Dear Cannabis Industry colleagues,
On Friday June 30, 2016 several people met at the Hotbox to discuss the appointment by the Trudeau Government of a Taskforce headed by former Federal Liberal Justice Minister Ann McLennan to “seek input on the design of a new system to legalize, strictly regulate and restrict access to marijuana. Their advice will be considered by the Government of Canada as the new framework is developed”.
More information at:
As you will see at the bottom, the new legal framework effects every level of the industry.
The CFBA will be lobbying all the points below.
Please see notes below that effect your portion of the industry.
Plans were already being made to retain a lobbying firm to provide the Federal Government with the views of medicinal and recreation users, dispensary owners, compassion clubs, growers, extractors and edible manufacturers. We discussed a comprehensive proposal by the Lobby Firm Counsel PR on how they could assist CFBA. – http://www.counselpa.com
The partners and senior staff at Counsel PR have strong connections to both the Federal and Provincial Liberal parties having worked on various aspects of Federal and Provincial campaigns. They have a long track record of successfully lobbying all three levels of government on behalf of various clients on a range of issues. We are confident that Counsel PR is well placed to lobby all three levels of government on our behalf though between now and November they will be focussing on the Taskforce and other federal government institutions such as Health Canada
Please see our ask at: https://www.dropbox.com/s/rqhapcutv7cbc8r/CFBA_LOBBY_ASK.pdf
Counsel PR will charge CFBA a monthly fee of $30,000. This means that between now and November by when the McLennan Taskforce’s report needs to be submitted to the Federal Government, CFBA will need to come-up with approximately $180,000 (which includes HST and incidentals).
Assuming that there still are about 60 dispensaries and compassion clubs in business this works out to approximately $3,000 for the five-month period per location or approximately $600 per month.
We are also looking to recruit canna-lounges, extractors, growers, edible manufacturers
(Currently we have membership from all levels of the industry)
With the involvement of the entire Cannabis Industry, the per location cost accordingly decreases.
All funds received will be recorded and receipted and the records will be open to the members to review.
We will follow-up this letter with personal visits and telephone calls to gather your input.
We also need your participation in three committees – Executive Committee of about seven to nine members, Fundraising Committee of five to seven members and the Lobby Liaison Committee also of about five to seven members. Please consider which of these committees you would like to participate in.
If you have any questions, please call Abi Roach at (647) 339-9115
Thank you for your attention.
ON BEHALF OF THE CFBA COMMITTEE
Abi Roach – Lisa Campbell – Amy Brown – Marko Ivancicevic
Some of the key government questions we look to address through our lobbying efforts:
4) Restrictions on marijuana products: THC is the main psychoactive component of marijuana. Current research shows average THC levels of between 12-15%. In contrast, marijuana from the 1980s had average THC levels of 3%. In addition, various higher potency marijuana products such as “shatter” are available with THC concentrations reaching levels as high as 80-90%. As outlined in section 1, higher concentration products have added risks and unknown long term impacts, and those risks are exacerbated for young people, including children. Given the significant health risks, maximum THC limits could be set and high-potency products strictly prohibited.
- THE INDUSTRY
2) Advertising and marketing restrictions to minimize the profile and attractiveness of products:
Since marketing, advertising and promotion of marijuana would only serve to “normalize” it in society and encourage and increase usage, it has been proposed that these should be strictly limited so as to dampen widespread use and reduce associated harms. This is particularly the case for promotional materials that would otherwise be targeted to impressionable youth. As in the case of tobacco, there may be limitations to possible restrictions on marketing, advertising and promotion of marijuana; however, within those limits these restrictions should be as tight as possible. Moreover, other limitations could include products being sold in plain packaging with appropriate health warning messages.
- TAXATION AND PRICING
When used appropriately, effective taxation and price controls can discourage the use of marijuana and provide the government with revenues to offset related costs (such as substance abuse services, law enforcement, and regulatory oversight). As such, the design of any regulatory framework should allow accommodation for an appropriate taxation regime in which there is sufficient flexibility in controlling the final price to the consumer. However, the use of taxation and pricing measures to discourage consumption must be properly balanced against the need to minimize the attractiveness of the black market and dissuade illegal production and trafficking.
- BAKERS & MANUFACTURERS
5) Restrictions on marijuana products: Marijuana can be consumed in many ways, including a wide range of products like foods, candies, salves or creams. Some people may choose these methods of consumption, rather than choosing to smoke dried marijuana. However, certain products present increased risks, notably when considering the increased potency of some of these derivative products and the increased harms associated with their use. They also represent an increased risk of accidental or unintentional ingestion, particularly by children. This view is supported by the experience in Colorado, where the availability of edible products led to a rise in the number of accidental or unintentional overdoses (non-fatal). As a result, the state government amended their regulatory framework to enact limits on dosing and potency. It is understood that individuals may choose to create marijuana products, such as baked goods, for personal consumption. However, consideration should be given to how edibles are treated in the new regime in light of the significant health risks, particularly to children and to youth, including whether and how to limit the potency of marijuana and types of products sold.
- BAKERS & MEDIBLES
1) Production Model: Experience with both home cultivation and government-controlled production in the context of relatively small numbers of medical users suggests neither approach would be in the public interest in the context of the larger numbers of users expected in a legalized market. Therefore, some form of private sector production with appropriate government licensing and oversight could allow for safe and secure production of legal marijuana with adequate choice (both price and strain) for consumers.
2) Good production practices: In general, ingestible products must meet certain quality standards. In the medical marijuana regime, Health Canada has established product content and production controls that have proven effective in minimizing risks to clients. Similarly, safeguards could be put in place to ensure that marijuana is produced and stored in sanitary and secure conditions. There could be strict security requirements to minimize the possibility of diversion. Controls could be placed on pesticides that can be used, and on microbial and chemical contaminants. Marijuana could also be subject to analytical testing so that those consuming can be reliably advised of its contents, particularly amounts of THC and CBD.
- MANUFACTURERS & FARMERS
3) Product packaging and labeling: The way in which products are packaged and labelled offers an opportunity to minimize the harms of marijuana, particularly for children and youth. Measures to consider implementing include: child-proof packaging to prevent accidental ingestion by children; and, labels on packages to contain both important information about the product (e.g., THC and CBD content) as well as appropriate health warning messages.
1) Phased-in approach to distribution:In the initial stages of legalizing marijuana, only allowing a proven system of distribution (e.g., through the mail, as is currently done in the medical marijuana regime) could minimize the risks of uncontrolled/illegal retail sales outlined above. This system could enable access for adults while using caution in taking a step that may inadvertently put youth at increased risk.
2) Storefronts: On the other hand, allowing for some ability for the sale of marijuana to occur in a legal, regulated retail environment may be required in order to provide an alternative to the current illegal sellers that exist in certain Canadian cities. Ensuring that the marijuana sold in such establishments comes from a legal source would be critical.
3) Local choice: Alternatively, decisions on appropriate distribution mechanisms could be left to provincial and territorial governments to determine the best approach based on their unique circumstances. This scenario could result in different models being adopted across the country.
- CANNA LOUNGES
3) Restriction of consumption to the home or a limited number of well-regulated publicly accessible sites: Consumption of marijuana could be restricted to private residences. However, the system may need to be pragmatic to respond to the demand for venues to consume marijuana outside the home in order to avoid proliferation of consumption in all public spaces.
Consideration could be given to identifying—and strictly limiting and controlling—allowable sites for use by adults. This could serve to minimize normalization of marijuana and protect against the exposure of non-users to second-hand smoke and vapours. In addition, consideration will need to be given to the use of marijuana in workplaces. For example, a zero tolerance policy could be applied for those who operate heavy machinery or conveyances.