Response from the VMD...
A follow up from The Hemp Hound Agency's article: Novel Thoughts
On the 4th of April this year, The Hemp Hound Agency released an article that asked several questions to certain government agencies who all have a level of control over cannabis based products in the UK. It's been an ongoing concern of mine that some of these agencies aren't playing fair, and that one specifically seems to be calling the shots.
One of those agencies I contacted was the Veterinary Medicines Doctorate (VMD), and this is the question I asked them:
What scientific evidence was used to determine that animals don't need, or deserve, a supplementary hemp and CBD product to allow their owners to keep their pets healthy by keeping their Endo-Cannabinoid System topped up?
Well I'm happy to say that the VMD have replied, however their reply confirms something I verified back in 2020 when I launched a related Freedom of Information Request (FOI, available below) asking for all emails between them and the HO in regards to cannabis, cannabinoids and CBD products. In the reply, the VMD all but stated that they outlawed CBD pet products without reviewing any scientific data, and seemingly at the direction of the Home Office (HO).
When I say "all but stated", what I mean is that every email from the VMD pretty much starts with "someone has asked if they can do...", and every reply from the HO is along the lines of "No chance, MoDA, MoDR". After I received the initial FOI files in 2020, I went back to the VMD, asking if they were using scientific data to determine the status of pet grade CBD supplemental products or the word of the HO, their reply was:
The FOIA gives you the right to request access to recorded information held by the VMD. The Information Commissioner’s Office guidance – “When is information covered by the Freedom of Information Act?”- is clear on this. It says a public authority is only required to provide information it already has in recorded form. The FOIA does not require the VMD to create new information or to find the answer to a question.
Surely animals who like us have an Endo-Cannabinoid System (ECS) should be able to have access to supplemental cannabinoid based products, right?
Well I'm glad you ask, because I personally think that the lack of academic evidence used to make their determination that CBD products for pets are purely medicinal in design stinks like a burst drain!
It's worth noting that the MHRA did pretty much the same thing in 2016 when they tried to to define CBD as a purely medicinal compound, but they ran into a bit of a roadblock in the backlash from consumers and stakeholders at the time.
It wasn't just the MHRA though, the FSA have been trying to restrict the CBD world at the behest of the HO for a good 3 or 4 years now, so why haven't they been able to as quickly as the VMD did in 2018? Simple, when it comes to human grade products, we all have a voice and can use it to ask questions. However, If you are furry, four legged and get walked by, or look at a human with contempt, then odds are that the human in question hasn't spent enough time at University to have anything that resembles a veterinary qualification (7 years!!!), and knows jack .... !
In a nutshell, none of us are Dr Dolittle, so we can't speak for our animals!
How many of you go out with your dog and see them eat grass, plants, and anything green without them doing it because they're looking for a little 'stomach purging'? Why do they do that when they allegedly have fully nutritionally tailored food that is 'vet approved' from your local supermarket? Simple, there's a level of memory passed down on a genetic level that helps dogs (and cats) know when they need a top-up of sorts, just like how we know when a Vitamin tablet or 2 might be handy.
That being said, not everyone lives near a hemp field where a farmer is happy for your pooch to chew on some leaves now an then, so how are you supposed to be able to provide for a pets phyto-cannabinoid needs? And if the VMD are refusing the sale of pet grade supplemental products in the UK, are they not in fact 'starving' our pets to the point where CBD does cross the line from supplemental to medicinal?
Think about that for a bit...
So, what 'is' this ban of CBD supplemental pet products? Directed, that's what it is!
If it wasn't, the VMD would be able to provide a true definition on CBD pet products, with an acceptance of the ECS in animals, and that is focused on first class evidence.
Unfortunately, and despite them having nearly 4 years to rectify this matter, they haven't addressed what I feel is a level of inequality. I want to be able to give my dog CBD supplements if I feel he needs them, and I don't think that it's appropriate for the VMD to tell me I could be fined £2000 or get imprisoned for 6 months if they haven't even had the decency to apply sound scientific knowledge to their reasoning on why I can't give my dog a supplemental product. Pointing at guidelines does not answer anyone's questions, in fact doing so almost suggests that the VMD are holding your pet's ECS to ransom, just like the HO do for access to medicinal cannabis products as a whole.
Anyway... here is the VMD's reply to my question, and my thoughts are posted next to each comment:
The VMD has published a statement on its position regarding veterinary medicinal products containing Cannabidiol.
We consider that products containing CBD fulfil the following definition of a veterinary medicine in the Veterinary Medicines Regulations (VMR) by virtue of the effects they have: “any substance or combination of substances that may be used in, or administered to, animals with a view either to restoring, correcting or modifying physiological functions by exerting a pharmacological, immunological or metabolic action, or to making a medical diagnosis.”
Really??? On that basis, would I be going to jail for just feeding my pets then?
And what about "by virtue of the effects", surely by virtue of the ECS, that cannabis has been accepted as a food source for animals over millennia, and that there's a human supplemental market, there should in fact be an animal supplemental market as well, right?
By this definition, the VMD have blurred the lines between preventative medicines (foods and supplements) and curative medicines. As a pet owner, I think that's a bit off, especially as this definition does not include 'maintain' as a keyword. I want to 'maintain' my animals ECS, which requires a supplemental product, but I can't, because they're outlawed for pets by the VMD...
The VMD has not banned the use of CBD as your article suggests, however due to the medicinal status of CBD, products for use in animals require a marketing authorisation before they can be sold or supplied in the UK.
Rewind, my selecta! The VMD has said I'm wrong, whilst confirming I'm right. They have banned/outlawed/prohibited/disallowed/forbid supplemental products containing CBD due to them 'believing' that CBD has medicinal status. BUT, they have not in anyway pointed out where, or from whom, that 'medicinal status' came from...
More information on how to apply for a marketing authorisation and the supporting data requirements is available on gov.uk.
As there are currently no CBD products authorised in the UK for veterinary use, CBD must only be obtained via a veterinary surgeon, who may prescribe a legally sourced human CBD product under the provisions of the prescribing cascade.
This statement says to me that supplemental products are totally off the table, but then it also suggests that some veterinary surgeons could be aware of the ECS. If there are, then there's no way on earth that any of them could ethically argue against the need for a pet grade supplemental CBD product, which is free (without penalty) to access for pet owners across the UK.
CBD, as a food, is known to have similar effects to other foods whilst also delivering essential Phyto-Cannabinoids to help maintain the ECS. In its basic sense, it can help regulate core bodily functions such as mood, memory, appetite and the sleep/wake cycle (glossy coat and shiny nose). I will happily debate anyone who thinks these bodily functions are best served with medicines over nutritional input!
So why on earth should I restrict my pets access to CBD products past a supplemental need, and why is it that I can only access cannabinoid products for my pets when their need is medicinal in context, meaning any prescription will overpriced due to consultation charges with a veterinary surgeon who ultimately prescribes a human grade product via the cascade route?
I don't know about you, but there's no way I'm paying over £100 for a £30 product!
Administration of an unauthorised product containing CBD without a veterinary prescription is an offence under Regulation 8 of the VMR.
Her Majesty's Butlins for 6 months, anyone? What about 'donating' £2,000 to her Government's coffers?
According to the Animal Welfare Act 2006 Section 9, all domestic animals have the legal right to:
live in a suitable environment
eat a suitable diet
exhibit normal behaviour patterns
be housed with, or apart from, other animals
be protected from pain, suffering, injury and disease
By outlawing pet grade CBD supplemental products, the VMD are restricting owners from obliging parts 2 & 5. This is exactly the same with the Human Rights Act 1998 (Article 2: The Right to Life) vs the Misuse of Drugs Act 1971. We, as do most of our pets, have an ECS, which means that we should have a fundamental right to be able to top that ECS up in anyway we see fit, which is a right that should be extend to pets and their owners with supplemental products, to ensure that owners are upholding the legal obligations to their pets.
Companies supplying CBD products for human use in line with the requirements of the Medicines and Healthcare products Regulatory Agency must not indicate or recommend their products for use on animals.
I can't grumble at this as it goes, because CBD products come in all shapes and sizes, as do animals. What is prescribed may not have that 'je ne sais quoi-nnabinoid' content that fills the needs of the animal that it's signed to, and to legally make any medicinal claim on a product opens the crazy (Pharma) door to a supplemental focused company's products. However, if companies could sell supplemental CBD products for pets, which in most cases are identical in makeup to most human grade supplemental products, there wouldn't be that much of a need to look for cannabinoid based products in a medicinal sense, and to pay through the nose for a human grade product that in normal circumstances would be illegal for anyone to administer.
To round up...
I want to thank the VMD for replying, and I would like to think they can see past some of my frustrations, which are shared by many.
But I think it's past the point for honesty with the consumer here, the VMD need to (respectfully) look past the guidelines, and explain to every pet owner why they can't provide their animals with a CBD food supplement product to maintain their ECS, and to explain why they believe that CBD products are purely medicinal in focus, when there's over 1.2 million people in the UK who take CBD food supplements to maintain their ECS.
This will be sent to the VMD out of courteously, with a further invite to comment.