Thursday, January 29, 2015

NOTES FROM THE NEW DRUG WAR by Jessica LeRoux - Jan 29, 2015

Dear members of the Senate Finance committee,

I am writing today because I have had a chance to review SB15-1115 the sunset bill for SB10-1284. Since I don't see much flesh on that bone yet I'd like a chance to tell you what I see as the BEST way to move the medical industry forward.

Ideally we could do away with vertical integration or make it optional but not compulsory. At the very least we could do away with the 70/30 requirements ASAP. The problem with vertical integration is that when businesses went recreational in january of 2013 they were required to convert a portion of their dedicated medical grow space to do so. A majority of owners converted much greater than 50% of the grow space to recreational plants, and 20-30% of owners have done away with medical sales growing entirely. This means that the dedicated medical OPC space today is less than 35% of what it was in 2013. At this same time the medical registry has grown by approximately 8000-9000 people. It is imperative that there be adequate amounts of top quality medical grade cannabis to supply the needs of these patients in a safe retail setting.

One way to resolve this problem is to stop tying plant counts to specific patients on the Registry and instead adopt the sensible tiered model used by recreational OPC's. Set a plant limit for each level of licensing, and let owners decide what their OPC can support, and pay fees accordingly.

I have had a chance to review the Audit recommendations document from OSU that Senator Holbert mentioned might be able to be resolved legislatively. It appears that many still unresolved issues from Diane Ray's 2013 Audit of MED are being ignored in favor of cherry picking to use only those recommendations that support the anti-caregiver portions of HB15-014, a fact I find appalling. The 2013 Audit of MED also recommends doing away with the badging process if the MED fails to streamline it down to a single day process by 3-1-14, a date long past… As of this date it still takes 8-10 days for a badge applicant to be able to start their new job and begin earning a CO taxed paycheck. Why don't we look at legislatively fulfilling those Audit recommendations as well?
Going back to my concerns about the use of selective audit recs to pound one more nail in the coffin of caregivers, I need to make sure that you understand that as a patient it is imperative for me to be able to pick the VERY BEST provider of medicine for ME! Be that a MMC, an RMC, or a Private caregiver, it should not matter how many other patients agree with me that my choice of provider is the best provider. I simply want to decide that for myself and not be limited to a choice of substandard growers who cannot keep 5 patients happy. This is especially important in rural areas where retail of medical or recreational cannabis is banned. In the flat earth county known as Mesa a patient can expect to drive 2 hours in any direction before finding a single sales option, knowledgable caregivers are an important stop gap in areas that would rather bury their head in the sand than collect tax revenue.

Overlaying Rec edibles rules onto patients will be an unfair punishment of those sever pain suffers who rely on stronger medical doses of edible THC/CBD to curb their agony. It will mean they get diabetes before they get even a hint of relief. There are separate programs for Med and Rec for good reasons, patients are NOT know-nothing tourists. Furthermore given the complete lack of any edibles related fatalities EVER it is ludicrous to punish the patients who've been promised that our program would be left alone, in favor of lazy parents who can't keep their kids from stealing from patients, since that is how kids are getting these products. Child safe packaging is only effective in kids too young to read, once you understand the instructions its all fair game! There is always a responsibility to parenting that you can never legislate away. Parents in CO have never had a better intro into the difficult conversation about the family policy on substance use. If they fail to grasp it, parents should be punished, not patients.

Thank you for taking the time to read this, I look forward to Tuesday's hearing and hope some of these suggestions will make the cut before then.

Jessica LeRoux
MED Cannabis regulatory rule making board member.


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