\tI 502 Draft Rules \tHere are some of the highlights of the I 502 draft rules:The Washington Liquor Control Board released its draft of I 502 rules on May 16, 2013. As Alan Rathburn noted in our last seminar, we will have 30 days to submit any ideas for changes to rules@liq.wa.gov. In mid June, they are expected to formally file the guidelines for I 502. The regulatory timeline will would end by later in August. LCB hopes that the rules will start being implemented at that time. LCB told us that this trial period is the time to make any changes and they are urging the public to submit ideas for any changes. They want to hear about the solutions that we can come up with for the problems that we might be facing. Here are only some basic areas of importance, as we see it, in the draft rules: \tI 502 Draft License Requirements Highlights\tBackground Checks Personal criminal history form with license forfeiture if incomplete or incorrect Fingerprinting of all potential licensees WSP and FBI background checks of licensees and financiers \tPoint System The LCB will apply a disqualifying point system similar to liquor Draft rules allow exceptions for two misdemeanor convictions of possession w/in three years \tProperty Leases License applicants must submit an affidavit signed by a potential landlord that he/she knows their property will be used for the cultivation, processing or retailing marijuana \tTaxes License applicants must submit a signed attestation that they are current on taxes owed \tI 502 Producer Structures Draft rules allow producer operations in secure indoor grows or greenhouses \tTraceability LCB will employ a robust and comprehensive traceability system (software) that will trace product from seedling to sale LCB enforcement can match records to actual product on hand One person or entity CANNOT own all three licenses \tBackground checks Personal criminal history form Fingerprinting of all potential licensees WSP and FBI background checks of licensees and financiers \tPoint System LCB will apply a disqualifying point system similar to liquor (with exceptions). \tViolation Guidelines $1,000 criminal penalty for sales to a minor Sets strict tiered system of violation record over a three year period. Example: Group 1 public safety: First violation: 10 day suspension or $2,500 Second violation: 30 day suspension Third violation: license cancellation \tSecurity Similar to Colorado: video camera requirements, no third party \tAdvertising Restrictions Law restricts advertising within 1,000 feet of schools, public parks, transit centers, arcades, and other areas where children are present \tLocation Restrictions of Retail Stores 1,000 feet from perimeter; 8 entities listed in statute Advance notice to local authority Board to determine number of retail outlets If the number of applicants in a county exceeds the limit, the LCB will hold a lottery. BOTEC determining county consumption levels. Consumption will drive retail outlets. \tConsumer safety Behind the counter storage No containers \tStrict packaging and labeling requirements Serving size Lot number Net weight Concentration of THC and five other cannabinoids Usage warnings (specific warning for indigestible foods/liquids about effect delays) Out of state removal warning (produced in Washington icon) Upon request Third party lab that tested lot All pesticides, herbicides, fungicides found in product \tServing size Defined serving sizes on label 10mg of THC per serving 100mg of THC per product \tStore signage and product warnings No minors allowed in stores Required product and usage signs within stores \tPotential Issues and Challenges Federal uncertainty Illegal at the federal level. No clarity about DOJ reaction Concerns expressed about controlling diversion Minimizing illicit market Balancing product demand with production and over-production Medical marijuana competing system that is largely untaxed and unregulated Banking Federal banking laws prevent marijuana-related businesses Taxation and pricing Will it be competitive? \tRemember we only have 30 days from draft issuance dates to submit any ideas. Email the LCB with your ideas for changes to rules@liq.wa.gov.
Is no one else bothered by the fact that the LCB wants to kill off medical cannabis in Washington....and they don't even have the LCB stores anywhere close to being open? In the public records request we filed, we also found out that they have discussed implementing "marijuana tax stamps" to show which pot is legal and which is "black market" illegal pot. Does this sound familiar to anyone? Isn't this exactly how the prohibition on marijuana started in 1937? Is this the new definition of "legalization"? It sounds an awful lot like the old definition of prohibition and complete government control of cannabis to me. Everybody OK with that whole concept? You're going to do all the growing and selling, risking federal prison, and the state will make all of the money and risk nothing? You can't really say too much about all the draft rules because you haven't seen them yet. As Clay points out, some of the most difficult issues were not dealt with at all in the first set of preliminary draft rules they released. You couldn't even put together a decent business plan with all the information that's currently missing from the rules. You don't know how much you can grow and you don't know how much it's going to sell for. Aren't those kind of critical parts to any business plan? How can you project revenue when you can't project sales, or the cost of sales? And without a bank account, how will you be paying your taxes? One thing you can be sure of, the state cartel stores will not be able to compete with the black market. If you kill off medical, those people are NOT going to stop growing and selling....we all know that. Now you've just expanded your black market supply with high quality products (including concentrates that the stores won't have) at a much lower price than the LCB stores....and with far less overhead. How's that supposed to work, exactly? We all know the answer to that. How many people are going to pay $40 a gram when they can buy it from their friends at $10? We know that answer too....it's "damn few". The LCB has missed every one of their own deadlines so far....including this latest one. June 13th just became July 3rd and they are now behind schedule. If changes have to be made to the rules, that will cost them another two months because they have to start all over again with the CR101 process....they've already said this publicly. So if you're doing a timeline for yourself, pencil in February for the licenses to be handed out. If they kill off medical, that vote will happen in January, and no later than February because it's a short session next year. Ninety days from the time they pass the bill to kill medical, the law will go into effect....so May at the very latest. They can't have the cartel stores up and running before July or August because there won't be any cannabis ready until then. So for a period of at least three month, there will only be black market cannabis available to anyone. Since most of you that don't get I-502 licenses are not going to stop growing, the cops will have a "target rich environment". Those with licenses will be snitching off those without them because no one will buy from their cartel stores when they can get it from former medical growers and get better product, including concentrates, far cheaper. That won't solve their problems because, if history has taught us anything, it's that you can't kill off a black market with high prices. So the I-502 model will fail. When it doesn't bring in the promised revenues, the state will kill off 502....just as the Colorado legislature has already promised to do with 64 if they don't get the anticipated tax revenues. So if they kill off medical, and then do the same to I-502 when it produces less in revenues than the system costs to maintain and regulate, we will go back to where we were in Washington seventeen years ago. And we'll be behind that states that are just now passing medical. And if we let them kill it off here, how long will it be before we can afford to pass a new initiative for either medical or recreational. Sadly, no one seems to concerned, let alone angry about this. Maybe they won't be until it's too late to do anything about it or until they get arrested. Me, I'll quit growing. Growing will be a class B felony if they kill medical and you don't have an LCB license. I'm too old to want to spend the rest of my life in prison. Maybe I'll just move back to Hawaii....the weather is better there anyway and there are plenty of cute girls in small bathing suits. Steve Sarich Cannabis Action Coalition
Steve....talk about overreaction, dude, I-502, while not perfect, absolutely will NOT kill the medical law, maybe the greedy dispensary owners who like to call themselves "providers". I am so tired of people bitching about this law, it's a HUGE first step in federal legalization and anybody who isn't with that can kiss my ass. So there. Sent from my HTC VLE_U using Grasscity Forum mobile app
Steve,,if they "killed" the mmj law in WA,,would you quit growing your own or using marijuana as a medicine? If they overturned I-502 tomorrow do you think anyone would quit? Whatever laws they screw up now can be fixed,,including the DUI law and no personal grows,,,just keep spreading the herb and the knowledge,,attrition and maryjane will take care of the rest.
Sorry....I'm not kissing your ass. I'm sorry you still have blinders on and you apparently don't watch the news much. We're marching on Olympia next week because they've put an amendment into the budget bill that will end up turning control of medical marijuana over to the Liquor Control Board....the same Liquor Control Board that has stated that medical marijuana is the biggest threat to the success of their I-502 model. Didn't know that? Not paying attention? Watch the news next week....it's happening. Remember the promises? That wasn't supposed to happen, right? Kiss MY ass.
I like that same old bullshit. It's OK to fuck it up now....we can fix it later....right? We have 3 more per se DUID bills going through the legislature right now. When exactly were you planning on fixing the FIRST one? When they take away personal grows from patients, when do you plan on introducing your bill for personal grows for everyone? No...few people will quit growing even if they pass this new amendment next week. They'll keep growing and eventually a lot of our friends will simply go to jail for Class B felonies. I guess that's OK with you? When you go to jail for your DUID and you're not stoned....you're OK with that too? If the answer is "yes", that you're OK with going to jail for new marijuana crimes, and you insist on calling that "legalization", I'm afraid there's really nothing I can say to you. Keep spreading shit on your toast and calling it jam if that works for you.
You are a joke Sarich,,quit sitting around waiting on someone else to do it and do it your self,,so far your biggest contribution to legalization has been a steady stream of bitching and sniveling,,have you done one thing positive for legalization except bitch about what others are doing?
Well I-502 didn't do it....but you seem OK with that fact. So what are YOU doing to legalize it? That's not my job....I have a job already. My job to protect patients and keep them out of harms way. That's a big enough job to tackle...and I-502 is making that job tougher every day. I'm just completing my DRE (Drug Recognition Expert) certification so that I can be an expert witness in court and save your sorry ass from that per se DUID law....if I can. That's costing thousands of dollars so the I can protect patients that are going to jail even when they aren't the slightest bit impaired. I know....you don't care. And you won't till you find yourself in jail and don't know what to do next, besides cry about how unfair the law is.
Wow....protect patients Steve...what a joke...all you do is spout off how bad I-502 is for medical and how police will be filling jails with duid's. The law has been in effect for 7 months now and I have yet to see or hear of any dramatic increase in duid's. Quit using your scare tactics to frighten patients who you claim to "protect.". What a bunch of BS. Sent from my HTC VLE_U using Grasscity Forum mobile app
Steve, Well thanks for protecting patients from the strawman in the closet. You are as bad as the anti-pot faction,,you try to scare people with what may happen but there is no evidence to support your fears,,only rhetoric. Before any prosecutor can convict anyone of a dui for having 5 nano's of cannabis metabolites as positive proof of impairment they will have to show that it does,,with the recent screening of the drivers with three to five times that amount driving an obstacle course with cops watching and still not seeing driving that would have them stopping any of the drivers for impaired driving it is a long way from happening. Tell me Steve,,how much do "professional" witnesses make off defendants requiring the "trained" professional witness? There is a guy in TX that does that and he has made millions,,going all over the country,testifying in trials for the prosecution on the dangers of marijuana and the crazed addicts that use it,,,his business is falling off rapidly and he is whining about his lost income,,,I guess we can always hope to hear how you wasted your money getting qualification for something you may never use.
I know plenty of medical patients here in Washington and they all have had the same view on steve and his "medical marijuana businesses" shady, unprofessional, and just plain in it for the money. Steve you are just as crooked and money hungry as the politicians you bash. God you are a joke.
But it legal who cares. SMH. Don't worry bro we got plenty of room for ya down in ca. 99 personal plants with no prob. We are not going to fall for that BS down here.
