California cannabisThis week, the Bureau of Medical Cannabis Regulation (BMCR) is holding its first pre-regulatory meeting for stakeholders to discuss topics related to the general licensing requirements for medical cannabis dispensaries, distributors, manufacturers, testing laboratories and transporters. The meetings will be held jointly with the Office of Medical Cannabis Safety (OMCS), which operates under the California Department of Public Health and is responsible for licensing manufacturers.

During each meeting, the agencies will provide updates on the development of medical cannabis regulations under the Medical Cannabis Regulation and Safety Act (MCRSA) and discuss issues relevant to all license types. Topics to be covered during each meeting include:

  • Owners and financial interest
  • Background checks
  • Priority for application review
  • Rehabilitation consideration factors
  • Local-government approval

Separate breakout sessions will be held for each license type. Since the breakout sessions occur at the same time, the agencies have asked that attendees only register for one session per meeting and have also asked stakeholders only register for one meeting location, which means anyone who is interested in multiple licenses types will have to pick one session to attend or send someone on your behalf.

For dispensaries, the breakout sessions will cover:

  • Subtypes of dispensary licenses
  • Employee requirements
  • Delivery requirements
  • Transaction limits

For distributors, the breakout sessions will cover:

  • Product quality assurance
  • Repurposing of medical cannabis
  • Labeling
  • Sample collection for testing purposes

For transporters, the breakout sessions will cover:

  • Shipping requirements
  • Transportation thresholds
  • Vehicle requirements

For manufacturers, the breakout sessions will cover:

  • Extraction methods
  • Minimizing incidental exposure
  • Variables in licensing fees
  • Standards or practices for quality and safety

For testing labs, the breakout sessions will cover:

  • Best practices for safety and quality
  • Analytes to test for
  • Variables in licensing fees
  • Practices or standards for statistically valid samples

Attendees will have several opportunities to provide input and the agencies state that they are interested in exploring any alternatives suggested. On their published agenda, the agencies also made sure to emphasize that any thoughts they share are not final and that neither licensing authority will be making any decisions on regulations during the meetings.

The stakeholder meetings will continue through September and October throughout California so there is still time to register, though several of the dates are already sold out. These pre-regulatory meetings are only the first step in the regulations process, however the agencies are currently still set on completing their rule-making by the end of 2017 with the goal to begin accepting applications on January 1, 2018. We will be following this process closely and will continue to provide updates as the agencies move forward, but for anyone hoping to get a state license under the new medical cannabis regulations this is the time to reassess your business plans and either provide your input or get ready to make some changes.