Are CBD Oil Products in Scope?

Cannabidiol Products (CBD) are getting more and more popular. Make sure you know what is within the scope of practice. The FDA has issued statements regarding the prosecution of those marketing CBD derived products that have not been approved.

Transcript:

We hope everyone’s having a fantastic day. We get a number of questions from our doctors regarding cannabidiol products, or CBD products, and whether or not that is within the scope of a chiropractic physician. In fact, about a year ago is when these questions really began to surface, as a lot of vendors began to carry a lot of these products, and in our initial diggings, in fact, conversations with IDFPR in regards to whether or not that they would pursue what the comments typically were coming from IDFPR were, if it’s being sold in, you know, the area, pharmacies as an over the counter product, no TC, then it would be within scope and they wouldn’t pursue prosecution. However, a lot has changed the last 12 months.

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The FDA is, in fact, modified quite a few different rulings and and clarified their FAQs in regards to CBD products in the last 10 months. And so what we have found is there’s a big shift. In fact, they’ve actually made some pretty strong statements in regards to pursuing prosecution of those who are marketing and selling CBD derived products that have not been approved by the FDA. And on that note, actually they’ve only approved one. In fact, this happened towards the end of June, and I think that’s why we have another resurgence of questions that are coming in regarding CBD oils and CBD being products being sold in your practice, because now that the FDA has approved some what happens is, some people have said, hey, does this mean that that is now within scope? And the fact of the matter is, actually couldn’t be further from the truth. What has happened is the FDA commissioner released a statement on the same day that they approved the specific CBD product, and made some clarifying statements to make sure it’s abundantly clear exactly what was approved and what the pursuit of the FDA is here forward. A couple of things that he said in the in the statement, one is that this was an approval of one specific CBD medication for a specific use. And then later in the statement, made some more specific qualifying statements and this is what he said, the FDA has taken recent actions against companies distributing unapproved CBD products. These products have been marketed in a variety of formulations such as oil drops, capsules, syrups, teas and topical lotions and creams. So this would really now he’s talking about pretty much all types of CBD products, whether it be through a nutritional supplement, through a an ingestible type form, or whether it be topical in nature. In this statement, he included all of those things. But then he goes on to say, these companies have claims that very CBD products could be used to treat or cure serious diseases such as cancer, with no scientific evidence to support such claims.

Now he’s giving that as an example of some of those that they’ve gone after. And the key here is that if they make unscientific claims, and the only way that scientific evidence builds up, if you read the entire letter, is that if you meet all of the FDA requirements, which this one company did for their one approval, then he goes on to say, we’ll continue to take action when we see the illegal marketing of CBD containing products with unproven medical claims. So really, what this means is, at this stage, there’s only one product approved by the FDA requires a prescription which that would take that product outside of your scope of practice. And with the statements contained within this clarifying letter and the statements that are made in their FAQ regarding CBD oil, we now can pretty firmly tell you that, based on all of that information, that CBD oil would fall outside of the scope of practice of a chiropractic physician. Quite candidly, except for this one particular product, it would really fall outside of the scope of almost all practitioners at this stage, just simply because it hasn’t been approved for those particular uses. Hopefully this information helps you out, and we’ll catch you next week.