*** Independent Lab Advisory Committee 2/6/2015
Feb 2nd Handouts ILAC
Microbial Discussion On Differentiating Between “Bad” and “Good” Bacteria
DB Labs document that brought this to ILAC attention.
***Proposed Regulations Meeting
On Feb 4th, the Division conducted a meeting to go over the new proposed regulations. This was the second time that a meeting has taken place to talk about the proposed regulations. It was not communicated at this meeting, but at the ILAC that the next meeting to finalize these would be March 25th. Multiple MMEs expressed their concerns with regards to annual financial audits, raising the total amount of THC from the limit of 100mg, removal of CBD testing. I believe the division will raise the limit after many expressed their disapproval.
There are a few things that stand out for me such as a “production run” allowing you to send 15lbs of dry or 125lbs (Stated at meeting not in policy or proposal) of wet to be extracted with the final product being tested saving MME money. Page 10 of the document at the end of section 23, has the area talking about an audit conducted by an independent certified public accountant for renewals that was of concern. On page 16, section 33, multiple concerns with regards to production facilities not being able to purchase concentrates from other production facilities. For example if you owned a edibles company, you could not purchase extra CO2 oil from an existing marijuana infused products facility. On page 18, section 33, item 7, the Division on July 1st, 2016 will begin a seed to sale inventory program. There was no clarification whether the portal was going away or could be communicated with via API on that date. Page 23, section 40, adds CBD products by the state and will soon require the same standards of testing that are currently on THC products. Please contact CBD vendors to make sure they or it will be you picking up the cost of testing these CBD products.
Please review this most recent Division document to make changes to your SOPs or financial projections.
Proposed Regulations
All analysis above is my opinion and you should talk with an attorney or your consultant.
***Nevada Marijuana Council Meeting Feb 5th
I currently sit on the Lab/ Cultivation / Production Committee for the Marijuana Council, so please continue to reach out to me and other committee members to build consensus on what MME issues in the next legislative session are important.
Some of the speakers at the event included Senator Segerblom talking about the importance of starting with promotion of IP1(Adult Use) in March. I will work through the many outlets I have, to register voters and raise awareness early about IP1. The adult use committee suggested that we made sure medical patients pay less when IP1 passes, make cards easier to obtain, and streamline the card process. The MME owner committee suggested we increase patient card access, cards should be valid for 2 years, remove criminal background check for patients, speedup the card process. One person stated that their is a communication system that needs to be setup by the DMV to communicate with the Division and the money has been allocated. Senator Segerblom stated he would make that happen. The same committee also wanted to make it a felony or civil penalty for an illegal delivery service or to advertise one. The same committee talked about the inconsistency coming up with standard child packaging rules.
The Cultivation/Lab/Production committee, which I sit on, had the following suggestions of testing patient medicine and allow transfer of product between production facilities. CBD products should be subject to the same testing requirements as THC products and CBD products should be produced in the state of Nevada by MMEs.
The Banking Committee says currently there is nothing to help in this area because the banks and credit unions need will not be allowed a master account if they are in the cannabis industry. The 4corners Bank wanted a master account and it was denied on appeal. Currently, we are a cash based business with minimal banking solutions.
Patient issues committee wants to change DUI laws, extend rights to grown, and make it easier to get a card. Segerblom says he will make a separate patient bill that extends the patient card, extends discounts to veterans and seniors and deal with the “weedmaps” problem.
Nevada Marijuana Council Meeting Documents Handed Out
https://drive.google.com/file/d/0B_exG6ypAYM0YTJJeUxzUlhqUWM/view?usp=sharing
***Nevada Dispensary Association - Speed Up Patient Cards
The NDA sent a memo to DPBH requesting several changes that would allow patients to obtain cards quickly. The NDA Board is continuing to work on this critical issue. If you have the opportunity to speak to elected officials about patient access, please note that the following would have the most dramatic effect in reducing turnaround time.
Goal: Qualified Nevada medical patients deserve to obtain their patient card within 10 days of the beginning the application process.
The NDA sent a memo to DPBH requesting several changes that would allow patients to obtain cards quickly. The NDA Board is continuing to work on this critical issue. If you have the opportunity to speak to elected officials about patient access, please note that the following would have the most dramatic effect in reducing turnaround time.
Goal: Qualified Nevada medical patients deserve to obtain their patient card within 10 days of the beginning the application process.
Process Improvements Required:
1) Make the full application available online;
2) Perform instantaneous background checks; and
3) Issue the card directly to the patient without requiring the patient to go to the DMV
Riana Durrett, Esq.
Executive Director
Nevada Dispensary Association
(702) 782-4180
***Vegas Cannabis Magazine Please Purchase Advertisement And Support Cannabis Media
Please support cannabis magazines with your advertising dollars. They are instrumental in the Nevada marijuana community by informing patients, future patients, and out of town guests who are cannabis patients. They also normalize cannabis consumption for the Nevada community and the world. It is going to take a good 6 months of continued advertisement for your brand to really resonate with consumers. Each magazine allows you to reach a different segment of cannabis consumers, so I advise that you advertise in both.
Please contact me if you would like to advertise in Vegas Cannabis Magazine. Rate sheets are below:
***WECAN 702 Please Help Us
Our WECAN facebook has over 150,000 likes. We want to help connect you with the cannabis patient community. We can also give you a tax receipt because WECAN is a non-profit. Please assist us in helping more patients get their cards who can not afford them and need cannabis as a medicine. We always welcome your support and want to help you as well.
WECAN Rate Sheets
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If I can be of help in some capacity, please don’t hesitate to contact me and always let it ride on green.
Jason Sturtsman, B.A.E., Ed.S.
Nevada Independent Cannabis Laboratory Advisory Committee Member (ILAC)
Nevada Marijuana Council (Cultivation / Production / Labs Sub Committee)
Wellness Education Cannabis Advocates of Nevada (WECAN) Vice President
Healthcare Options For Patients Enterprises (HOPE) Cultivation / Production
Vegas Cannabis Magazine Advertising / Sales
Wecan702.org
702-325-9923
JasonS@wecan702.org
