Reminders – Meeting Tonight and Grow Class on Wednesday

TUESDAY (TOMORROW) NOVEMBER 29 – MEETING FOR PATIENTS and CAREGIVERS 

If you are confused, have questions, or have info that you would like to share, you are in good company. Please join us at our monthly meeting in Johnston this Tuesday(last Tuesday of every month) at 7pm.. All MMj cardholders are welcome. Bring questions, opinions, get advice from the most knowledgeable experts on growing and Program rules and changes.  7PM   1192 Plainfield Street, APWU Hall, Johnston, RI    All RI MMP cardholders are welcome when you present your MMj card at the door.

WEDNESDAY, NOVEMBER 30 – RIPAC GROW CLASSES BEGIN

Just a few seats left for MMj cardholders. Learn from the best

Thank you to Green Cross for hosting our grow classes at their new Providence office at 135 Gano Street.in Providence. Classes start this Wednesday and there are a few seats open, so register NOW. You won’t regret it. Register by replying to this email and indicating your interest in registering or email: joanne@RIpatients.org   Licensed patients and caregivers only. Here is the schedule:

November 30  Introduction.  Grow room set up, environment

December 14   Selection of containers, mediums, nutrients, water & ph requirements

December 28    Seed germination, transplanting seedlings, cloning, transplanting clones

January 11        Pests and diseases, prevention, treatment of infected plants

January 25      Vegetative growth, vegetative nutrients, transplanting, topping and training

February 8       Flowering cycle, flowering nutrients, patience

February 22     Harvest, drying, curing

March 8            Making concentrates safely -bubble hash (with ice), butter and tinctures

 MMj license must be brought to each class with 25 dollar donation.  

Reminder: Public Hearing and Comments

A public hearing will take place this morning , 11/22/16 at 10am in the auditorium at the Health dept. on the proposed regulations. RIPAC will be there to testify about the new obstacles the regulations create for patients. Of particular concern are the proposed requirements for physicians which may lead to fewer physicians signing patient applications and increased clinic visits that are not covered by insurance, the prohibition on caregivers residing out of state which will eliminate some quality reliable caregivers, and requiring “authorized purchasers”to pay an annual registration fee of 100 dollars so that they may perform acts of kindness by picking up MMj at compassion centers for patients who may not be able to get there. We will try to dissuade the Health Dept. from placing more burdens on patients, their doctors, and their caregivers.    The Health Dept. will not be making decisions today. Written comments on the regulations may be submitted until December 7. For more info, scroll down on this website for summary of Health Dept. and DBR regulations.

Grow Classes are back by popular demand. Offered at a fraction of the cost of other classes in New England. We want to make these classes as accessible as we possibly can to patients and their caregivers who take the classes for all the right reasons.  Our classes are exclusive.  We will not teach you to grow unless you are legal to grow.  We are committed to preserving the integrity of the MMj Program, so you must be a licensed patient or caregiver. This class is not about growing “weed” or “pot”.  It is about growing medicine for qualified patients. Whether you are new to the MMj Program and have never seen a plant or whether you have some experience, please join us.  You will be glad you did. Mike, our instructor is the best. Not only is he an amazing grower, he has taught some of the best growers in RI.  Here’s a sample:

“I starting growing because my wife was a MMj patient. She was in the hospital constantly before I learned to produce the strains that she needed. Mike was my teacher. He has an unbelievable ability to explain things. Because of him, my wife has effective medicine and some compassion centers have asked me to grow extra and sell it to them. People consider me an expert. That is because I learned from Mike. He is a real expert who knows how to teach”. CP, a patient and caregiver from the Providence area

 

This is a “hands on” course. We won’t just show you photos, we want you to see, feel, and help care for a plant at every stage of growth.

 

Classes are in Providence on select Wednesday evenings, 7-9pm. Directions to the class will be given upon registration. Below is list of classes, dates and content

November 30   Introduction.  Grow room set up, environment

December 14    Selection of containers, mediums, nutrients, water & ph requirements

December 28    Seed germination, transplanting seedlings, cloning, transplanting clones

January 11      Pests and diseases, prevention, treatment of infected plants

January 25     Vegetative growth, vegetative nutrients, transplanting, topping and training

February 8       Flowering cycle, flowering nutrients, patience

February 22     Harvest, drying, curing

March 8            Making concentrates safely  – bubble hash (with ice), butter and tinctures

 MMj license must be brought to each class with 25 dollar donation.  We suggest registering for all 8 classes but that is not required.  Email joanne@RIpatients.org to register and ask questions.  REGISTER TODAY. SPACE IS LIMITED

 

Summary of Proposed Health Dept. and DBR Regulations

 

 

Both the Health Dept. and the Department of Business Regulation (DBR) have recently proposed  substantial regulations for the RI MMj Program.  The DBR regulations are 80 pages long.  Written comments can be submitted to DBR and the Health Dept. until December 7. Written comments on the DBR proposed regulations should be sent to:   Attn: Norman Birenbaum    Principal Policy and Economic Analyst    Rhode Island Department of Business Regulation    Medical Marijuana Program, 1511 Pontiac Avenue, Building 68-1, Cranston, RI 02920    Email Address: DBR.MMPCompliance@dbr.ri.gov .  Written comments on the Health Dept. proposed regulations should be submitted to: James McDonald, 3 Capitol Hill, Room 205, Providence, Rhode Island 02908-5097 or by e-mail to James.McDonald@health.ri.gov.

PUBLIC HEARING INFORMATION: A public hearing to consider both sets of regulations shall be held on Tuesday, November 22, 2016 at 10:00 a.m. in the Auditorium of the Rhode Island Department of Health on the lower level of the Cannon Building, Three Capitol Hill, Providence, Rhode Island at which time and place all interested persons will be heard.

DEPT. OF HEALTH PROPOSED REGULATIONS – SUMMARY OF KEY PROVISIONS   You can read the actual text of the proposed regs but please note that the changes are not indicated. If the link does not work, please cut and paste into your browser. http://sos.ri.gov/documents/archives/regdocs/holding/DOH/MMP_PublicHearingDraft_7Nov2016.pdf

Here is a summary of the proposed Health Dept. changes followed by a summary of the DBR proposed regulations:

New limit and definition of “Wet marijuana” the harvested leaves and flowers of the marijuana plant before they have reached a dry usable state. Marijuana that has been dried to a usable state shall be assumed to have yielded twenty percent (20%) of the weight of the wet marijuana.

Wet flower weight  Dry Flower Weight (20% of wet)
12.5 oz. wet 2.5 oz. dry
25 oz. wet 5 oz.  dry
37.5 oz. wet  7.5 oz. dry
50 oz wet  10 oz.  dry

 

Conversion Tables to calculate edibles and concentrate equivalency.  The law says that a patient may possess 2.5 ounces of Usable marijuanameans the dried leaves and flowers of the marijuana plant, and any mixture or preparation thereof, (but does not include the seeds, stalks, and roots of the plant). These tables provide equivalencies that will count toward limit.

 

FLOWER WEIGHT  Equivalent number of 10mg edible units
   1 oz flower         83
 0.25 oz. of flower         21
    1 gram of flower           3

 

FLOWER WEIGHT   Equivalent grams of concentrate
  1 oz. flower         7.7
   0.25 oz. of flower          1.9
   1 gram of flower          0.3

 

 Expedited applications for chemo and hospice patients. Patients receiving chemotherapy or have been admitted to hospice will be expedited and their applications will be approved within seventy-two (72) hours.

 Patients and caregivers who grow must register grow locations with Health Dept and be subject to DBR regulations .

Authorized purchaser –   new category. Someone who is registered with the health dept. for the purpose of assisting a qualifying patient in purchasing marijuana from a compassion center. An authorized purchaser may assist no more than one patient, and is prohibited from consuming marijuana obtained for the use of the qualifying patient. Must be 21 years old, satisfy National Criminal Records Check, pay 100 registration fee for one year, but cannot cultivate. Can live out of state.

Caregivers can no longer reside out of state. Must be RI resident

 New requirements for physicians who sign applications:  The physician must obtain three (3) hours or equivalent of Category 1 continuing medical education (CME) regarding medical marijuana every two (2) years as part of usual CME requirement.

 

Patient Education: The certifying practitioner must document in the medical record

and provide in written or verbal format, that patient was educated regarding maximum daily dose of active ingredient, minimum interval between doses, possible drug interactions – including risk of co-ingesting alcohol. The certifying practitioner must document after examination, the patient’s response to conventional medical therapies and explain the risks and benefits of the use of marijuana to the qualifying patient.  The certifying practitioner must be committed to the continual assessment of the patient and the patient’s response to the use of marijuana. This must be demonstrated through follow-up appointments, semi-annually at minimum, before the card is renewed. The practitioner will send updates to the primary care provider (if not the PCP), at intervals not to exceed twelve (12) months, documenting patients progress or experience using medical marijuana.

Before issuing a written certification, a certifying physician must review the Rhode Island Prescription Drug Monitoring Program, review the patients’ prescription history and make a judgement about the potential for drug interaction, adverse events or untoward clinical outcome from adding medical marijuana. Physician must document in the medical record a full assessment which means: history of present illness, social history, past medical and surgical history, alcohol and substance use history, physical exam and documentation of therapies with inadequate response.

DBR PROPOSED REGULATIONS The following is a summary of the key provisions of the new proposed DBR Regulations.  The proposed regulations are 80 pages long and you can read them at: http://www.dbr.ri.gov/documents/divisions/medicalmarijuana/Notice_MedicalMarijuana_Proposed_Rulemaking.pdf  If the link does not work, please cut and paste into your browser. There are four sections: compassion centers, cultivators license and plant tags for patients and caregivers.

I. COMPASSION CENTERS (pages 1-31 of DBR proposed regulations) The new law requires that the responsibility for regulating the compassion centers be transferred from the Health Dept to DBR. It also authorizes DBR (with Health Dept) to regulate labeling and testing of MMj products. The proposed regulations provide the following specifics. Labels would have product weight, amounts of THC and CBD, all ingredients (for edibles), pesticides, type of extracts used including solvents or chemicals used in production, applicable instructions for use and storage.  Several warning labels would also be required. Containers must be child resistant.

Pesticides – only “minimal risk pesticides” are be permitted. Must qualify for “food use” by EPA standards. No pesticides for flowering plants.  Application of pesticides must be recorded on video. Must use best cultivation practices to limit mold, mildew, pests, pesticides, fungus, etc.

Mandated Outreach Activities to Educate Patients –  Centers would be required to provide Frequently Asked Question information sheets including option for how to use products, potential side effects, etc.  Centers may also be required to inform patients about changes in the MMj Program.

Purchasing from Cultivators – No purchasing from patients and caregivers after Jan.1, 2017.  Can purchase from licensed cultivators only, with whom they have formal agreements. Must pay cultivators within 60 days.

One year license/renewal – All licenses, including patient, caregiver, co-ops and cultivators will have one year cycle. DBR will conduct annual review of compassion centers and consider whether they are adequately providing patients at “reasonable rates”.

Financial interests- A compassion center and “key persons” could not have any “material  financial interest or control” in another compassion center, a cultivator, or a  licensed cooperative cultivation or vice versa. a compassion center may not have any material financial interest or control in a Rhode Island DOH-approved third party testing entity.

Note: specific requirements on testing are not included in this set of proposed regulations.

II. LICENSED CULTIVATOR (pages 32-60 of proposed regulations)

Can sell only to compassion center. Cannot be a caregiver.

Only Class A and Class B licenses will be available for the first years. Application fee is 5,000 dollars

Class A is a grow facility of 5000 sq ft or less. Annual licensing fee is 20,000 dollars. When seed to sale program is implemented, there will be no plant limit.  Until then it is 250 mature and 250 seedlings. Can have up to 5lbs of uncommitted dried usable.  Otherwise, all inventory must be under formal agreement with a compassion center.

Class B is a grow facility of 5001-10,000 sq. ft. with 35,000 dollar annual licensing fee. Until seed to sale program is implemented, the plane limit is 500 mature and 500 seedlings. Can have up to 10 lbs of uncommitted dried usable. Otherwise, all inventory must be under formal agreement with a compassion center.

A licensed cultivator and “key persons” thereof, may not have any “material financial interest or control” in another licensed cultivator, a compassion center, or a licensed cooperative cultivation or vice versa    Licensed cultivator may not have any material financial interest or control in a Rhode Island DOH-approved third party testing provider and vice versa.

Concentrates and edibles – may only receive medical marijuana and marijuana products from a Rhode Island registered compassion center if the receipt is pursuant to a written contract or purchase order for the cultivator to process the medical marijuana into a product to be furnished back to the compassion center.

Need zoning approval from local city or town for location and building.

May acquire clones from co-ops.

III. CO-OPS (pages 60-70 of proposed regulations)

The proposed regulations do not change the current rules regarding co-ops. They add to them as DBR implements new oversight and licensing requirements. If you currently have a co-op, we suggest you read the proposed regs from pages 60-70 in their entirety.

 Application fee for all co-ops is 25 dollars

Annual licensing fee for residential co-ops is 250 dollars

Annual licensing fee for non-residential co-ops is 500 dollars

These fees are in addition to the existing patient and caregiver registration fees and upcoming plant tag fees.

All documentation currently required (zoning approval or electrician affidavit, fire dept approval) must be submitted to DBR with list of members, d.o.b.s, MMP registration numbers, mailing addresses, email or phone numbers, evidence of ownership or landlord permission.

Non-residential co-ops must submit security plan and draft diagram of premises.

Must submit tax affidavit filled out by the “primary applicant” or legal entity who will hold the license stating compliance with RI tax obligations.

Must still register with state police or can have DBR register  with state police for you.

Co-ops and their key people cannot have a financial interest or control in another co-op, licensed cultivator, compassion center or vice versa.

Methods of extraction must be approved by DBR and fire dept. or fire marshal.

Residential Co-op possession limits stay at 24 mature plants and 24 seedlings, 10 ounces of dried usable and 50 ounces of wet.   Possession limits for marijuana possessed in mixed forms shall be calculated as a total equivalent to the maximum limit of dried usable marijuana in pounds in accordance with the equivalency conversion factors delineated in DOH Regulations.

Non-residential Co-op limit stay at 48 mature plants and 48 seedlings and 10 ounces of dried usable and 50 ounces of wet.   Possession limits for marijuana possessed in mixed forms shall be calculated as a total equivalent to the maximum limit of dried usable marijuana in pounds in accordance with the equivalency conversion factors delineated in DOH Regulations.

Licensed cultivators may acquire 12 clones per month from a co-op (no more than 8 inches long). Co-op may supply a maximum of two licensed cultivators with clones per month.

Co-ops are subject to reasonable inspections by DBR which could include local zoning officials.

DBR could assess fines or revocation of license for non-compliance.

 IV. PLANT TAGS FOR PATIENTS AND CAREGIVERS

All plants being grown by patients and caregivers must have tags by April 1, 2017.

A set of tags will cost 25 dollars. A set is for one mature plant and for one seedling.

Qualifying low income patients will be eligible for 12 sets of free tags.

Caregivers growing for a qualifying low income patient will be eligible for 12 sets of free tags.

The specific qualifications to determine who is eligible for free tags are not in regulations.

A caregiver must have at least one set of tags for each patient they are registered for.

Co-ops must have tags on all plants.

Tags must be renewed and paid for annually, unless income eligible for free tags.

Plants must be is secure indoor location with four walls and a roof.

Reasonable efforts must be made to control odors.

Tags will have patient or caregiver numbers on them with location of grow and expiration date of tags.

DBR and Health Dept will have access to tag data.

DBR will not inspect patient or caregiver grows unless DBR has reasonable basis to believe that a cardholder is not in compliance. In which case, DBR shall first send a letter stating concern. If no response after 10 days, DBR shall send another letter. If no response after 10 days, DBR may attempt an alternative way to contact such as telephone. If that is unsuccessful then DBR will make an effort to schedule an inspection in advance.

Non compliance could result in administrative fines or revocation of tags.

 

 

 

 

 

 

 

 

 

 

 

 

 

More Regulations Proposed by DBR

As expected, the Dept. of Business Regulation (DBR) has issued substantial proposed regulations.  The proposed regulations  are on the DBR website:                                                                 http://www.dbr.ri.gov/documents/divisions/medicalmarijuana/Notice_MedicalMarijuana_Proposed_Rulemaking.pdf

There will be a public hearing on the proposed regulations on Tuesday, November 22, 2016 at 10:00 a.m. in the Auditorium of the Rhode Island Department of Health on the lower level of the Cannon Building, Three Capitol Hill, Providence, Rhode Island . Written comments can be submitted until December 7, 2016 to: WRITTEN PUBLIC COMMENT SUBMISSIONS: Mailing Address: Attn: Norman Birenbaum Principal Policy and Economic Analyst Rhode Island Department of Business Regulation Medical Marijuana Program 1511 Pontiac Avenue, Building 68-1  Cranston, RI 02920      Email Address: DBR.MMPCompliance@dbr.ri.gov     Written public comments should clearly designate “Public Comment – Medical Marijuana Regulations” on the written submission.

RIPAC will provide a summary of the proposed regulations on this website as soon as we can.

Monday Meeting Rescheduled to Nov. 14

The meeting which is usually held on the 1st Monday of the month at the Bell Street Chapel (5 Bell Street, Providence)will take place on the following Monday, November 14 at 7pm, this month only. For licensed patients and their caregivers and anyone interested in learning more about the Program. Learn your rights, responsibilities, options for legally obtaining medicine, pitfalls to avoid,learn about caregivers,how to choose a responsible caregiver, compassion centers,what to do if you have an encounter with law enforcement, how to become a patient and more! Bring your questions.
DIRECTIONS to Bell Street Chapel in Providence: From North: 95s to exit 21 (Atwells Ave.) Go straight on service road to second light. Turn right on Broadway. Bell Street is .8 miles on right.
From South: 95n TO exit 21 toward Broadway. At light, turn left on Broadway. Bell St. is .8 miles on right.