On Monday, July 28, 2025 from 10:00 AM to 12:00 PM, the California Department of Public Health will be conducting a public hearing on proposed hemp rules that are of concern for patients in the state (Zoom link). Written comments can also be emailed to regulations@cdph.ca.gov prior to the hearing. Read below for San Diego ASA’s comment on the proposed rules.
To Whom It May Concern,
As the San Diego chapter of Americans for Safe Access—a national nonprofit dedicated to ensuring safe and legal access to cannabis for therapeutic use and research—we respectfully urge the California Department of Public Health to amend DPH-24-005 to include the following exception:
Exception: Subsection (1) shall not apply to full-spectrum hemp-derived CBD oil tinctures intended for therapeutic use with that contain less than 0.3% total THC by dry weight with a ratio of 20:1 CBD:THC or higher and that are: clearly labeled as “for therapeutic use only,” not marketed to minors, and accompanied by a certificate of analysis confirming compliance with federal limits.
We acknowledge and share your concerns regarding public health and the potential for underage access to hemp-derived cannabinoid products. However, it is essential to recognize that many patients depend on full-spectrum hemp-derived CBD products to manage chronic conditions and improve their quality of life.
In California, fewer than half of all jurisdictions allow legal cannabis businesses, and taxes on cannabis products can exceed 30%, leaving many patients without affordable or practical access to state-regulated medical cannabis. Compounding the problem, patients often need high doses of CBD that are not readily available through licensed dispensaries. As noted by Dr. Bonni Goldstein, some individuals require up to 1,600 milligrams of CBD per day—far more than what is typically offered in dispensary products, which rarely exceed 600 milligrams per bottle. For these patients, full-spectrum hemp-derived CBD products remain one of the few accessible and effective options for treatment—offering life-saving therapeutic benefits without posing significant risks to public safety or undermining the regulated cannabis market.
We urge you to consider this narrow, patient-focused exception to protect access for those who rely on these products for legitimate medical purposes.
Thank you for your time and consideration.
Sincerely,
Shelby Huffaker, MPH
Chair, San Diego Chapter of Americans for Safe Access
About the San Diego Chapter of Americans for Safe Access
The San Diego Chapter of Americans for Safe Access (ASA) is the local chapter of the largest national member-based organization of patients, medical professionals, scientists, and concerned citizens promoting safe and legal access to cannabis for therapeutic use and research. ASA works to overcome political and legal barriers by creating policies that improve access to medical cannabis for patients and researchers through legislation, education, litigation, grassroots actions, advocacy, and services for patients and their caregivers. ASA has over 150,000 active members with chapters and affiliates in all 50 states. San Diego ASA helps protect the rights of cannabis patients. We are working to change local and federal policy to meet the immediate needs of patients as well as create long-term strategies for safe access and programs that encourage research.
