Letter to the FDA on Descheduling Cannabis

The FDA is accepting comments on descheduling cannabis until April 23rd.

The United Nations World Health Organization is due to review the current international classification of marijuana, THC, cannabidiol, and other related compounds and preparations this year. In the lead up, the WHO is asking member nations submit feedback, of which no nation is more influential than the United States.

Source: Take Action: FDA Seeking Comment On The International Scheduling Of Cannabis – NORML.org – Working to Reform Marijuana Laws

Here’s my comment.

Cannabis can replace shelves full of physically addictive pharmaceuticals. Benzos, if you get behind on a dose by even a couple hours, gnaw at you body and soul. Not so cannabis. Cannabis is kind and not possessive. A tolerance break requires no slow ramping down of doses, you just stop.

I’ve been in neurological wards where the talk is of cannabis. Every single one of my doctors has said they wish they could prescribe it to me. Parents of autistic kids and kids with seizures are blowing hash oil in their back yards so kids can get relief (or uprooting their families and heading to legal states). Picture this: white, middle-class, suburban families all over the country making hash oil in their backyards so that their kids and neighbors have medicine. Is that your image of cannabis users? Does that fit the biases inculcated in us by decades of racist and immoral messaging?

Cannabis is the least harmful way for we humans to cope with sentience, senescence, and mortality. Cannabis is popular in STEAM cultures, at least the ones I’ve inhabited. It is part of the process of living, creating, and coping. Neurodivergent people have long used it to regulate and cope in a world that does not accommodate. If your neurodivergence is accompanied by tics, seizures, paresthesia, fasciculations, panic, anxiety, sensory processing disorders, or self-harming stimming, as but a handful of examples, then cannabis is a tool and ally. There are as many human operating systems as there are humans. The endocannabinoid system is a useful interface to all of those operating systems, one for which we have a natural, easy-to-grow, non-physically addictive key. All humans and their mammalian kin share this interface and this plant. We plucky Prometheans figured out how to decarboxylate with fire.

The drug war preys on and abuses the different and the powerless. It puts marginalized kids in pipelines to prisons and foster systems where the incentives are to drug minds into compliance so that bodies can be more conveniently warehoused and souls more conveniently iced. It tears apart families so savagely that the effects are felt epigenetically. The great many of us using cannabis to medicate and regulate are under constant threat of violence, humiliation, and confinement in inhumane jails and prisons where we will be denied the medicine that works. The drug war’s perverse notions of addiction, addicts, and coping limit our vocabulary, stifle our empathy, and harm us all. The drug war and the zero tolerance and compliance cultures born of it are enemies of neurodiversity and disability and all marginalized people.

Cannabis is a neuroprotectant and powerful harm reducer that is friendly to neurodivergence and the human condition. It is the safest active ingredient in humanity’s medicine cabinet, yet we shame and punish its use. The reasons cannabis is schedule 1 are racist and without science. “According to a comprehensive review by the United States National Academy of Sciences, cannabis’ dependence liability is similar to that of caffeine (7 percent) or anxiolytics (9 percent), and is far lower than the dependence liability associated with other substances like alcohol (15 percent) and tobacco (32 percent).

We have taken what is arguably one of nature’s (or God’s, if you’re so inclined) greatest gifts to humanity and reduced it to a way to put souls under carceral control.

See also,

Using data on all prescriptions filled by Medicare Part D enrollees from 2010 to 2013, we found that the use of prescription drugs for which marijuana could serve as a clinical alternative fell significantly, once a medical marijuana law was implemented. National overall reductions in Medicare program and enrollee spending when states implemented medical marijuana laws were estimated to be $165.2 million per year in 2013. The availability of medical marijuana has a significant effect on prescribing patterns and spending in Medicare Part D.

Source: Medical Marijuana Laws Reduce Prescription Medication Use In Medicare Part D

The researchers found that in states with medical marijuana laws on the books, the number of prescriptions dropped for drugs to treat anxiety, depression, nausea, pain, psychosis, seizures, sleep disorders and spasticity. Those are all conditions for which marijuana is sometimes recommended.

If the trend bears out, it could have other public health ramifications. In states that legalized medical uses of marijuana, painkiller prescriptions dropped – on average, the study found, by about 1,800 daily doses filled each year per doctor. That tracks with other research on the subject.

Marijuana is unlike other drugs, such as opioids, overdoses of which can be fatal, said Deepak D’Souza, a professor of psychiatry at Yale School of Medicine, who has researched marijuana. “That doesn’t happen with marijuana,” he added.

Source: After Medical Marijuana Legalized, Medicare Prescriptions Drop For Many Drugs : Shots – Health News : NPR

A 2002 review of seven separate studies involving 7,934 drivers reported, “Crash culpability studies have failed to demonstrate that drivers with cannabinoids in the blood are significantly more likely than drug-free drivers to be culpable in road crashes.” This result is likely because subject under the influence of marijuana are aware of their impairment and compensate for it accordingly, such as by slowing down and by focusing their attention when they know a response will be required. This reaction is just the opposite of that exhibited by drivers under the influence of alcohol, who tend to drive in a more risky manner proportional to their intoxication.

Today, a large body of research exists exploring the impact of marijuana on psychomotor skills and actual driving performance. This research consists of driving simulator studies, on-road performance studies, crash culpability studies, and summary reviews of the existing evidence. To date, the result of this research is fairly consistent: Marijuana has a measurable yet relatively mild effect on psychomotor skills, yet it does not appear to play a significant role in vehicle crashes, particularly when compared to alcohol. Below is a summary of some of the existing data.

The results to date of crash culpability studies have failed to demonstrate that drivers with cannabinoids in the blood are significantly more likely than drug-free drivers to be culpable in road crashes.

“Cannabis leads to a more cautious style of driving, but it has a negative impact on decision time and trajectory. However, this in itself does not mean that drivers under the influence of cannabis represent a traffic safety risk. … Cannabis alone, particularly in low doses, has little effect on the skills involved in automobile driving.”

1. There is no evidence that consumption of cannabis alone increases the risk of culpability for traffic crash fatalities or injuries for which hospitalization occurs, and may reduce those risks.

In contrast to the compensatory behavior exhibited by subjects under marijuana treatment, subjects who have received alcohol tend to drive in a more risky manner. Both substances impair performance; however, the more cautious behavior of subjects who have received marijuana decreases the impact of the drug on performance, whereas the opposite holds true for alcohol.”

Evidence from the present and previous studies strongly suggests that alcohol encourages risky driving whereas THC encourages greater caution, at least in experiments. Another way THC seems to differ qualitatively from many other drugs is that the formers users seem better able to compensate for its adverse effects while driving under the influence.”

Source: Marijuana and Driving: A Review of the Scientific Evidence – NORML.org – Working to Reform Marijuana Laws

The reduced rate of opioid-related fatalities translated into about 1,700 fewer deaths in 2010 alone. The researchers suggest several possible explanations for this effect. “Patients with chronic noncancer pain who would have otherwise initiated opioid analgesics may choose medical cannabis instead,” Bachhuber et al. write. “In addition, patients already receiving opioid analgesics who start medical cannabis treatment may experience improved analgesia and decrease their opioid dose, thus potentially decreasing their dose-dependent risk of overdose. Finally, if medical cannabis laws lead to decreases in polypharmacy-particularly with benzodiazepines-in people taking opioid analgesics, overdose risk would be decreased.”

That last possibility could be more significant than you might think, since opioid-related deaths typically involve mixtures with other drugs, with benzodiazepines playing a substantial and increasing role. Bradford and Bradford found that medical marijuana laws were associated with decreases in prescriptions for drugs used to treat anxiety and sleep disorders. Benzodiazepines are commonly used for both purposes.

“We find fairly strong evidence…that states providing legal access to marijuana through dispensaries experience lower treatment admissions for addiction to pain medications,” Powell et al. write. “We provide complementary evidence that dispensary provisions also reduced deaths due to opioid overdoses….Our findings suggest that providing broader access to medical marijuana may have the potential benefit of reducing abuse of highly addictive painkillers.” Like Bachhuber et al., they found that the longer medical marijuana was legally available, the bigger the apparent benefit.

Source: Medical Marijuana Replaces More Dangerous Drugs – Reason.com

“The Silk Road website was in many respects the most responsible such marketplace in history, and consciously and deliberately included recognized harm reduction measures, including access to physician counseling,” he wrote. “Transactions on the Silk Road website were significantly safer than traditional illegal drug purchases and included quality control and accountability features” that kept purchasers “substantially safer” than regular drug purchases.

Many reformers, myself included, have long been highlighting the forward-thinking benefits of Silk Road and the ways it began to slowly revolutionize drug sales around the world. For instance, it provided a platform that could allow indigenous growers and cultivators around the world to sell directly to the consumer, potentially reducing cartel participation and violence… None of the transactions on Silk Road, for instance, resulted in women drug buyers being sexually assaulted or forced to trade sex for drugs, as is common in street-level drug transactions. Nor did any Silk Road transactions result in anyone having a gun pulled on them at the moment of purchase.

In his declaration, Caudevilla testifies that the site “espoused a harm reduction ethos which was reflected in the individual buyer-seller transactions on the site and in the community created on the site’s forums.” That community “enabled some site participants to reduce, if not entirely eliminate, their drug use.”

Caudevilla participated on the Silk Road forums for seven months and states that he “never came across even a single report of a Silk Road-related drug overdose.” Ulbricht’s lawyers point to the lack of such a “report” as a telling fact, although one wonders which section a user who had overdosed was expected to post in.

Source: Ulbricht’s lawyer: Silk Road was “the most responsible” drug market in history | Ars Technica

Default to Open: Open Education, Open Government, Open Data, Open Web, and Open Source

My posts on boren.blog connect humane tech, tech ethics, tech regrets, indie ed-tech, open source, open web, open data, distributed work, backchannels, indieweb, neurodiversity, #ActuallyAutistic, the social model of disability, design for real life, behaviorism, structural ideology, mindset marketing, psychological safety, and public education. That jumble of tags is full of connections and overlap. It’s full of lessons on building for humans and the commons. I try to bring these communities together with my writing and sharing, because in connection there is serendipity, and we urgently need a lot of that going on between tech, education, and social model communities. I feel good and reenergized when educators, tech workers, and autistic and disabled people interact in threads I start. These moments are necessary and make a difference. Cheers for being in the space. Cheers for helping make the commons.

Open education, open government, open data, open web, and open source. These are the foundations of the commons. They should be public, taxpayer supported, and open by default. They should be informed by neurodiversity and the social model of disability because systems are better in every way when designed for real life, pluralism, and bodily autonomy.

Software and the internet are at their best when making human systems more inclusive, accessible, and transparent. In my estimation, the web and the open source stack that powers it were built so that public infrastructure, particularly education, could default to open.

We are responsible for humanizing flow in the systems we inhabit. We do that best when we default to open. This is our calling. Let’s build a tech and ed-tech that confront injustice instead of amplifying it. do_action.

For education to fulfill the promise of “free, life-changing, and available to everyone”, we need indie ed-tech and the social model. “We need to design learning where there is no option for oppression.”

One of the legacies of the counterculture, particularly on the left, is the idea that expression is action. This idea has haunted those of us on the left for a long time.

But one of the reasons that the Tea Party came to power was that they organized—they built institutions. So the challenge for those of us who want a different world is not to simply trust that the expressive variety that the internet permits is the key to freedom. Rather, we need to seek a kind of freedom that involves people not like us, that builds institutions that support people not like us—not just ones that help gratify our desires to find new partners or build better micro-worlds.

Source: Don’t Be Evil

It’s no secret people are more likely to trust the government and value what the government provides if their local government shares information and involves them in the decisions that affect their lives. And when government organizations do share data, best practices, and code, the government as a whole does better by its citizens. Everyone wins.

Source: Default to open · Code for America

Indie Ed-tech is infrastructure that supports scholarly agency and autonomy.

Source: A Journey to discover what is Indie Ed-tech | Heart | Soul | Machine

For his part, in that Stanford talk, Jim Groom pointed to 80s indie punk as a source of inspiration for indie ed-tech. “Why 1980s indie punk?” Groom explains,

First and foremost because I dig it. But secondly it provides an interesting parallel for what we might consider Indie Edtech. Indie punk represents a staunchly independent, iconoclastic, and DIY approach to music which encompasses many of the principles we aspired to when creating open, accessible networks for teaching and learning at [the University of Mary Washington]. Make it open source, cheap, and true alternatives [sic] to the pre-packaged learning management systems that had hijacked innovation.

The LMS is our major record label. Prepackaged software. A prepackaged sound.

Pre-packaged sound. Pre-packaged courses. Pre-packaged students.

If we don’t like ‘the system’ of ed-tech, we should create one of our own.

“Indie ed-tech” – what we’re gathered here to talk about over the next few days – is inherently ideological as it seeks to challenge much of how we’ve come to see (and perhaps even acquiesce to) a certain vision for the future of education technology. An industry vision. An institutionalized vision. Indie ed-tech invokes some of the potential that was seen in the earliest Web technologies, before things were carved up into corporate properties and well-known Internet brands: that is, the ability to share information globally, not just among researchers, scientists, and scholars within academic institutions or its disciplines, but among all of us – those working inside and outside of powerful institutions, working across disciplines, working from the margins, recognizing the contributions of those who have not necessarily been certified – by school, by society – as experts. Distributed knowledge networks, rather than centralized information repositories. “Small pieces, loosely joined.”

“Indie ed-tech” offers a model whereby students, faculty, staff, and independent scholars alike can use the “real-world” tools of the Web – not simply those built for and sanctioned by and then siloed off by schools or departments – through initiatives like Davidson Domains, enabling them to be part of online communities of scholars, artists, scientists, citizens.

Source: ‘I Love My Label’: Resisting the Pre-Packaged Sound in Ed-Tech

Note: LMS = Learning Management System

We roil at the limitations and oppressive qualities of the LMS. But the problem here is not the LMS-it is that, despite our best efforts at creating other platforms, we still think through our own internal LMS. The problem is that whether we are using Blackboard or teaching in Canvas or building a Domains project, we are most likely not doing thinking that is liberative enough.

The point is not just about platform. The point is about praxis.

the LMS is an outlook, a standpoint, a conviction. Like it or not, it is in our blood as a product of our privilege and our educations. It is not a cage we put students in as much as it is an artificial playground over which we can be masters. It is, in fact, a learning space, but not for the content we put there; rather it is a space of enculturation into an oppressive educative model which each of us has born the weight of, and into which we each believe, to varying degrees, students should be baptized. The same is true of the classroom, the academy, the professional conference. These are spaces we understand, where we are not marginal, but where we can invite the marginal to participate, to become not-marginal. And this invitation to the middle is an act we say is elevating, is doing good.

There are multitudes of voices that we won’t hear because we do not feel safe in their spaces, on the margins. And safe, for educators, usually means expert, superior, capable, competent. When we enter the margins from our roosts in academe, we suffer the surrender of our confidence. In the face of what might be being created in the spaces we don’t occupy, our knees wobble.

By offering a room, we make ourselves the lessors. By making space, we claim space. “These are your walls,” we say. “These are your walls that I’ve given you. These are your walls to hang upon them what you would like. I have made them of plaster and drywall. I have painted them. I have put in the studs and I have raised high the roofbeams. But truly, this is yours. I have made you a space where you can be who you want to be.”

We need to design learning where there is no option for oppression.

Source: If bell hooks Made an LMS: a Praxis of Liberation and Domain of One’s Own

There are other considerations as well. How does this tool represent a politics of oppression-the surrender of privacy, data, authorship, authority, agency, as well as issues of representation, equity, access? Who owns the tool and what are their goals? How is the production of this tool funded? What influence does the maker of this tool have on culture more broadly writ? What labor is rewarded and what labor is erased? What is the relationship between this tool and the administration of the institution? Who must use this tool and who is trained to use this tool, and is that labor compensated? These are all important questions to ask, and the answers may play a role in the adoption of any given tool in a classroom or learning environment.

But in many cases, and especially with the LMS, adoption comes regardless of consent. In only a minority of situations are faculty and students part of the discussion around the purchase of an LMS for an institution. In those situations, we must abide by the use of the LMS; however, that doesn’t mean we must acquiesce to its politics or its pedagogy. In order to intervene, then, we must step back and rather than learn the tool, analyze the tool.

When we do that with the LMS, we find that its primary operation is the acquisition of data, and the conflation of that data with student performance, engagement, and teaching success.

Source: Reading the LMS against the Backdrop of Critical Pedagogy, Part One – OFFICE OF DIGITAL LEARNING

Previously,

Letter to My Representatives on SESTA and FOSTA

I am currently retired, but for many years I was lead developer of software that now runs 30% of the web. I helped build an open source companydedicated to the open web—that employs over 600 people. I’ve been at this awhile, doing my part to champion small platforms and lawful speech along the way. I was there for the CDA black out in 1996 and the resulting Declaration of the Independence of Cyberspace. We blacked out WordPress.com and WordPress.org for SOPA/PIPA in 2012.

Here we are again. Lawmakers have combined the worst elements of SESTA and FOSTA into a “monster of a bill that would be a disaster for Internet intermediaries, marginalized communities, and even trafficking victims themselves.” SESTA is “a terribly drafted bill which no one can explain how it will actually stop sex trafficking.” There are “half a dozen ways #SESTA-#FOSTA could have been drafted to do less damage to small platforms and lawful speech”.

Much of this could have been avoided if anyone in Congress were actually interested in understanding how the internet worked, and how to write a bill that actually addressed problems around sex trafficking.” Congress has yet to demonstrate the curiosity or capacity to understand the internet. CDA, SOPA, PIPA, SESTA, and FOSTA is a record of bad faith and insistent ignorance.

Sources referenced: