UW ADAI - Symposium - 2022 - Exploring Solutions - Addressing the Risks of High THC Cannabis Products
(September 16, 2022) - Perspectives of Washington Stakeholders

UW ADAI - Symposium - High-THC Cannabis - Legislative Report
[ Event Details ]

The principal researcher responsible for organizing the high THC cannabis symposium and delivering the policy report presented their findings from surveys of recruited stakeholders.

Here are some observations from the Friday September 16th University of Washington Addictions, Drugs, and Alcohol Institute (UW ADAI) 2022 Symposium on “High-THC Cannabis in Legal Regulated Markets.”

My top 4 takeaways:

  • Carlini gave a presentation on “How to Address High THC [tetrahydrocannabinol] Cannabis Products’ Risks and Harms: Perspectives of Washington Stakeholders,” sharing survey results of respondents who proposed, and later ranked, policy options for the products (audio - 22m, video, presentation).
    • Carlini focused her remarks on “what Washington stakeholders think about all that that we talked about today.” Through a 2021 budget proviso, she noted legislators appropriated $500,000 to the Washington State Health Care Authority (WA HCA) for UW ADAI“...to develop policy solutions in response to the public health challenges of high tetrahydrocannabinol potency cannabis.” With a final report due by the end of 2022, she said they’d been looking into “what kind of policy works, and in several areas that had similar challenges” and “what local stakeholders think about this issue.” Carlini stated it was “obvious” to many researchers, but she wanted to be clear that “the brightest ideas cannot be implemented, or not be sustainable, if you don't involve stakeholders and hear where they sit on all the ideas.”
      • WA HCA officials were given responsibility for submitting two reports to “the office of financial management and the appropriate committees of the legislature.”
        • An initial report was submitted in December 2021 to “summarize progress made to date, preliminary policy recommendations, and next steps.” Carlini gave an update to members of the Washington State House Commerce and Gaming Committee (WA House COG) on the initial report in November 2021.
        • A final report “must be submitted by December 31, 2022, and shall summarize the analysis conducted by the institute, the process and stakeholders involved, an inventory of relevant cannabis policies in other states, and recommendations for policy changes to reduce the negative impacts of high potency cannabis in Washington state.”
    • In order to arrange the survey, Carlini had found some stakeholders through existing lists, given “30 years of work, ADAI had collected a lot of emails from important stakeholders from all different perspectives” including at WSLCB and the WA HCA Division of Behavioral Health and Recovery (DBHR). Additionally, she said UW ADAI researchers “reach[ed] out to the cannabis industry through journals and associations, and also selected social media.” Through these networks, “we got the main stakeholders we were looking for” who were then divided up into three groups:
      • Communities: “Prevention, social justice and youth-centered organizations, parents, educators and youth”
      • Professionals: “Health care providers, law enforcement, government agencies, researchers”
      • Cannabis Advocates: “Workers, representatives, press, consumers”
    • “We had the two round of questions to the stakeholders in our study,” explained Carlini, who said the first round had stakeholders “come with ideas…How can our laws about high THC cannabis products be strengthened in Washington state to decrease risk to consumers?” This round of questions encouraged a wide range of responses and didn’t require participants to justify them with data, Carlini described, evoking 302 ideas from respondents, caveating that “a lot of them were repeats.” This “brainstorm phase was open for about three weeks” online, she added.
    • Working with Polygon, Inc on the concept mapping methodology, Carlini said the company “consolidate[d] the repeats…and the redundancy to avoid bias” before UW ADAI officials picked “46 unique policy ideas” for a second round of surveying. Respondents were shown the ideas and asked to group them however they liked, she stated, then they were asked to rank whether each idea was “impactful or not on addressing the issue at hand, and second if they were approved” how feasible would successful implementation of each idea be.
      • She typified this as concept mapping, “a way to capture collective thinking to find policy solutions,” indicating it had been employed for “urban development decisions and healthcare services.” Carlini argued this system was “equitable” and could be an approach that didn’t have “a high error key to show when they are participating.” The process kept participants anonymous, she mentioned, observing that it was “very exciting for us to apply” concept mapping to drug policies.
    • In total, she told attendees 109 individuals participated in the first round of surveys, and 160 participants in the second round, with no way for researchers to know how many were repeat respondents. “It's not common to have this amount of participation when you are trying to get people involved on making decisions on policy and giving their opinion,” Carlini suggested, gauging it “a very successful amount of participation for this kind of process.”
      • Carlini acknowledged that participants identifying as a member of the Cannabis Advocate cohort had the lowest participation level in the survey at 23%, but she still felt all three of the groups “participated well in the two phases of our study.”
    • Carlini claimed responses were geographically diverse as well, though most survey participants were from “the most populous areas, yes, had more participation…probably proportional with the demographic distribution.”
      • Carlini’s presentation identified 6 of the 29 counties in Washington. Below is the percentage of Washingtonians residing in that county at time of publication according to federal census data, along with the proportion of survey respondents from that county:
        • King County: 29.1% of population, 23% of respondents
        • Pierce County: 11.9% of population, 4% of respondents
        • Snohomish County: 10.7% of population, 3% of respondents
        • Thurston County: 3.8% of population, 16% of respondents
        • Spokane County: 7% of population, 6% of respondents
        • Whitman County: 0.6% of population, 8% of respondents
    • Carlini then reviewed self-reported demographics of respondents:
      • Round 1 - Solicitation of policy ideas
        • 41% racial/ethnic minorities
        • 54% Female
        • 45% between 21-44 years
      • Round 2 - Ranking of selected ideas
        • 36% racial/ethnic minorities
        • 54% Female
        • 54% between 21-44 years
      • Census estimates from July 2021 for Washington state indicated that 36.2% of the population identified as a racial group other than White, and 49.6% identified as female.
    • Participants were asked to rank their level of concern over “high levels of THC,” Carlini elaborated, with the average ranking of 3.8 out of 5, which she called “pretty high.” The subjective measure of perceived risk could have ranked higher, she explained, but “cannabis consumers themselves have a pretty moderate concern…around 2.8 and the industry was around 1.4.”
      • In the interest of full disclosure, both Cannabis Observer Founder Gregory Foster and I were participants in this survey. Both of our responses were logged as Cannabis Advocates, though several roles in multiple groups felt applicable to me. Carlini reached out and Cannabis Observer provided assistance recruiting survey participants from the cannabis sector as well as patients and consumers.
    • When it came to ranking the 46 ideas that were proposed, Carlini told attendees “there were seven policy areas that they divided in big buckets” and respondents were asked to rate the “feasibility and impact” of risks associated with high concentration products. She described the policy areas as:
      • Empower consumer/public with information
      • Taxation
      • Advertising Restrictions
      • Product and purchase caps
      • Ban High-THC Products
      • Licensing
      • Age Restrictions
      • Do Nothing, for those who thought “things are good as they are.” 
    • Preferred policy solutions landed in a “go zone” described by Carlini as ideas rated as both “feasible and impactful” by most stakeholders. There were lower priority ideas considered feasible but of low impact, she commented, as well as ideas stakeholders deemed “very impactful…but very difficult to implement.” Additionally, some policy ideas had “no importance…or feasibility,” Carlini remarked. Next, using a “mixed method approach,” she said survey data on policy ideas was “plotted” based on the “average impact or feasibility score.” Carlini laid out how the most supportive responses covered four policy areas:
      • Empower consumer/public with information was “firmly in the go zone…and this was supported by all the three groups pretty much equally.” This included ideas like “place public health message at point of sale,” doing “research to determine” proper label readability, or having “warning labels that’s specific to high potency products.” Opinions were slightly less unanimous around “posting store warning about high THC products. And the idea of ‘a dab will do’ would be the education that was like, maintain things as they are, but just teach moderation,” an approach that “community/professionals were not that jazzed about…and put it outside” the go zone even though most stakeholders endorsed it.
      • Three advertising restrictions reached the go zone, Carlini explained, “probably for a very easy reason to understand, because it's already in force” in state law. However, she noted, “‘eliminate all advertising of high THC products’ was also in the go zone when you see all the stakeholders together.”
      • Product and purchase cap policy ideas were “mostly situated on the no go zone or discard zone.” But three ideas were in “the consider zone” which many stakeholders “considered impactful, but just wonder[ed] about the feasibility” of enacting them:
        • “Cap THC by product category”
          • “Professionals were definitely more excited and moved to the go zone capping THC products by category,” Carlini added. 
        • “Cap THC concentration at 10% total”
        • “Limit serving size to five milligrams in all products or limiting to 10 milligrams”
      • The only taxation idea with general stakeholder support: “increased taxes on products with more than 35% THC.” Increases for “products thought to be harmful” or on “total THC by weight” had lower, but significant respondent support. Support varied, with cannabis industry representatives and consumers placing taxation ideas “in the remove option,” whereas professionals ”put it on the go zone.” Cannabis industry respondents did favor decreased taxes for products with cannabidiol (CBD) added.
      • Doing nothing was widely perceived to be feasible but have little impact, which evoked some laughs among the audience.
    • Carlini promised the report to the legislature would include additional commentary, but she interpreted her results as “good news from those that are rallying for population health in Washington state: stakeholders are concerned with high THC products for non-medical use, and they support policy changes.” Some policy ideas stakeholders supported “are in fact backed by science and research,” she stated, with general respondent support for “adding health warning labels and making the labels readable,” advertising bans “specifically for this products, and a tax increase proportional to THC content or concentration for non-medical use.” Carlini insisted other ideas were supported by science, but not stakeholder opinion, which she felt spoke to “the importance of doing more consumer and public education…on this matter.”
    • Thanking participants and those who’d helped conduct the survey and analyze the results, Carlini specified her gratitude to:
  • Cannabis Observer obtained a draft of the legislative report by Carlini and others which leveraged the survey results and offered legislators potential policy changes to further regulate high concentration cannabis items.
    • A November 1st draft of the legislatively mandated report was acquired via a public records request. At publication time, Cannabis Observer had not encountered more recent language for the report which remained due December 31st.
    • Here are selected excerpts from the draft executive summary:
      • “This report describes the recommendations for state policies based on the perspectives of WA stakeholders, research evidence on public policies designed to mitigate harms associated with non-medical use of high THC cannabis products and other legally commercialized health-compromising products, and cannabis policies that have been considered or adopted in North America…This report recommends a comprehensive package of policies aimed at: 
        • decreasing access to high THC products, 
        • preventing initiation of high THC products
        • empowering consumers and the public with information and education about high THC products.” 
      • “Notably, we are not recommending capping THC content at this time. Capping THC content to allow only low concentrations of THC is an evidence-based policy to be considered in the future, however it received low stakeholder support from all three groups involved in ADAI assessment. This is a policy option that could become more feasible as cannabis education and THC literacy increases in WA, THC testing accuracy improves in our state, and more is learned from caps in other states and provinces.”
    • The draft recommendations to legislators outlined what data researchers had reviewed, what other policies had been studied, and how stakeholder opinion had been incorporated along with International Cannabis Policy Study (ICPS) information.
      • The draft acknowledged that “tribal partners were invited to share their perspectives through a Dear Tribal Leader Letter distributed by WA HCA in January of 2022 and in a presentation at the January 2022 Monthly Tribal Meeting, and nine tribal organizations and indigenous groups were invited to participate in concept mapping. Participation in concept mapping is anonymous, but notably, no one chose “tribal partner” as a primary identity. Therefore, recommendations are based on WA state stakeholder perspectives and further consultations with tribes that may be impacted by changes to state policy should continue to be explored.”
      • “The recommendations made in this report refer solely to public health challenges derived from the availability of high THC non-medical products, recognizing that medical users have specific needs and work in partnership with their clinicians to make decisions that are appropriate to their health (and therefore are out of the scope of this report).”
      • WSLCB Board members heard from University of Waterloo School of Public Health Sciences Professor and University Research Chair David Hammond about ICPS data related to Washington on November 8th.
    • Seven recommendations were made based on the areas Carlini indicated were generally popular with stakeholder groups.
    • Other “Evidence-based policies to be considered in the future”:
      • Cap THC concentration
      • Set purchase limits for THC content
      • Education in communities/schools about high THC products risk”
    • Additional recommendations:
      • “Sufficient funding is imperative
      • Patients should not be affected by policies to mitigate the harms of high THC products
      • Place regulation of hemp-derived consumable cannabinoids under WSLCB jurisdiction”
    • And the draft conclusion:
      • “As WA cannabis markets increase production and sales of high THC products, it is extremely likely the negative health effects associated with its use will also increase. WA stakeholders are concerned with non-medical use of high THC products and support policy changes. Now, while the market is relatively nascent, is the time to make course corrections that will protect the health of WA residents from unforeseen harm. Policies that empower consumers to make educated choices, that reduce access for people under 25, and that use taxation to incentivize use of products with lower THC concentration will lead the way in evidence-based cannabis policy that supports a balanced approached to cannabis legalization.”
    • Draft appendices linked included:
    • On November 29th, UW staff published a press release (“Report addresses mental health risks of high-THC cannabis”) drawing on an interview with Carlini about the impending report and her recollection of the history of I-502.
      • “​​Proponents of the law said people should be able to access cannabis to change their perception of reality and to treat medical conditions without stigma.”
      • “Because these products lack labeling about a serving size, users can be unaware that they have consumed a chemically synthesized, mind-bending ‘hit’ equivalent to 190-proof alcohol.”
      • "The cannabis plant's raw flower material can have between 10 and 20% of THC concentration..."
        • The complex and diverse cannabis plant, inclusive of hemp cultivars, can have less than 0.3% THC upwards towards 30% THC by dry weight measurement.
        • Some researchers consider products with more than 10% THC to be “high-THC cannabis.”
    • On Friday December 2nd, WA House COG members planned to host a work session to hear an "Update on Cannabinoid Product Regulation and Enforcement and Summary of Research on High-THC Concentration Cannabis." In addition to a WSLCB panel, the agenda lists Carlini as the sole UW ADAI presenter.

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