DENVER, CO (4/19/13) - When the Massachusetts Department of Public Health (DPH) released their highly anticipated initial draft regulations on March 29th, medical marijuana experts at Denver Relief Consulting sought to assist the process. Assembling and working with some of the broadest and most knowledgeable cannabis organizations in the country, they coordinated a thorough and careful review of the regulations. The goal was to offer specific feedback based on their direct experience as a consultant and dispensary owner.
Denver Relief Consulting, along with Arizona’s 4Front Advisors, the Massachusetts Medical Marijuana Association and the Coalition for Responsible Patient Care, combed through the DPH recommendations and worked together to draft a brief report addressing key areas for clarification and improvement. The primary concern of the group was to identify portions where patients may be unfairly restricted. “The letter was drafted with the patient in mind, not operators,” notes Denver Relief Consulting Partner Kayvan S.T. Khalatbari. “We saw first hand in Colorado what can happen when the interests of businesses are placed before people with debilitating illnesses and we want to avoid that if we can.”
While the team was in agreement that the DPH had done an exceptional job in drafting the regulations, they still felt there were areas that required additional clarification or revision. With experience in multiple states, they quickly picked up on several small but key details that needed adjustment. “We were impressed with the level of detail and thought that went into the initial work at the DPH,” said Ean Seeb, Partner at Denver Relief Consulting. In the end, they focused on five key areas of improvement, including:
- A revision that would allow patients to purchase from any Medical Marijuana Treatment Center (MMTC) and not only one that would be designated as their primary provider. “In the current draft, one failed crop at their primary MMTC and a patient can be left without access to medicine. This can also restrict access if a patient is travelling in another region of the state and in need of medicine or if they require a certain strain or infused product only another MMTC carries, such as those carrying often hard to find high-CBD options,” notes 4Front Advisors Principal Kris Krane.
- A revision that would allow wholesale between licensed MMTCs. “Again, crop failure is a legitimate concern in this industry and allowing wholesale between MMTCs allows patients access to a variety of strains and products that they otherwise may not have available to them. It allows for each MMTC to have a full offering of products that are consistent and readily available,” said Anne Johnson, Executive Director of the Massachusetts Medical Marijuana Association.
- Striking a provision requiring businesses to be in operation within 120 day of application approval. “Design, permitting and construction, coupled with the growth cycle of cannabis makes this impossible without clarifying what ‘operation’ means. The construction process alone can take longer than the 120 days allowed, especially when dealing with local building departments and contractors who are unfamiliar with these types of installations. ” said Mr. Khalatbari.
Their full list of recommendations is available here and members from each team will be in Massachusetts to discuss these issues and others with the DPH at their public comment hearings on April 19th. The public comment is preliminary in nature, with a Public Health Council vote on May 8th determining the future of medical marijuana in Massachusetts. There is still a long way to go before retail operations begin and this team is going to be with Massachusetts every step of the way.
4Front Advisors
Kris Krane, managing partner
4148 N. Arcadia Dr.
Phoenix, AZ 85018
P. 510-387-2440
[email protected]
Coalition for Responsible Patient Care
Robert Hunt, chairman
10 Liberty Square, 5th Floor
Boston, MA 02109
P. 617-574-0781
[email protected]
Denver Relief Consulting
Ean Seeb or Kayvan Khalatbari, principals
1 Broadway #A205
Denver CO 80203
P. 303-420-7526
[email protected]
Massachusetts Medical Marijuana Association
Anne Johnson, executive director
One Beacon Street, Suite 1320
Boston, MA 02108
P. 855-666-2669
[email protected]
Leave a Reply