Looks like the MED is wanting to create “uniform regulations between Medical and Retail edible products.” What does that mean? Judge for yourself. This is the framework they will be using for tomorrow’s working group on marking marijuana edibles:
All multi-serving medical and retail marijuana edibles must be marked with the Universal Symbol on each single serving (10mg THC or less). The requirement for child-resistant packaging that retains its effectiveness for multiple openings remains in place.
If it is not practicable to apply the Universal Symbol directly on the product, then each edible product must be a single serving (10mg THC or less), be properly labeled to include the Universal Symbol, and be packaged in child-resistant packaging that immediately surrounds the edible.
All liquid edibles must be single-serving products and placed in a child-resistant container that is labeled with the universal symbol.
First and foremost… there is NO established serving or dose of Medical marijuana. 10mg may be a serving size for Retail marijuana, but that does NOT apply to Medical. There’s good reason for it. Medical marijuana patients need a variety of dosages for a variety of conditions, and they control their dose by self-titrating. Do you expect me to eat 20 cookies just to get the 200mg dose I need? How about a cancer patient dealing with severe nausea from chemotherapy?
How will the restriction on liquid edibles handle sublingual mouth sprays and tinctures, commonly used by patients? How about sauces and condiments? Single-serving implies 10mg, which will be totally unworkable for patients. Remember those cancer patients? How about kids who need a THC rescue dose, usually a tincture or concentrated oil? Even for recreational use, this is ridiculous.
Even more challenging, how will you get concentrated oil into 10mg dosages? Capsules? Will I have to take 20 capsules to get the 200mg dose I need? Will cancer patients have to take 100 capsules to get the 1000mg they need each day?
Packaging continues to be an issue with no concern for the challenges faced by medical marijuana patients, many of whom have conditions that make it difficult, if not impossible, to open these child-resistant containers.
People wonder why I’ve paid so much attention to the regulations on recreational marijuana. This is why. I knew that sooner or later they would try to push the recreational regs onto medical. In some cases, that might be good. In this case, it would be very bad.
We will not stand for any restrictions or regulations that affect potency of products available to medical marijuana patients! A 10mg single serving size for medical use is completely unreasonable!
This is all coming out at Tuesday’s working group. There will be time for public comment at the end. You should join me.
Ralph L. Carr Colorado Judicial Center
August 11, 2015 from 1:30 PM until 4:30 PM
1300 Broadway, Room 1B
Denver, Colorado 80203
For additional information, please visit the MED website.
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