Public Comments on the co-location of Adult-use and medical-use marijuana operations:
Chairman Hoffman, Commissioner Title and other distinguished members of the Cannabis Control Commission, I want to thank you for the opportunity to speak about 935 CMR 502.000 Colocated Adult-use and medical-use marijuana operations.
Our biggest concerns here at MRCC are the following:
- Two sets of regulations for labs to follow if testing medical-use and adult-use products
- The commission delegating authority to the Executive Director
- To start off, we are very confused why two different regulations are required for labs looking to test both medical and recreational Cannabis products.
Labs that test medical marijuana face additional fees and requirements in order to be certified by the commission to test recreational marijuana. As you know, it costs $300 to apply and $5,000 a year for the license. Medical marijuana labs don’t have any of these fees.
Labs seeking permission to test recreational marijuana in Massachusetts must also negotiate host community agreements with the city or town in which they’re located. Host community agreements are not required for labs certified to test medical marijuana.
We believe labs should have 1 license for both medical and recreational testing in order to remove barriers to entry.
2. According to 502.700: Waivers;
“For CMOs, in addition to waiver provisions set forth in 935 CMR 500.700 and 935 CMR
501.700, the Commission may delegate its authority to the Executive Director to waive
administrative regulatory requirements under either 935 CMR 500.000 or 935 CMR 501.000. The Executive Director may determine the process or manner of the waiver process, including whether a registrant, licensee or applicant is required to request a waiver in writing. There can be no waiver of statutory requirements. A waiver of the regulatory requirements cannot pose a risk to the public health, safety or welfare.”
We are confused: why would the executive director, who does not have a scientific background in marijuana, be granted such power? Regulations should not be bypassed by the executive director.
Thank you,
Kamani Jefferson, President
617-245-8646 (cell)