mmpr growers frequently asked questions
DESCRIPTION
TRANSCRIPT
To Green House/Warehouse Growers: (Sensitive, Private & Confidential)
Action Plan after hours of research to apply for MMPR Producers License:
822476 Ontario Inc. P.O. BOX 1500 Woodbine Avenue, Toronto, Ontario, M4C 4G9 Canada
www.CanadaMedicalCannabisGrowersCoop.ca Cell 1-647-999-9993 bus: 1-416-519-0266
HST 106580798 RT0001 [email protected]
Health & Welfare Documents: http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/index-eng.php and
http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/add-supp-eng.php
Checklist Action Plan: Attention 15 page application has been updated & is attached partially filled in:
1. Download and print all above web documents which I usually have attached previously.
2. 15 page application is filled in partially to help you get approved and help give your location
privacy on MMPR Producers web site with our Growers Coop / Marketing above contact info.
3. ExperChem Lab’s Terry Pilkey, B.SC., DPCT (Hon.), C.Chem Regulatory Affairs Director will act as
your Qualified Person in Charge with degrees & worked for Health & Welfare. When you
forward attached quote signed with $5000.00 retainer who then will send by e-mail Standard
Operating Proceedures SOP questionnaire; that will help them fill in SOP for your application.
ExperChem Labs will be your Health & Welfare contact (no need to hire other consultants,
lawyers etc…) They save you money hiring a Qualified Person In Charge. They will bill you
monthly for more work which is booking onsite advice and training to your usually a family
member that will not leave company while inspecting property with advice on security,
sanitation, & qrowing techniques etc..which are listed in above downloadable docs links.
4. Submit copies of 3 letters with below suggested letter to Mayor, Police and Fire Chiefs showing
modified GreenHouse / Warehouse drawings incorporating all security, infrastructure, barbed
wire fences, shipping/vault/storage/curing room. Canada Flowers vendors list: Gerry Harrison
http://www.ggs-greenhouse.com/ 905-562-7341 & Growers Requisites 1915 Setterington Dr.
Kingsville Toll Free: 1-800-819-8776 [email protected] www.greenhousepoly.ca Jeremy.
5. Fill in 7 page Security background check for all persons that will be any rooms: SECURITY
CLEARANCE APPLICATION FORM MARIHUANA FOR MEDICAL PURPOSES REGULATIONS and
take it in with 3rd party fingerprint form to accredited Digital Fingerprinting (see below)
6. Please understand you are replacing over 15,000 MMAR growers supplying over 30,000
registered patients by March 31st, 2014. Your job is grow another flower which you do now but
get your applications, fingerprints, and hiring a Qualified Person in Charge such as ExperChem
Labs in ASAP. Then you have to immediately hire contractors to make your required changes
since with all above done properly with over 100 applications that they are looking for all items
properly filled in and submitted or will return package to resubmit. The pre inspection call can
happen at any time and if still not ready you can give them an extended date. ACTION WINS.
This is a daunting project however revenue projections below will hopefully overcome fear of
ACTION. The http://www.flowerscanadagrowers.com/flower-growers/directory has banking,
vendors, and suppliers lists that will support ACTION. Download hundreds of pages E-Books
strains & growing techniques: http://www.howtogrowweed420.com/1036.html see local
bedding green house www.mmar.ca . You can add clay stones to absorb extra water with
aeration pipes and if new cement floors put heated water radiant heating keep bedding warm
with less labour re-potting & also allow up to 4x4 allows to lay plant down producing 25%++.
7. The http://www.howtogrowweed420.com/1036.html how to start from seed or cuttings which
if you know any legal MMAR grower who if not getting new MMPR license thus will want to
move production to you to help their patients out which when you are approved will give you
the documents to do this. So the key is ACTION before MARCH 31st 2014 before they have to
destroy all product. Also you can trade within Coop to have multiple strains available.
8. The BioTrack THC Growers software demo http://stme.in/xr2UNM64l We are getting Coop
pricing saving a couple hundred per month linking up all Coop growers so I can see who has
inventory when patients are approved to buy www.CanadaMedicalCannabisGrowersCoop.ca
Megan Greene • [email protected] BioTrackTHC 1173 S. Huron St. Denver, CO
80223 http://www.BioTrackTHC.com • Phone: (720) 398-6421 • Fax: (720) 274-5671
9. When we are listed on Health & Welfare’s approved Producer’s website: Patients will send to
P.O. Box original medical form with up to 150 grams per month allowed; signed by Doctor or
Nurse Practioner which I will verify and forward on to grower that patient picks strain in stock,
place future and in stock orders for certain strains, packing slip and barcoded labels on child
proof up to 30 gram containers is there legal right to possess in Canada. The E-commerce
platform and above BioTrack THC software will track how many grams each grower sold so I
can pay at end of month planned $6. & $2-4 Sweet Leaf per gram (see below revenue formula)
Normal merchant accounts can be cancelled if selling retail. I have high risk merchant account.
Please forward to me the 15 page digital application attached using 30 day free Adobe Acrobat
http://www.adobe.com/cfusion/tdrc/index.cfm?product=acrobat_pro&loc=us&promoid=KHXXW
which I can review then see #3 instructions to send to ExperChem Laboratories Inc. 1111 Flint
Road, Unit 36 Downsview, ON M3J 3C7 with $5000.00 retainer to get her signature & answer
their SOP questionnaire who then submit your SOP & completed applications (see above links
and my attachments) to become a Licensed Producer under the Marihuana for Medical
Purposes Regulations, including all applicable attachments by registered mail to:
Controlled Drugs Section, Licences and Permits Division, Office of Controlled Substances
Controlled Substances and Tobacco Directorate, Health Canada
150 Tunney’s Pasture Driveway, Tunney’s Pasture, A.L.: 0300B
Ottawa, ON K1A 0K9
All relevant sections of the application form must be completed and all required documents
must be submitted. An incomplete application will not be processed. If your application is
incomplete, it may be returned to you.
Congratulations you survived the fun instructions however please feel
free to pass on to associates; to help fellow growers grow the
business (no pun intended)at up to $6. Per gram. I am helping other
grower’s fill in below and attachments application’s for FREE
(ExperChem Labs will do just app for $2000.+ $150 per hour) with all
supporting docs at these link’s and attachment’s if they wish to join
www.CanadaMedicalCannabisGrowersCoop.ca ready to take future orders
when first grower approved. For $2 per gram I will offer to be the
Coop’s marketing board to provide e-commerce due to major Canadian
Banks merchant accounts and online banks credit cards do not wish to
handle what they rate high risk transactions. I will aim be only
contact on your behalf on MMPR’s Health & Welfare’s site when you are
approved after doing below security upgrades and attached above paper
work. I suggest highly print all documents I attached from above
links and read security requirements implementing upgrades since
every grower will be approved with no volume restrictions if you
follow all guidelines and laws. I also with my associates will search
for Doctors/Nurses to provide patients original medical form which
will be mailed to our P.O. Box to enroll in our service. Patients
will have to pay us what the going market rate will sustain which
Health & Welfare has suggested at $8. per gram (see below $1.344
million is what each 2,000 square feet could produce) with creative
programs of selling sweet leaves for $2-4 per gram what market will
buy which help’s patients create medicine by vaporizing, teas, oils,
edibles etc. to help their pain and curing of many diseases that are
now wide open to Doctor’s permission to help. Information for Health
Care Professionals Cannabis (marihuana, marijuana) and the
cannabinoids; 158 page PDF from Health & Welfare
http://www.hc-sc.gc.ca/dhp-mps/marihuana/med/infoprof-eng.php
Health & Welfare Documents:
http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/index-eng.php and
http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/add-supp-eng.php
Health and Welfare’s MMPR application attached to grow Medical Cannabis
shipped direct to patients from your greenhouse shipping area modified to
store narcotics you have to refer to 54 page Health and Welfare to see
what Security Level you would be at if more or less 50km from major city
listed. How much Medical Cannabis you will store in Vaults they describe:
http://www.hc-sc.gc.ca/hc-ps/alt_formats/hecs-
sesc/pdf/pubs/precurs/dealers-distrib/phys_securit_directive/psreqs-
eng.pdf
Of course many infrastructure upgrades will be needed; however to give
you incentive to consider this project; the gross revenue on 4,000 square
feet would be approximate $2.688 million if below formula happens.
Greenhouse 2000 square feet: Take your square feet you are starting with
average width of plant up to 4x4 square feet 2000/16 square feet = 125
plants x 16 oz. = 2000 Oz’s / (35.27ozs= 1kg) every 12 weeks depending on
strain, light, cleanup, harvesting, drying, curing etc..) x 4 crops a
year =8000oz x 28 (equals oz.) = 224,000 grams x $6.00= $1,344,000
growers gross revenue. The loose leaves/shake could be sold @ $4.00 per g
Of course this gross revenue will be less with lower producing strains.
Videos growing techniques: Dr.Sanjay CNN Weed, Colorado, Canada Weed Wars
https://www.youtube.com/watch?v=Z3IMfIQ_K6U
https://www.youtube.com/watch?v=GhTYI3DeNgA&feature=player_detailpage
https://www.youtube.com/watch?v=1rEbBB-Hfoc
http://www.truliteled.com/video-tutorial-on-curing-cannabis/
With a reported value of over six billion dollars, it's no secret that
marijuana in British Columbia is big business. However, due to the recent
legalization of recreational and Medical Cannabis in Washington and
Colorado, (total 21 states) the draconian crime laws pushed forward by
the Canadian Conservative government's omnibus crime bill, and recent
changes to medical marijuana regulations, the entire industry is suddenly
facing an identity crisis.
Below template up to xxxxx’s could be used to notify while not asking
permission to Police Chief, Mayor’s Office, and Fire Chief putting in
contact info in attached 15 page application & submit drawings to ALL:
“I have submitted a MMPR application to become licensed producer, which
under the requirements it’s asked me to put your contact info that I
notified you of my intentions to comply under new Marihuana for Medical
Purposes Regulations, including, but not limited to: obtaining the proper
personal security clearances; meeting the physical security requirements
for the cultivation and storage areas. For further information:
http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/index-eng.php
[email protected] or call us at 1-866-337-7705.
8.1 A licensed dealer is authorized to have a narcotic in their
possession for the purpose of exporting the narcotic from Canada if they
have obtained the narcotic in accordance with these Regulations or the
Marihuana for Medical Purposes Regulations. SOR/97-514, s. 1; SOR/2013-
119, s. 204. Previous Version 8.2 To be eligible for a dealer’s licence,
a person must be
(a) an individual who ordinarily resides in Canada;
(b) A corporation that has its head office in Canada or operates a branch
office in Canada; or
(c) the holder of a position that includes responsibility for narcotics
on behalf of a department of the Government of Canada or of a government
of a province, a police force, a hospital or a university in Canada.
SOR/2004-237, s. 4.
8.3 (1) A licensed dealer
(a) shall designate one qualified person in charge, who may be the
licensed dealer if the licensed dealer is an individual, who must work at
the premises specified in the licence, have responsibility for
supervising activities with respect to narcotics specified in the licence
and for ensuring, on behalf of the licensed dealer, that those activities
comply with these Regulations and the Marihuana for Medical Purposes
Regulations; and
(b) May designate an alternate qualified person in charge who must work
at the premises specified in the licence and have authority to replace
the qualified person in charge when that person is absent.
(2) The qualified person in charge and, if applicable, the alternate
qualified person in charge
(a) shall be familiar with the provisions of the Act and the regulations
under it that apply to the licence of the licensed dealer who designated
them and have knowledge of chemistry and pharmacology and experience in
those fields to properly carry out their duties;
(b) shall either
(i) Be a pharmacist or a practitioner of medicine, dentistry or
veterinary medicine, registered with a provincial professional licensing
authority, or
(ii) possess a degree in an applicable science — such as pharmacy,
medicine, dentistry, veterinary medicine, pharmacology, organic chemistry
or chemical engineering — that is awarded by a Canadian university or, if
awarded by a foreign university, that is recognized by a Canadian
university or a Canadian professional association; and
(c) Shall not have been convicted, as an adult, within the preceding 10
years, of (i) a designated drug offence, (ii) a designated criminal
offence, or (iii) an offence committed outside Canada that, if committed
in Canada, would have constituted an offence referred to in subparagraph
(i) or(ii).
Attached is the Quote for analytical testing from 3 narcotic labs.
As you know, Division 4 of the MMPR deals with Good Production Practices
which consist primarily of Quality Assurance activities. These activities
include; testing for Microbial and Chemical Contaminants, Pest Control
Products and Analytical testing for the percentages of delta-9-
tetrahydrocannabinol, cannabidiol and cannabinol (THC, CBD, CBN). A copy
of Division 4 of the MMPR is attached “Division 4-MMPR”.
Furthermore, in the Marihuana for Medical Purposes Regulations (MMPR),
each batch or lot of dried marihuana must be approved for release by the
LP’s Quality Assurance person, who must have the training, experience and
technical knowledge relating to the activity conducted and the
requirements of Division 4 of the MMPR. ExperChem can perform this
function on your behalf however we can act as a Quality Assurance Person
on your behalf. See attached quote A Quality Assurance person would; Terry Pilkey, B.SC., DPCT (Hon.), C.Chem Regulatory Affairs Director
Help you with our QA/QC protocols for compliance with Division 4. (please
see attached)Have the technical knowledge to be able to assess analytical
testing results in order to be able to make the determination of whether
the dried marijuana is suitable for sale. Help investigate quality-
related complaints (analytical testing) and help take corrective and
preventive actions, if necessary. If you have any questions, please feel
free to call me.
Lisa Plante & Sohil Mana 416-665-2134 Ext. 298
416-665-9251
QA Director
ExperChem Laboratories Inc.
1111 Flint Road, Unit 36
Downsview, ON M3J 3C7
1-866-610-5576
www.experchemlab.com
Guidance: Signage and Physical Barriers
If your site is a stand-alone building, or a space within a building that
shares walls, then physical barriers and signage posted at the perimeter
and entrance to your building/space can assist in ensuring that your site
is secure. The main purpose is to prevent unauthorized access and to act
as a definite demarcation. Physical barriers are required for securing
all areas within a site where cannabis is present. Physical barriers
should provide sufficient resistance to impede unauthorized access to the
premises where cannabis is present. For example, a physical barrier of
some kind (e.g. a fence surrounding the site) and a sign stating that it
is private property or a restricted area and that unauthorized access is
prohibited are appropriate. Guidance: Entrances, Doors and Frames
Minimizing the number of entranceways to the site and areas within a site
where cannabis is present will assist in securing and monitoring the
space; however, it should remain consistent with fire and building safety
codes. Securing all entrances to the building, site or areas within a
site where cannabis is present would prevent unauthorized access. For
example, entranceways to areas within a site where cannabis is present
could be equipped with commercial steel doors and frames. Doors may be
specified as fire rated where required. The doors could also be equipped
with the appropriate locking hardware, door closers, contact switches,
and electronic access control mechanisms (biometric fingerprint), to
assist in providing appropriate security against unauthorized access.
Keeping your entranceways closed and locked to the extent possible given
your business operations can assist in ensuring that your site and areas
within a site where cannabis is present are secure. Keeping doors and
entrances to the areas within your site where cannabis is present closed
at all times with an operational intrusion detection system on (alarm
system that operates at all times) would further prevent unauthorized
access. Guidance: Openings, Ducts and Mechanical/Electrical Pass-Throughs
Minimizing the number of openings, ducts and pass-Throughs in your site
and areas within your site where cannabis is present will assist in
preventing unauthorized access. Protecting all other openings with
security screens, steel bars or equivalent material, welded to steel
frames will assist in preventing unauthorized access to your site. The
screens and bars are most effective in preventing unauthorized access
including quick entry, grab and exit type intrusions. Where appropriate
to accommodate pipe or conduit movement or expansion, pipes and conduits
can be enclosed in a close-fitting sheet metal sleeve and fastened to a
frame to provide appropriate security. Guidance: Wall Construction the
walls of your site should be constructed to assist in ensuring that
unauthorized access to your site and areas within your site where
cannabis is present is prevented. For example, slab-to-slab construction
and steel mesh sheets attached to the underside of structural joists can
assist in ensuring wall security. Guidance: Glazing Panel Security
Appropriate use of glazing panels can assist in ensuring that
unauthorized access to your site is prevented. For example, any glazing
panels used in roofing (in a greenhouse for example) should be attached
directly to the roof structure in such a manner as to preventing removal
from the outside. Building security can be further ensured by using
appropriate electronic equipment to monitor glazing elements, including
sensors that can detect breakage of glazing panels. Mechanisms that can
provide secure monitoring of glazing elements include at least one of the
following: • Glass-break sensors of sufficient number may be
appropriately installed to provide 100% coverage of the glazing area. •
Electrically conductive foil or wire can be incorporated in the glazing
elements to provide detection of breaks.• Volumetric or beam-break
detection systems can be employed to provide 100% coverage of the
interior surface area of the glazing.5.2 Regulatory Provisions Relating
to Monitoring and Detection Perimeter of the Site MMPR s43. (1) The
perimeter of the licensed producer’s site must be visually monitored at
all times by visual recording devices to detect any attempted or actual
unauthorized access. MMPR s43. (2) The [visual recording] devices must,
in the conditions under which they are used, be capable of recording in a
visible manner any attempted or actual unauthorized access. MMPR s44. The
perimeter of the licenced producer’s site must be secured by an intrusion
detection system that operates at all times and that allows for the
detection of any attempted or actual unauthorized access to or movement
in the site or tampering with the system. MMPR s45.(1) The system must be
monitored at all times by personnel who must determine the appropriate
steps to be taken in response to the detection of any occurrence [of
attempted or actual unauthorized access]. MMPR s45.(2) If any such
occurrence is detected, the personnel must make a record of: the date,
time of the occurrence; and the measures taken in response to it and the
date and time when they were taken. Areas Within a Site Where Cannabis is
Present MMPR s48.(1) Those areas [within a site where cannabis is
present] must be visually monitored at all times by visual recording
devices to detect illicit conduct. MMPR s48.(2) The devices must, in the
conditions under which they are used, be capable of recording in a
visible manner illicit conduct. MMPR s51.(1) The intrusion detection
system must be monitored at all times by personnel who must determine the
appropriate steps to be taken in response to the detection of any
occurrence [of illicit conduct, any attempted or actual unauthorized
access to or movement in those areas or tampering with the system]. MMPR
s51.(2) If any such occurrence is detected, the personnel must make a
record of: the date, time of the occurrence; and the measures taken in
response to it and the date and time when they were taken. Guidance:
Video Coverage Visual monitoring of the perimeter of your site, as well
as the areas within your site where cannabis is present can be achieved
using closed circuit video equipment (CCVE). Appropriate lighting
equipment in conjunction with CCVE can assist in the detection,
classification, assessment, and recognition of the images recorded.
Camera should be in sufficient number and appropriately located to cover
the area to be monitored. Guidance: Redundancy and Back-Ups Keeping all
cameras recording 24/7, and having appropriate back-up mechanisms in
place can achieve the appropriate coverage to detect illegal activity,
unauthorized access and any attempts to breach the security of your site
and of the areas within your site where cannabis is present. Back-up
mechanisms must ensure that all visual recordings and records of a
detected occurrence be retained for two years. These back-up mechanisms
may include storing the visual recordings on multiple media devices. 5.3
Regulatory Provisions Relating to Access Control MMPR s42. The licensed
producer’s site must be designed in a manner that prevents unauthorized
access. MMPR s46. (1) Access to each area within a site where cannabis is
present must be restricted to persons whose presence in the area is
required by their work responsibilities. MMPRP s46.(2) The responsible
person in charge or, if applicable, the alternate responsible person in
charge must be physically present while other persons are in those areas.
MMPR s46.(3) A record must be made of the identity of every person
entering or exiting those areas. Guidance: Securing access to the site
perimeter and areas within a site where cannabis is present There is a
wide range of appropriate electronic access control systems, including
intrusion detection mechanisms and CCVE that may be employed to ensure
that access to the site, and areas within the site where cannabis is
present, is restricted to the appropriate personnel and that a record is
kept of each person entering or exiting those areas. The system that you
install must be capable of identifying each individual who enters or
leaves restricted areas to comply with regulatory requirements. A
personal identification number (PIN) credential system alone is not
sufficient for access control because PINs can be purposefully or
inadvertently disclosed. For example, a security system that requires a
PIN and an identification card, or biometrics and visual monitoring are
examples of ways to prevent both unauthorized access to those areas
within a site where cannabis is present, and keep track of the movements
of personnel that enter and leave those areas. Guidance: Security System
Control Mechanisms Steps should be taken to ensure the appropriate
control of codes, keys, combinations and other elements of your security
system. For example, to ensure appropriate security, only senior
personnel including the senior person in charge, the responsible person
in charge and any alternate responsible persons in charge should have
access to alarm codes, vault combinations and other security elements for
the site. Changing combinations and codes on a regular basis and when
there are any changes with any senior personnel will assist in ensuring
appropriate control of the security system. 5.4 Regulatory Provisions
Relating to Intrusion Detection Perimeter of the Site MMPR s44. The
perimeter of the licenced producer’s site must be secured by an intrusion
detection system that operates at all times and that allows for the
detection of any attempted or actual unauthorized access to or movement
in the site or tampering with the system. MMPR s45.(1) The system must be
monitored at all times by personnel who must determine the appropriate
steps to be taken in response to any occurrence of an attempted or actual
unauthorized access to or movement in the site or tampering with the
system. MMPR s45.(2) If any such occurrence is detected, the personnel
must make a record of: the date, time of the occurrence as well as all
measures taken in response to it and the date and time when they were
taken. Areas within a site where cannabis is present MMPR s49. Those
areas [within a site where cannabis is present] must be secured by an
intrusion detection system that operates at all times and that allows for
the detection of any attempted or actual unauthorized access to or
movement in those areas or tampering with the system. MMPR s51. The
intrusion detection system must be monitored at all times by personnel
who must determine the appropriate steps to be taken in response to the
detection of any occurrence [of illicit conduct, any attempted or actual
unauthorized access to or movement in those areas or tampering with the
system]. A robust intrusion detection system can assist in securing both
your site and areas within your site where cannabis is present. Guidance:
Monitoring your site’s perimeter and areas within your site where
cannabis is present via an intrusion detection system with personnel in a
central location will allow your personnel to detect any unauthorized
attempts to enter those areas; or to tamper with security equipment.
Appropriately trained personnel will assist in responding to any incident
involving detected unauthorized activity. When there are no responsible
personnel present, a link to a monitoring station will enable
notification to the appropriate personnel and law enforcement. A response
plan should be designed to ensure quick action when detection has
occurred. Guidance: Records of Detected Matters Keeping all cameras
recording 24/7, and having appropriate back-up mechanisms in place can
achieve the appropriate coverage to detect illegal activity, unauthorized
access and any attempts to breach the security of your site and areas
within your site where cannabis is present. Back-up mechanisms must
ensure that all visual recordings and records of a detected occurrence be
retained for two years. These back-up mechanisms may include storing the
visual recordings on multiple media devices. Guidance: Tampering the
effectiveness of any system is dependent on the signal reaching the
individuals responsible for the monitoring of the signal and the response
to its warning. Depending on how the signal is carried, tampering with
the line carrying the signal may result in the signal not reaching its
intended destination. An acceptable system should be able to identify,
record, and notify if the lines are tampered with or if an attempt has
been made. A response plan should be designed to ensure quick action when
tampering occurs. Guidance: Power Supply In order to comply with
regulations, your security system must include visual recording devices,
access control and an intrusion detection system which must operate on a
continuous basis. For example, supporting your security system and all
components (e.g., sensors, control units and communicators /enunciators,
volumetric sensors, glass-break detectors, beam-break sensors) with an
uninterruptible power supply sufficient for 24/7 continuous operation
would effectively maintain the integrity of your security system. 5.5
Regulatory Provision Relating to Air Filtration MMPR s50. Those areas
[within a site where cannabis is present] must be equipped with a system
that filters air to prevent the escape of odours and, if present, pollen.
Guidance: Air Filtration to assist in the prevention of the escape of
pollen, odours, and other particles, all exhaust air from your
cultivation area and other areas within your site where cannabis is
present can be filtered through appropriate air filtration systems. For
example, a high-efficiency particle air filter such as a H13 HEPA filter
can ensure appropriate ventilation and filtration of exhaust air.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Local buyers guide: http://leamingtongrower.com/buyers_guide
http://www.rcmp-grc.gc.ca/cr-cj/ps-sp-elect-eng.htm /www.policecheck.com
Fingerprinting Places across Canada. Toronto RCMP accredited finger
printing offices that usually do pardons/waivers as well; one would be
CSI 215 Spadina Suite 206 (5 doors north of McDonalds at Queen)
Wait times for a criminal record checks and VS checks vary depending on
many different factors such as: •The type of submission received: paper
fingerprint or electronic fingerprint •The number of applications
received at different times of the year •The amount of manual processing
related to the application
The approximate wait times for fingerprint submissions received by the
RCMP when there is no match to an RCMP fingerprint holding. Application
for Paper fingerprint submission Electronic fingerprint submission
Criminal record check Inked Fingerprints submitted by a police service or
accredited fingerprinting company 22 weeks vs. Digital VS check
Fingerprints submitted by a police service 4 weeks Fingerprints submitted
by an RCMP certified, accredited fingerprinting company.
You need and your security / construction company to be know & read
54 page Directive on Security attached and Health & Welfare Documents:
http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/index-eng.php and
http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/add-supp-eng.php
Most locations if within 50Km of cities listed and predict storage 50-
250k of product thus most in division 6 for lab/storage/shipping area
separate from Greenhouses surrounded by correct cement / rebar / mortar
walls / biometric steel doors: 12.1.1. The caged area is to be located at
least 1 metre (3') from an outside wall if located on a ground floor or
accessible from a roof. The Office considers a common wall shared with
another firm to be an outside wall; therefore, a 1 metre (3') free area
is required. The Office may consider equivalents to the 1 metre (3') free
area (see examples 4.1.5). 12.1.2. The caged area should preferably be
located in a locked room. 12.1.3. Sufficient electrical detection to
detect unauthorized movement within the caged area. 12.1.4. Cage door or
gate to be secured with an approved padlock (see Appendix "E") or its
equivalent. 12.2 Cage Construction 12.2.1 WALLS/CEILING a) The walls &
ceiling of a caged area will be constructed of 3.5 mm (10gauge) rolled
and flattened metal mesh which has 2.5 cm x 5 cm (1" x 2")diamond shaped
openings securely fastened together. If the existing floor and ceiling
are to be used then the walls are to extend from structural floor to
structural ceiling. The gate or door will provide force resistance
equivalent to that of the walls and ceiling and be equipped with
electrical door contacts. PADLOCKS: The following is a list of some of
the padlocks available which meet or exceed the Office's requirements.
SHACKLE MANUFACTURER MODEL DIAMETER CLEARANCE(mm) (mm)ABLOY 3071 11 25
AMERICAN 570 10 28(with dead locking)BEST 27B462 12 32(with security
sheath)MASTER 15 11 25MEDECO 50-600 10 25 PAPAIZ CR60 10 35 VIRO 304/60
MM 10 35
FAQ: Below is copy and pasted from Health and Welfare:
Frequently Asked Questions
For Clients
For Licensed Producers
For Health Care Professionals
For Police / Law Enforcement
For Municipalities
For Clients
How do I access marihuana during the transition period?
Until March 2014, individuals, who have the support of a health care
Practitioner, may access marihuana for medical purposes through either:
The Marihuana Medical Access Regulations (by applying to Health Canada);
or the new Marihuana for Medical Purposes Regulations (by registering
with a licensed producer once they become established).
Under the Marihuana Medical Access Regulations, you can apply to Health
Canada to access one of the three sources of supply: Health Canada
supply; Personal-Use Production Licence; or Designated-Person Production
Licence. For more information on how to apply for one of these sources of
supply, please visit the "How to Apply" web page.
Under the new Marihuana for Medical Purposes Regulations, once licensed
producers are established, you can have your health care practitioner
complete a medical document. You must submit the original medical
document directly to a licensed producer along with a completed
registration form from the licensed producer of your choice.
Please note that you may only have access to marihuana for medical
purposes under either the Marihuana Medical Access Regulations or the new
Marihuana for Medical Purposes Regulations, not both.
During the transition period, what is my proof of authority to possess?
Marihuana?
If you continue to access marihuana under the Marihuana Medical Access
Regulations, your Authorization to Possess (ATP) will remain your proof
of authority to possess until March 31, 2014. As of April 1, 2014, your
ATP can no longer be used as proof that you are authorized to possess
marihuana for medical purposes.
If you register with a licensed producer under the new Marihuana for
Medical Purposes Regulations (regardless of whether it is before or after
March 31, 2014) your proof of authority to possess will either be the
label on the packaging or a separate document accompanying the shipment
of dried marihuana from the licensed producer.
How do I find out how much a licensed producer is charging for marihuana?
You must contact the licensed producer directly for pricing information.
Once licensed producers are established, a list of licensed producers and
their contact information will be maintained on the licensed producers
web page.
I have a valid Personal-Use Production Licence or Designated-Person
Production Licence. Can I sell my plants to a licensed producer?
Yes. If you hold a valid licence to produce issued under the Marihuana
Medical Access Program, you may provide starting materials (plants, seeds
or clippings) to a licensed producer. To do so, you must submit an
application to Health Canada.
If you hold a Designated-Person Production Licence, the consent of the
authorized individual will be required. If you produce for more than one
person, you will need to submit this information for each person.
Once the application is received, Health Canada will verify the
information. If all of the information is valid, a notice will be sent to
the licence holder, the authorization holder(s) (if applicable) and the
licensed producer authorizing the transfer of materials.
All Personal-Use Production Licence or a Designated-Person Production
Licence expire no later than March 31, 2014, so this is the last day this
type of transfer may take place.
For Licensed Producers
Where can I obtain the application form to become a licensed producer?
The application along with guidance documents are available on the
Becoming a Licensed Producer web page.
What are the requirements to become a licensed producer?
To become a licensed producer, you must meet all requirements of the new
Marihuana for Medical Purposes Regulations, including, but not limited
to: obtaining the proper personal security clearances; meeting the
physical security requirements for the cultivation and storage areas;
And submitting a completed licensed producer application.
For further information, please refer to the Becoming a Licensed Producer
web page.
If you have any questions about these requirements or the application
process, you can send us your questions by email to [email protected]
or call us at 1-866-337-7705.
Once complete, your application must be submitted to the following
address:
Controlled Drugs Section
Licences and Permits Division
Office of Controlled Substances
Controlled Substances and Tobacco Directorate
Health Canada
Address Locator: 0300B
Ottawa, ON K1A 0K9
All relevant sections of the application form must be completed and all
required documents must be submitted. An incomplete application will not
be processed and may be returned to you.
Does Health Canada provide information on how to produce marihuana?
No. Health Canada does not provide this type of information.
Where can I obtain a legal source of starting materials?
There are four legal sources of starting materials:
Health Canada;
Personal-Use Production Licence holders;
Designated-Person Production Licence holders; and
Importation.
The process varies by source. Please contact the Office of Controlled
Substances at [email protected] for details.
Does Health Canada have a list of Personal-Use and Designated-Person
Production Licence holders who are interested in selling starting
materials to licensed producers?
Licensed producers must identify their own source of starting materials.
Health Canada is unable to provide any information about Personal-Use and
Designated-Person Production Licence holders.
What documents are required for a client to register with a licensed
producer?
Licensed producers may accept the following documents:
A medical document - A medical document must be completed in full and
signed by a health care practitioner.
An Authorization to Possess - This document is issued by Health Canada
and can only be used until the end of its validity period, or the expiry
date if no separate validity date is indicated.
A Form B "Medical Practitioner's Form" - While this form is primarily for
use under the Marihuana Medical Access Regulations, if your health care
Practitioner has already completed it, it may be used during the
transition period so long as it is within one year of the date it was
signed by the health care practitioner.
A licensed producer may also require clients to provide additional
supporting documentation.
Once my company registers a client who submitted their Authorization to
Possess, what do I do with this document?
Once the client has been successfully registered, you must send the
original Authorization to Possess document to Health Canada at the
following address:
Marihuana Medical Access Program
Controlled Substances and Tobacco Directorate
Healthy Environments and Consumer Safety Branch
Health Canada
Address Locator: 0300A
Ottawa, ON K1A 0K9
Once an Authorization to Possess holder registers with a licensed
producer, Health Canada will revoke the Authorization to Possess and any
associated licence to produce.
Is there a restriction on how much I can charge patients for dried
marihuana?
No. Licensed producers may set their own prices.
What strains of marihuana can I cultivate under a production licence?
The new Marihuana for Medical Purposes Regulations do not specify or
limit what strains of marihuana can be cultivated.
Can I sell cannabis resins, oils, extractions and edible marihuana
products?
No. The new Marihuana for Medical Purposes Regulations only permit the
sale of dried marihuana.
Can a production site be located outdoors or in a greenhouse?
Production sites can only be located indoors. You can cultivate in a
greenhouse if it meets the requirements of the new Marihuana for Medical
Purposes Regulations, including for physical security.
Can I operate a storefront?
No. You must ship dried marihuana directly to the client (or their
physician, if requested).
Can I sell/provide product to a compassion club or dispensary who will
then distribute on my behalf?
No. Only licensed producers are authorized to sell or provide dried
marihuana. Licensed producers must ship dried marihuana directly to the
client (or their physician, if requested) in accordance with the new
Marihuana for Medical Purposes Regulations.
Do municipal zoning by-laws apply to my production site?
Licensed producers are required to notify their local government, local
police force and local fire officials of their intention to apply to
Health Canada, so that local authorities are aware of their proposed
location and activities. Licensed producers are also required to
communicate with local authorities whenever there is a change in the
status of their licence. Licensed producers must comply with all federal,
provincial/territorial and municipal laws and by-laws, including
municipal zoning by-laws.
Is there a limit to how many production licences Health Canada will issue
under the Marihuana for Medical Purposes Regulations (MMPR)?
No. Health Canada will not impose a limit on the number of production
licences.
For Health Care Professionals
What medical conditions qualify for the use of marihuana as a treatment
option under the Marihuana for Medical Purposes Regulations (MMPR)?
The MMPR do not contain any limitations on the conditions for which a
health care practitioner can support the use of marihuana for medical
purposes.
You may wish to refer to the document entitled Information for Health
Care Professionals: Cannabis (marihuana, marijuana) and the Cannabinoids
for the latest information on the use of marihuana for medical purposes.
Please note that if you are supporting an application under the Marihuana
Medical Access Program (by completing a Form B "Medical Practitioner's
Form"), applicants must qualify under either the Category 1 or Category 2
medical conditions.
How does my patient access marihuana through the new Marihuana for
Medical Purposes Regulations (MMPR)?
If you support your patient's use of marihuana for medical purposes you
will need to complete a medical document with specific information that
is similar to a prescription. If you choose to use a different
template/form you must ensure that all required information as described
in the sample medical document is provided.
Once complete, your patient must send the original medical document to a
licensed producer with a registration form (provided by the licensed
producer). The licensed producer will fill and ship your patient's order,
based on the daily amount of dried marihuana indicated on the medical
document.
What is the difference between Form B and a medical document?
Form B "Medical Practitioner's Form" is the document that must be
completed by the health care practitioner as part of an application to
Health Canada for an Authorization to Possess marihuana for medical
purposes under the Marihuana Medical Access Program.
If your patient chooses to order dried marihuana from a licensed producer
under the new Marihuana for Medical Purposes Regulations, you must
complete a medical document. This document does not require all of the
same information as Form B.
Are there daily amount and duration restrictions under the Marihuana for
Medical Purposes Regulations?
Various surveys published in peer-reviewed literature have suggested that
the majority of people using inhaled or orally ingested cannabis for
medical purposes reported using approximately 1-3 grams of cannabis per
day.
While there are no restrictions under the new Marihuana for Medical
Purposes Regulations on the daily amount that you may recommend, there is
a possession cap of the lesser of 150 grams or 30 times the daily amount.
The medical document must be completed annually (or sooner if you
recommend a shorter duration) to ensure that you continue to support your
patient's use of marihuana.
We recommend you consult the document entitled Information for Health
Care Professionals: Cannabis (marihuana, marijuana) and the Cannabinoids
for further information.
What routes of administration can I recommend for my patient?
Typically dried marihuana is consumed orally or inhaled. Smoking is not
recommended. Some individuals use their dried marihuana with a vaporizer
or in teas.
Please note that licensed producers can only provide dried marihuana.
Other forms of marihuana, such as edibles or oils, are not permitted to
be sold by licensed producers under the Marihuana for Medical Purposes
Regulations.
Is there information available that indicates which strains are better
suited to certain conditions?
Health Canada is not aware of any clinical research on this subject.
Will dried marihuana be assigned a Drug Identification Number?
Marihuana for medical purposes is not an approved therapeutic drug in any
country in the world, including Canada. Scientific studies of its safety
and efficacy are not conclusive.
Where can I obtain information on the product my patient is considering?
You may contact the licensed producer(s) directly to obtain information
about the strain(s) of dried marihuana available. Each product label must
include the percentage of Tetrahydrocannabinol (THC) and percentage of
Cannabidiol (CBD) in the lot and batch that is being sold.
Once licensed producers are established, a list of licensed producers and
their contact information will be maintained on the Licensed Producers
web page.
In addition, Health Canada has posted a detailed document entitled
Information for Health Care Professionals: Cannabis (marihuana,
marijuana) and the Cannabinoids, which contains updated information on
the use of marihuana for medical purposes. This document is available on
the Health Canada website.
For Police / Law Enforcement
How do I determine whether or not someone is authorized to be in
possession of marihuana for medical purposes?
Until March 31, 2014, individuals may hold an Authorization to Possess
(ATP) marihuana for medical purposes issued by Health Canada under the
Marihuana Medical Access Regulations (MMAR), OR they may register with a
licensed producer to access dried marihuana under the new Marihuana for
Medical Purposes Regulations (MMPR), but not both.
Under the MMAR:
For individuals who continue to access marihuana for medical purposes
under the MMAR, the ATP will remain the same (a pink, watermarked, legal-
sized document). On March 31, 2014, all ATPs (and licences to produce)
issued under the MMAR expire and will no longer provide individuals
authority to possess marihuana. As of April 1, 2014, the only legal means
to access to marihuana for medical purposes will be through licensed
producers.
Until March 31, 2014, law enforcement officials may continue to contact
the Marihuana Medical Access Program's police services line to verify
information related to authorizations and licences requested in the
context of an investigation.
Under the new MMPR:
Individuals can access marihuana by registering with a licensed producer.
These individuals will not be issued an ATP. Instead, either the label on
the packaging or a separate document accompanying each shipment of dried
marihuana will provide the authority to possess marihuana. In the course
of an investigation, law enforcement officers may contact the licensed
producer directly to confirm whether the individual is a client of the
producer, an individual who is responsible for a client of the producer
and the daily quantity allowed.
Who can I contact if I am investigating someone who may or may not be
authorized under the MMPR?
If an individual presents you with the packaging or a document included
in their order of dried marihuana from a licensed producer, you may
contact the licensed producer to confirm the registration and the daily
quantity of dried marihuana.
The licensed producer must confirm that you are a member of a Canadian
police force, the information must be requested in the context of an
investigation under the CDSA or the Marihuana for Medical Purposes
Regulations and you must provide the name of the individual, the date of
birth and the gender.
Will authorization and licence documents issued under the MMAR constitute
valid authority to possess or produce marihuana after March 31, 2014?
No. On April 1, 2014, all Authorizations to Possess (ATPs), Personal-Use
Production Licences (PUPLs) and Designated-Person Production Licences
(DPPLs) will expire. All individuals who possess and/or produce marihuana
under the Marihuana Medical Access Regulations (MMAR) will be advised to
destroy or dispose of their marihuana and/or plants no later than March
31, 2014.
As of April 1, 2014, the only legal means to access marihuana for medical
purposes will be through a licensed producer under the Marihuana for
Medical Purposes Regulations (MMPR).
What is the difference between an expiry and validity date?
The Marihuana Medical Access Regulations (MMAR) will be repealed on March
31, 2014. As a result, between now and March 31, 2014, Health Canada will
issue Authorizations to Possess (ATPs) with two dates: an expiry date and
a validity date.
The expiry date on all ATPs will be March 31, 2014.
The validity date, which may go beyond March 31, 2014, is now included on
an ATP. This date enables ATP holders to switch to a licensed producer by
using their ATP instead of returning to their health care practitioner to
have a medical document signed.
Is there a limit to the amount of dried marihuana someone can carry on
their person under the Marihuana for Medical Purposes Regulations?
Yes. The new Marihuana for Medical Purposes Regulations impose a maximum
possession cap of the lesser of 150 grams of dried marihuana or 30 times
their daily amount at any one time. For example, if an individual has a
daily amount of 2 grams per day, their possession cap would be 60 grams.
Will Health Canada release a list of production sites that were licensed
under the MMAR after March 31, 2014, so that local authorities can ensure
they are dismantled?
No. This information is protected under the Privacy Act.
For Municipalities
Are licensed producers subject to local legislation and by-laws?
Yes; however, it is the responsibility of the municipality to conduct the
relevant inspections for compliance with by-laws such as zoning. Health
Canada can only inspect for compliance with the Marihuana for Medical
Purposes Regulations and any related federal legislation. Note that
licensed producers are required to notify their local government, local
police force and local fire officials of their intention to apply to
Health Canada, so that local authorities are aware of their proposed
location and activities. Licensed producers are also required to
communicate with local authorities whenever there is a change in the
status of their licence.
Can municipalities stop the licensing process if they disagree with the
proposed site of production or any other requirement?
No; however, local authorities can communicate any concerns directly to
the production site owner and enforce local legislation and by-laws.
Can compassion clubs dispense for a licensed producer?
No. Licensed producers must ship dried marihuana directly to the client
or the client's health care practitioner (if indicated).
Will Health Canada provide the municipality with a list of production
sites that were licensed under the MMAR after March 31, 2014?
No. This information is protected under the Privacy Act.
Will Health Canada ensure that these sites have been dismantled once the
MMAR is repealed on March 31, 2014?
Health Canada will provide guidance to all current program participants
regarding the appropriate means to dispose of their dried marihuana and
marihuana plants.
The production of marihuana in homes beyond March 31, 2014, is illegal
and may result in law enforcement action.
December 31, 2012 Number of persons who hold an Authorization to Possess Dried Marihuana in Canada: 28,115
Number of persons who hold a Personal-Use Production Licence in Canada: 18,063
Number of persons who hold a Designated Person Production Licence in Canada: 3,405
Number of persons in Canada who have indicated they will access dried marihuana and/or
marihuana seeds from Health Canada for medical purposes: 5,283
Regional Information as of December 2012
Region Authorization to
Possess
Personal-Use
Production Licence
Designated Person
Production Licence
Yukon - - -
Northwest
Territories - - -
Nunavut - - -
Newfoundland and
Labrador 146 49 -
Prince Edward
Island 68 35 -
Nova Scotia 1,864 1,338 132
New Brunswick 566 433 31
Quebec 884 556 120
Ontario 8,617 5,044 640
Manitoba 443 276 68
Saskatchewan 688 276 56
Alberta 1,438 677 115
British Columbia 13,362 9,369 2,232
Building a Legal Marijuana Industry From the Ground Up
Washington’s Initiative 502 legalized pot across the state, but provided only a few guidelines
for how to produce, process, and retail the drug. What regulations will lawmakers put in
place—and will they convince black market users to switch to a new, regulated industry?
If all goes according to plan, by the end of this year farmers across Washington State will begin
large-scale cultivation of a commodity they’ve never been allowed to mass-produce before—
marijuana. Washington won’t just have the kind of quasi-legal medical marijuana regime now
operating in 18 states and the District of Columbia. We’re talking about a place where weed can
be produced, sold, and consumed as openly and legally as milk.
As a result, state officials are also getting down to the business of cultivating pot, but in a
different sense. Now that the voters have spoken, the government’s task is to establish the
regulatory furrows and field boundaries that will shape the growth of the legal marijuana
industry itself. Governments invariably help shape markets through rules, subsidies, tariffs, and
other interventions designed to promote some priorities at the expense of others. Do you want
factories that produce as much as possible? Then make it easy for big manufacturers to buy up
smaller ones. Do you want to preserve jobs? Then do the opposite. But when it comes to
marijuana, the question of what kind of garden it’s best to grow is particularly complex.
That’s why Washington has hired Mark Kleiman, a jovially argumentative professor of public
policy at the University of California-Los Angeles. Kleiman is a burly, gray-bearded man
whose office is cluttered with haphazardly shelved texts on drug policy and criminology, his
own books on those topics, and a paperback edition of The Hobbit. He has assembled a team of
some 40 researchers to analyze the key issues confronting the Washington State Liquor Control
Board, the body overseeing the whole legal-marijuana endeavor, and sketch out the potential
outcomes of various approaches the board might take. “This isn’t just about making marijuana
use legal,” says Kleiman. “It’s about creating a legal industry. Very different proposition.”
For the industry to succeed, prices need to settle at a just-right “Goldilocks point”—not so high
that they drive people to the black market, but not so low that they promote overindulgence and
an illegal export market.
Initiative 502 (PDF), the ballot measure that legalized marijuana, spells out only a few
guidelines. Producing, processing, and retailing weed will each require a license and will each
be taxed at 25 percent. The product will be sold only to adults over 21, and only in government-
licensed stores that carry nothing but pot products and related paraphernalia. “They can’t even
sell the Doritos,” deadpans Kleiman.
That leaves several key questions unanswered. How many licenses do you hand out? Who gets
them? How big can a retailer, processor, or grower get?
One route Washington could take would be to issue lots of grower licenses and limit farm size
to end up with a large number of small producers. Call it the mom-and-pop, artisanal-weed
option. That would generate competition, which keeps prices low, encourages innovation, and
makes it much more difficult for the industry to accumulate the kind of political power wielded
by, say, Big Tobacco—the three companies that control 85 percent of the national cigarette
market. On the other hand, it’s more difficult to monitor and regulate hundreds of small
businesses than a few big ones. “And,” points out Kleiman, “they’re not making as much, so
each of them has a stronger incentive to push stuff out the back door”—into the black market.
If the state instead allowed only a few big growers to operate, they might get rich enough to
become powerful players in state politics. But their centralized operations would be much easier
to keep tabs on, and they would have a powerful incentive to abide by the law. “Otherwise they
could lose their oligopoly position, which is basically a license to print money,” says Kleiman.
The first round of draft regulations, issued in May for public comment, seems to at least leave
the door open for the mom-and-pop option. The rules don’t mention any cap on the number of
producers’ licenses to be issued. But nor do they set a limit on how big grow operations can get.
And the rules could well change before they are finalized in late summer.
One major advantage of having a few big growers is it would likely keep prices high. That’s a
plus not only for state tax revenues, but for public health as well, because of the way price
influences the behavior of a particular group—serious potheads. “The daily and near-daily users
are the ones who really drive the market,” says Beau Kilmer, the co-director of the RAND Drug
Policy Research Center, who is working with Kleiman. “They’re about 20 percent of total
users, but they account for about 80 percent of total consumption.” The proportions are similar
among alcohol drinkers. Studies have found that higher prices keep a lid on how much those
hard-core boozehounds imbibe, says Kleiman. Which is a good reason to keep weed prices up
too. Marijuana may be a relatively benign drug, but it’s not harmless.
But here’s where the legal-pot industry runs into a unique and fiendish challenge: Washington
can’t let the price drift too high because, of course, marijuana is not really a “new” industry.
There is already a well-established system of marijuana producers, processors, and
consumers—it’s just not a legal one.
Coaxing the estimated half-million-plus Washington residents who currently get their ganja
from either the black market or the grey medical market to switch to a new, regulated industry
amounts to a social-engineering project something like trying to divert a wild river into an
improvised canal.
A certain amount of illegal trade is pretty much guaranteed to continue. About a quarter of total
cannabis use is by people who are under 21, for whom marijuana won’t be legal even after
legalization, Kleiman noted in a recent radio interview. “It means we’re only legalizing about
three-quarters of the market,” he said.
For adults, the legal market will have the huge advantages of being, well, legal, and of
providing reliable, tested products. But prices are bound to be higher than in the medical and
black markets. Producers in those systems don’t have to shoulder the costs of complying with
regulations and paying taxes. The multimillion-dollar cigarette smuggling business attests to
how many people are willing to run a little risk to get something cheap. Or think about digital
music: iTunes has cut down on illegal file sharing by offering fans music that is easily
procured, reasonably priced, and of guaranteed quality. But millions of songs are still illegally
downloaded for free every year. And scoring a joint in Washington is almost as easy as pirating
a song on your laptop. “Anyone who wants a medical card can get one,” says Kleiman. Which
raises the question: Suppose they threw a legalized pot industry and nobody came?
For the industry to actually succeed, prices need to settle at what Kleiman calls a just-right
“Goldilocks point”—not so high that they drive people to the black market, but not so low that
they promote overindulgence and an illegal export market. Regulations can’t set those prices;
they can only try to influence them.
All of which makes it exceedingly difficult to figure out how much tax revenue Washington
will actually pull in from legal pot—a key point in selling the initiative. The state’s Office of
Financial Management recently published its best guess on how Initiative 502 will impact
Washington’s bottom line. Regulating the pot industry, the report points out, will certainly
incur millions of dollars in administrative costs, as well as lots of other potential bills. (Don’t
forget the teensy detail that the federal government still considers all marijuana flat-out illegal.
That means it’s possible Washington will find itself having to pay for the legal defense of state
employees targeted by federal prosecutors.) Best case, the report estimates, the state could gross
nearly $2 billion over five years. Worst case? “The total amount of revenue generated to state
and local government could be as low as zero.”