Recently I dissected the MHRA's yellow card list for CBD, and I have to be honest, there wasn't anything great to say about it.
In a nutshell, an article was published in regards to the UK hemp and CBD industry ridiculing the list, but I thought that only the basics had been covered, so I decided to dig deep, and with as much surgical precision as I could muster, I broke down many of the points that I thought raised the most questions.
What I found was a list that I believe hides the identity of the products that are responsible for most if not all the listed reports in plain sight, whilst distancing them at the same time by suggesting the potential for reports for other companies products, even though there's a question mark over why those companies are included on the list in the first place.
I covered some of the further issues with that data through a series of posts on LinkedIn, to which someone said, "If you want a laugh, check out the data for THC", and now I have, and lets just say, I'm glad I was sitting down when I did.
The Cannabis Sativa list is supposed to be representative of high THC bud and extracts, this can be determined by the inclusion of Skunk outside of Cannabis Sativa, inside of the list... for Cannabis Sativa. But CBD companies are also named, just as in the CBD list, and that's just a fraction of what's wrong with it.
Why is Skunk on there though, why has it been included in a list for adverse reactions to Cannabis Sativa as a medicine? I mean, GW Pharmaceuticals grow Skunk, but I don't see their products on the list. Equally, we don't see any of the pharmaceutical brands who are supplying medicinal cannabis products named on the list either, or the strains they supply, but they are on the CBD list (Not strain names though), so work that one out!
Here's a link to the MHRA's yellow card list for Cannabis Sativa, take a look, and let me take you through the points that show it's not worth the pixels that you see it on.
1 - Associated brand names
The Cannabis Sativa list is supposed to be representative of high THC products, so why are Becarma, Blessed CBD, CBD Brothers, Earthly Body, Healthspan, Natures Aid, Simply CBD and Skin Salvation on this list?
In fact, Becarma should be screaming from the hill tops, because they've been directly named in the 'Single Constituent Brand Names' section with Cannabis Sativa [not otherwise coded] and Skunk, as well as being in the same section on the CBD list, but they don't make medicines, a doctor is highly unlikely to prescribe their supplemental products as a medication, and somehow, I doubt that a pharmacist would report a supplemental grade product to the MHRA as well, knowing that food products are the domain of the FSA.
This is only half of the companies named on the CBD list.
So why are Becarma, or any other CBD company for that matter, named on the Cannabis Sativa page, and the CBD one for that matter? The reason for this question will become evident as we go on from here.
Exactly what is this list for Cannabis Sativa supposed to 'represent'?
That's more a question for the MHRA, see this link will take you to the list for CBD products, and in the associated brand names, you'll see a lot of products that are more THC than anything else.
You'll see Becarm of course, but you'll also see Epidiolex and Sativex, and the maker of those products has a well known association with Skunk #1, so one question is why, at least in the case of the latter, aren't GW Pharmaceuticals products on the Cannabis Sativa list?
Bare that in mind as you read through
2 - Reported reactions
That is from 1972...
Now before we look further into those stats, we should look at the history and intent of the Yellow Card Scheme.
The Yellow Card Scheme is an integral part of this monitoring. Developed by Bill Inman in 1964, it is the UK system for collecting information on suspected adverse drug interactions to medicines and vaccines. Originally just for doctors, it was extended to pharmacists in the late 1990s and is now open to members of the public.
The absolute long and short of it can be traced back to the impacts of Thalidomide, but there you have it, these lists are intended for medicines and vaccines, not food supplemental products.
So let's look at the first Adverse reaction back in 1974 - It's signed off as 'Multiple congenital abnormalities', and immediately I'm confused.
The recommended definition of multiple congenital abnormalities is "a concurrence of (1) two or more (2) different (i.e. different localized errors in morphogenesis) (3) major congenital abnormalities in the same person"
Definition of multiple congenital abnormalities - PubMed
Are you buying that? I'm not, with everything we know about cannabis, I find it hard to believe that 1970's weed would leave you close to multiple organ failure. Yes there were some products with cannabis extracts still available in pharmacies past 1972, but only a doctor could have sign that report off, so we're talking about a report for a legitimate product, or one that comes off the back of a clinical trial.
But...
There is another possibility, and that is that the report itself is a fabrication. It is dated one year after the Misuse of Drugs Act came out after all.
Is there a question mark over the credibility of this list already?
Well moving on doesn't make it any better, after 1972 we have four more reports up until 1983, and all are labelled under 'Congenital, familial and genetic disorders', and the sub-categories are:
Heart disease congenital (2)
Congenital musculoskeletal disorder of limbs (1)
Congenital musculoskeletal disorder (2)
Genitalia external ambiguous (1)
"Genitalia external ambiguous"?!?! That is insane!!!
The reports I highlighted so far have one thing that bind them, they focus on conditions that you're most likely born with, and as with the rest of the list, are misrepresented as being reactions to Cannabis Sativa.
Is it a deliberate move though? Well yes, that's why Skunk is named and nothing else that would indicate the list to be genuine, and I believe it's been done to protect one company.
And here comes a big indicator of that being a strong possibility
Reactions attributed to Cannabis Sativa from '93 to the current day
Between '72 and '97, there were 8 reports that catalogued 11 reactions, and none were fatal. Then we get to 1998, and that's where Cannabis Sativa starts to get a little malicious.
It's the year that GW came into life, having been licensed to grow cannabis in 1997. It's also a year were a very interesting report was filed. It's the first report that lists a reaction under 'General disorders and administration site conditions'.
Looking at all the documented reactions paints a very interesting picture, but I would invite you to check that report from 1998 out yourself (Date bar on the left of the list), because it almost suggests that someone was given a really large spliff, and then prodded and poked by people in white coats for an hour or so.
But as there were no other companies in the UK at the time that were focusing on cannabis, there's an extremely high chance that those in white coats were employed by GW Pharmaceuticals
They received a research license in 2001, and in 2002 we have our first fatalities from Cannabis Sativa, despite there being zero in the 30 years the list had been open beforehand, and you've got to ask if it's around this point that 'Skunk' had been added to the list.
Reaction reports from 2001-2023
159 reports (out of 168 total from '72), 104 for men, 44 for women, and 11 that were classified as 'sex unknown', which gets me a bit, but I'll touch on that later.
There's 33 fatalities that occurred during this timeframe, and how they've been catalogued more than raises an eyebrow. Below is the first point that drew my attention, and I think for fair reasons.
Does that sound like 3 people dropped down dead after getting a £10 bag of Skunk to you? Equally, can you call a dealers or any of the illicit cafe's out there 'administration sites'?
Cannabis and fatalities have no place in the same sentence, let alone next to each other. That's in a consumer or recreational sense anyway, however when the context switches to medicinal, it seems that anything's possible.
Remember, up until recently only doctors and chemists could submit a report to the yellow card list for adverse effects, and even though the public are able to now, reporting must be on the basis of reactions from medicines or vaccines.
And on a side but slightly related topic, did you know that GW tried to dip their toe in the vaccine market recently?
But back to that list, and I want to look at the figures for psychosis related reactions. Between '72 and '00, two reports were submitted, so if this list really did reflect cannabis use be it by cannabis sativa [not yet coded] or 'Skunk'... where's the 'Reefer Madness'?
Don't let the CBD companies listed up top fool you, Cannabis Sativa in this case is supposed to represent high THC cannabis, hence why 'Skunk' is named, but then that just reinforces the absurdity of this list, as well as that for CBD products.
But there are cases of 'Reefer Madness' on there - from the point of GW getting their research license in 2001, reports involving psychosis went from those 2 in 26 years, to 63 in 10 years.
16 fatalities out of the 33 documented are attributed to psychosis
Now here's the kicker, GW Pharmaceuticals have been looking at psychosis for some time, it stands to reason. They have multiple patents that focus on schizophrenia, mood control and depression, and you know that psychosis is a small step away from there.
Recently it was announced that GW was supplying Epidiolex for a global study on CBD vs Psychosis, but a portion of the CBD present may have been harvested from their Skunk plants, and since they have been undertaking R&D, psychosis events attributed to Cannabis Sativa have gone from one every 13 years, to one nearly every 2 months.
Tell me that raised an eyebrow!
Just to cover my backside here, I'm not saying that all of the events reported are associated with Sativex, Epidiolex and whatever other preparations have been trialled and tested so far. I believe there's an overflow with the CBD list, which is why Sativex and Epidiolex seem to be hidden inside a list of food supplemental businesses on there.
So then that raises another question, are all the reports on the Cannabis Sativa and CBD pages all related to products and R&D from GW?
I can't answer that question, but I have my suspicions
I've waffled on in this section long enough, so all I'm going to say is this. If you have an adverse reaction to a food product, you would tend to think that you would be directed to the FSA, so the inclusion of CBD companies on a list that is supposed to cover medicines and vaccines raises many questions. Is their presence on the list more to hide GW in plain sight, and is 'Skunk' on the Cannabis Sativa list a brilliant plan (I mean, fair play... ish) to protect their IP by demonising the source which they own the genetics to?
We can only suspect the answer to the first question, but the second is a firm yes, and they're allowed to protect their IP because of the 1941 Pharmacies and Medicines Act, which banned herbalists from making claims on their wares whilst allowing the pharmaceutical companies to rip the plants apart and patent preparations which include their active compounds.
Remind me, what was one of Novel Food's side shows, separating cannabis from cannabinoids?
Now... I've just dropped the NF bomb in an article that focuses on the MHRA's yellow card list, and you might be asking why that's the case.
Essentially, Novel Foods, the CBD and Cannabis Sativa yellow card lists represent certain elements of control over cannabis and cannabinoid based products. They also have something in common, and that is in redactions.
Novel Foods itself is based off an Article 4 Determination published in 2020, the document related to this specifies that it's for CBD isolate in MCT oils, but it's the ruling that affects all products regardless of carrier oil or format, and regardless of whether it's a full or broad spectrum product and not isolate based.
Whilst the ruling was published in 2020, EFSA gave an opinion in 2019 that set the tone. The document in question is below, and straight away you can see the redactions I've referred to.
The top one is 37 characters long, which could be 'UK Home Office and GW Pharmaceuticals'... or, it could also be 'GW Pharmaceuticals and UK Home Office', that fits as well.
Then there's the second redaction, 19 characters long... Epidiolex/Epydiolex anyone?
Am I right? Who knows, you might well be reading the ramblings of a mad man, but then the MHRA's CBD list is a redacted document, and the one for Cannabis Sativa seems to be as well, so who's being hidden not just from the public, but also from the hemp and CBD industry as a whole?
Who had interests in cannabinoid based products before we left the EU? One company, just give me one other company than GW and I'll crawl back in my hole.
3 - The 'unknowns'
Whether it be through a medical trial, details of a prescription, medical report or whatever, you'd like to think that you would be able to determine the sex of the person who has been reported as having an adverse reaction, right?
Well if 7 of the 11 'sex unknown' happened to be 'age unknown', you'd be well within your rights to ask questions.
I don't get it, you'd think that reports from doctors or pharmacists would come with all the appropriate information, and age plus sex is just that. Equally, why are the MHRA allowing incomplete records to be added to the yellow card lists?
We don't have it on the Cannabis Sativa list, but on the one for CBD, there are 2 fatalities listed as 'sex unknown', which really raise questions about the nature of reporting, and the reports themselves.
This is not a new frustration for me, but it's reinforced by the 7 reports on the Cannabis Sativa list that are both age and sex unknown. Recording death with sex unknown suggests either the body was mutilated, which would then raise questions on whether Cannabis Sativa was the true cause, OR, the files are incomplete, which raises questions on the validity of the reports and why they have been included.
In total over the Cannabis Sativa and CBD lists, 64 reports are for persons who're defined as 'sex unknown', and 54 of them are 'age unknown'.
4 - Skunk can give you the flu! (And other questionable reports)
Yep, this might be a Hemp Hound exclusive. There are 4 reports here, which I suspect aren't well known, so I'm chuffed that I'm possibly the first to draw your attention to these very worrying reports.
'Worrying' because I believe this further shows a serious misrepresentation of Cannabis Sativa, I mean come on, flu?!?! Flu and Covid enter the body in the same way, so checking out the multiple studies that show how CBD at least prevents Covid will suggest that this is a bizarre occurrence.
And yeah, chuffed, because if that didn't make you nearly shoot tea out of your nose, I don't know what will... although there is more to come, just so you know.
Haemolytic anaemia - A blood condition that occurs when your red blood cells are destroyed faster than they can be replaced.
There was one case of this in 2021, and it's insane to see it up there. Up until five seconds ago I thought it was a hereditary condition, however it can be induced by sickle cell anemia and thalassemia, but both happen to be hereditary conditions...
One thing to note is that this report is one of the 7 that were someone is labelled as sex and age unknown.
Cardiac arrest - I don't think I need to explain that one for you.
3 reports, one of which was fatal. I will happily bet 20p that none of those reports are associated to the CBD companies named on that list, and with the amount of other reports associated with Cardiac Disorders (22, 3 fatal), they are definitely reports associated to clinical trials, and who's the only one with a history of R&D in the UK on cannabinoids derived from Skunk (and others)?
Tinnitus - The perception of sound that does not have an external source, so other people cannot hear it. Tinnitus is commonly described as a ringing sound, but some people hear other types of sounds, such as roaring or buzzing.
Now this is something I know about - Tinnitus is caused by the destruction of nerve hairs on the basilar membrane, which can be found in the cochlea, and they don't grow back. So how is Skunk causing that?
There's a similar report on the CBD list, and you have to ask if someone is putting Cannabis Sativa in peoples ears. Equally with tinnitus, a question needs to be asked on if there was a level of aftercare to determine whether it was permanent, because if it wasn't, it isn't tinnitus!
Treatment non-compliance - This refers to the non-use or discontinuity of the treatment process and inattention or failure to follow the prescribed treatment by the patient.
Say what now???
Mind you, 'treatment' easily suggests that Skunk has no place on this list, unless of course 'someone' has been doing clinical trials on Skunk as well as preparations derived from it.
Infections and infestations - This is another topic I don't need to explain.
Past the 4 reports for flu in this area, others need to be highlighted: Infection (Pathogen unspecified, 1), Pneumonia aspiration (1), Sepsis (1), Sinusitis (1), Disseminated tuberculosis (1), Acute hepatitis C (1), Post viral fatigue syndrome (1), and Viral infection (Unspecified, 1)
That's a bit scary don't you think? Sepsis and Hepatitis C are the ones grabbing my eye the most, but then they're all horrible, and none up until this list have ever been associated to Cannabis Sativa in the sense that it could caused these conditions. In fact the opposite is true in that Cannabis has been used to help against the symptoms of some of these conditions, and that was from before GW was formed and functioning in 1997.
Let's up the game a bit and delve in to a category called 'Injury, poisoning and procedural complications'
Below is the sub-category of 'Poisoning and toxicity'
So you can get alcohol poisoning from cannabis then, am I reading that right?
Poisoning deliberate? That's an interesting one, but toxicity to various agents really grabs my eye. Surely that suggests an allergic reaction of sorts to whatever the Cannabis Sativa is carried in, and not the Cannabis Sativa itself, right?
Then there's this...
There is a distinct possibility that the fatality above is from products associated with GW, and that scares the hell out of me before I consider that there's another 32 recorded fatalities.
Cannabis has never killed anyone, in fact it's impossible to overdose on it, unless of course it's in extremely refined cannabinoid rich medicinal preparations that are being chucked down your throat.
Only 12 reports of reactions have been logged due to cannabis inhalation since 2010, and whilst there is the possibility for some of them to be by using self administered extracts, there's no fatalities there, and none of the reports are logged as Injury, poisoning and procedural complications.
There are 12 reports though in that section under 'Oral Use' though, and 140 were the route to administration is logged as 'unknown', which includes 32 of the 33 fatalities.
Then there's 9 reports under 'Routes with few reports', one of which is the other fatality.
Routes to administration, routes with few reports... So why are CBD brands named in the list?
5 - Transplacental...
Passage through or across the placenta. Transplacental usually refers to the exchange of nutrients, waste products, drugs, infectious organisms, or other substances between the mother and the foetus.
HIV.gov
Ocular disorders congenital NEC (1), Neurological disorders congenital NEC (2), Strabismus (1), Developmental delay (1), Drug withdrawal syndrome neonatal (1), Exposure via breast milk (1), Foetal exposure during pregnancy (2), Metabolic acidosis (1), Somnolence (1), Structural brain disorders NEC (1), Poor weight gain neonatal (1), Neonatal disorder (1), Umbilical cord around neck (1), Renal impairment (1)... and that's from six reports, but three of them are labelled as 'sex unknown'.
Do you see a problem there, or is it just me? Let's just skirt around the fact that 50% of the reports fail to list very important details, some of the above can easily be influenced by other factors outside of taking cannabis products through pregnancy.
Then there's the Endo Cannabinoid System (ECS), the fact that women naturally overproduce Endo-Cannabinoids when they're pregnant, to which are passed on through breastfeeding to help stimulate the child's own immune system and ECS. In essence, mothers transfer a level of cannabinoids, so why on earth are we seeing 'Drug withdrawal syndrome neonatal'?
Cannabis sativa in its raw sense would never cause that, or any of the other conditions listed above, neither would a food grade supplemental product. A medicinal product though?
Lets wrap this up...
Is this list to demonise skunk, but also protect the company who uses Skunk to create their products?
Think about it, if Sativex and Epidiolex were listed on there, suspicion over the sources of the fatalities would raise questions, so you say 'Skunk' on the Cannabis Sativa list whilst distracting people by adding some CBD brands, and then hide Epidiolex and Sativex on the CBD list (because they have to be seen somewhere) in amongst more CBD companies as there's an active market to further demonise to ensure the maximum potential of profits for the shareholders.
I say demonise, and I think that's justified. The reports on the Cannabis Sativa page misrepresents that very plant massively, as does the CBD list misrepresent supplemental focused products. It's like the MHRA are continuing on the Skunk narrative, which considering they're medicinally focused raises questions. Skunk is the domain of the Home Office after all, who have a 20+ year strong working relationship with GW pharmaceuticals.
It's also like they're trying to influence the CBD food supplemental industry by misapplying questionable data to it. Is that sour grapes? They tried to commandeer CBD in 2016, they've stated in the past that they weren't quite happy about that failing to happen, and up until this day, they reserve the right to define CBD as a purely medicinal compound.
One wonders whether the two list are to allow for that eventual move to claim that which is destined for them in accordance to the TIGRR report...
But if that were to happen, we would then see exactly where these fatalities connected to Cannabis Sativa are coming from, because if any came from CBD products, you can be sure that there wouldn't be a CBD food supplemental industry.
In fact, if we go back to the CBD list, you'll see that the first recorded fatality was in 2006. There was no CBD industry back then, not even in the US, so what product did that person die from?
That by the way is something that devastates me, has someone turn the plant into a potential killer? 33 fatalities... Those reports start in 2002, one year after GW Pharmaceuticals were awarded a research licence.
Coincidence? I doubt it, but then there were zero fatalities before GW Pharmaceuticals started trials, and that's over 30 years since the Cannabis Sativa list was created
So again, what is 'this' list? Well it's blatantly a lie, but it's a lie that hides an ugly political truth.
You noticed that no other cannabis strains are named other than Skunk, but we do see the words 'Cannabis Sativa [not otherwise coded]? Well the simple question is why has no other strain been coded?
There's enough of them after all, but for some reason the UK Government only chooses to acknowledge Skunk, a strain that faded into obscurity nearly 20 years ago, not long after GW Pharmaceuticals brought the rights to the genetics.
It's not just them though, every politician refers to Skunk in a way that seems either pre-planned, or shows them to be embarrassingly out of touch.
It's not the latter though, there's something more organised going on behind the scenes than most people would care to accept. Skunk on a list that charts adverse reactions to medicines and vaccines is proof of that, as is the dominance of GW and their lab reports both domestically and abroad.
And about those vaccines?
Far be it for me to just say "I suspect that you've killed someone" without something a bit more solid than a redacted list, but there's more on that list than I have time to cover.
What does the above show? Well quite simply, someone has been preparing Cannabis Sativa into an injectable format, and you have to ask why?
Is it GW Vaccines? Maybe that's not the right question, maybe we should be asking whether anyone else outside of GW has explored the potential of injectable Cannabis Sativa.
Do you remember me telling you that a large amount of reactions have the route to administration labelled as 'unknown'? These three reactions are in that number, as are 32 fatalities outside the one whose route to administration is marked as routes with few reports.
So at least with these three, they are far from being unknown in regards to the route to administration, which to me further reinforces that the MHRA's yellow card list for Cannabis Sativa is a list of half truths designed to protect GW Pharmaceuticals, and that the UK Government is a party to that action.
Clinical trials can come with reactions and tragedies, but the government and MHRA need to be honest with any report that is added to the yellow card list, AND they either need to define Skunk, or admit to who 'uses' it within their R&D.
For more information on The Hemp Hound Agency, email cefyn.jones@hemphound.co.uk
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