As a professional body representing psychologists with various perspectives on the issue of decriminalization of cannabis, the Chamber refrains from taking a position for or against decriminalization. Therefore, this feedback focuses on highlighting concerns related to the issue, which the Chamber believes must be taken into account when making legislation related to cannabis use, such as was proposed in the white paper.
As a general comment, the Chamber agrees with the approach of not treating drug users as criminals. On another note, the MCP believes that if steps will be taken to decriminalize cannabis, it is essential that this is done in a manner that does not downplay the potential harms that are associated with cannabis consumption, especially when initiated in adolescence.
The following sections make suggestions directly relating to specific sections of the white paper.
V. Consumption in public places
A specific concern relates to cannabis use in public places and related enforcement. The white paper proposed that the penalties resulting from cannabis use in public places will mirror those resulting from tobacco use in places where it is prohibited. Whilst this makes sense in principle, the MCP expresses concern over the ability of such penalties to effectively restrict public consumption of cannabis unless significant improvement is made in terms of enforcement of such laws.
Ensuring cannabis-free public places is important to protect the public from second hand smoke of cannabis. This may be particularly important to assist those who are in recovery from substance use addictions involving cannabis consumption, who may be adversely affected if cannabis use in public places becomes normalized due to lack of enforcement.
VI: Administrative measures for minors
The white paper outlined that special care should be taken to distance persons under the age of 18 from cannabis, due to the greater adverse effects resulting from cannabis use initiated in adolescence. However, research clearly indicates that brain development is still occurring up to the age of 25 years (Arain et al., 2013). Considering the adverse effects of cannabis on brain maturation, the Canadian Discussion Paper titled “Toward the legalization, regulation and restriction of access to marijuana” cited in the White Paper in question, suggests that one should consider 25 years as an age limit of vulnerability, rather than the age of 18 years.
The MCP recommends that adolescents found in possession or who are believed to be under the effect of cannabis will receive appropriate interventions through referrals to rehabilitation agencies that have experience dealing with problematic adolescent substance use in the community.
Legislators should also consider the possibility that adolescent use may increase with decriminalization of adult use. While this is by no means inevitable (for an example, see Anderson, Hansen, Rees & Sabia, 2019) such effects were most recently noted in California after adult recreational use was legalized in 2016 (Paschall, García-Ramírez & Grube, 2021). Although Canada has noted no statistically significant increases in adolescent cannabis use following legalization (Leyton, 2019), it is worth noting that lifetime use of cannabis among Canadian adolescents was already very high (over 30%) before legalization, and had already seen increases following the availability of medical cannabis (Zuckermann et al., 2021).
VII: A dedicated Cannabis Authority
The MCP understands the need of having an independent authority that would manage any funds that might stem from fines issued in observance of the proposed legislation. However, it encourages the same authority to utilise the funds effectively by sponsoring agencies offering specialized substance use treatment, and also commissioning scientific and evidence-based research on the subject matter.
The MCP specifically recommends that this authority monitors the impact of this legislation on use through population surveys among both the youth and the general population, besides the regular monitoring of the 15-16-year-old age group, which already takes place through ESPAD.
The MCP believes that if cannabis were to be decriminalized, an educational campaign is an essential part of a responsible plan to do so. However, the MCP is concerned that the white paper appeared to emphasize the need to eradicate the stigma surrounding cannabis, based on the finding that many people in Malta believe cannabis to be more harmful than alcohol. Since no comprehensive data is available on Maltese attitudes towards cannabis consumption, we must rely on the experience of professionals working in the field of substance abuse on the popularity of the opposite view, where many people in Malta, especially among those who use cannabis, are under the impression that use is almost completely harmless, even in large quantities. It is essential that the education campaign gives due attention to the following:
- the possibility of dependence and addiction: 1 out of 10 who ever try cannabis, 1 out 6 users who start regular use in adolescence (Anthony, 2006).
- the increased risk of psychosis especially to those with family history of psychosis (DiForti et al., 2014).
- the impact on brain development when used under the age of 25 (Arain, 2013).
- the adverse and prolonged (up to 24 hours after use) impact on the ability to drive and operate machinery, after moderate use.
- risk of increased tobacco consumption & additional detrimental health effect if used together with tobacco, as is common practice (Bennett, 2008).
- the magnified adverse impact when consumed with alcohol – persons “who smoke marijuana should be counseled to have a designated driver if possible, to wait at least three hours after smoking before driving if not, that marijuana is particularly likely to impair monotonous or prolonged driving, and that mixing marijuana with alcohol will produce much more impairment than either drug used alone” (Sewell, Poling & Sofuoglu, 2009).
- information to groups at particular risk, such as people with asthma (Allergy & Asthma Network, 2020).
- the differences between cannabis and synthetic cannabinoids, and the extreme harms that the latter might have on the consumers (Akram, 2019).
- unbiased information on cannabis and its other derivatives.
The education campaign should also focus on equipping parents to have discussions with their children. Information must be provided in English and in Maltese, and cannot be only in printed or text-based format in order to reach those people who most need to hear it. Suggested material to use as a model is available at: https://www.drugfreekidscanada.org/wp-content/uploads/pdf/Cannabis-Talk-Kit_EN.pdf
This would need to be adapted to the Maltese context, accurately representing the Maltese legal and cultural situation. We acknowledge the need of de-stigmatisation of cannabis users, however, it is very important that culture of addictions and substance abuse does not become a normalised culture.
Prevention of use in adolescents
The MCP also recommends that a pilot project utilising the Icelandic Prevention Model (IPM) with young people in Malta is undertaken or EMCDDA model for the development of prevention curriculum, which is evidence based and a model favoured in the EU. The IPM (Sigfusdottir, Kristanjanssan, Thorlindsson & Allegrante, 2008) has been designed to influence risk and protective factors related to substance use within the community, school, peer and family contexts. The IPM favours a whole community approach which encourages youth participation in prosocial activities and moves away from the notion of substance use as a legitimate way of recreation. This model includes various elements recommended in the European Prevention Curriculum (EMCDDA, 2019), which offers valuable information on evidence-based substance use prevention approaches (vide https://www.emcdda.europa.eu/publications/manuals/european-prevention-curriculum_en).
Prevention of driving under the influence
It is common knowledge that driving under the influence of alcohol is relatively common in Malta. If cannabis is to be decriminalized, it is likely to lead to increases in consumption (Rotermann, 2019), possibly leading to more people driving under the influence. Research shows that drug-driving, together with drunk-driving, is one of the three killers related to road accidents, apart from speeding and not wearing seatbelts (European Traffic Police Network, 2011). According to the European Monitoring Centre for Drugs and Drug Addiction (2012), drivers who have recently used cannabis are on average 1.5 to 2 times more likely to be involved in a car crash. This may be attributed to the effects of cannabis on cognitive and psychomotor performance, with impairment found to be higher when cannabis is consumed orally rather than smoked, which may last up to 10 hours after consumption (EMCDDA, 2014). Driving performance is deteriorated by 50% with blood-THC concentration at 11ng/ml, and a blood-alcohol concentration of 0.73% (Berghaus, Krüger and Vollrath, 1998). Driving under the influence of cannabis is especially problematic when combined with alcohol consumption, with the risk of accidents increasing drastically (Maes, Charlier, Grenez, and Verstraete, 1999).
For further information on this matter, you may refer to a document by the National Centre for Freedom from Addictions titled ‘Exploring Drug Driving Legislation in Malta in the Context of the European Landscape’ (2016).
Due to the above-mentioned facts, the MCP recommends a zero-tolerance policy towards drug-driving, and urges the authorities to ensure that enforcement of both drink and drug driving will be increased to better safe-guard the safety of all road users.
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