Rulemaking Public Comment.FINAL.LETTERHEAD

November 23, 2007 Via Regular Mail Deputy Administrator Drug Enforcement Administration Washington, DC 20537 ATTENTION: DEA Federal Register Representative/ODL RE: Docket No. DEA-308P; Proposed Rule; Technical Amendment to Listing in Schedule III of Approved Drug Products Containing Tetrahydrocannabinols; 72 Fed. Reg. 54226, September 24, 2007 Public Comment of Americans for Safe Access Dear Madam/Sir: Herein is the public comment of Americans for Safe Access (“ ASA” ) regarding the above-referenced proposed rule. A. Interest of ASA ASA is a non-profit advocacy organization dedicated to advancing safe and legal access to cannabis therapeutics and research. Dronabinol, or Delta-9-THC, is the name of a particular isomer of a class of chemicals known as Tetrahydrocannabinols (“ THC” ), and is one of the more than 60 cannabinoids present in whole-plant cannabis. As such, ASA has a direct interest in the scheduling of drug products containing THC. ASA’s interest includes, without limitation, an interest in assuring that drug products containing THC are assigned to the respective schedules under the Controlled Substances Act and the Code of Federal Regulations with due regard to the proven medical benefits of THC and other cannabinoids. B. ASA’s position on the Proposed Changes to 21 C.F.R. § 1308.13(g) ASA respectfully submits regarding the proposed changes to the wording of the current Schedule III designation of ...