MEDICINES CONTROL COUNCIL - mccza.com

1 cannabis Growing of cannabis for medicinal use March 2017 Page 1 of 32 MEDICINES CONTROL COUNCIL CULTIVATION OF cannabis AND MANUFACTURE OF cannabis -RELATED PHARMACEUTICAL PRODUCTS FOR MEDICINAL AND RESEARCH PURPOSES This document highlights the quality, security and standard operating procedures relating to the cultivation, manufacture and use of cannabis and related pharmaceutical products for medicinal and research purposes and also includes the minimum requirements to be in place should an application be submitted to the MEDICINES CONTROL COUNCIL and the Department of Health for consideration. This guideline represents the MEDICINES CONTROL COUNCIL s current thinking on the measures required to be in place to ensure that quality products are cultivated and harvested and made available to patients when prescribed by an authorized prescriber / physician. COUNCIL and the Department reserve the right to request any additional information and may make amendments in keeping with current knowledge.

2 First publication for comment March 2017 Closing date for comment 30 March 2017 Use the Guideline Comments Form1 available on the MCC website when submitting comments. Submit comments in hard copy to the Registrar of MEDICINES , Civitas Building, Thabo Sehume Street, Pretoria. Alternatively, e-mail to Mr Griffith Molewa at DR JC GOUWS REGISTRAR OF MEDICINES 1 Guideline Comments Form Dec08 cannabis Growing of cannabis for medicinal use March 2017 Page 2 of 32 TABLE OF CONTENTS Page 1 INTRODUCTION .. 4 2 LEGAL STATUS OF cannabis .. 4 3 APPLICATIONS FOR GROWING OF cannabis FOR MEDICINAL PURPOSES .. 6 4 PERSONNEL REQUIREMENTS .. 6 Suitable Fit and Proper Requirements: Applicant .. 6 Personnel .. 7 Personnel Training .. 7 5 SECURITY REQUIREMENTS .. 8 Mandatory Requirements .. 8 Risk of Diversion .. 9 Key Security Measures .. 9 Transportation of cannabis .

3 10 6 BUILDINGS AND FACILITIES .. 11 7 EQUIPMENT .. 11 8 PRODUCTION AND MANUFACTURING .. 12 Seeds and Labelling Material .. 12 Cultivation .. 12 Harvesting .. 13 Packaging .. 13 9 STORAGE AND DISTRIBUTION .. 14 10 SPECIAL PROVISIONS FOR THE PRODUCTION OF cannabis INTENDED FOR PROCESSING INTO A STANDARDISED HERBAL medicine .. 14 11 DOCUMENTATION .. 15 Record Keeping and Reporting .. 16 12 GOOD MANUFACTURING PRACTICES (GMP) RELATED TO MEDICINAL cannabis AND RELATED PRODUCTS .. 17 Compliance with Good Manufacturing Practice (GMP), Good Laboratory Practice (GLP) and Good Agricultural and Collection Practices (GACP) .. 18 Quality and Safety .. 18 13 COMPLIANCE AND ENFORCEMENT .. 19 cannabis Growing of cannabis for medicinal use March 2017 Page 3 of 32 TABLE OF CONTENTS Page 14 ACCESS TO UNREGISTRED cannabis FOR MEDICINAL USE FOR PATIENTS .. 20 15 REFERENCES .. 21 16 UPDATE HISTORY .. 22 ANNEX A: SECURITY.

4 23 ANNEX B: RECORD KEEPING AND REPORTING .. 30 cannabis Growing of cannabis for medicinal use March 2017 Page 4 of 32 Return to ToC 1 INTRODUCTION The MEDICINES and Related Substances Act, 1965 (Act 101 of 1965) ( the MEDICINES Act ) mandates the MEDICINES CONTROL COUNCIL (MCC) to regulate the availability of quality MEDICINES which are safe and efficacious for their intended use. This mandate requires the MCC to apply standards for the manufacture, distribution, sale and marketing of MEDICINES , medical devices and Scheduled substances. In considering the availability of any medicine for human or animal use, the MCC assesses the balance between its benefits and risks. 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. In terms of Sections 21 and 22A(9)(a)(i) of the MEDICINES Act, medical practitioners can apply to the MCC for permission to access and prescribe unregistered MEDICINES , which may include the substance cannabis , when intended to treat their patients.

5 cannabis products intended for medicinal purposes may thus be made available, in exceptional circumstances, to specific patients under medical supervision. Only registered, authorised prescribers may apply for authorisation to prescribe a medicine for a patient and authorisation is dependent on the submission of an appropriate dosage regimen, an acceptable justification for the proposed use, and regular reporting to the MCC. To date, patient access to unregistered pharmaceutical products containing cannabinoids has been enabled by the MCC through importation of these products. In order to ensure availability of standardised quality-assured medicinal cannabis grown locally for the manufacture of suitable pharmaceutical products, the Department of Health and the MCC may permit the cultivation of cannabis solely for medicinal and research purposes.

6 This framework, developed in consultation with the Department of Agriculture, Forestry and Fisheries (DAFF), is intended to CONTROL the cultivation, production and manufacturing of cannabis products for medicinal use in South Africa. Licensed domestic cultivation of cannabis for medicinal use is aimed at ensuring sufficient local supply for medical, scientific and clinical research purposes and the implementation of CONTROL measures necessary to prevent diversion and misuse, as well as to ensure patient safety. This guideline provides information to Applicants relating to the standards required for the production and processing of cannabis as a herbal starting material and identifies the critical production steps that are needed to ensure a product of reliable and reproducible quality. The MCC encourages and supports scientific and clinical research in order to further contribute to the evidence base for cannabis -containing medicinal products.

7 All studies involving medicinal cannabis for clinical or scientific research purposes require a permit issued by the Director-General of Health in terms of Section 22A(9)(a)(i) and prior approval by the MCC. Approval by an independent research ethics committee may also be required. The detailed procedure and requirements for research are available at 2 LEGAL STATUS OF cannabis International Treaties South Africa is a signatory to the United Nations Single Convention on Narcotic Drugs (1961) ( Single Convention ), which aims to combat drug abuse and trafficking through coordinated international cooperation directed at limiting the possession, use, trade, distribution, import, export, manufacture and production of narcotic drugs exclusively for medical and scientific purposes. The Single cannabis Growing of cannabis for medicinal use March 2017 Page 5 of 32 Return to ToC Convention therefore provides an international framework that recognises the medicinal value of narcotic drugs (including cannabis ) and ensures that these are available for such purposes while preventing their abuse and diversion.

8 As a signatory to the Single Convention, South Africa is committed to comply with its obligations by controlling medicinal cannabis cultivation and reporting to the International Narcotics Drug CONTROL Board (INCB) on volumes of production and manufacture. These obligations require South Africa to minimise the risk of diversion of cannabis and reserve its use for medical and scientific purposes only. Under the MEDICINES Act, and in line with the Single Convention, cultivation, production, manufacture and use of medicinal cannabis products may only occur through a licence issued by the MCC and a permit issued by the Department of Health. These conditions allow Government to limit quantities of cultivated and manufactured products based on quotas from the INCB, thus meeting a key obligation of preventing accumulation of cannabis material. Legislative Framework The MEDICINES Act allows for the acquisition, use, possession, manufacture and supply of medicinal use cannabis in order to provide a medical practitioner, analyst, researcher or veterinarian therewith for the treatment or prevention of a medical condition in a particular patient, or for purposes of education, analysis or research, provided that a permit is obtained from the Director-General of Health.

9 Consumer and patient access to MEDICINES and Scheduled substances in South Africa is dependent on the Schedule of the substance. cannabis is a prohibited substance listed under Schedule 7 of the Schedules to the MEDICINES Act. However, MEDICINES which have been registered by the MCC containing cannabis , cannabis extracts, and cannabis -derived substances such as cannabinoids which are intended for therapeutic use, may be rescheduled and listed in Schedule 6 to align these products with the scheduling status of other restricted MEDICINES . This measure allows patients to access medicinal cannabis products by means of a prescription issued by a medical practitioner where the product may be dispensed at pharmacy level. cannabis products that are not registered by the MCC will remain in Schedule 7. In addition, the MEDICINES Act allows the MCC to issue a licence to manufacture either a medicine or a Scheduled substance (Active Pharmaceutical Ingredient/API).

10 Section 22C(1)(b) of the MEDICINES Act enables the cultivation and manufacture of Scheduled substances and ensures the required oversight of the MCC in regulating these activities. This allows the MCC to license growers of cannabis when intended for medicinal use and enables regulatory oversight in a way that is compliant with South Africa s international obligations. The legislative framework addresses three regulatory aspects: Authorise cannabis production domestically, for medicinal and research purposes. Satisfy the requirements of South Africa s international obligations, under the Single Convention. Align the access of cannabis for medicinal purposes with that of other controlled MEDICINES . cannabis is a prohibited narcotic substance in South Africa, and cultivation for any purpose other than that explicitly allowed for through the licence and permit system under the MEDICINES Act, is a criminal offence.