Comment on FR Doc # 2026-09182
Akamai Cannabis ConsultingSupportIndividual
Summary: Dr. Clifton Otto, a medical cannabis certifying provider, supports the revision of the firearms transaction record to clarify the legal status of medical cannabis. He argues that the form should explicitly recognize state-licensed medical cannabis to ensure that patients who use it legally under state law are not unfairly barred from registering firearms.
COMMENTS ON OMB 1140-0020
Dear Mr. Gluck,
Thank you for the opportunity to provide comments on proposed changes to OMB
1140-0020 (Form 4473). I have an interest in this matter because I’m a certifying provider for registered patients in Hawaii’s Medical Cannabis Program, and there are many patients who wish to regain their right to lawfully register firearms now that state-licensed medical cannabis is no longer an illegal Schedule I controlled substance.
I’ve noticed in my state a reluctance to accept federal guidance on medical cannabis that is not accompanied by clear protection of intrastate medical use. To avoid misinterpretation, changes to firearms registration required by recent federal rescheduling should include explicit recognition of state-licensed medical cannabis.
To address this issue, please consider the following changes to Question 2d:
I am not an unlawful user of, or addicted to, marijuana or any depressant, stimulant, narcotic drug, or any other controlled substance. (Warning: You can be an unlawful user under federal law, even if your possession is legal under state law. Federal law does not permit the use or possession of marijuana for recreational purposes, but federal law does permit state-licensed medical cannabis.)
Thank you for considering these comments.
Aloha,
Clifton Otto, MD