“Many of the terpenes that the researchers discovered in the vaporized hash oil are also used in e-cigarette liquids. Moreover, previous experiments by Dr. Strongin and his colleagues found similar toxic chemicals in e-cigarette vapor when the devices were used at high-temperature settings. The dabbing experiments in the current study produced benzene—a known carcinogen—at levels many times higher than the ambient air, the researchers noted. It also produced high levels of methacrolein, a chemical similar to acrolein, another carcinogen.

“‘The results of these studies clearly indicate that dabbing, although considered a form of vaporization, may, in fact, deliver significant amounts of toxic degradation products,’ the authors concluded. ‘The difficulty users find in controlling the nail temperature put[s] users at risk of exposing themselves to not only methacrolein but also benzene. Additionally, the heavy focus on terpenes as additives seen as of late in the cannabis industry is of great concern due to the oxidative liability of these compounds when heated. This research also has significant implications for flavored e-cigarette products due to the extensive use of terpenes as flavorings.’”

“The United States is a party to the 1971 Convention on Psychotropic Substances (Psychotropic Convention). Article 2 of the Psychotropic Convention provides that if a party to the convention or WHO has information about a substance, which in its opinion may require international control or change in such control, it shall so notify the Secretary-General of the United Nations (the U.N. Secretary-General) and provide the U.N. Secretary-General with information in support of its opinion.

“Section 201 of the CSA (21 U.S.C. 811) (Title II of the Comprehensive Drug Abuse Prevention and Control Act of 1970) provides that when WHO notifies the United States under Article 2 of the Psychotropic Convention that it has information that may justify adding a drug or other substances to one of the schedules of the Psychotropic Convention, transferring a drug or substance from one schedule to another, or deleting it from the schedules, the Secretary of State must transmit the notice to the Secretary of Health and Human Services (Secretary of HHS). The Secretary of HHS must then publish the notice in the Federal Register and provide opportunity for interested persons to submit comments that will be considered by HHS in its preparation of the scientific and medical evaluations of the drug or substance.”