Cannabis products take many forms. “Topicals” are preparations which are applied to the skin generally in liquid form of viscosities ranging from runny oils to thick balms, and are normally seen in the form of a lubricant, spa product, lotion or balm. Among many other changes being implemented in Michigan, topicals have also been receiving a lot of attention from state legislators.
The Michigan Medical Marihuana Act requires that the Michigan Department of Licensing and Regulatory Affairs (LARA) adopt administrative rules which apply to topicals, including the maximum allowed THC content per dose, and the maximum per container. The first set of rules was the Emergency Rules, which were published for comment and then adopted after a public hearing. At the mandatory public hearing conducted by LARA, objections were made to the recommendation of a maximum six percent THC content allowed in topical products.
The discrepancy of these rules surfaced at the meeting. It was pointed out that under the rules, it would be legal for an individual to buy Rick Simpson Oil with the intention of eating it or even smoking it, but illegal to sell someone an infused cannabis product with the intention of rubbing it on their skin
The Emergency Rules stated that there is a six percent maximum tetrahydrocannabinol (THC) content in topical products. Following that, the Permanent Rules were published for comment and set for hearing. They contained the same six percent THC limit, and in spite of objections, the rules were passed without change.
Since that happened, the matter continued to be pressed. LARA Director Andrew Brisbo was confronted several times, in public and online, with the absurdity of the rule limiting THC percentages in topical products to six percent. Not only is there no intoxicating effect from topical preparations, but for some purposes, the higher the concentration of THC offered the better the results for those who suffer from serious skin conditions such as acne vulgaris, psoriasis, skin cancer and the cutaneous manifestations of systemic sclerosis.
“On Feb. 4, the Bureau of Marijuana Regulation released an Advisory Bulletin announcing a revision of the cannabis-infused product maximum allowable amount, making any limits not applicable to topical products for either dosages or containers.”
On Feb. 4, the Bureau of Marijuana Regulation released an Advisory Bulletin announcing a revision of the cannabis-infused product maximum allowable amount, making any limits not applicable to topical products for either dosages or containers. We look forward to the great advances in dermatology which could be made possible by the availability of strong, pure, lab-tested cannabis concentrates which can be used in all types of health and beauty products in the near future. It is nice to see common sense prevail, although it took dogged effort to cause the change.
This issue with the limit on THC content of topicals now seems to be replaying in the saga of the rising popularity of cannabidiol (CBD). Companies have been quick to seize on both the positive effects and the marketing cachet of CBD. To reduce the exuberance, the United States Food and Drug Administration (FDA), has now advised that CBD has not yet been approved as safe for human consumption, and so it is not allowed to be an ingredient of any food products. As pointed out recently by Bradley Forrester of Michigan NORML, it is apparently okay to sell CBD oil to use as a topical, or even to vaporize or to smoke. However the same CBD capsule may not yet be sold as a food or drug product (except for Epidiolex, which has been approved by the FDA).
We have a long way to go in investigating the usefulness of the cannabis plant, but at least we have begun the journey.