Town hall meetings for Illinois’ medical marijuana program concluded this week. Draft applications for cultivation centers and dispensaries were pensive subjects. Questions focused on cannabis packaging, edibles, infused products and fingerprinting.
Journal-Star says “more than 100 people” attended Monday’s forum at Peoria’s public library, and most of their questions sought clarification of regulatory rules and draft applications.
A takeaway theme from the Journal-Star is that applicants are better off disclosing more information than too little. If something is questionable, you should explain it. (This is intuitive, not surprising at all, to a highly qualified application writer who is passionate about Illinois medical cannabis law and regulations).
“We prefer more information than less,” [said Bob Morgan, an attorney for the Illinois Department of Public Health and the coordinator of the Medical Cannabis Pilot Program]. “When there’s a question, we prefer more.”
“I would lean toward disclosure… If you don’t know whether to include something, go ahead and include it,” said Ray Watson, general counsel for the Illinois Department of Agriculture.
Preference for Illinois residents?… Out-of-state experience?
The Journal-Star says lawyers wanted to know if preferential treatment would be given to in-state residents or organizations with cannabis experience in other regulated medical cannabis states.
Several attorneys who spoke referenced either out-of-state clients interested in expanding businesses from other medical marijuana states or home state clients wondering how they could compete against others who already had experience in the trade.
“We try to find an appropriate balance between encouraging those with experience versus those based in Illinois,” Morgan said. “We’re stuck trying to find the most qualified with a limited number of licenses.”
Unlike Colorado, Illinois law does not have an in-state residency requirement for ownership or participation in a licensed medical cannabis business. Regulations make clear that specialized experience related to cannabis medicine is desirable, but it’s difficult to demonstrate legal cannabis experience in Illinois without partnering with or otherwise employing out-of-state talent. A small preference for in-state residents manifests itself in the form of bonus points attainable by showing a company and owners have real ties to the state, such as organizational headquarters and residency.
Packaging of cannabis buds, edibles, infused products?
Chicago Tribune estimates “nearly 300 people” attended Wednesday’s town hall in Chicago. Associated Press says it was “attended by more than 500 people.”
Both newspapers say cannabis packaging at cultivation centers and dispensaries was a focal point of the audience:
Will retailers be able to open a package of marijuana to give customers a whiff?” (is the lead sentence of AP’s article).
“…A lot of people do like to see what they’re buying,” said Roeper, an attendee who asked whether dispensaries will be able to open marijuana packaging to let customers see and smell the product. Illinois requires medical cannabis to be kept in child resistant, light-resistant packaging.
Roeper didn’t get a direct answer, but was told the Illinois rules require that marijuana from an opened package must be disposed of within a week in a way that makes it unusable. Presumably, retailers could open samples for customers to see and smell, then destroy samples each week.
One cannabis packaging company in Illinois is already abreast of the regulations and is providing cultivation centers and dispensaries with help on the Product Safety & Labeling Plan part of their applications. Fisher Container Corp. of Buffalo Grove has a child-resistant, tamper-evident pouch called the MEDI-CRREO which is proving popular among cultivation centers because it is flexible, light-resistant, and tamper-evident. A clever pinch and zip design makes the pouch child-resistant.
Entities providing cultivation services to more than one organization?
According to Associated Press:
A master grower can work for multiple centers, with a caveat: The rules bar a single entity from winning permits for more than three cultivation centers and five dispensaries. If one master grower is named as a principal officer by numerous applicants, that could jeopardize the chances for any one of the applicants, Watson said.
“We’re trying to avoid concentration of permits in too few hands,” Watson said. “If someone is participating in 15 different applications, they may be affecting the ability of those who are applying.”
Avoiding Massachusetts’ problems
Associated Press again:
James Watts, of Firm Systems Fingerprinting, asked whether fingerprint-based background checks would reveal out-of-state convictions. He was told the current system does not, but that applicants will be required to disclose such convictions.
… And please, do disclose and be honest about everything. For you own sake, for the sake of other applicants, for the State of Illinois, for patients, and for the sake of making real social progress with cannabis issues. Illinois can’t afford to end up like Massachusetts.