S3 Collective and MCSA File Public Comment Response to Proposed Cannabis Rescheduling



S3 Collective and the Medical Cannabis Student Association (MCSA) have submitted a comprehensive public comment to the Department of Justice (DOJ) and Drug Enforcement Administration (DEA) supporting the reclassification of cannabis to Schedule III under the Controlled Substances Act. This official response to Docket No. 2024-11137 highlights the unique role that experienced technical organizations play in supporting federal policy, particularly where state entities are constrained by federal legality.

“S3 Collective and MCSA crafted an extensive response to provide additional information requested by the DOJ that clearly support the need for rescheduling cannabis to better reflect its medical utility and lower abuse potential compared to Schedule I and II drugs,” said Alena Rodriguez, MS, Technical Director of S3 Collective.

The response outlines several critical areas where current scientific and industry knowledge supports the rescheduling of cannabis:

  • Acknowledged Medical Benefits: Extensive data demonstrate cannabis’s efficacy in managing and treating chronic pain, nausea, and other medical conditions, which could be more thoroughly investigated and applied with reclassification.

  • Reduced Abuse Potential: Research indicates that cannabis has a lower potential for abuse and dependence than many substances in more permissive schedules.

  • Industry-Driven Public Health Improvements: With rescheduling, cannabis could be regulated more effectively, improving quality controls, safety standards, and consumer protections—all areas where industry expertise can significantly contribute to public health and policy.

David Vaillencourt, MS, Board Chair of S3 Collective, emphasized, “Our organizations are uniquely positioned to present scientific information to all stakeholders. By supporting a shift to Schedule III, we aim to unlock new opportunities and enable a regulatory framework that supports innovation, safety, and patient care in the cannabis sector.”


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