(Originally written for Lift Cannabis on 18 October 2016)
More in-depth analysis of Public Safety Canada’s recent report on cannabis legalization.
Public Safety Canada (PSC) recently released “Cannabis Performance Metrics for Policy Consideration: What do we need to measure?” For a concise synopsis of the report, I recommend this recent piece for Lift ’ by Jenna Valleriani.
The report is a great first step by PSC to identify measurement and evaluation (M&E) opportunities and needs in the cannabis industry. The Trudeau government would be wise to heed their advice and invest in M&E prior to legislation in the Spring of 2017. Tracking the landscape prior to, during and post-legalization will allow them to measure whether their policy changes are having the desired effect. It will have the further benefit of strengthening the results for dissemination (positioning the Canadian government as a world leader in effective public safety policy).
Below is an overview of the first of four categories outlined in the report. The first category is Public Safety; it is comprised of 18 subcategories, which have been sorted for analysis into four buckets: Law & Order, Personal Use Trends, Production, and Transportation & Point-of-Sale.
Law & Order
The authors do a thorough job of identifying opportunities for increased M&E in law enforcement, including tracking incidents reported to the police by the public, cannabis related charges laid by law enforcement, outcomes of said charges, cannabis-related probation infraction, and illicit crop eradication, amongst others.
One glaringly obvious trend emerges from reading this section: law enforcement agencies in Canada, including local and provincial police forces as well as the RCMP, do not have the tools or training needed to adequately identify, capture and measure their interactions with cannabis.
A central argument of advocates of legalization is the positive social and financial impact it will have on the the legal system. However, it will remain difficult to determine the validity of this hypothesis if law enforcement statistics are not adequately tracked.
It is imperative that the federal and provincial governments invest in better training and tools to assist frontline officers in tasks such as identifying crops, measuring levels of intoxication, determining the legal status of grow sites, etc. An investment in M&E infrastructure and training at all levels of law enforcement is clearly overdue.
This will be particularly important when it comes to performing roadside tests to determine a) whether a driver has consumed cannabis within the past two hours and b) whether that driver is actually impaired. The authors rightly identify that there is much to be done on determining what legal threshold of intoxication will be tolerated, as well as how we will adequately measure said levels.
Personal Use Trends
While there are Canadian organizations currently tracking cannabis use fairly well, the report identifies the need to add nuance to this data. Currently, the survey focus on frequency of use, and does little to measure volume of consumption, potency of the product consumed, or the method through which it is consumed.
As technology improves, we will see the emergence of better tools to help measure the quality and potency of cannabis products, as well as their impact on health and development. The report does a good job of identifying opportunities for evaluation and measurement on these fronts. It also identifies the benefits associated with a legal regime where potency and volume are clearly denoted on packaging, which will aid tracking consumption patterns.
The public safety concerns regarding the production of cannabis are, right now (as the authors of the report identify), both difficult to track due to their illicit nature, and likely to change under a legal regime.
The fire hazard of existing indoor home grows is one metric identified for M&E.
The risk of explosions and burns related to certain extraction processes of cannabis derivatives was also identified in the report. Under a legal regime, these factors will be mitigated to a degree, as the processes for indoor growing and extraction become more normalised, regulated and monitored.
Transportation & Point of Sale
The final sub category identified is the transportation and exportation of cannabis, as well as the point of sale. In particular, the report points to exports across the border and diversions to other jurisdictions. The authors point to Colorado, which legalized cannabis for personal use in 2014, and has seen an increase in not only the number of seizures of cannabis at the border, but also a significant increase in the volume of cannabis seized in such incidents. Denver Pot Czar Ashley Kilroy addressed this data earlier this year in Windsor.
The public safety concerns surrounding point-of-sale, whether that be at dispensaries or elsewhere, were identified as important to measure: particularly the myth that dispensaries bring crime to neighborhoods, and the danger posed to consumers forced to purchase their cannabis through illicit sources.
The authors have clearly done a thorough of the literature surrounding this subject, and highlighted many existing facts and figures throughout. They have also pointed to the unreliability and lack of credibility of much of the data. The federal government would do well to heed the advice of this report, and begin investing in baseline data immediately, prior to the legislation being introduced in the Spring of 2017.