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DEVELOPMENTAL MEDICINE & CHILD NEUROLOGY INVITED REVIEW

Epilepsy and cannabis: so near, yet so far


MARTIN KIRKPATRICK 1,2 | FINBAR O'CALLAGHAN 3
1 Tayside Children’s Hospital, Dundee; 2 School of Medicine, University of Dundee, Dundee; 3 UCL Great Ormond Street Institute of Child Health, University College
London, London, UK.
Correspondence to Martin Kirkpatrick at Tayside Children’s Hospital, Dundee DD1 9SY, UK. E-mail: martin.kirkpatrick@nhs.scot

Following media attention on children with refractory epilepsies reportedly deriving benefit
PUBLICATION DATA from cannabis-based medicinal products (CBMPs), the UK government changed the law in
Accepted for publication 27th July 2021. 2018 so that CBMPs could be legally prescribed. Subsequently, a pure cannabidiol (CBD) pro-
Published online 8th September 2021. duct has been licensed for two epilepsy syndromes. However, despite pressure from cam-
paign groups and allied politicians, almost no children have received unlicensed CBMPs
ABBREVIATIONS under the UK NHS. This review explores the science behind CBMPs in paediatric epilepsies
CBD Cannabidiol and highlights the areas that warrant further research. It identifies a lack of level I evidence
CBMP Cannabis-based medicinal for efficacy and safety as, currently, the major obstacle to prescribing. Unlicensed medicines
product are often used in paediatrics but almost all are used ‘off-label’, with supporting evidence of
RCT Randomized controlled trial efficacy and safety derived either from other age-groups or from disease conditions. CBMPs,
THC Tetrahydrocannabinol except for pure CBD, are unique in that they are currently both unlicensed and fall outside
the ‘off-label’ category. The review acknowledges the treatment gap in refractory epilepsies
and the potential use of CBMPs. However, it argues against exceptionally circumventing the
usual standard of evidence required by regulatory prescribing authorities and warns against
allowing vulnerable children to become the ‘trojan horse’ for deregulation of the commercial
cannabis market.

In November 2018, UK law changed so that clinicians on Russell Reynolds, a prominent neurologist at Queen Square
the General Medical Council Specialist Register were per- and President of the Royal College of Physicians, was also
mitted to prescribe cannabis-based medicinal products an advocate of cannabis for the treatment of migraine, neu-
(CBMPs). The change in the law was prompted by publicity ritis, and parasomnias. He was less enthusiastic about its
surrounding high-profile cases of children with refractory use in epilepsy, noting in The Lancet that, ‘In true, chronic
epilepsy who had accessed CBMPs abroad, who were report- epilepsy, I have found it absolutely useless, and this is the
edly deriving benefit, and had then had the medicines confis- result of very extensive experience’.3 Famously, in 1890,
cated by customs authorities on return to the UK. It was a Reynolds prescribed it to Queen Victoria for the relief of
striking example of a ‘manufactured scandal’ driving policy menstrual cramps. William Gowers, in his treatise on epi-
reform.1 In the House of Commons, the then Home Secre- lepsy and other chronic convulsive diseases, had a more
tary, Sajid Javid, said ‘The position we find ourselves in is considered view, describing Cannabis indica as being ‘some-
not satisfactory. It is not satisfactory for the parents, it is not times, though not very frequently, useful’ as a treatment for
satisfactory for the doctors, and it is not satisfactory for me’. epilepsy.4 However, during the 20th century CBMPs fell
Despite the subsequent change in the law, barely a handful out of vogue, partly because there was a move away from
of children and young people with epilepsy have received whole plant treatments as the ability to isolate individual
prescriptions for unlicensed CBMPs within the NHS in the molecules from plants increased, and partly for legal rea-
UK, although a small number of prescriptions have been sons because cannabis was considered a drug of misuse.
issued by physicians in private practice. How has it come to The position with respect to CBMPs has changed dra-
this? A substantial proportion of our media, politicians, and matically in the 21st century. There are still many chronic
perhaps the families of our patients, also struggle to under- medical conditions that have few effective treatments. For
stand why we are in this position. example, one-third of our patients with epilepsy do not
Cannabis has been used as a medicine for thousands of respond to current antiseizure medications. These patients
years. In UK medicine it achieved some acceptance in the and their families are understandably eager to try any
19th century thanks to the efforts of William Brooke treatment that may improve their condition. Some high-
O’Shaughnessy, an Irish physician who worked for the East profile cases have suggested that CBMPs may be the
India Company. He described the therapeutic effects of answer. In the US, one young female with Dravet syn-
Cannabis indica in a variety of clinical scenarios, including drome started taking a cannabis oil known as ‘Hippie’s
tetanus, rabies, and in an infant with convulsions.2 John Disappointment’ and later renamed ‘Charlotte’s Web’,

162 DOI: 10.1111/dmcn.15032 © 2021 Mac Keith Press


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that, apparently, dramatically reduced her seizures. In the What this paper adds
UK there have been similar cases that have suggested the • Unlicensed cannabis-based medicinal products should not circumvent usual
benefits of CBMPs. regulatory requirements before widespread prescription.
These cases coincided with the commercial interests of a • Children with epilepsy are at risk of being used as the ‘trojan horse’ for the
growing medicinal and recreational cannabis market in the cannabis industry.
UK that is predicted to be worth $55 billion globally by
2027.5 Campaign groups, such as ‘End Our Pain’, closely receptors, acts as an agonist at serotonin and dopamine
connected to politicians in the All-Party Parliamentary receptors, blocks voltage-gated sodium channels, and inhi-
Group for Medical Cannabis under Prescription, and with bits the enzyme fatty acid amide hydrolase that breaks
links to the cannabis industry, began to press for the pre- down endogenous cannabinoids.9 A review found evidence
scription of unlicensed CBMPs.6 They found common of CBD binding to in excess of 65 molecular targets.10
cause with clinical enthusiasts for the use of whole plant Both THC and CBD interact with transient receptor
cannabis, some of whom also had financial interests in a potential ion channels that are involved in the transduction
growing medicinal cannabis market, and also with a small of chemical and physical stimuli.11
number of politicians, not involved with the All-Party Par- In animal models, CBD has been shown to have anti-
liamentary Group for Medical Cannabis under Prescrip- convulsive effects across a series of different models.12
tion, who had long lobbied for the legalization of THC has been seen to be both pro- and anticonvulsant in
marijuana.7 Paediatric neurologists, imbued with the need animal models and the proconvulsant effects have been
to practice evidence-based medicine and wary of prescrib- passed on to future generations.13,14
ing unlicensed medicines that had inadequate safety data, There has been long-standing concern about the adverse
suddenly found themselves at odds with an array of vested effects of THC exposure. Adolescent cannabis use, with
interests and, most unfortunately, with the families of varying, uncontrolled amounts of THC showed clear
patients who were keen to try anything that would alleviate dose–response relationships with adverse outcomes in
the effects of their child’s seizures. young adults. These effects included reduced odds of high-
school completion and degree attainment with increased
WHAT IS CANNABIS? odds of later cannabis dependence, use of other illicit
There are two main types of cannabis plant that are used drugs, and suicide attempts.15,16
for medicinal purposes: cannabis sativa and Cannabis indica. There is some evidence that CBD may offset some of
The two different plants originate from different geo- the negative effects of THC. In a series of elegant experi-
graphical areas and may have varying amounts of different ments, Englund et al. demonstrated how CBD can reduce
cannabinoids. Sometimes the sativa and indica strains will some of the psychotic symptoms, paranoia, and memory
be hybridized. The plants contain over 140 cannabinoid impairment induced by THC administration.17
compounds. The most plentiful cannabinoids are tetrahy- Dose–response and drug–drug interaction information
drocannabinol (THC) and cannabidiol (CBD) and almost for the cannabinoids is scarce. However, CYP2C19 con-
all clinical research has focussed on them. THC is respon- verts N-desmethylclobazam to its inactive metabolite18 and
sible for most of the psychoactive effects of cannabis. CBD is a potent inhibitor of cytochrome P450 2C19
Plants can be cultivated to contain greater or lesser enzymes. Consequently, CBD significantly increases circu-
amounts of these two cannabinoids. lating levels of the more sedating N-desmethylclobazam in
Humans produce endogenous cannabinoids, anandamide patients taking clobazam.
and 2-arachidonylglycerol, that are key modulators of Cannabis plants also contain terpenes. Terpenes are aro-
synaptic transmission. They play a role in the regulation of matic hydrocarbons and are often responsible for the char-
feeding behaviour, perception of pain, and the neural gen- acteristic scent we associate with many plants, such as pine,
eration of motivation and pleasure. THC and CBD inter- lavender, oranges, lemons, and cannabis.19 The most abun-
act with the human endocannabinoid system and, in dant terpene in cannabis is myrcene, although there are
particular, the cannabinoid receptors CB1 and CB2. CB1 many other terpenes present and the terpene profile may
receptors are predominately expressed in the central ner- vary in different plants. A widely discussed issue is whether
vous system (CNS) in microglia, astrocytes, and oligoden- the terpenes add any therapeutic benefit, contributing to
drocytes and are found in high density in the the so-called entourage effect of ‘whole plant’ medicines.
hippocampus, brainstem, globus pallidus, and middle fron- The concept is that all the constituents of the plant
tal gyrus. They are also found in the myocardium. CB2 together to create ‘the sum of all the parts that leads to the
receptors are found predominantly in the immune system magic or power of cannabis’. Although commonly referred
and gastrointestinal tract, although there is evidence that to, there is little or no robust evidence to support the
they are also present in the CNS, but less abundantly than entourage effect as a credible clinical concept.20
CB1 receptors.8 THC acts as a partial agonist of CB1
receptors, inhibiting the release of GABA and glutamate. EVIDENCE IN PAEDIATRIC EPILEPSY
The mechanisms of action of CBD are less clear, but it The recent National Institutes of Health and Clinical
appears to prevent other agonists from binding to CB1 Excellence (NICE) guideline on cannabis-based medicines

Review 163
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(NG144) was unable to make a recommendation on the not included in the final analysis. Patients were treated for
use of CBMPs in refractory epilepsies, acknowledging that 20 weeks with a product containing 100mg/mL CBD and
‘current research is limited and of low quality, making it 2mg/mL THC. They started at a dose of 2mg/kg/day of
difficult to assess just how effective these medicines are for CBD and 0.04mg/kg/day of THC and were titrated up to
people with epilepsy’.21 The only high quality, level I evi- either 16mg/kg/day of CBD and 0.32mg/kg/day of THC,
dence that has been published are double-blind, random- or the maximally tolerated dose. The maximum target dose
ized placebo-controlled trials (RCTs) of a pure CBD was reached by eight of the 19 participants. Seizure fre-
product, Epidyolex (GW Pharma Ltd, Cambridge, UK), in quency at the end of the study was compared to baseline
Dravet syndrome, Lennox–Gastaut syndrome, and tuber- and 12 children had a ˃50% reduction in seizure rate and
ous sclerosis complex.22–25 Trials in all three scenarios there was a 70.6 median percentage reduction in motor
showed a significant benefit of CBD versus placebo at seizures.31
doses ranging from 10 to 20mg/kg/day in the Dravet syn- Prospective and retrospective open-label cohort studies
drome and Lennox–Gastaut syndrome trials and from 25 of both children and adults of a whole-plant CBMP pro-
to 50mg/kg/day in the tuberous sclerosis complex trial. In duct cultivated to have a CBD/THC ratio of 20:1 have
all the trials, the lower dosing regimens appeared as effec- been published from Israel. These studies have shown that
tive as the higher dose regimens, and CBD was more effec- the CBMP was associated with a ˃50% reduction in mean
tive in those patients concurrently taking clobazam. monthly seizure frequency in 51% to 56% of patients.32–34
Patients rarely became seizure free on CBD, with the med- In addition to these studies, there have been numerous
ian percentage reduction in seizure frequency varying open-label reports of the apparent effectiveness of a variety
between 38% and 48%. There was a significant placebo of different CBMPs in paediatric and adult epilepsies.
effect in these trials, with patients on placebo having a
median percentage reduction in seizure frequency between LEVELS OF EVIDENCE
14% and 27%. Sedation, diarrhoea, and loss of appetite In the vast majority of cases, medicines regulatory authori-
were common adverse effects. Some adverse effects related ties require level I evidence (i.e. RCTs) of efficacy and
to concomitant clobazam use and transient liver enzyme safety before licensing any new medicine. Unfortunately,
abnormalities were seen in some patients receiving val- apart from the studies of pure CBD in Lennox–Gastaut
proate. The efficacy of Epidyolex against multiple seizure and Dravet syndromes and tuberous sclerosis complex,
types and in multiple underlying aetiologies in the Len- level I evidence in the field of CBMPs and refractory epi-
nox–Gastaut syndrome trials suggests that pure CBD may lepsy is lacking. Some have argued that reliance on level I
have efficacy across the range of epilepsies. However, to evidence to make decisions about licensing and prescribing
date, it has only been trialled, and therefore licensed, in is misplaced. Professor David Nutt, in an opinion piece for
these very narrow and circumscribed diagnostic groups. the BMJ, argued that in the case of CBMPs, we should
There have been several open-label, non-randomized accept a lower standard of evidence, such as patient-
non-controlled studies of CBD (Epidyolex) used in other reported outcomes, observational research, and n-of-1 tri-
clinical scenarios (i.e. treatment resistant epilepsies in gen- als. He also argues that there are already many examples of
eral, CDKL5 disorder, Doose syndrome, Aicardi syn- drugs licensed without RCT evidence.35 In reality, such
drome, duplication of 15q, tuberous sclerosis complex, and licensing is relatively rare and almost always occurs in the
febrile infection-related epilepsy syndrome [FIRES]).26–33 context of haematological malignancy, solid tumour oncol-
All these studies suggest that CBD is effective as an anti- ogy, or metabolic conditions, where no effective treatment
seizure medication, but all are vulnerable to bias due to alternative is available, or where the drug is so obviously
their uncontrolled designs. effective that clinical equipoise no longer exists.36 This is
There has been a phase-2 open-label study of another not the scenario with CBMPs. The problem with lesser
oral CBD formulation in paediatric refractory epilepsy. standards of evidence is that they are vulnerable to bias.
The study looked at 16 children with refractory epilepsy of Open-label studies of drugs almost invariably exaggerate
whom 11 completed the study. A highly purified cannabis the benefits of medicines. In his evidence to the UK Par-
sativa extract, containing ˃93% CBD and ˂0.2% THC, liament Health and Social Care Committee inquiry, ‘Drugs
was delivered on gelatin beads. The maximum dose of Policy: Medicinal Cannabis’, the Chief Scientific Adviser
CBD was 25mg/kg/day. The mean reduction in monthly to the Department of Health and Social Care (and now
seizure frequency was 73.4%. Nine out of the 16 patients Chief Medical Officer) Professor Chris Whitty argued that
were classified as responders.30 CBMPs should be subject to the same level of scrutiny as
Studies of CBMPs containing both CBD and THC in other drugs and stated that ‘. . . it is very dangerous to have
paediatric epilepsies are scarce and there is no level I evi- a kind of cannabis exceptionalism’. In its conclusions to
dence. McCoy et al. published the results from a prospec- the inquiry the Health and Social Care Committee noted
tive, open-label trial of a CBD/THC cannabis oil in that, ‘Some have argued that double-blind, RCTs are inap-
children with Dravet syndrome. Twenty patients were propriate for cannabis research, but we do not support
recruited and 19 were analysed at the end of the study. making an exemption for this class of medicines’. The
One patient died during the course of the study and was committee also exhorted the CBMP manufacturers to put

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forward their products for research.37 With the exception Committees. In light of the lack of evidence of efficacy and
of the manufacturers of Epidyolex, they have conspicuously safety, together with their current costs, that approval has
failed to do this. rarely been forthcoming.
One of the problems with open-label studies is that they
fail to account for the placebo effect. The placebo effect is LEGISLATION IN DIFFERENT COUNTRIES
a real phenomenon and appears especially potent in the There is considerable variation in whether cannabis-use is
context of CBMPs. In the RCT of CBD in Dravet syn- permitted in different countries. In a recent review, it was
drome, for example, 27% of patients on placebo had a noted that the use of herbal cannabis for medicinal pur-
50% reduction in seizure frequency and 34% of patients poses is permitted in Argentina, Australia, Canada, Chile,
had an improvement on the caregiver impression of Colombia, Croatia, Ecuador, Cyprus, Germany, Greece,
change.22 Another example of the potency of the placebo Israel, Italy, Jamaica, Lithuania, Luxembourg, North
effect is a study from Colorado where the law restricting Macedonia, Norway, the Netherlands, New Zealand, Peru,
the use of cannabis products is relatively relaxed. In a sin- Poland, Switzerland, and Thailand, as well as a number of
gle tertiary epilepsy centre, they compared the epilepsy states in the USA.42 However, outside pure CBD, there
responder rates to a cannabinoid treatment between chil- has been no approval for cannabinoid products for the
dren of families resident in Colorado compared to those treatment of epilepsy by either the European Medicines
who had moved to Colorado in order to access cannabi- Agency or the US Food and Drugs Administration.
noid treatment for their child’s epilepsy. The responder In Canada, by 2019, some 165 cannabis producers were
rate for Colorado resident children was 22% but rose to licensed to sell cannabis products to authorized medical
47% for those families who had moved into the state.38 A patients, although pure CBD was unavailable at that time.
plausible interpretation of these results is that this is a ‘pla- That same year, the Canadian League Against Epilepsy
cebo by proxy’ effect.39 Medical Therapeutics Committee produced a guarded
position statement highlighting, again (with the exception
THE PRESCRIBING ENVIRONMENT of pure CBD in published RCTs), the lack of evidence for
The change of UK law in November 2018 permitted the efficacy and safety of cannabis medicines for children
access to a CBMP in one of three ways: (1) as a medicine with epilepsy.43
with a marketing authorization, (2) as part of a clinical
trial, or (3) through the prescription by ‘senior clinicians’ CONCLUSIONS
in cases of ‘exceptional clinical need’. The Departments of CBMPs hold promise for the treatment of refractory pae-
Health of the four nations of the UK noted that a senior diatric epilepsies. There is historical and low-level clinical
clinician’s decision to prescribe should take account of data suggesting the possible efficacy of these treatments.
General Medical Council guidance, have approval by the However, there is no reason why CBMPs should be
clinician’s local employer, and the decision to prescribe exempt from the same efficacy and safety trials required of
should be agreed by the multidisciplinary team.40 most other pharmaceutical products in medical practice.
The General Medical Council is the regulatory body for This requires properly designed and conducted RCTs.
doctors in the UK and its guidance clearly states that a There should also be further trials to evaluate the use of
clinician ‘must be satisfied that there is sufficient evidence pure CBD beyond the limited number of syndromes for
or experience of using the medicine to demonstrate its which it is currently licensed. Such an approach must be to
safety and efficacy’. Perhaps, given the standard of evidence the benefit of our patients. Furthermore, on behalf of our
that exists around CBMPs in paediatric epilepsy, it is not patients, the UK government and its research and regula-
surprising that many senior clinicians are not sufficiently tory agencies spend millions of pounds annually ensuring
reassured to prescribe. that this level of evidence exists for other medicines.
The unlicensed status of CBMPs is peculiarly unique. In All clinicians caring for children and young people with
UK hospital practice, up to 40% of medicines used for poorly controlled epilepsy recognize their plight and the
children are ‘unlicensed’ and in recent years the European wish of families to do the best for their child. There is a
Medicines Agency has attempted to address this.41 How- danger that vulnerable families will be unwittingly exploited
ever, almost all of the drugs prescribed in this way are pre- by vested interests using children with poorly controlled
scribed ‘off-label’ such that they have an existing license, epilepsy as a ‘trojan horse’ for deregulation of the cannabis
either for an older age group or for an alternative medical market; the idea being that widespread acceptance of medic-
indication. In paediatric epilepsy practice, perhaps with the inal cannabis will preface and accelerate the wider legalisa-
sole exception of rarely used potassium bromide, the tion of marijuana and open up a highly lucrative commercial
potential prescription of a CBMP would fall outside an market. Companies producing CBMPs should not be
off-label definition. It follows that there will have been no allowed to circumvent the usual standards of evidence
regulated trial efficacy or safety data on which to rely. required by regulatory authorities and they should be called
Furthermore, approval for the funding of unlicensed to account if they will not participate in RCTs. We need
medication needs to be obtained via individual funding carefully designed, good quality CBMP studies that produce
requests from NHS local Drugs and Therapeutics results on which we can rely. We can then work with

Review 165
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families to choose the best treatments for children and are co-applicants for an NIHR funded randomized controlled trial
young people with epilepsy. We owe this to them. on CBMPs. FOC was a member of the NICE clinical guideline
group on CBMPs in 2019. FOC was chief investigator of the
DECLARATION OF INTERESTS GWPCARE6 trial of add-on CBD treatment for drug-resistant
MK and FOC were clinician members of the UK Home Office seizures in tuberous sclerosis complex.
Expert Panel on cannabis-based medicines in 2019; this Panel is
no longer in operation. MK and FOC were joint authors, DATA AVAILABILITY STATEMENT
amongst others, of the BPNA Guidance on the use of CBMPs for Data sharing not applicable – no new data generated, or
use in children and young people with epilepsy. MK and FOC the article describes entirely theoretical research.

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DEVELOPMENTAL MEDICINE & CHILD NEUROLOGY INVITED REVIEW

EPILEPSIA Y CANNABIS: TAN CERCA, PERO TAN LEJOS


Tras la atencio n de los medios sobre los nin~ os con epilepsias refractarias que supuestamente podrıa tener beneficiarse de los pro-
ductos medicinales a base de cannabis (PMBC), el gobierno del Reino Unido cambio  la ley en 2018 para que los PMBC pudieran
prescribirse legalmente. Subsecuentemente, un producto de cannabidiol puro (CBD) recibio  licencia para dos sındromes de epilep-
sia. Sin embargo, a PMBC de la presio  n de los grupos de campan ~ a y polıticos aliados, casi ningu ~ o ha recibido PMBC sin
 n nin
licencia bajo el NHS del Reino Unido. Esta revisio  n explora la ciencia detra  s de los PMBC en las epilepsias pedia  tricas y destaca
reas que justifican una mayor investigacio
las a  n. Identifica una falta de evidencia de nivel I para la eficacia y la seguridad como,
en la actualidad, el mayor obsta  culo para la prescripcio  n. Los medicamentos sin licencia se utilizan a menudo en pediatrıa, pero
casi todos se utilizan "fuera de etiqueta", con pruebas de apoyo de eficacia y seguridad derivadas de otros grupos de edad o de
enfermedades condiciones. Los PMBC, a excepcio  n del CBD puro, son u  nicos en el sentido de que actualmente son ambos sin
licencia y quedan fuera de la categorıa "fuera de etiqueta". La revisio  n reconoce la brecha de tratamiento en epilepsias refractarias
y el uso potencial de PMBC. De todos modos, eso argumenta en contra de eludir excepcionalmente el esta  ndar habitual de eviden-
cia requerido por las autoridades reguladoras que prescriben y advierte contra permitir que los nin ~ os vulnerables para convertirse
en el "caballo de Troya" de la desregulacio  n del mercado comercial de cannabis.

~ PERTO E AINDA TAO


EPILEPSIA E CANNABIS: TAO ~ LONGE

Apo ~ o da mıdia sobre criancßas com epilepsias refrata


 s a atencßa  rias supostamente se beneficiarem de produtos medicinais a  base
de cannabis (PMBCs), o governo do Reino Unido mudou a lei em 2018 para que os PMBCs pudessem ser legalmente prescritos.
Posteriormente, um produto de canabidiol puro (PMC) foi licenciado para duas sındromes de epilepsia. No entanto, apesar da
pressa ~ o de grupos de campanha e polıticos aliados, quase nenhuma criancßa recebeu PMBCs na ~ o licenciados sob o NHS do Reino
Unido. Esta revisa ~o explora a cie^ ncia por tras de PMBCs em epilepsias pedia tricas e destaca as areas que justificam mais pesqui-
sas. Identifica a falta de evide ^ ncia de nıvel I para efica
cia e segurancßa como, atualmente, o maior obsta culo a ~ o. Os medi-
 prescricßa
camentos na ~o licenciados sa ~o frequentemente usados em pediatria, mas quase todos sa ~o usados ’off-label’, com evide ^ncias de
apoio de efica cia e segurancßa derivadas de outros grupos eta rios ou de doencßas e condicßo ~ es. Os PMBCs, exceto o PMC puro, sa ~o
 nicos, pois atualmente sa
u ~o ambos na ~ o licenciados e esta ~ o fora da categoria ’off-label’. A revisa ~o reconhece a lacuna de trata-
mento em epilepsias refrata rias e o uso potencial de PMBCs. No entanto, argumenta contra contornar excepcionalmente o padra ~o
usual de evide ^ncia exigido pelas autoridades reguladoras de prescricßa ~ o e adverte contra permitir que criancßas vulnera  veis para se
tornar o ’Cavalo de Troia’ para a desregulamentacßa ~o do mercado comercial de cannabis.

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