Health Canada has released their report on health products containing cannabis.
The report was compiled over the past few years by Health Canada’s nine-member external Science Advisory Committee on Health Products Containing Cannabis for human and animal use.
The report provides recommendations for some very limited forms of therapeutic CBD use for both humans and for dogs. These are not regulatory changes, only recommendations that could guide future changes.
Starting in 2019, the committee looked at the potential for products containing CBD to be purchased without needing a prescription from a medical professional, similar to other over-the-counter products.
Taking into consideration numerous public health concerns, the committee provides several recommendations:
“The lack of high-quality research on the safety and efficacy of cannabis when used to treat minor health problems led the committee to be particularly cautious in its conclusions around safe use for the healthy adult population.”
Due to concerns with how CBD is absorbed into the body, the committee recommends their advice only apply to CBD that will be given orally.
Recommendation A
“The committee unanimously agrees CBD is safe and tolerable for short-term use (a maximum of 30 days) at doses from 20 milligrams per day (mg/day) to a maximum dose of 200 mg/day via oral administration for healthy adults, provided they discuss the use of all other medications and substances used with their pharmacist.”
The committee also noted that any person using CBD should use caution when considering potential dosages since most dosing limits and ranges do not account for the possible interactions between CBD and other drugs a person might take, which could result in adverse effects.
Recommendation B
“The committee strongly recommends that all health products containing CBD should carry statements on potential interactions between CBD and other drugs or alcohol, and should not be used for individuals who are pregnant, lactating, or considering pregnancy, or people with allergies or hypersensitivity to cannabis, cannabinoids, or other components of the manufacturing process.”
“It is also strongly recommended that a warning be prominently placed on the product label and insert which states that due to the potential of harmful effects of CBD products on fetal development, this product should not be used by individuals who are pregnant, considering pregnancy or breastfeeding.”
Recommendation C
“The committee recommends that packaging for health products containing CBD should have clear dosing instructions and warnings of potential side effects, emphasizing that side effects can be worse at higher doses.”
Recommendation D
“CBD is not habit forming, however, the committee recommends that health products containing cannabis should carry a warning to clarify they are not intended to help reduce consumption of opioids or alcohol as there are no definitive studies that have validated its use for those indications.”
Recommendation E
“The committee recommends that the approval of health products containing CBD should be accompanied by public education to explain possible benefits and risks, information on safety, and on gaps in research knowledge around the non-prescription use of CBD.”
Committee members focused their review on three main issues: using CBD for relieving minor symptoms of stress and nervousness, for promoting sleep, and for relieving minor pain.
The committee unanimously agreed that there is some early evidence that CBD may be effective for the short-term (ie., less than 30 days) treatment of mild symptoms associated with stress and nervousness. But the committee also agreed that there is not yet enough scientific or clinical evidence to support or refute the short-term use of CBD-based products for either promoting sleep or relieving minor pain.
Recommendation F
“The committee recommends that: Labels on health products containing CBD should encourage consumers to report adverse reactions that result from using the product by offering multiple, easy-to-use reporting options.
“All platforms and resources for reporting adverse reactions should be designed to ensure equitable access for the wider Canadian community. Health products with CBD should be packaged in boxes, so an insert with key details on the product can be included with every sale. Consultation with a pharmacist should be encouraged if taking other medications; therefore health products containing CBD should only be available in pharmacies.”
Veterinary Subcommittee:
Using the same objectives as CBD products for human use, the panel’s veterinary subcommittee was launched in January 2021.
Because the report notes there is more research available that looks at the use of CBD for dogs than cats, it only provides recommendations for dogs.
Recommendation G
“Among the evidence available for CBD use in companion animals, subcommittee members agreed that there was only sufficient safety evidence for CBD use in dogs. Specifically, when administered at very low doses between 0.2-2mg/kg orally twice daily.”
Specifically, the subcommittee looked at evidence regarding the efficacy of CBD for the treatment of pain associated with osteoarthritis in dogs. They agreed that any CBD product for that purpose should be accompanied by a confirmed diagnosis of osteoarthritis from a veterinarian.
Recommendation H
“Subcommittee members agreed there was sufficient evidence regarding the efficacy of CBD for the treatment of pain associated with osteoarthritis in dogs, however insufficient information to recommend a specific dose.”
Similar to their recommendations for humans, the subcommittee recommended products should be sold in a box with an insert giving dosing details and other information. The label should state that the product should only be used if a veterinarian has diagnosed the animal’s condition and discussed the possible use of CBD (including its benefits and risks) with the owner. Members noted that labels should indicate relative contraindications and that any CBD product should not be used in dogs with liver function impairment or severe heart disease, or used in dogs who are breeding, pregnant or lactating, or immature.
Recommendation I
“The subcommittee recommends that any CBD product that is intended only for dogs should have a confirmed diagnosis of osteoarthritis from a veterinarian.”
“Until more safety and efficacy information becomes available, pet-owners should consult a veterinarian prior to administering CBD to their pets.”
Research considerations for human use
The committee also notes that there is still a need for more research on the subject of CBD use for various ailments in humans.
Recommendation J
“The committee recommends that high-quality clinical research into the safety and efficacy of cannabis, CBD and other phytocannabinoids, should be further supported by governments and funding agencies.”
Because the available studies and research on CBD products are still quite limited, the committee noted that more information is needed on different routes of administration, such as for CBD creams and ointments.
This lack of consistent, quality data made it difficult for the committee to draw concrete conclusions and recommendations. These same limitations exist for research looking at CBD use for pets.
Although the committee notes that their recommendations may not please all stakeholders, especially the industry looking for new ways to sell CBD products in a less highly regulated environment, their report emphasizes that they had to strike a balance between safety and accessibility.
“While our goal is to support consumer access to safe products, we also need to consider knowledge gaps and public health risks. The recommendations provided are based on the scientific evidence available at the time of the committee’s review and will evolve as the information on CBD continues to develop. We strongly encourage Health Canada to review these recommendations on a regular basis as further high-quality research is conducted on cannabis for health indications and as experience is gained on the use of health products containing cannabis in Canada and internationally.”
