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Combine Public Input.Pdf Amber Virkler From: Angela Whitfield <[email protected]> Sent: Monday, June 1, 2020 9:23 AM To: CCB Regulations Subject: Comment on Proposed Regulations RC025, RP016 MMNV2 Holdings Please see the below comments defined by section for the proposed regulations. Thank you for this opportunity to provide comments. 1.125 Can the different “Lots” also be described in grams. Items in the seed to sale tracking system must be in grams according to training. 1.165 Can Production Run also be described in grams. Items in the seed to sale tracking system must be in grams according to training. 1.245 Is an immature cannabis plant less than 8” tall and 3” wide? For the purposes of the seed to sale tracking software, a cannabis plant is considered “vegetative” and no longer “immature” once it was reached 8” tall and 3” wide. 6.010 Can “one ounce” of usable marijuana be expressed in grams. One ounce is actually 28.3g but I understand the state has defined one ounce to be 28 grams. Can this be explicitly stated? Also mentioned in section 12.010. 6.080 Section 3: if we can acquire seeds from anyone how can these be tracked in the seed to sale tracking system if the supplier does not have seed to sale tracking software? Currently we have no way to introduce seeds into the seed to sale tracking software. All new plants must come from another plant or be transferred from another license. 6.135 Quarterly reporting is currently reported on the 30th of the month for the three previous months. Ex: Jan, Feb, March reporting is due April 30th. Due to harvesting and curing schedules, it would be impossible to fully capture the entire month of March by April 15th. Curing schedules can take up to 21 days before product is fully cued and ready to package. Reporting by April 15th would lead to completely inaccurate harvest data. 9.040 Section 3. Guidance was provided by the department on common items and understood shelf life of those items. Any exception to these understood lives would require testing by the manufacturing facility. Will a similar memo be issued by the Board? 10.035 Section 3 mentions that all components must be stored 6 inches off the floor. 9.030 states “fifteen centimeters”. Can the units system in the regulations please be unified to avoid confusion? 12.010 While tincture is called out separately here, it is packaged and treated as an edible in the seed to sale tracking software. The single package limit for tincture versus edibles are very different. Can more clarification be given on how to package tincture in the seed to sale tracking software? 1 12.035 Can it please be stipulated that the serving size statement is not required for concentrated cannabis product and is only required for edible products. Serving sizes are not defined and are not required to be defined for concentrates so have a serving size statement on these labels is incompatible. 13.015 Section 4, the distributor must updated the manifest to accurately depict any delays in arrival times, any route change, or any new driver information. The originating establishment cannot be responsible for knowing, or entering this information in the seed to sale tracking software. Angela Whitfield Production Manager MedMen.com NOTICE: This message is intended only for the named recipient and may contain confidential, proprietary and/or legally privileged information. Any dissemination, distribution, or copying of this information is strictly prohibited. If you have received this message in error, please advise the sender by reply email, and delete this message and any attachments immediately. 2 Amber Virkler From: Marla McDade Williams <[email protected]> Sent: Monday, June 1, 2020 9:25 AM To: CCB Regulations Subject: Re: Proposed Regulations of the CCB Thank you for providing these draft regulations. Will they replace the regulations in NAC Chapter 453A and 453D in whole? Sign up for our free weekly newsletter To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. Strategies 360 MARLA MCDADE WILLIAMS Senior Director C 775.315.4728 O 702.800.2100 F 702.728.2750 CARSON CITY: 810 E. 5TH STREET CARSON CITY, NV 89701 LAS VEGAS: 10801 W CHARLESTON BLVD STE 420 LAS VEGAS, NV 89135 STRATEGIES360.COM From: Medical Marijuana <[email protected]> on behalf of Nevada Department of Taxation, Cannabis Compliance Board <[email protected]> Sent: Friday, May 29, 2020 5:25 PM To: [email protected] <[email protected]> Subject: Proposed Regulations of the CCB Please see attached memo regarding the proposed regulations of the Cannabis Compliance Board. A reminder notice will go out again on Monday morning. - Cannabis Compliance Board To unsubscribe from the MEDICALMARIJUANA list, click the following link: http://listserv.state.nv.us/scripts/wa.exe?TICKET=NzM3NjA0IG1hcmxhbXdAU1RSQVRFR0lFUzM2MC5DT00gTUVESUNBT E1BUklKVUFOQRX5rvbh3ItN&c=SIGNOFF 1 Amber Virkler From: Savino Sguera <[email protected]> Sent: Thursday, June 4, 2020 10:52 AM To: CCB Regulations; Marco Troiani Subject: Comments on proposed CCB regualtions Greetings. Please see comment below. ******************************************************************************** Savino Sguera Comments on proposed CCB regulations Page 101, 11.055.b (4) Alpha-terpinolene is incorrect terminology. It should be written as "delta-terpinene" or "terpinolene". ********************************************************************************* -- Savino Sguera Chief Science Officer, Digamma Consulting +1 (631) 834-9227 This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited 1 Amber Virkler From: Dennis Gutwald <[email protected]> Sent: Thursday, June 4, 2020 9:03 PM To: CCB Regulations Subject: Propose Regulation section 2.040(1) and (3) seem to say the same thing unless I am missing something. Dennis Gutwald | Partner McDONALD CARANO 2300 West Sahara Avenue | Suite 1200 Las Vegas, NV 89102 P: 702.873.4100 | D: 702.257.4517 C: 702.807.9862 BIO | WEBSITE | V-CARD ® MERITAS PERSONAL AND CONFIDENTIAL: This message originates from the law firm of McDonald Carano LLP. This message and any file(s) or attachment(s) transmitted with it are confidential, intended only for the named recipient, and may contain information that is a trade secret, proprietary, protected by the attorney work product doctrine, subject to the attorney-client privilege, or is otherwise protected against unauthorized use or disclosure. This message and any file(s) or attachment(s) transmitted with it are transmitted based on a reasonable expectation of privacy consistent with ABA Formal Opinion No. 99-413. Any disclosure, distribution, copying, or use of this information by anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you receive this message in error, please advise the sender by immediate reply and delete the original message. Personal messages express only the view of the sender and are not attributable to McDonald Carano LLP. 1 MEMO To: State of Nevada Compliance Board From: Anansi Enterprise LLC – (Tim Eli Addo & Kofi Forkuo-Sekyere) Date: June, 6, 2020 Re: Recall Procedures for Cannabis in Nevada Nevada should be proactive in its approach for strengthening recall procedures for contaminated cannabis products. Increasing strength of lab testing is an important step for guaranteeing consumer safety. However, stronger testing needs to be paired with ways for warning the public of contaminated cannabis products. Establishing an effective cannabis recall program now will help ensure Nevada’s gaming industry can safely create revenue share models for cannabis. The gaming and tourism industries will seek to profit from another potential lucrative revenue stream as cannabis get closer to federal legalization. Furthermore, the Proposed Final Regulations of the Cannabis Compliance Board does not address how contaminated cannabis products should be recalled or recorded. Regulation 6 of the Proposed Final Regulations of the Cannabis Compliance board does not address how contaminated cannabis products should be recalled or recorded. Regulation 10 of the Proposed Final Regulations of the Cannabis Compliance board does not address how contaminated cannabis products should be recalled or recorded. Regulation 11 of the Proposed Final Regulations of the Cannabis Compliance board does not address how testing facilities should respond during a recall for contaminated cannabis products. Regulation 13 of the Proposed Final Regulations of the Cannabis Compliance board does not address how distributors should respond during a recall for contaminated cannabis products. Anansi Enterprise is prepared to provide recall procedures for each step of the cannabis supply chain (sellers, producers, distributors, testing facilities). Policy Issue: The current method the Department of Taxation uses to notify the public of recall is ineffective in notifying all the parties involved. The lack of notification to affected parties can be fatal, especially since medicinal cannabis patients may already suffer from a compromised immune system. Nevada needs to be equipped with a method of notification and containment for potential recalls on cannabis products. Public safety should be the highest priority for cannabis regulators This memo is not written in fear that an issue may happen. Fatalities from contaminated cannabis have already happened in two states.
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