Former Cannabis Regulators Submit Comment to DEA Supporting Rescheduling of Cannabis

Today, six former state cannabis regulators submitted a comment to Drug Enforcement Agency (DEA) Administrator Ann Milgram, supporting the agency’s proposed rule to reschedule cannabis to Schedule III under the Controlled Substances Act (CSA). The former regulators from Nevada, Massachusetts, Maine, California, Minnesota, and Washington, represent former public officials who were directly responsible for oversight of both medical and adult-use cannabis marketplaces across the United States and have first-hand experience with the challenges faced by having cannabis listed currently as a Schedule I drug.

As state regulators, we have seen firsthand the value and effectiveness of cannabis as medicine.

Pairing our experience in states alongside more robust and structured research should set the table for continued reform efforts in the near future.
— Shawn Collins

As detailed in the submitted comment, the former regulators commend the U.S. Department of Health and Human Services (HHS) for their careful evaluation of the evidence and the Drug Enforcement Administration (DEA) for initiating this rulemaking process. They also highlighted the federal government’s opportunity to reassess its own approach and begin the long-overdue process of aligning policy with science.

Former regulators cited the potential for expanded access to clinical research and the opportunity to close gaps in scientific understanding that have vexed policymakers. They are calling on the federal government to engage with states to leverage lessons learned in service of better public policy at every level of bureaucracy.

Furthermore, the former regulators shared their experiences and knowledge in overseeing cannabis markets and underscored the opinion that cannabis does not meet the criteria for Schedule I.

“It is clear that the designation of cannabis as a schedule I controlled substance needs to change,” said Tyler Klimas, former Executive Director of the Nevada Cannabis Compliance Board. “Leaning on the experience of states and supporting stakeholders during this process will help the federal government immensely.”

“As state regulators, we have seen firsthand the value and effectiveness of cannabis as medicine,” said Shawn Collins, former Executive Director of the Massachusetts Cannabis Control Commission. “Pairing our experience in states alongside more robust and structured research should set the table for continued reform efforts in the near future.”

"Rescheduling cannabis is a pivotal step towards aligning federal policy with science and acknowledges the tireless work of state regulators,” said Erik Gundersen, former Executive Director of Maine’s Office of Cannabis Policy. “I am hopeful this will pave the way for more comprehensive and sensible cannabis policies in the future.”

“The great paradox of the United States’ approach to drug scheduling is that it impedes the very research most needed by policymakers,” said Christina Dempsey, former Deputy Director of Policy and Research for the California Department of Cannabis Control. “Rescheduling is an opportunity to accelerate academic study and finally align federal cannabis policy with science.”


Shawn Collins

Shawn Collins is one of the country’s foremost experts in cannabis policy. He is sought after to opine and consult on not just policy creation and development, but program implementation as well. He is widely recognized for his creative mind as well as his thoughtful and successful leadership of both startup and bureaucratic organizations. In addition to cannabis, he has a well-documented expertise in health care and complex financial matters as well.

Shawn was unanimously appointed as the inaugural Executive Director of the Massachusetts Cannabis Control Commission in 2017. In that role, he helped establish Massachusetts as a model for the implementation of safe, effective, and equitable cannabis policy, while simultaneously building out and overseeing the operations of the East Coast’s first adult-use marijuana regulatory agency.

Under Shawn’s leadership, Massachusetts’ adult-use Marijuana Retailers successfully opened in 2018 with a fully regulated supply chain unparalleled by their peers, complete with quality control testing and seed-to-sale tracking. Since then, the legal marketplace has grown at a rapid pace and generated more than $5 billion in revenue across more than 300 retail stores, including $1.56 billion in 2023 alone. He also oversaw the successful migration and integration of the Medical Use of Marijuana Program from the stewardship of the Department of Public Health to the Cannabis Control Commission in 2018. The program has since more than doubled in size and continues to support nearly 100,000 patients due to thoughtful programmatic and regulatory enhancements.

Shawn is an original founder of the Cannabis Regulators Association and also helped formalize networks that provide policymakers with unbiased information from the front lines of cannabis legalization, even as federal prohibition persists. At the height of the COVID-19 pandemic, Collins was recognized by Boston Magazine as one of Boston’s 100 most influential people for his work to shape the emerging cannabis industry in Massachusetts.

Before joining the Commission, Shawn served as Assistant Treasurer and Director of Policy and Legislative Affairs to Treasurer Deborah B. Goldberg and Chief of Staff and General Counsel to former Sen. Richard T. Moore (D-Uxbridge). He currently lives in Webster, Massachusetts with his growing family. Shawn is a graduate of Suffolk University and Suffolk University Law School, and is admitted to practice law in Massachusetts.

Shawn has since founded THC Group in order to leverage his experience on behalf of clients, and to do so with a personalized approach.

https://homegrown-group.com
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