Comments on the MCC’s Procedures for Medicinal Dagga

By |Published On: March 9th, 2017|

The Medicines Control Council has published their guidelines for “Cultivation of Cannabis and Manufacture of Cannabis-Related Pharmaceutical Products for Medicinal and Research Purposes.” We have had a careful look at the document and urge our supporters to do the same.

Public comments are open until the end of March 2017 but we get the feeling that the MCC are a bit scared of the inevitable flood of comments so they are being a bit obtuse about where to do this. You can try the following link:


Dr Joey Gouws, Registrar of Medicines, Medicines Control Council, Private Bag X828, Pretoria, 0001
Email: [email protected] / Tel: 0027 (0) 12 395 8003

Please post your comments to the MCC on our Dagga Stories page so that everyone can read what everyone has to say:

After introducing their mandate in terms of the law, the MCC states that “In recent years, a small but growing body of evidence has emerged claiming that Cannabis may have medicinal value for some patients in conditions where other treatments have failed.” This sets the tone for the entire document and should alert all South Africans who have a thorough knowledge of this plant to the extent of the MCC’s knowledge, as well as their overall attitude, from the start. We know that there is an enormous body of evidence that proves that Cannabis is an effective treatment for a vast array of ailments and should not be left as a last resort.

Next, the authors write about the international treaties that supposedly govern the use of Cannabis and only allow it’s use, cultivation and trade for medicinal and research purposes. The MCC fail to mention that the International Narcotics Control Board also states very clearly that: “The Board encourages States to adopt nonpunitive responses for minor drug-related offences committed by drug users, instead of arrest and incarceration, as an alternative provided by the international drug control conventions.” The guidelines go on to state, in no uncertain terms, that “Cannabis products that are not registered with the MCC remain in Schedule 7″, which means that an institution that claims to have the best interests of the public at heart is endorsing the harms of prohibition by keeping the same substance in two different schedules – hardly rational or scientific.

With the system proposed by the MCC there will always be someone who will play god. “The integrity of a person who is granted a license, or who has the ability to substantially influence the conduct of activities under a license, is fundamental to the medicinal Cannabis scheme. The applicant’s interactions and associations will be considered by the MCC in assessing whether the fit and proper person principle is met, taking into account convictions…” In short, the vast majority of South Africans who know the most about cultivating this plant also use this plant. This valuable cache of knowledge is excluded from the MCC’s “scheme” and Cannabis farmers will thus continue to work underground, servicing the large sector of the population who will not be able to afford the medicine. This section of the document is followed by a paragraph on personnel training that implores applicants to “…ensure that competent staff with appropriate skills are appointed…” Go figure?

Security, hygiene and good governance requirements outlined in the document are all well and good. All businesses should take these factors into account. However, because this “scheme” takes a plant that is used, for whatever reason, by a very large number of people and places it within a highly restricted, highly bureaucratic, overly controlled environment, the aforementioned requirements need to be strictly enforced. So strictly enforced that this will inevitably push up the price of the “product” and exclude most of the people it is intended to help. This is the only reason there is a strongly worded paragraph called “Risk of Diversion“. Wouldn’t it be disastrous if any of us dreadful, healthy, unregistered responsible adult users get our hands on their impeccable medicinal weed!

The section on “Production and Manufacturing” is a selective cut and paste from a report from the Canadian task force working on Cannabis legalisation. Imagine you are a South Africa Cannabis connoisseur who has cultivated a particular strain that you know works for a particular medical condition. You are about to be dictated to about which strains you are and aren’t allowed to grow and you will have the authorities breathing down your neck every step of the way. We would like to take this opportunity of wishing you, the South African Cannabis farmer who is keen to turn your illegal business into a legal one, all the best with your application to the MCC. Be prepared to deal with people who know nothing about what you do. Good luck!

This document only deals with the cultivation and manufacture of Cannabis. Our big question is, yes this is about medicinal use of the plant but what about the Traditional Healers? There is a gaping hole that leaves the primary healthcare providers to millions of South Africans in the dark. We don’t expect an answer to this question anytime soon as the Department of Health are famous for sidelining this important sector.

Yes, the latest developments are a step in the right direction BUT they are nowhere near what is required in terms of the bigger picture. The best thing about the latest announcements is that it is keeping the story in the media and helping to spread the word about our favourite plant. Many publications are saying the same thing as we are. We implore all of our supporters to take the time to write carefully considered comments on the document and send them to the MCC as directed above.

For us, it is 143 days to The Trial of the Plant. There are an estimated 1000 arrests for Cannabis EVERY DAY in South Africa. That makes 144000 arrests before we get to court. That is what worries us. The MCC can make Cannabis available to a few select, rich, connected citizens and we will soldier on in our quest for Fields of Green for ALL – ALL SOUTH AFRICANS. We can do this because we KNOW that this plant enhances our lives and we KNOW that we have massive support. Thank you.




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Thank you to our FGA Affiliates who help to make our ongoing content creation possible!


About the Author: Myrtle Clarke

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