The Alberta government is currently considering how to regulate the distribution, sale and use of recreational cannabis in Alberta. A public health framework should be applied to cannabis regulation to protect public health, to reduce harm and to avoid the unintended consequences of cannabis legalization. This process must take into consideration the strong association between cannabis and tobacco use and the potential for cannabis legalization to impact tobacco initiation and consumption. Strong complementary regulations are needed to effectively control cannabis and tobacco in Alberta.
Background: cannabis and tobacco use
Cannabis and tobacco are two of the most commonly used psychoactive substance in the world. Approximately 17 percent of Canadians currently smoke tobacco products.1 When last surveyed, 12 percent of Canadians claimed to have used cannabis at some point during the previous year.2 Higher cannabis use is generally observed among youth and young adults than among the general population. According to the World Health Organization, Canadian youth have the second highest cannabis use rates worldwide.3
Studies suggest that up to 90 percent of cannabis users are also tobacco users and that cannabis use during adolescence and early adulthood is associated with increased risk of initiation of tobacco use and nicotine dependence.4 Joint or mixed use of cannabis and tobacco presents a serious concern for tobacco control efforts. According to current Ontario data, about 30 percent of cannabis smokers mix tobacco in their “joints”5 and tobacco blunt wraps are often used for this purpose. There exists a strong and consistent association between tobacco use and cannabis use.6 Dual use of tobacco and cannabis is associated with an increased risk of adverse health effects compared with using cannabis alone.7 Tobacco and cannabis use may act as behavioral cues for increased use of either substance.8,9 Evidence shows that tobacco users who smoke cannabis are more likely to relapse when attempting to quit using tobacco.10 Thus, any increase in overall cannabis use resulting from legalization may increase tobacco use, particularly among youth.11
Current federal and provincial legal framework
The federal government has introduced legislation to legalize cannabis by July 1, 2018 which outlines broad policy direction. The focus of the federal legislation (Bill C‐45 ‐ Cannabis Act) is to provide legal access to cannabis and to control and regulate its production, distribution and sale. The objectives of the federal Act are to prevent young persons from accessing cannabis, to protect public health and public safety by establishing strict product safety and product quality requirements and to deter criminal activity by imposing serious criminal penalties for those operating outside the legal framework. The federal Act is also intended to reduce the burden on the criminal justice system in relation to cannabis.12
Under the federal framework, the provinces as well as municipalities have a role in controlling the consumption and distribution of cannabis. In order to manage this role the Alberta government will be developing legislation which will focus on:13
- Limiting the illegal market for cannabis;
- Keeping cannabis out of the hands of children and youth;
- Protecting public health; and
- Protecting safety on roads, in workplaces and in public space.
Complementary legislation for tobacco and cannabis
Cannabis legalization presents a critical opportunity to develop comprehensive legislation that will support controls on recreational use of cannabis and to fill gaps in tobacco control regulation. Complementary policies for both substances would mitigate the full scope of negative unintended consequences resulting from cannabis legalization. These policies would also have the benefit of further regulating the most widespread and deadly form of substance abuse— commercial tobacco use. Alberta needs evidence‐based taxation policies, a full retail licensing regime, and best practice legislation focused on keeping both cannabis and tobacco out of the hands of youth.
Taxation: Taxation should be a cornerstone of the province’s strategy to reduce tobacco and cannabis use, as its effectiveness in reducing consumption has been well documented.14 In fact, tobacco taxes are the single most effective measure to reduce tobacco use.15 The federal government’s task force report on cannabis legalization has recommended that an evidence‐based tax rate be implemented for cannabis products which would focus on preventing and reducing consumption while at the same time restraining the illicit market.16 When implementing a cannabis tax framework in Alberta, tobacco taxes should also be increased simultaneously to match tobacco product affordability levels in neighboring provinces and reduce the likelihood of mixed/joint use. Alberta currently has the most affordable cigarettes of any province for youth aged 15 to 24 due to our suppressed tax levels and higher wages.17 A significant portion of any new cannabis and tobacco tax revenue should be earmarked for research, programming and education to prevent and reduce the harms of substance use.
Retail Licensing: Evidence indicates that when strong retail licensing requirements are implemented and actively enforced, they are effective at reducing tobacco product sales to minors and can help reduce consumption among youth.18 Fees collected from licensing can provide steady revenue to support active oversight and enforcement by regulatory agencies. Alberta’s regulatory framework for alcohol (managed by the Alberta Gaming and Liquor Commission) is a possible working model that could be used to develop a regulatory framework for cannabis and tobacco. The liquor licensing system places strict requirements on retailers which are actively enforced by AGLC inspectors to limit alcohol consumption and harm.
Protecting Youth: Several additional policy measures have been proven to protect youth from dangers of tobacco use which can be applied to cannabis regulation. These measure also have the potential to decrease the negative impact of cannabis legalization on tobacco control. These measures include actively implementing and enforcing sales‐to‐minors restrictions, prohibiting flavoured products, maintaining smoke‐free public spaces including a ban on cannabis smoking in public, prohibiting the co‐location of retail sales, discouraging joint use or poly‐substance use (the use of tobacco, cannabis and alcohol together is not uncommon among youth19), and prohibiting the sale of mixed products.
ASH encourages the Alberta government to consider the following specific policy recommendations to minimize the potential harm of tobacco and cannabis use:
- Fully implement and apply tobacco product sales‐to‐minors requirements within the Tobacco and Smoking Reduction Act and assign a provincial government agency such as the Alberta Gaming and Liquor Commission to administer and regulate cannabis and tobacco sales in Alberta.
- Set equivalent minimum age of purchase and use for both tobacco and cannabis and ensure active enforcement of laws prohibiting sales to minors using underage test shoppers. Introduce an evidence‐based tax rate on cannabis and increase tobacco taxes by at least $1.50 per 20 pack to match affordability levels in neighboring provinces.
- Commit to raising both tobacco and cannabis taxes over time and protect taxes from being eroded by inflation or wage increases.
- Allocate a significant portion of any new cannabis and tobacco tax revenue to prevention, research, programming and education.
- Fully proclaim and implement the ‘tobacco‐like’ provisions in the Tobacco and Smoking Reduction Act to prohibit all forms of smoking including cannabis in public spaces and workplaces.
- Ban the co‐location and sale of tobacco and cannabis at any retail outlet.
- Ban the sale of any cannabis products mixed with tobacco and ban the sale of any tobacco products that are intended to be used with cannabis such as tobacco blunt wraps.
- Ban the sale of all flavoured tobacco and cannabis products. This ban should include removing the exemption for flavoured pipe/waterpipe tobacco in the Tobacco and Smoking Reduction Act.
1. Statistics Canada. Canadian Community Health Survey, 2015. http://www.statcan.gc.ca/daily‐quotidien/170322/dq170322a‐cansim‐eng.htm
2. Government of Canada. Canadian Tobacco Alcohol and Drugs (CTADS), 2015 Summary. March 2017. https://www.canada.ca/en/health‐canada/services/canadian‐tobacco‐alcohol‐drugs‐ survey/2015‐summary.html
3. McKiernan, A, Fleming, K. Canadian Youth Perceptions on Cannabis. Ottawa, Ont.: Canadian Centre on Substance Abuse. January 2017. http://www.ccsa.ca/Resource%20Library/CCSA‐ Canadian‐Youth‐Perceptions‐on‐Cannabis‐Report‐2017‐en.pdf
4. Agrawal, A, & Lynskey, M. T. Tobacco and cannabis co‐occurrence: Does route of administration matter? (English). Drug And Alcohol Dependence 2009; 99(1‐3), 240‐247.
5. Ialomiteanu, A. R., Hamilton, H. A., Adlaf, E. M., & Mann, R. E. (2016). CAMH Monitor e‐Report: Substance Use, Mental Health and Well‐Being Among Ontario Adults, 1977–2015 (CAMH Research Document Series No. 45). Toronto, ON: Centre for Addiction and Mental Health. Available at: www.camh.ca/en/research/news_and_publications/ Pages/camh_monitor.aspx
6. Leos‐Toro C, Reid JL, Madill CL, Rynard VL, Manske SR, Hammond D. Cannabis in Canada ‐ Tobacco Use in Canada: Patterns and Trends, 2017 Edition, Special Supplement. Waterloo, ON: Propel Centre for Population Health Impact, University of Waterloo
7. Leos‐Toro C, Reid JL, Madill CL, Rynard VL, Manske SR, Hammond D. Cannabis in Canada ‐ Tobacco Use in Canada: Patterns and Trends, 2017 Edition, Special Supplement. Waterloo, ON: Propel Centre for Population Health Impact, University of Waterloo
8. Agrawal, A, & Lynskey, M. T. Tobacco and cannabis co‐occurrence: Does route of administration matter? (English). Drug And Alcohol Dependence 2009; 99(1‐3), 240‐247.
9. Peters, E. N, Budney, A. J, Carroll, K. M., et al. Clinical correlates of co‐occurring cannabis and tobacco use: a systematic review (English). Addiction (Abingdon. Print) 2012; 107(8), 1404‐ 1417.
10. Hindocha, C, Shaban, N. D, Freeman, T. P., et al. Associations between cigarette smoking and cannabis dependence: A longitudinal study of young cannabis users in the United Kingdom. Drug And Alcohol Dependence, 2012; 148165‐171. doi:10.1016/j.drugalcdep.2015.01.004.
11. Hindocha, C, Shaban, N. D, Freeman, T. P., et al. Associations between cigarette smoking and cannabis dependence: A longitudinal study of young cannabis users in the United Kingdom. Drug And Alcohol Dependence, 2012; 148165‐171. doi:10.1016/j.drugalcdep.2015.01.004.
12.Legislative Summary. An Act respecting cannabis and to amend the Controlled Drugs and Substances Act, the Criminal Code and other Acts or Cannabis Act. Retrieved from: http://www.parl.ca/LegisInfo/BillDetails.aspx?billId=8886269&Language=E&Mode=1&View=8
13. Alberta Government. Cannabis legalization across Canada: Alberta’s approach. Retrieved from: https://www.alberta.ca/cannabis‐legalization‐in‐canada.aspx
14. U.S. National Cancer Institute and World Health Organization. The Economics of Tobacco and Tobacco Control. National Cancer Institute Tobacco Control Monograph 21. Chapter 4. The impact of Tax and Price on the Demand for Tobacco Products. NIH Publication No. 16‐CA‐8029A. Bethesda, MD: U.S. Department of Health and Human Services, National Institutes of Health, National Cancer Institute; and Geneva, CH: World Health Organization; 2016. https://cancercontrol.cancer.gov/brp/tcrb/monographs/21/index.html
15. U.S. National Cancer Institute and World Health Organization. The Economics of Tobacco and Tobacco Control. National Cancer Institute Tobacco Control Monograph 21. Chapter 4. The impact of Tax and Price on the Demand for Tobacco Products. NIH Publication No. 16‐CA‐8029A. Bethesda, MD: U.S. Department of Health and Human Services, National Institutes of Health, National Cancer Institute; and Geneva, CH: World Health Organization; 2016. https://cancercontrol.cancer.gov/brp/tcrb/monographs/21/index.html
16. Government of Canada. A framework for the legalization and regulation of cannabis in Canada. The Final Report of the Task Force on Cannabis Legalization and Regulation. December 2016.
17. Campaign for Smoke Free Alberta. Tobacco Tax Recommendations: Reducing the Affordability of Tobacco Products to Improve the Health & Quality of Life of Albertans. 2007. on file
18. Pacula, R. L, Kilmer, B, Wagenaar, A. C., et al. Developing Public Health Regulations for Marijuana: Lessons From Alcohol and Tobacco. American Journal Of Public Health 2014; 104(6), 1021‐1028. doi:10.2105/AJPH.2013.301766.
19. Haines‐Saah, R, Moffat, B, Jenkins, E., et al. The Influences of Health Beliefs and Identity on Adolescent Marijuana and Tobacco Co‐Use. Qualitative Health Research, 24(7), 946‐956.