How accessible will MDMA and psilocybin be, following the Australian government's decision to make them available as Schedule 8 controlled drugs?
Probably not very accessible at all, for a bunch of reasons:
First, the Therapeutic Goods Administration has determined that from July 1 2023, MDMA to treat PTSD and psilocybin to treat treatment-resistant depression may be approved for patient use by a qualified psychiatrist.
However, before treatment is permitted, the psychiatrist must become an Authorised Prescriber for the drug and medical condition in question. This requires them to seek the endorsement of a Human Research Ethics Committee or specialist College, and the TGA.
To get that endorsement, the psychiatrist must satisfy the HREC/College that they have sufficient processes, procedures and expertise to safely use the drug in clinical practice, including a detailed treatment protocol. Then do the same thing for the TGA to get AP approval.
The TGA's statement clarifies that "there does not currently appear to be any established treatment protocols", leaving the "onus and opportunity with a prospective prescriber" to develop, justify, and seek HREC and TGA approval for their protocol.
That is a significant hurdle. But not as big as this: the Royal Australian and NZ College of Psychiatrists stated in July 2022 that, "clinical use of psychedelic substances should only occur under research trial conditions".
So any psychiatrist who wants to pursue this treatment option for their patients will have to develop a new treatment protocol and get that approved by an HREC, or by their College, which formally opposes what the psychiatrist will be seeking permission to do.
Based on very similar events that occurred with the legalisation of medicinal cannabis, I predict that, at first, access will be non-existent. HREC/College endorsements will be declined. People will blame the TGA, who will say it's not up to them, there's a process, so follow it.
This will go on for months while the media runs stories featuring desperately sick people who can't get the treatment they want, and a small number of psychiatrists who don't care about painting a professional target on their backs.
Eventually the political pressure will get too much, and the TGA will be forced to expand access, possibly to include the SAS-B pathway which does not require HREC/College endorsement. This will give rise to psychedelic clinics, which will proliferate.
Access will be massively expanded, and hopefully this results in better treatment outcomes for more people. But we should do everything we can to ensure that potential harms are minimised, especially for vulnerable populations.
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1/ You can *not* get CBD over-the-counter at pharmacies in Australia
You won't be able to for at least 1-2 years and possibly never
There has been a lot of misleading news coverage about this which I think is irresponsible and could end up harming people
2/ The TGA has determined that low-dose CBD products, which have been proven through clinical trials to treat specific symptoms at low doses, might be available over-the-counter, once they have gone through an expensive and time consuming drug approval process
3/ There is little evidence that CBD at low doses is effective for treating anything
A small number of companies are in the early stages of planning or running initial clinical trials to further investigate the possibility of clinical efficacy
2/ The best part of this analysis is it’s based on proprietary data taken from the largest chain of cannabis clinics in #Australia. So, although the patient access data I publish is more comprehensive, theirs is more precise. Here are the highlights:
3/ Counting active patients in Australia is diff-i-cult. Freshleaf’s definition is anyone seeing a clinic #doctor, receiving a script or receiving a new or replacement approval. My preferred definition is anyone in possession of an active recommendation but here's their graph
2/7 First off, some of you may have already seen me post this a couple of weeks ago, but here are the national figures for SAS-B approvals up to June 2019
3/7 But wait, there's more! We also have updated condition-specific data up to the end of May 2019. Here's the same graph from the article with an additional three months of data