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process for extramural research, a highly competitive process with a success rate in 1997 of 32% of approved NIDA grants.41 Through the separate protocol review, in which a researcher funds research independently of an NIH grant, NIDA submits the researcher's protocol to several external reviewers who evaluate the protocol on the basis of scientific merit and relevance to the mission of NIDA and NIH.

Through those two avenues marijuana has been supplied to several research groups—most of those that apply. While there has been much discussion of NIDA's alleged failure to supply marijuana for research purposes, we are unaware of recent cases in which they failed to supply marijuana to an investigator with an NIH-approved grant for research on marijuana. Donald Abrams's difficulty in obtaining research funding and marijuana from NIDA has been much discussed,2 but the case of a single individual should not be presumed to be representative of the community of marijuana researchers. Failure of investigators who apply to NIH for marijuana research grants to receive funding is hardly exceptional: in 1998 less than 25% of all first-time investigator-initiated grant applications (known as ROls) to the NIH were funded.38

To import marijuana under the CSA for research purposes, the procedures are more complex. Under DEA regulations, marijuana can be imported, provided that the researcher is registered with the DEA, has approval for marijuana research (21 CFR § 1301.11, .13, and .18), and has a DEA-approved permit for importation (21 CFR § 1312.11, .12, and .13), and that the exporter in the foreign country has appropriate authorization by the country of exportation. Importation would enable U.S. researchers to conduct research on marijuana grown by HortaPharm, a company that has developed unique strains of marijuana. However, no U.S. researcher has imported HortaPharm's marijuana because Dutch authorities have refused to issue an export permit, despite the issuance of an import permit by the DEA (D. Pate, HortaPharm, personal communication, 1998).*

HortaPharm, which is in the Netherlands, grows marijuana as a raw material for the manufacture of pharmaceuticals. Through selective breeding and controlled production, HortaPharm has developed marijuana strains that feature single cannabinoids, such as THC or cannabidiol. The plants contain a consistently "clean" phytochemical profile and a higher

*It might eventually be possible to import HortaPharm's marijuana from England, where HortaPharm is growing its marijuana strains for research use in clinical trials for multiple sclerosis (Boseley, 1998).0 England, as the country of origin, would have to provide appropriate authorization for export of the strains to the United States. Permission to export for research purposes is part of the basis for HortaPharm's participation in this project with GW Pharmaceuticals through a special set of licenses with the British Home Office (David Pate, HortaPharm, personal communication, 1998).



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