-PATIENT RELATIONSHIP AFTER THE PHYSICIAN HAS COMPLETED A FULL ASSESSMENT [NOTE: "assessment," singular, not plural; 1, not 4] OF THE QUALIFYING PATIENT'S MEDICAL HISTORY.


So, one full assessment, specify the qualifying condition, sign, and date-done!

Without the authority to do so, Az DHS proposes:


R9-17-202
5e. A statement, initialed by the physician, that the physician:
i.
Has a professional relationship with the qualifying patient that has
existed for at least one year and the physician has seen or assessed the qualifying patient on at least four visits for the patient's debilitating medical condition during the course of the professional relationship; or
ii.
Has assumed primary responsibility for providing management and routine care of the patient's debilitating medical condition after conducting a comprehensive medical history and physical examination, including a personal review of the patient's medical record maintained by other treating physicians, that may include the patient's reaction and response to conventional medical therapies;


Key points:


• Any Arizona physician may in a single visit prescribe "speed," e.g., Adderall, to a kindergartener-without 4 visits spread out over 1 year any Arizona physician may prescribe to a kindergartener a drug that can kill that child by heart attack, stroke, seizures, or other "side effects."
• Cancer, HIV, Hepatitis C, and ALS patients often do not have 1 year to live.
• The patients that do live are cruelly being told to change doctors or suffer for 1 year.
• Deadly and addictive drugs such as the opiates are prescribed in a single visit by Arizona physicians and, despite the best efforts of physicians, some of those deadly and addictive drugs are illegally diverted, but that does not cause the AzDHS to demand 4 visits, 1 year of visits, or that the pain specialist assume primary care of the patient.
• Marijuana is 100% safe, gives patients good relief, and cures some conditions-Marijuana is not deadly and is not addictive.
• The alternative offered by the AzDHS to avoid 1 year of suffering, the cannabis specialist takes over the primary care of the pt's qualifying condition, is done nowhere else in medicine-Nowhere else in medicine does a specialist take over a patient's primary care.
• The AzDHS does not have the authority to define or re-define the patient-physician relationship or the number of doctors visits, or the length of time for those visits-that infringes on the patient's choice
• The draft regulations are cruel and unreasonable.


We still believe that an evaluation and a signed physician recommendation stating the patient's qualifying condition currently gives an "affirmative defense" in the event of a legal encounter at least until the final regulations, not merely the draft regulations, are announced by the AzDHS. Once the final regulations are promulgated, we will, of course, abide by them. Until then, we are still making recommendations to qualified patients. If the AzDHS succeeds in forcing 1 year and multiple visits upon patients, it is to the advantage of qualifying patients to start the process as soon as possible.


Please speak out now and defend your rights! Mobilize other patients and family!

Sincerely,
Edgar A Suter MD
DoctorSuter.com
(formerly Arizona Comfort Care)


My Voice Nation Help
47 comments
Ronlaw13
Ronlaw13

I, for one am glad that Dr Suter is being robust, assertive, and "asking for trouble" in his methods of keeping AZDHS on it's toes. That is exactly the kind of person we need to support, not ridicule or criticize. It shows Dr. Suter is an effective champion, and I applaud his temerity and efforts regarding patients rights.

sonickf
sonickf

Thank goodness Dr. Suter has spoken out. These additive doctor/patient definitions MUST be changed, or challenged in court if Mr. Humble sees them through. I suspect he will remove them entirely from the second draft as a pragmatic move. If not, there is going to be a legal fight that is already being prepared, just in-case.

If your current physician or specialist won't prescribe, or is prohibited from prescribing Marijuana where easily indicated, you then have the only option of moving decades of doctor/patient relationship, or specialties that another doctor cannot even begin to address.

How are you going to transfer your entire care system to a doctor that doesn't even specialize in your disease process, or even that portion of your body ? Let compassion guide the treatment. This is about PATIENTS, not the occasional abuser.

Diversion and abuse WILL HAPPEN. We cannot prevent that 100%. We prescribe opiates and anxiolytics because of their efficacy where indicated, and because medicine is a profession of COMPASSION. Marijuana must be treated the same way, given it's powerful medicinal profile thus far, and even more promise for the future. Fortunately, marijuana doesn't have anywhere NEAR the destructive abilities of other diverted drugs.

Let COMPASSION guide the treatment, not FEAR of diversion and abuse. We have other systems in place for treatment and investigation of diversion. These unconstitutional doctor/patient requirements must go.

Kathy
Kathy

Just a thought....I would leave out the key point regarding Adderall. There are many other good examples to use. I am sure this is not what the doctor is suggesting, but we don't want to create the impression that we should give children some form of cannabis. Naturally, cannabis is safer, but we should never drug our kids- and this has become the national norm.

Our children need our time, love, and attention. This is why they call it Attention Deficit. American kids have deficiency of attention from their parents. Folks want to put their kids in front of the tv or computer and walk away, then they wonder why their children cannot pay attention in school. No one pays attention to Them.

Try giving your child a day filled with good nutritious food and exercise. Have days where there is no computer or television pumping them full of useless information. Talk with them. Share time with them. Do not drug them.

When my daughter was 7 and acted up, her Catholic school teacher told me to give her a sound spanking and take away her sugar. While I regret taking the spanking advice, taking away the sugar fixed the problem.

I always advocate the natural choice, but never for kids unless they are, heaven forbid, in some stage of severe illness.

http://www.chaada.org/contact....

KathyWomenForMarijuana.org

Stephanie
Stephanie

Kathy,

I was wondering what medical school you attended and what area of medicine you specialize in?

I happen to have attention deficit disorder and its definitely not because my parents didn't pay attention to me. I find your uneducated medical analysis to be quite insulting and distasteful.

I think that I'm not the only patient who would rather have a board certified Dr. give me my medical advice rather than a political activist.

Besides, Prop 203 has a provision that does allow minor's to use medical marijuana. It is FAR safer for children than Adderall, for example. Not to mention how much safer it is than nearly EVERY other prescription pill being given to our kids. I'd prefer my son to use a safe and non-lethal medication if he were to become sick, god forbid.

The discussion of medical marijuana for children isn't always related to psychological problems either. Many children can benefit from medical marijuana who suffer from a number of diseases and medical conditions. Unfortunately, many conditions such as Cancer and ALS have little regard for a person's age. We voted this in as a medicine, not as a legal way to get high. So we should begin to treat it as such.

Stephanie

Kathy
Kathy

I do not have to be an MD to know that it is negligent to put children on maintenance medication. You only need to click on the link above to begin to understand what is being done to our country and people through pharmaceuticals.Human beings are beautiful just as they are. Putting people on a maintenance prescription when they are little only keeps them needing something extra when they grow up. Why not strive to keep people clean?

Kathy
Kathy

The comment below was made in response to public comments made by Dr. Suter to AZDHS, which are not included in this article

oscar
oscar

Last I remember this is an open forum and anyone can comment.Kathy Andrew did not bring this issue to the state, As you know this issue was voted by the people of Arizona in the past. What Mr. Myers did was get a team of attorneys and reword the the prop to make it bullet proof. Andrew is a front person, a talented speaker and a media darling.It appears he is more selfserving and he believes everything is says is gold. I was at a meeting last month when he attempted to rebuke Dr. Suter on numorious points only to be found to be wrong. You are correct we do not need this type of division right now. You seem to have danced aroud the issues I brought up. I was at the city council meeting where your Daughter and Andrew were on the citys side requesting the Special use Permit. Nancy your daughter even stood up to be recongized. This was against everything the prop 203 community was for. If Mr. Myers is truly dedicated to the "cause" he need to follow the National agenda and replicate what he did in Arizona in the next state that needs his PR talents. He needs leave the rest of the battle to EDUCATED PROFESSIONALS who are already on the front lines. Including Dr. Suter and you know which attorneys are involved. I am sorry your daughter has got mixed into the politics. I did not mean to offend you. The facts will speak for themselves there has been an open invatation for everone to air out thier veiws at a meeting tomorrow. Hope to see you all there.

Charles Ward
Charles Ward

What horse shit: Andrew, as a representative of the MPP, certainly did bring the issue to the state. If not for the MPP Arizona would not have had the measure to vote on.

Nancy Tea
Nancy Tea

Oscar: You seriously have no idea what you're talking about.

I stood to be recognized at the city council meeting in support of what the was suggested at the zoning meeting prior-- not to support the use permit. You are confused.

You also happen to be completely clueless as to how much heart was put into this campaign, and continues to go into it, from Andrew, myself, everyone at AMMPP and from everyone now with AzMMA.

As far as Andrew being "found to be wrong" last month, well, that's an incredible fabrication you have, there, friend. We attended the meeting to help and Ed got all "open mic night" all over the place and well... That was about it.

I'm wasting no more time disputing your nonsense, and I hope my mother will do the same. You obviously have some misplaced anger, but let me tell you, brother-- aiming it at myself, my mom, or Andrew, some of the people who care the most, well, that's just dumb.

Kathy
Kathy

Re: that $100,000 ~

Oscar, how much do you think it costs to run an ad on television ? Did you see that ad? Some folks just do not understand what it takes to pass a bill like this one.

Kathy
Kathy

Oscar obviously has no information about Andrew's extensive education and history of service to the public.

Kathy
Kathy

While I like Dr. Suter personally, I am afraid I have to respectfully disagree with him.

As someone who has been working in the Phoenix marijuana reform community for three years, I have watched the progress of the campaign go from Zero to a Win last November. We did not have these things to bicker over back then. I am so very glad we do now.

One year ago, we at Phoenix NORML went through the painful process of deciding amongst ourselves whether or not we would back a decriminalization campaign while we had the medical marijuana bill coming in November of 2010. This decision was hard on all of us because we all believe in decriminalization, but we wanted to do what was right for the medical campaign. By a narrow margin, we voted to wait with the decriminalization effort until after the medical bill passed. If you watch nationwide reform, it generally goes this way. First folks understand the value of the medicine, and then, perhaps, they become open to further progress. We would take the first step needed toward reform and clear the patients from that battlefield in the War on Drugs.

While I understand the need for change, it never comes all at once. This is the lesson we learned by winning Proposition 203 last fall. Progress takes time and comes in steps. If we want to appeal to the mainstream of society, we have to tolerate rules and order. I am afraid there are some who do not remember who brought medical marijuana to Arizona, though it happened so recently. I would like to know where these people were when we all were working so hard these past two years. Trouble is, no matter what sort of bill was written, it would not have made every one happy. We see that happening all over, even in California.

We also know the lessons learned by watching California. Our campaign manager has been up front from the very start that this would not be as it is there. He told us there would be strict rules and that it would be rather hard to get a dispensary license due to the red tape they would have in place to discourage rouge dispensaries and to keep our state clean of the problems other states have endured without such regulations. They have been honest and transparent about that from the very start, even before Andrew Myers joined this campaign.

If not for Andrew Myers we would not have medical marijuana in Arizona right now. He single-handedly put the last months of this campaign together, without salary and without funding. He has worked tirelessly to make this happen. No one is a bigger champion for the little guy than me, and knowing our campaign manager, Andrew Myers for two years now, I must say this recent characterization of him is incorrect. I have had nothing but the utmost respect for the man, and this began long before he started dating my daughter.

The proposals that Dr. Suter sites are reasonable to approach one at a time, but proclaiming blanket injustices to forward the agenda of folks who want to see Arizona with the same troubles as California and Colorado is simply not prudent.

Kathleen TranchesePhoenix NORMLPhoenix MarchWomenForMarijuana.org

oscar
oscar

it seems these so called campaign leaders are focasing on big money rather than patient care. I was at a meeting a couple of months ago when mr. Myers asked for 10 people to donate $10,000 to his newly formed association. thats $100,000. His relationship with Mr. Humble is being questioned. Your Daughter stood up and applauded city of phx special use permit. Kathy you seem to be one of the few trying to belittle Dr. Suter, who is sticking out his neck and career for something he and 51% of the population voted for. Your veiw is not that of NORML but of Mr. Myers. His national Campain is done here in Arizona, he needs to get out of town with your daughter and do what he does best... win another state and leave the politics to real Zonies who care about helping those in need.

and 51% of the citizens of arizona voted for believei

Nancy Tea
Nancy Tea

This is her daughter-- and no, I did not support the special use permit, which directly conflicts federal law and is just generally a headache.

Do you think that all 10 of those people Myers asked to donate, did in fact donate? Hell no. There is a small group of investors who did step up to donate (all local Arizona business people) and they are now the AzMMA. That seed money funded the campaign-- without them, this law would not have passed and you'd have nothing to combat right now, Oscar. Do you have any clue how much it costs to run a successful statewide campaign? Obviously not, otherwise you wouldn't be sore over $100K. $100K buys a TV spot for a week or two across all stations, and that's exactly what was done. Add yard signs, literature, and other expenses on top of that and you need damn near half a mill just to function-- and that's without any major opposition. Andrew did all of that on his own, without MPP or any major backers-- and that deserves respect.

P.S. Andrew is local-- he's been here since '05 and I've lived here for 15 years. I didn't start dating him until I saw the valor he possessed through the campaign hardships. You are way out of your element.

Kathy
Kathy

Oscar, it appears that you and many others have forgotten who brought medical marijuana to Arizona in the first place.

Who are you to comment? Where were you when we were all working so hard to get this done? How dare you suggest my daughter leave when she and Andrew have made such a tremendous contribution to this state.

If not for she and Andrew and the help of MPP, none of you would even be Close to having access to medical marijuana.

sonickf
sonickf

Everyone, just let it go. Don't let your ego drive you to reply, any of you (my choice of reply-to is chronological, not indicative).

Andrew and the MPP were clearly the architects this time around, and deserve all the credit for the win. At the same time, let's allow those with tons of wisdom to contribute.

WE DO NOT NEED MORE 19-esque infighting.

Kudos all around.

Kathy
Kathy

and furthermore I am not about belittling Dr. Suter. I have much respect for him and have been an opponent of prescription drugs since I was a kid in high school. I agree with what he says but I do not appreciate the approach. We have just arrived on the scene of reform, and there is much work to do.

There is no reason to take sides and divide this community.

Kathy
Kathy

^ The above is in response to Dr. Suter's public comment to AZDHS

PHUKMYLYFE
PHUKMYLYFE

ohhHHKAaY!_question_veteran w/ motor neuron disease, Guillianne Barre syndrome, Bells Palsy ,I.B.S" ecessive and unexplained weightloss in excess of fifty pounds, unwanted and w/in 12 months,PTSD, mAjor Depression< anxyety, because _ as I c myself withering away < im scared !_prescribed opiates and Benzos_ started losing conciousness_ and someone wants to rule or control MY HEALTH/LYFE during a 1 year trial _ PHUKDAT!_oh and BTW-yes this is military and no they DO NOT TAKE CARE OF YOU WHEN THIS IS CLEARLY A NEXXUS CONNECTION!

Michelleb
Michelleb

My son is 17 years old. He has been batteling Tourettes Syndrome and Bi-Polar diagnosis since he was about 4. At 4 years old he was prescribed Tenex and Haldol. At 5 and 6 he was taking dexedrine - after that they prescribed him ritalin - concerta - staterra and depakote. All with good results for a little while and then back to his normal, well, not so normal self. Most of these medications should never be given to a Tourettes Patient, but they prescribe it anyway with another pill to even out the other one. Some of these pills made him a monster. Now as a single mother, I have endured alot. My son's behaviors are extreme. I have called the police for help, they take him and then I have to go and pick him back up. He is very dangerous and explosive. Once he found cannabis, 80% of his tics and behaviors went away, over night it seemed. This stuff was working. Now I'm batteling the courts in regards to his cannabis use. They look at my son like he's completely normal teenager who smokes pot all day, well he looks normal, but isn't normal in his brain. In regards to the new law. They really need to look at the mental illness side of how cannabis helps. The American Board of Psychiatry even has cannabis on their own web site and how it helps Tourettes Patients. It helps, it works and pick and choose your battles. Kids are trading ritalin at school and chopping the pills up and snorting them like cocaine. Cannabis is a natural substance that heals.

Ma'am
Ma'am

...This is kind of a non sequitur, Michelleb. Arizona agrees with you-- that's why Prop 203 passed. This blog is about the type of rules that accompany Prop 203.

LEAPSpeaker_AZ
LEAPSpeaker_AZ

It's a draft, if you don't like something, now is the time to tell the department of health. Use this link http://www.azdhs.gov/prop203/i... These are the important dates for the rules process.* December 17, 2010: ADHS posts an initial informal draft of the Rules

* December 17, 2010 – January 7, 2011: ADHS receives informal (electronic) public comment on the initial informal draft rules

* January 31, 2011: ADHS posts official draft Rules for public comment

* January 31, 2011 – February 18, 2011: ADHS receive public comment on a revised draft of the Rules

* February 14 – 17, 2011: ADHS holds 4 public meetings about the draft Rules:

o Flagstaff: Monday, February 14, 2011 at 10:00 am, 211 W. Aspen Ave

o Phoenix: Tuesday, February 15, 2011 at 1:00 pm, 250 N. 17th Ave

o Tucson: Wednesday, February, 16, 2011 at 1:00 pm, 400 W. Congress, Room 222

o Phoenix: Thursday, February 17, 2011 at 1:00 pm, 250 N. 17th Ave

* March 28, 2011: ADHS publishes the final Rules that will be used to implement the Act

* April 2011: ADHS begins to accept applications for registry identification cards and for dispensary certificates

Jay

What is wrong with AZ??
What is wrong with AZ??

admit it Mr Humble, you have no idea what you are doing here - step aside, you don't like it, your ego is in the way and you are seeking to put innocent people at risk by treating this as a crime - childish proposals - go back and fearmonger the swine flu with your buddy Art Mollen - you may actually have some clue about that - if you do not understand the benefits of medical marijuana, you do not deserve the Dr you put in front of your name -also, please burn your VHS tape of Reefer Madness and join us in the 21st century

Daggerpan
Daggerpan

Wow what a discusting display of power! Let the sick medicate!

Sealatt Moore
Sealatt Moore

"Discusting" is spelled "disgusting". And no one is going to keep the sick from medicating-- it's law. No one is changing the law. I don't know who you think is showing a "discusting display of power", but it certainly isn't AZDHS-- this is only the first draft. They don't even know what they're doing. You think they've ever regulated a pot industry before? NO. You people don't understand public policy.

Kathy
Kathy

it is more like a beautiful display of reform.

Swapa
Swapa

Dr Suter, on behalf of the patients of SW Arizona Patient Alliance (SWAPA) I would like to say thank you for standing up for all patient's in AZ. Your observations and comments are both based on fact and insightful. We need more Dr's to step up and speak out for patients, as you have. By joining together and building strong communities that support the rights of our medical cannabis patients, we will finally realize the will of the people in this state.

Kid Adams
Kid Adams

AZDHS evaluate the side effects and addictive dangers of the drugs being dispensed and in some cases forced on our children by the big pharmaceutical industry. After doing so use a little common sense and ask yourself, would I rather have dangerous highly addictive chemicals created by a "scientist" put into my and my children's body; Or would i rather induce my and my children's body with a safe plant created by God?

Coz
Coz

Unfortunately what's right has nothing to do with AZDHS's and it's managements personal agenda.

Azindisat
Azindisat

Thank you Doc for speaking up. Your observations about these rules is right on.

Coz
Coz

You really didn't expect anything else to happen did you ?

If the political hacks in this state could have over rode the vote again, you can be your ass they would have.

Instead, they'll just screw with it so much until it becomes totally redicu....no wait... it already is totally ridiculous.

Go get-en Doc !Great job....!

>>Proposed restrictions on Arizona's voter-approved medical marijuana law are worse than illegal, says one Valley doc -- they're "cruel and unreasonable."

PCPSC, LLC
PCPSC, LLC

I to am glad that someone is standing up to the state. I like the comment about "Listen Up Will the people who voted no lost so they do not have a say.". I know when I vote no to an initiative or proposition and it passes there is never any crazy hoopla I just have to accept it and move on with life. I don't like the fact that driving while drunk is illegal but ever since I moved to Prescott, AZ I have seen more drunk drivers than any 15 cities I have lived in across the country and there is never a policeman around yet I see people getting pulled over all the time for speeding. Thanks to all the people who are helping and speaking out.

Team PCPSC, LLC

www.prescottmedcard.com

Spiritwheel
Spiritwheel

you should come visit yuma if you want to see more drunk drivers than prescott! also folks who haven't learned about seatbelts or child restraing devices. cops sit and watch kids jumping around in vehicles and do nothing.

Contactus
Contactus

On behalf of Arizona medical marijuana patients. We thank you Dr Suter for standing up for us. We salute you.

Informed Patient
Informed Patient

I do not. This fellow is a radical, and less than someone that I would like representing me. I'd prefer someone who was a well-informed gentleman. This person is less than that.

Boosting Immunity
Boosting Immunity

These guys are AMAZING!!!!

Thank you Dr. for the insight we are alerting everyone we know to do something about this. This is just another way for the state to say yeah we accept your vote but now we are going to make the rules impossible to follow.

I am not a smoker by my girl has Chron's and I for one do not want to see her keep medicating herself illegally. She should also be able to smoke in public. You do not have to take any other prescriptions in your home...

J Curwen
J Curwen

Glad to see some pros stepping up for the fight. Suter asked for trouble and it seems he's going to get it. Too bad HE personally won't have to pay the costs of the litigation that seems to be on the horizon. Rather, the financial costs will be covered by our flush state coffers. The human costs will be paid by those already suffering.

bobby mueller
bobby mueller

How do you figure Suter asked for trouble,when all he is doing is attempting to keep DHS honest and do what the voters voted for. I predicted months ago that the Dhs was going to pull this and even more.It would serve Az right if no dispensarys popped up in Phoenix and everyone grew thier own.Or if the rich who seem behind this madness are boycotted and forced to shut down.

Charles Ward
Charles Ward

Actually it wasn't Dr. Suter who asked for trouble. I think you must have confused him with Mr. Humble. Now that I think of it, Humble is an ironic name for a man shackled by such hubris.

Boosting Immunity
Boosting Immunity

it is not so much that they will keep suffering it is the fact that for them to be legal they are going to make them jump through hoops. that is just wrong. the statement that Will Humble made says it all:

“We are using the Initiative as a guideline to set up a system that is good for all the people in Arizona – those who voted yes and those who voted no,” said Will Humble, ADHS Director. “We really need everyone’s input to make this work, because everyone will be affected by it, whether they use medical marijuana or not.”

Listen Up Will the people who voted no lost so they do not have a say.

EdgarASuterMD
EdgarASuterMD

Key observation!

Think about what Mr. Humble said. Think about what such lawless subversion of the initiative implies:

“Segregation lost, but we are going to make the rules ‘good’ for segregationists too.”

Another key observation, the fundamental assumption underlying Mr. Humble’s sadistic, elitist, and unreasonable rules:

“Your life belongs to the State. If we say ‘Suffer!” you will suffer. If we say ‘Wait and die!’ you will wait and die.”

Informed Patient
Informed Patient

Sadistic? Elitist? OMG, someone is getting all fired up over the FIRST DRAFT of these rules... And there isn't anything horrifying enough in there to go and call Will Humble and DHS, who have been nothing but non-partisan and fair in the creation of these, ugly names. This is just some high school-minded radical trying to allow outsiders an in and gain an "elitist" advantage in telling the rule-making authority who they are. It's laughable.

Acer
Acer

Hey Mr. Natural, tell that to a cancer patient or someone who got caught and paid a penalty. Lots of people care.

That said, those of you who do care and don't write in, well...

Please do. Write. Protest. Fight.

MR NATURAL
MR NATURAL

its easy to get pot so who needs legal pot anyway? they can make all the rules and laws for all the sheeple out there they want to. its no big deal. i had a steady pot connection since 1971 to 2010 and still do and it has never run dry ever. you just gotta know the right people is all. your friend, MR NATURAL

SmokeyMacPots
SmokeyMacPots

everyone knows you can get pot easier than beer, its the fact that in AZ you can go to jail, and charged as a felon. Felonies ruin peoples lives, its much more difficult to do the things we deserve. Screw medical, I'm for Recreational.

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