CSA and AIA Project

Desired Outcome:

  • Provide Science based data to cause the upcoming statutory amendments to the Controlled Substances Act made by the DEA to include language that “Cannabis America / 0.00% THC cannabis genetic variety” shall be exempt from the CSA.


  • Use science-based data of Cannabis America to “codify in the Drug Enforcement Administration (DEA) regulations the statutory amendments to the Controlled Substances Act (CSA) made by the Agriculture Improvement Act of 2018 (AIA), regarding the scope of regulatory controls over marihuana, tetrahydrocannabinols, and other marihuana-related constituents”.
  • Complete for timely submission, comments to DEA’s Docket No. DEA-500, RIN 1117-AB53
  • Inform key federal and state lawmakers, federal and state agents and all counties served by FSA.
    • Send translated version of a letter and overview to BO’s key export countries.

Project Objective:
Prepare and educate Michael and others for meetings with the DEA and the 10/20/20 deadline.
Deliver a SWOT focused on political and leadership of the Objective.
Who will love this, who will not love this?

Task List (partial, iterative)

  • Compile copies of relevant portions of the CSA and the AIA.
  • Check all federal comments for info on the subject areas
  • Confirm contact info of Key personnel at USDA involved with the AIA edits, sonny Purdue, the three administrators I met in 2019.
  • Beyond Scott Brinks at DEA, who, where, how do we get the initiative package to the key people.
  • Upload to Outlook Contacts or Excel, contact list of all Key Contacts and influencers to receive our information.

DEA Comments due 10/20/2020

Electronic comments must be submitted, and written comments must be postmarked, on or before October 20, 2020. Commenters should be aware that the electronic Federal Docket Management System will not accept comments after 11:59 p.m. Eastern Time on the last day of the comment period.
ADDRESSES: To ensure proper handling of comments, please reference “RIN 1117-AB53/Docket No. DEA-500” on all correspondence, including any attachments.
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FOR FURTHER INFORMATION CONTACT: Scott A. Brinks, Diversion Control Division, Drug Enforcement Administration; Mailing Address: 8701 Morrissette Drive, Springfield, Virginia 22152; Telephone: (202) 598-2596.


Most recent letter to DEA 09/16/2020

While the global pandemic has captivated the world, marijuana sales have skyrocketed. News and society may have stopped speaking about the opioid crisis, Bazelet Health is developing solutions targeting ways to fix opioid epidemic using chemicals found in cannabis sativa L. We seek to research 0.00% THC cannabis that we believe will be effective in activating the Endocannabinoid System.

Cannabis America plants are grown with 0.000% THC. Used legally in research trials, 0.00% THC Cannabis America shows ability and promise of alleviating pain without the side effects of Opiods.

The ability to obtain certain effects of a safe medication while not creating other effects is the true science and goal. By completing human clinical trials for pain management using cannabis America, Bazelet Health sees an enormous opportunity to remove abuse potential of opioid addiction while providing patients safe, reliable and affordable pain therapies with products containing cannabis compounds found in THC free Cannabis America.

Bazelet Research is collaborating with teams in Israel that possess scientific evidence of the use of cannabis as medicine. The FDA has approved a cannabidiol [CBD] drug, a chemical found in cannabis. THC, another chemical in cannabis has seen astounding popularity around the world and is impacting every industry. These products are an enormous, virtually unrivaled economic driver yet it remains a schedule one drug and arrests still take place daily.

Our position is that cannabis does have medicinal value and is only highly addictive if compared to a good addiction similar to love, health, and the addiction for using scientific evidence and not old policy for almost 80 years that have helped make millionaire drug dealers, wasted billions in defense, and created the most prolific state run drug cartel groups now taking over politics, law, and the American democracy.

The DEA must stand down on anything marihuana and the FDA must stand up and work with trusted university partners and private enterprise to bring to market the safest most effective medicinal, homeopathic, Ayurvedic, pharmaceutical, and recreational marihuana for use globally.

Opportunities and potential separating out the respiratory failure, the overdose from pain relieving properties.