M2 Petition Decision

July 19th, 2012 by Will Humble Leave a reply »

The voter approved list of conditions that already qualify patients for an AZ Medical Marijuana Registration Card (with a doctor’s certification) includes any of the following: any chronic or debilitating disease or medical condition (or its treatment) that causes severe and chronic pain, severe nausea, severe and persistent muscle spasms, wasting, or seizures, cancer, glaucoma, HIV, Hepatitis C, ALS, Crohn’s disease, agitation of Alzheimer’s disease.  The AZ Medical Marijuana Act also requires us to periodically accept petitions to permanently add new medical conditions to the list of conditions that qualify folks for a card.  

We accepted petitions from the public to add new medical conditions back in January.  Folks submitted numerous articles as a part their petitions for PTSD 1PTSD 2; Depression; Migraines; and Generalized Anxiety Disorder.  We also received lots of informal comments regarding adding PTSD; Depression; Migraines; Generalized Anxiety Disorder and General comments.  We also heard in person testimony from dozens of folks at our public hearing in May.

Because my guiding principle for making the decision was to use science and research, we contracted with the U of A College of Public Health to do an evidence review of published scientific studies to help us to make a more informed decision.  You can see the UA’s analyses for Depression; Generalized Anxiety Disorder; Migraine Headaches; and Post Traumatic Stress Disorder (PTSD) on our petition website.   The UA used the GRADE methodology to evaluate the quality of the studies looking at the benefits and harms of using Cannabis to treat or provide relief for the conditions that were petitioned to add to the list of qualifying conditions for a Medical Marijuana Registration card.  Also, our ADHS Medical Advisory Committee reviewed and analyzed the data and provided me with recommendations earlier this week.

We heard and received a host of moving stories from the public both on-line and during our a public hearing in May.  Many of the commenters and folks that testified self-reported that they believe Cannabis provided relief for the petitioned conditions.  However, our literature review found limited scientific evidence to document whether Cannabis is helpful or not for the petitioned conditions or that support permanently adding the petitioned conditions to the statutory list of qualifying debilitating conditions identified in the Act.  In short- I didn’t approve the petitions because of the lack of published data regarding the risks and benefits of using Cannabis to treat or provide relief for the petitioned conditions. 

However, some of the petitioned conditions (such as migraine headaches) already qualify patients for a medical marijuana registration card if they cause severe and chronic pain, severe nausea, severe and persistent muscle spasms, wasting, or seizures.

Whatever you think of the decision, just know that our team and I really took an objective and close look at the scientific evidence before making this decision.  And remember, the Act provides for a judicial review of this decision and a continuing petition process.  In fact, we’ll be accepting petitions again next week.



  1. Alex Romero says:

    Thank you.

  2. JR Hubbard says:

    Mr. Humble,

    I understand why you made the decision you did based on the limited scientific evidence referenced in the aforementioned petitions. It’s disappointing, but understandable.

    That being said, I’m a bit confused by your ruling concerning migraines. And concerned this confusion will be shared by the medical community.

    I don’t think there’s any doubt – scientifically speaking – that migraines cause severe & chronic pain, among other symptoms (including nausea). You yourself underscore this fact, stating that many sufferers already qualify for mmj cards based on these symptoms alone. So how exactly do migraines not meet the requirements? Who seeks relief from migraines that don’t cause severe & chronic pain? Migraines are – by definition – characterized by severe & chronic pain.

    Migraines aren’t curable (excepting unusual circumstances like tumors & such). Treatment is 100% symptom management. So again – I don’t see how the severe & chronic pain presented by migraines differes from the severe & chronic pain presented by any other ailment.

    My main fear is that doctors will feel compelled to deny migraine patients recommendations based on this ruling. How are they going to provide a recommendation based on severe & chronic pain when the DHS has ruled that the source of that pain is not a qualifier??

    I had purposefully held off attempting to secure a card based on the pending applications, sure that if any condition met the qualifications, they did. Now I feel I missed my only chance, as once doctors get wind of this ruling, they’re going to be highly reluctant to write “severe & chronic pain” combined with “migraine” in the same sentence. And even if they do – what will the DHS do when they receive such an application?

    • Will Humble says:

      As a practical matter the essential question in the petition was can migraine headaches be considered a qualifying condition in the absence of both severe and chronic pain. When a clinician believes that a patient meets these criteria and the condition that caused the severe and chronic pain was a migraine headache, and they believe that cannabis is an appropriate management strategy, they can certainly in good faith sign a certification (as long as they meet the other routine attestations).

      In fact, we have already processed and approved cards in which migraine headaches were the condition that resulted in severe and chronic pain.

      We will work this issue into our Continuing Medical Education efforts that we’re working on with the UA to make this more clear to physicians.

      • JR Hubbard says:

        I appreciate your response, Will. And appreciate the fact this issue will be worked into the medical education efforts you mentioned. Thank you.

  3. David says:

    Theirs plenty of data mr. humble your just ignorant and ignore it. There would be even more “data” if the U.S. Government would alows us to study it, But I guess foriegn studys are inaccurate cause those people dont have citizenship here in the US huh guess this keep arizona safe affects aliens in outer space too…. Hey humble heres another fact theyre isnt a single recorded death from a overdose related to marijuana!

    • Why are referring to a book Marijuana as Medicine that was written in 2001 I know that there are way more informative books out there I made sure I understood exactly what I was Ingesting in my body before I medicated. For some THC for getting is not high is not the main attraction .

  4. David says:

    … (M.A.P.S) has done many studys related too ptsd and cannabis! Dr. grinnspoon, Dr. Taskin all scientific data including uclas study on cannabis finding it needs to be rescheduled from 1 to possible a schedule 3 or 4 substance… Mr. Humble open your eyes man, the constitution is written on ” HEMP ” Medical Marijuana is real and so are the people who use it! Help are vets obtain safe access they fought for our country they should be allowed to use its medicine!

  5. Michael Copeland says:

    Everybody knows the DEA and the US Gov. WILL NOT GIVE/RELEASE any cannabis for any type of research so for you to say you can’t make a decision is complete BS. You knew there was no research when you started this fairy tale about adding other conditions. You are just hiding behind that fact to push your personal/political beliefs on other people. You have made it clear from day ONE you don’t want any thing to do with this program. If you want this program to be above the standards of other Medical Marijuana programs like you have said a number of times why don’t you take some of those millions of dollars you have taken from us, funny you don’t complain about all that extra money you have and start a research program here in AZ. I know the government will NOT LET YOU do that so lets just call it an immigration program and the state (sentence removed by editor). You know like we did with SB 1070. So why don’t we do that with Marijuana, because you want this program to fail.

    PS it would hurt if you would show a little back bone and set these local police department straight on the different between concentrate and cannabis and marijuana. Hint there is not different.

    • David says:

      prop 203 – usable marijuana means the dried flower and any mixture or preparation thereof!!! Read the law and enforce it concentrates are fully legal under state law until they pass one saying its not….

    • JR Hubbard says:


      I understand your frustration (trust me – 110%), but if we wish to change things, it’s my opinion we need to extend the same level of understanding to those such as Mr. Humble as we wish to receive ourselves.

      I don’t know what Mr. Humble’s personal opinions are regarding medical marijuana. Frankly the issue is irrelevant. What I do know, however, is that if I were to place myself in his shoes – I’d be hesitant to do anything whatsoever that could be deemed as even questionable.

      Imagine spending your entire life building a career, ascending to the position of head of the DHS, only to be dealt the hand of running a program that’s in direct violation of federal law. And when you (aka the state of AZ) asks the federal government for assurance that state employees – including Mr. Humble himself and everyone in his charge – will not be criminally prosecuted for their part in this, they say “Can’t make no promises”.

      Would you risk your career, your freedom, your house, your marriage, and all the other fun things you lose going to prison to defend the ‘rights’ of those who basically don’t do anything more than criticize you at every turn? I admit, it’s probably pretty unlikely. But again, how far would you stick your neck out for a cause you didn’t have a personal stake in, where no matter what you did all the feedback you got was negative?

      If we want to accomplish change, we need to do more than gripe at those who are hamstrung by political reality. As the saying goes, you catch more flys with honey than you do with vinegar. We want Mr. Humble to understand and empathize with our plight. Isn’t it only fair we do the same?

      • Anonymous says:

        What we really need to do is reschedule cannabis Federally off of Schedule I so that it can be studied. This vicious cycle of no-research, but we can’t do research is ridiculous.

  6. Scott says:

    Thousands of years of medical use should mean something.
    Mr Humble you may fool some but not all. You should be ashamed of yourself. This is clearly politically motivated.
    Your actions has caused needless pain and suffering and that bad karma belongs to you to have to deal with one day.

  7. CJ says:

    Thank you for your objectivity and professionalism in handling this petition.

  8. scott says:

    I find it interesting that you feel you are so much more qualified than the people of every single other mmj state, that you would contradict them. All states did studies and strangely they all disagree with your conclusions. I guess your out of touch and the public should petition for your removal.

  9. Joyce says:

    Following the Colorado massacre, we have come as close to real time war as any American has in its history. And you wonder why someone feels a little better using mm products? Mr. Humble wants to rule over a mental and behavioral health domain, but he’s shown us he doesn’t know that domain. He gives a little power to some so-called experts he’s afraid will actually usurp his royalty. So he pulls rank on them.

    I think that he has either used mj, has had depresssion, thinks migraines and ptsd will go away if you use tough love measures. These methods are typically used by parents when they haven’t had success beating the just say “no” method into their children.

    Father Humble, we don’t want mm to defeat you but to save ourselves. Learn it is not about you, unless you partake in our disabilities. Speaking of humble, it’s okay to change your mind, advocate for the ill instead of the Feds or State. You have made many of us homeless denying flex funds and medicine and seem to blame us for our illness. I personally can’t afford the heavy burden of purchasing the certificate, the doctor’s fees and the mm. Work on making it affordable instead of using it as a way to have your name printed on millions of certificates.

    When Colorado comes to Phoenix, or Tucson comes to Phoenix you will come close to understanding depression, ptsd, stress and all the conditions manifested in our minds and bodies. Can’t believe you got your position without really knowing and that authority was given you. And see how much it has hardened your heart.

  10. Meeghan says:

    Are you aware of this website, which has a list of 103 peer-reviewed studies on medical marijuana? http://medicalmarijuana.procon.org/view.resource.php?resourceID=000884

  11. Curt Larson says:

    I think that in order to institute a grading principle for new additions that you must first evaluate the existing statutory conditions using the same grading principle and then adjust your “GRADE” accordingly. In other words, you are going to have to grade on a curve using the statutory conditions as a benchmark. This must be done considering the lack of studies currently for a variety of diseases and disorders were the symptoms of which most likely would be positively treated with cannabis.

  12. Old Hippie says:

    There are numerous examples of people’s very lives being saved by using cannabis to treat conditions such as depression and PTSD, and peer-reviewed studies to boot. Considering how non-addictive and relatively harmless cannabis is (as cited by a DEA administrative law judge!), you’d think that “erring on the side of caution” would give the result of allowing people to use it, not stopping them.

  13. Farrok says:

    It does not matter what any study says or what any patients say. The object of the Arizona political system is to turn off the use of marijuana. It’s about Politics Not helping the sick and ill. The Voters need to go back to the Polls and legalize marijuana for personal use or the politicians and police will always have their fingers in the pie.

  14. Todd says:

    Are you missing the point. I am not a service member but are involved with many and cannibus helps. Your reaserch lacks real evidence and what lil you think you obtained is wrong. The real facts are that these people are suffering from things most people could never understand. So knowing that how could you say what works and what doesnt. Im here to tell it does,I see it everyday and from all sorts of service men and women. And each form works for each person diferently and may all not work for everyone,the multitudes of diferent ways to get into the body will work for just about everyone without any harmfull side affects that pharm. meds do.

  15. MARGIE says:

    Mr Humble, thank you for taking the time to make sure that marijuana is an effective treatment for the diagnoses for which it is allowed to be prescribed. I would like to see it treated like any other drug and go through rigorous trials and research before it becomes easily available as a medicine.

  16. Ricy Mardona says:

    Well done. Nice information. Keep it up.

  17. María Marín says:

    Address 31 county RD 8020 is. Off hill crest. And 61 hwy 12 mile south of concho 1 block off 61hwy your GPS like every one elses is reading it off5020 hwy 25 mile rong dirétion jps gets it rong all time!!!!!!!!

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