Dr. Benedikt Fischer is a senior scientist, Institute for Mental Health Policy Research, CAMH and psychiatry professor at the University of Toronto
Last week, the federal government tabled long-awaited legislation to legalize and regulate non-medical cannabis use and supply in Canada. Under the proposed cannabis legalization plan, the provinces will be mandated and get to decide and design their respective cannabis retail distribution systems.
This is, by no means, a trivial responsibility. Rather, getting the design of retail models for cannabis right will be crucial for whether legalization will work for or against the paramount goal of furthering public health.
So, what specifically should the cannabis retail distribution model look like in Ontario? Many options have been bandied around – and, of course, few are free of political or economic agendas (or both), as the stakes are high in both these realms. Given the projected size of the economy of recreational cannabis use, not only will a substantial amount of profit be drawn at the retail level – the retail system's design will also decisively influence demand and consumption levels.
There are several options for a public health-oriented cannabis distribution system in Ontario. We believe that the LCBO – the publicly run provincial monopoly for alcohol distribution – should be at its core. This is for several reasons. The LCBO has an existing province-wide infrastructure of outlets; it is an operation designed for and experienced in the handling of a psychoactive substance (alcohol); and it operates under a social responsibility mandate. Hence, it is a ready-to-go system well designed for the safe and sensible distribution of cannabis products.
There is one caveat, however, from a public-health perspective: LCBO outlets are essentially specialized supermarkets for alcohol, with products on colourful display, available on a self-serve basis, even combined with advertising, promotions and discounting. None of these distribution features are compatible with public health-oriented cannabis distribution. Rather, as consistently advocated elsewhere, distribution of recreational cannabis ought to be free of advertising, with pricing solely driven by the goal of bringing users into legal markets while keeping demand low, and actively promoting low-risk consumption. For this to happen, we believe that cannabis distribution within LCBO outlets should happen from behind the counter, in limited quantities, involving product information from trained staff.
A second, and contentiously discussed option, are community storefronts (currently illegal "dispensaries"). We believe that there is a place for a select number of these storefronts to be licensed as a complementary element in the distribution system, as they may help to bring additional users into legal market distribution – provided they are held to the same standards as distribution proposed for the LCBO: no advertising, behind-the-counter distribution by trained staff only, and within limited hours. In addition, the zoning of all outlets would need to follow an integrated metric, for example, in regards to density limitations, proximity to schools, hospitals, etc., as these factors are known to influence substance-related demand and harms.
A third element of cannabis distribution might occur by online or mail order. This is, indeed, a sensible option, especially towards equitably facilitating cannabis distribution in areas, or for users, where availability or access to physical outlets is not easily granted. Mail-order distribution is currently operated by Canada's licensed producers for medical marijuana. However, it would be desirable to avoid "vertical integration" and to separate cannabis production from distribution. Hence, online distribution should ideally be provided by entities mandated for retail distribution.
Which brings us to the fourth element proposed for cannabis "distribution": home growing. Federal legislation tabled allows for the growing of up to four cannabis plants in people's homes for "self-supply." We believe that this option is at categorical odds with public-health principles, and ought to be swiftly abandoned. The reasons? Just as we would not allow people to assemble fireworks or compound pharmaceuticals at home – cannabis-plant growing in homes brings environmental hazards, escapes the reach of any product safety or quality regulations, and brings ready risks for diversion that are virtually uncontrollable.
Further – if the goal of legalization is to keep cannabis "out of the hands of children and youth," home growing is a likely but predictable way to undermine this laudable objective. If in any way possible, we recommend that Ontario opt out of or refrain from implementing this supply option.
Getting the retail distribution system for cannabis right will crucially determine public-health impacts. Ontario has various options, but ought to choose, combine and manage them wisely.