Information Session with BMMR
On June 1, 2016, officials from the Bureau of Medical Marijuana Regulation (BMMR) help an information session in San Francisco. We were there to report what happened.
Details are below, but the key points were:
BMMR and other responsible agencies will kick off the process of drafting regulations with pre-regulation meetings with stakeholders on specified topics later this year, with draft regulations to follow in the spring of 2017.
BMMR wants input fron the public and stakeholders. They've set up a survey for that purpose, or you can just email them at email@example.com. They will share that with the other agencies if you give consent.
The regulatory development process also provides opportunities for public input after publication of draft regulations. The best chance for regulations that make sense is consistent and focused attention from the industry, at every stage.
Here is more context and detail.
The location for the meeting, a conference room in San Francisco Police Headquarters, is steeped in irony. This was heightened by two burly uniformed police officers walking into the meeting and sitting in the front row just as the meeting was starting.
Lori Ajax kicked off the meeting and introduced herself as Bureau Chief of BMMR. BMMR has been holding these meetings across the state. Ajax's background is in alcohol, and she is working to learn the cannabis industry. She explained the she has been hiring staff at BMMR, and hopes to grow the team to 15 strong.
Ajax introduced two other speakers: Tamara Colson, who will soon assume a role as assistant chief counsel at BBMR, and An-Chi Tsou, senior policy advisor at BMMR.
Ajax explained BMMR's role as compared to other responsible agencies. BMMR, under the Department of Consumer Affiars, will license and regulate dispensaries, distributors and transporters. Department of Food and Agriculture will license and regulate cultivation and run the track/trace program. Department of Public Health will license and regilation manufacturing and testing. All of that could change with legislation.
Ajax reiterated the the goal is to accept applications by January 2018. This requires all regulations be finalized by December 2017.
Tamara Colson reviewed the rulemaking process. She outlined the key steps:
- Pre-regulation meetings with stakeholders on targeted topics
- Drafting regulations by the teams of lawyers of the agencies (BMMR/DCA, DFA, DPH)
- Public notice of the draft regulations to interested parties (by email or mail) and through the notice register (a state publication)
- Public comment
- Any changes to draft regulations, followed by more public comment (may repeat)
- Final approval by agency head (DCA/DFA/DPH) and Office of Adminstrative Law
- Sent to Secretary of State and put into effect
There was also an extensive comment and question period run by An-Chi Tsou. Ms. Tsou, who previously had a key role running MMRSA through the legislature, showed a strong command of the issues and the legislation.
Very little new information was revealed during the comment and question period. Most folks wanted answers to questions that will have to await regulatory development. There were also many questions about county and city regulation and licensing, which BMMR cannot address except to say that under BMMR, local authorization is required for a state license.