In response to the Proposed Cannabis (Licensing and Regulation) Act 2020, the Inter-Agency Committee for Children and Families, a network of social and human service providers and non-profit organisations, reached out to its membership to solicit feedback, concerns and questions regarding the legislation. This submission is a compilation of comments and questions received from IAC members. Areas of concern fall primarily around the research regarding the negative effects of cannabis legalisation and cannabis use, and the preventive plans to safeguard youth. The second area of concern and desire for clarity pertains to the justification for the evolution of the legislation from decriminalisation/medicinal use only to full regulated legalisation.This submission includes questions our stakeholders would like to have answered by the Government and questions to be considered by all members of the community.Potential negative impacts of legalisationThe greatest concern expressed by IAC members relates to the present research around the negative effects of both cannabis use and of the early evidence of legalisation of cannabis, especially given our climate where service providers across the board are seeing significant increases in substance abuse and mental health issues. A 2019 literary review of the health and safety effects of cannabis legalisation, which included data from Colorado — a fully legalised and regulated market since 2014 — found “cannabis legalisation has led to significant health consequences … the most concerning include psychosis, suicide and other substance abuse. “There are deleterious effects on the brain and some of these may not be reversible with abstinence. Other significant health effects include increases in fatal motor-vehicle collisions, adverse effects on cardiovascular and pulmonary systems, inadvertent pediatric exposure, cannabis contaminants exposing users to infectious agents, heavy metals and pesticides”¹.Specifically, Colorado has seen a significant increase in hospital admissions and emergency-room visits with cannabis-related billing codes. Furthermore, the review of the literature shows associations of cannabis use with the following outcomes — all of which increase as frequency of use does:• Health outcomes: schizophrenia and other psychoses, depression, anxiety, suicide, social-anxiety disorders and cognitive impairment• Social/behavioural outcomes: poorer education outcomes, lower incomes, greater welfare dependence and unemployment, lower relationships and life satisfaction; and increased traffic fatalities where blood/urine screens tested positive for cannabinoidsDespite all this evidence, the policy paper makes no reference to this data and only mentions a National Institute of Health study in process that will inform the analysis in the future. Furthermore, IAC members have noted that the validity of the concerns in the public domain with respect to drink-driving should further encourage the Government to proceed with caution.Based on the data, IAC members have the following questions:1, Has the research that does exist on the negative effects of both cannabis use and the legalisation of cannabis been considered?2, Have we looked at the outcomes for other jurisdictions — positive and negative, expected and unexpected across all domains — and determined whether, based on the research, this is a desirable move for Bermuda? 3, Has the Government conducted a cost-benefit analysis taking all factors into consideration, including social factors and, in particular, who is mostly likely to be negatively impacted? If not, what is the foundation of the perspective that this venture would be good for Bermuda?4, How does the Government plan to ensure that the proposed legislation does not have a negative effect on the most vulnerable within our population; ie, those who are using substances to medicate their struggles and pain, and those who are already experiencing employability and educational attainment challenges?5, How does this legislation intend to protect our youth from the dangers of cannabis use?a, What is the educational component and will prevention organisations be invited to contribute to the plan?b, The Department of National Drug Control conducted a national youth survey last year. This data is crucial to effective prevention programme planning. When will this data be released to the public and will it be released before the legislation being passed so we understand the existing prevalence among our youth?c, What provisions are made to dissuade manufacturers from packaging and marketing products to children? For example, the vaping industry had to reconsider this issue, as many companies packaged their products in ways that directly made their products attractive to children.6, The Government is proposing to use the same format used for alcohol awareness, but given the present crisis around drink-driving traffic crashes, is it reasonable to assume that the alcohol-awareness campaigns are effective at changing behaviours and preventing substance misuse?7, The fine of $300 for procuring cannabis for consumption and aiding a minor in obtaining and consuming cannabis in a retail shop seems like a mild deterrent regarding protecting our youth. Furthermore, there is a concern for the safeguarding of minors in all aspects of the legislation, and terms used such as “who appears to be under the age of 21” present enforcement issues. How will the Government ensure that the legislation has teeth for proper enforcement to protect our young people in all aspects of this law?Rationale for the change in approach to cannabis useIAC members would also like to better understand the rationale for the shift from a limited focus on medicinal use of cannabis to fully regulated legalisation, and how this aligns with the Government’s overall intentions for strengthening our community. It is interesting to note that this legislation is being driven by the Cabinet minister that is also responsible for drug prevention and drug treatment through the mandate of the Department of National Drug Control.It is pertinent to recall that the DNDC has two notable mandates:1, To advocate and educate on prevention, treatment, rehabilitation and harm reduction, which concerns alcohol, tobacco and other drugs2, To provide technical advice, educational resources and financial support to drug prevention, treatment and rehabilitation servicesFurthermore, in 2018, this government drafted a Green Paper “to seek ways to reduce drug abuse and increase rehabilitation in Bermuda”.At the time, the Green Paper was described as “an area of priority for the Government in the 2017 Speech from the Throne”. Further comments made by the DNDC and the Attorney-General in recognition of Recovery Month 2019 discussed the importance of prevention and addressing mental-health and substance-abuse issues, and was focused on “celebrating those who were committed to living a healthy and drug-free lifestyle”.Additionally, the Government’s present health strategy outlines 14 health sector goals to be addressed “that lead to high cost and poor value” in the health system. Goals include encouraging healthy lifestyles as well as increased access to interventions to prevent and manage non-communicable diseases and their risk factors. It stands to reason that recreational cannabis use is something that should be deterred rather than encouraged within the context of the Bermuda Health Strategy. Given all of this, the push for the legalisation of cannabis seems contradictory.The justification that is provided refers to public consultative feedback on the original scheme and public desire for legislation to go beyond medicinal use to regulated legalisation. However, in the policy paper, data is cited showing that only 19 per cent of the public were in favour of “no legal consequences for cannabis use”. Greater support was shown for decriminalising and reforming/reducing legal consequences — 55 per cent to 58 per cent. Comparing those percentages would not appear to justify widespread public support for full legalisation beyond medicinal use and decriminalisation. Based on this perspective, IAC members have the following questions:1, Given the Government’s previously stated priority for substance abuse prevention and treatment, can you explain the Government’s rationale for the evolution of the legislation? Additionally, what has been the perspective and feedback from the DNDC on legalisation, and the Government’s response to that feedback?2, What is the quantifiable impact to our economy, and people, that the Government is hoping to achieve in building the distribution of cannabis into a legitimate industry within the Bermuda economy?3, Where is there evidence that building on an industry of substance use, such as cannabis availability, has supported significant growth of economies, particularly for minority populations, without increasing maladaptive behaviours and increased substance abuse?Additional questionsThe following are additional questions regarding the specifics of the legislation:1, Will there be regulations around the percentage of tetrahydrocannabinol in cannabis products? Will it be written in the Act?2, What will be the maximum amount of cannabis that can be sold in retail shops and what is the rationale for that amount?3, Cannabis Advisory Authoritya, What qualifications will be required of authority members and what authorises them to sit on the authority?b, What is the process for their appointment/selection and will authority members be political appointees?c, The Cannabis Advisory Authority is set to have five representatives from different fields. However, only one representative will come from the health profession. Is there capacity to also include a mental health representative, given the likelihood of mental health consequences as well as a children’s advocate, given the priority need to safeguard youth.d, What is the rationale for determining which decisions the minister makes relative to the authority? What is the plan to mitigate risks such as external/interested parties influencing decisions, corruption, overriding of authority recommendations without basis, and other undue influences?4, The legislation grants an amount of power to the minister, seemingly without protections in place to reduce ministerial abuse, and by extension the legislation as written does not appear to offer the minister any protections for any fallout for decisions made. Will this be addressed in the rules associated with this legislation, or is this something that could be added to the legislation?5, Cabinet ministers often are not technical experts. By what provisions would the minister make decisions regarding restrictions on certain strains? What authorities would the minister consult to make such decisions?6, Section 7(2)(1) states “the authority may formulate standards and guidance to be observed by licensees”. Which body/individual would be responsible for this if the authority does not carry out this task? And under what conditions would this take place or not take place?We hope the Government and the wider community consider these questions, and more broadly the social consequences that will likely occur if legalisation takes place.• ¹Roberts B. A. (2019). Legalised Cannabis in Colorado Emergency Departments: A Cautionary Review of Negative Health and Safety Effects. The western journal of emergency medicine, 20(4), 557–572. https://doi.org/10.5811/westjem.2019.4.39935• Nicola Paugh, PhD, is the Programme Co-ordinator for the Inter-Agency Committee for Children and Families