Comment Submissions - Developmental and Reproductive Toxicant Identification Committee Meeting Scheduled for December 11, 2019, Notice of Availability of Hazard Identification Materials for Cannabis (Marijuana) Smoke and Δ-9-Tetrahydrocannabinol (THC)

Dear OEHHA Thank you for the opportunity to respond to the document - Evidence on the Developmental and Reproductive Toxicant - Cannabis Smoke. I am providing a statistical brief in response to the discussion on page 84 regarding marijuana exposed infants and NICU admissions. The Surgeon General on August 29, 2019 issued an advisory in which the following statements were made: Studies have shown that marijuana use in pregnancy is associated with adverse outcomes, including lower birth weight. The Colorado Pregnancy Risk Assessment Monitoring System reported that maternal marijuana use was associated with a 50% increased risk of low birth weight regardless of maternal age, race, ethnicity, education, and tobacco use.With low birth weight being a serious, even live threatening condition. Regarding the paper's discussion and cited studies regarding low birth weight "marijuana exposed" babies and admission to NICU units it is my view that additional reports, including statistics on admissions would benefit this discussion. The hospital admission statistics and reports that are available could assist in this discussion. The National Academies of Science and Technology in their 2017 report to Congress reported they concluded that the science on low birth and marijuana exposure was given the rating of substantial. Ref: https://www.hhs.gov/surgeongeneral/reports-and-publications/addiction-and-substance-misuse/advisory-on-marijuana-use-and-developing-brain/index.html#use-pregnancy The Surgeon General's advisory also stated: Studies have revealed that the use of marijuana during pregnancy and right after birth can have a detrimental impact on a baby’s developing brain. This early exposure can result in “hyperactivity, poor cognitive function, and other long-term consequences.” The use of the drug during pregnancy can also result in a 50% higher risk for a low birth weight, which could result in premature death or a child with a disability. Ref: https://dailycitizen.focusonthefamily.com/the-surgeon-general-announces-new-advisory-on-the-dangers-of-marijuana-for-pregnant-women-and-adolescents/ Hospital data substance abuse neonatal and maternal admissions: https://hcup-us.ahrq.gov/reports/statbriefs/sb193-Neonatal-Maternal-Hospitalizations-Substance-Use.pdf I would also like to offer this study for your review. It discusses the impact of parental cannabis use on offspring in terms of damage that may be useful to your own discussions. https://www.ncbi.nlm.nih.gov/pubmed/27580483 RESULTS: We examined 1 743 525 cohort members (48.7% female; total follow-up, 27.2 million person-years). Risks for offspring suicideattempt and violent offending were elevated across virtually the full spectrum of parental psychiatric disease. Incidence rate ratios were the most elevated for parental diagnoses of antisocial personality disorder (suicide attempt, 3.96; 95% CI, 3.72-4.21; violent offending, 3.62; 95% CI, 3.41-3.84) and cannabis misuse (suicide attempt, 3.57; 95% CI, 3.25-3.92; violent offending, 4.05; 95% CI, 3.72-4.39), and for parentalsuicide attempt (suicide attempt, 3.42; 95% CI, 3.29-3.55; violent offending, 3.31; 95% CI, 3.19-3.44). Parental mood disorders (and bipolar disorder in particular) conferred more modest risk increases. A history of mental illness or suicide attempt in both parents was associated with double the risks compared with having just 1 affected parent. Associations between parental psychiatric disease and offspring violent offending were stronger for female than for male offspring, whereas little sex difference in risk was found for offspring suicide attempt. CONCLUSIONS AND RELEVANCE: The similarities in risk patterns observed between the 2 outcomes may evidence a shared etiology. Early interventions to tackle parental mental disorders may be beneficial to both parents and children. Sincerely, Pamela McColl www.preventdontpromote.org www.cleartheairnow.org pjmccoll@shaw.ca