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August 5, 2015 Volunteer Recap: Recreational Marijuana Rules Technical Committee; Licensing, Compliance and Enforcement

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In response to the volunteer request to attend OLCC Rules Advisory Committee and Subcommittee hearings, Joseph Lopez Jr contributed the following summary of the August 5 Technical Committee on Licensing, Compliance and Enforcement.  Tremendous thanks to Joseph for contributing his time to attend and summarize the meeting for us.

The following is the write-up he sent for the benefit of members of Portland NORML:

I have listed below topics discussed and bullet points I made during discussion. 

  1. Review subgroup recommendations on Packaging and Security
  • Universal symbol to identify product (Flowers and Oil).
  • Discussion of what constitutes a “batch” and labeling what exactly the parameters of a “batch” qualifies as (quantity of flowers or oil equates to batch=X).
  • Tobacco did not relabel packaging until 2008 taking away old notions of “Lite”, “Mild”, “Low tar,” which was used to make their products attractive.
  • Packaging must not contain health of physical claims.
  • If flowers should be pre packed quantities for sale or still allow hands on weighted product by tender at location of purchase.
  • Processor vs. wholesaler packaging, what labels are needed for distribution.
  • Allowing for transportation of product in larger increments based upon production center and grow center.

 

  1.     Discuss Packaging
  • Driving force of having Product prepackaged; ease of audit and control of inventory.
  • Reason behind control having 180grams of product then creating a humidifier  to increase weight from 180grams-240grams was argued amongst growers and control.
  • Washington does pre pack product for sale, Colorado does not.
  • Question of packaging some manufactures are using i.e. cans similar to tunafish style, and images attractive to kids a concern when packaging products.
  • Average package of cigarettes cost around five U.S. dollars which makes a single cigarette approximately twenty five U.S. cents.
  • Industry does not want to see its product sold similar to cigarettes which would equate to a buyer having to purchase 3.5 grams of 1.8 an oz rather than individual smaller increments.
  • Oregon is very liberal in free speech ideals which could create controversy for freedom of labels.
  • Creating a symbol similar to Mr. Yuck (Often placed as a sticker on bleach and other poison control products) to deem unattractive for youth.
  • Discussion of how product should be packaged for growers, wholesales, shop owners, and buyers. How labeling will affect product and what is needed to be labeled on product.
  • Oils opposed to flowers would be much easier to label and also control the amount of packaging and amounts needed. Flowers pose the largest controversy of how packaging and lab testing will affect orderly times for distribution throughout the year once recreational markets open.
  • Once Flower or oil is lab tested for pesticides no further labeling of pesticides found would be needed other than lab test results. Eliminating excessive labeling was of utmost concern.
  • Eliminating concern of consumers need to know every single chemical in process of manufacturing through excessive labeling.

 

  1.     Discuss Security
  • Regulating the security to keep Federal government happy.
  • Topic of 24/7 video surveillance imposed for safety of business, production, and grow centers opted during discussion amongst business owners.
  • Video surveillance should be sole properly of business owner rather than in the hands of OLCC was discussed.
  • Security of Lab tested products dependent on turnaround of Labs and how they will deal with demand of recreational product.
  • Concern of a Business having to utilize a safe, vault or standard of protection while also still being appealing to consumers and not attracting theft or diversion based upon know of location.
  • Indoor Vs. Outdoor grow Security, how much security should be imposed for outdoor grows based on land use laws of surrounding perimeters.
  • Keeping digital information on Cloud storage vs. hard storage in case of theft or diversion.

 

It is great to see the industry moving forward with state protocol for packaging and security, yet there is still a lot of work to do. The meeting was led by John Mountain an attorney who has specialized in large quantity grass seed purchases amongst golf courses. Peter Gendron represented growers with many points concerning packaging and security of what methods would be needed in order to create the best possible solutions for successful state legalization. It will be up to Executive Director Steve Marks in more upcoming meetings to see what the O.L.C.C. has in store for an industry that is creating new platforms for an industry that is still in its infancy.

-Joseph M. Lopez Jr.

I asked Joseph if the various conversations appeared to be coming to any conclusions, and he responded:

The discussions that took place did not formulate any sound conclusions for the areas of packaging and security. The grey areas of indoor and outdoor grow  area security are still being discussed with many variables that are being addressed. The only sound conclusion was that packaging of oils would come standard. The notion that it is much easier to keep inventory of oils, while the packaging of flowers could create mildew and other variances to the quality of the product.

We greatly appreciate Joseph helping to keep Portland NORML members apprised of the work of this committee!  There are still a lot of details to be worked out that are important to consumers and cannabis businesses and these decisions are being made in these various committees.   If you are interested in following a committee and reporting back to us, please contact me at [email protected]

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