Miesiąc: sierpień 2022

The cannabis trade publication, MJBizDaily, published an article last week bearing the headline, “$1 billion in illegal cannabis seized in California over past year, regulators say.” At the bottom of that article were related stories, including one headlined, “Why 3 illicit marijuana operators decline to go legal in California,” and another linking to a report titled “California Market Report: Illicit Market Woes.”

Taken altogether, that web page provided a perfect snapshot of California’s total failure to get cannabis policy right, and how that has led what should be a thriving new industry into near-collapse, or at least arduous, unnecessary struggle.

The central, unspoken irony of the first article is that the state government, in announcing the seizure figure, was actually bragging. Thirteen months ago, the three cannabis-regulating agencies were all merged into one, the Department of Cannabis Control (DCC). That just so happens to be the time period the DCC measured to reach the billion-dollar mark.

The merger was a good idea; it never made much sense to have several agencies regulating weed. They often worked at cross-purposes, and policy often didn’t make sense. Cannabis businesses were constantly confused by the morass of rules that sometimes contradicted each other. That situation has improved since the merger, and will likely continue to do so.

But the fact that so much illegal weed is still being sold in the state that authorities can seize that much of it in a single year is not anything the DCC should be bragging about. The seizures are perhaps necessary (though that’s more debatable than it might appear), but it’s necessary because the state doesn’t have its act together in the first place. Pot is legal in California. There shouldn’t be a substantial “illicit market” for it any more than there’s a substantial “illicit market” for booze. It’s as if, after prohibition was repealed, moonshiners not only continued to thrive, but actually had been far more successful than legal distillers.

Nevertheless, the agency devoted to implementing cannabis policy in California wrote a congratulatory letter to itself about the seizures. “This important milestone was reached through close collaboration with local, state, and federal partners and furthers California’s efforts to go after activities that harm communities and the environment, including water theft, threats of violence, elder abuse and human trafficking, to name a few. These operations and the products they produce threaten consumer safety and the vitality of legal and compliant licensees.”

But is it a ‘milestone’ or a millstone?

Later in the announcement, the DCC declares that it’s “working to expand access to tested cannabis products for consumers and lower barriers of participation for businesses. This includes a recent allocation of $20 million to DCC to grant cities and counties with funding that will support the creation of cannabis retail access in areas that currently do not allow it.”

That’s all good, as far as it goes. As was the legislature’s recent decision to eliminate (at least temporarily) the state’s cultivation tax. But the state’s 15% excise tax on weed sales, which comes on top of the regular sales taxes, as well as any local levies, is still hobbling the industry (the DCC doesn’t decide tax rates, of course: This is the Legislature’s failure). So are confusing and severe regulations.

The one problem the DCC specifically cited—the fact that most local governments refuse to license cannabis businesses, including retailers—is probably the worst of all in terms of giving Californian’s access to legal weed. We’ll see what good the $20 million in grant money does, but it seems unlikely to put much of a dent in the state’s illicit market, which generates about $8 billion a year in revenue, according to Global Go Analytics, while legal weed sales in the state are only about $4.4 billion.

Global Go Analytics estimates California’s illicit cannabis market generates $8 billion in annual sales, nearly double that of the legal market, which the MJBizDaily says brought in about $4,4 billion last year. No matter what the DCC does to “support the creation of retail access,” that situation won’t be relieved until the state starts treating cannabis like any other legal business.

The head of the Natural Products Association (NPA) slammed FDA for not substantively responding to a citizen petition that seeks to create a pathway to market for hemp-derived CBD in dietary supplements. And in an email Tuesday, NPA CEO and President Dan Fabricant said his organization “will keep all our options open that support and pursue actions that clear a path forward for a regulatory mechanism that effectively oversees the sale of hemp-derived extracts such as cannabidiol in foods and dietary supplements.”

The director of FDA’s Office of Dietary Supplement Programs (ODSP), Cara Welch, advised Fabricant in an Aug. 19 letter that FDA has not reached a decision on NPA’s petition within 180 days due to “the complex nature of your requests.”

NPA’s petition requested FDA either determine CBD is not excluded from the definition of a dietary supplement or apply “enforcement discretion in a specific and selective manner over CBD products following a safety review of a notification on an individual dietary supplement product submitted consistent” with FDA regulations, according to Welch’s letter. The petition alternatively requested FDA recommend the issuance of a regulation legalizing CBD, she noted.

Beginning in 2019 with a petition submitted by the Consumer Healthcare Products Association (CHPA), three industry trade organizations have filed citizen petitions with FDA to create a legal pathway for marketing CBD in dietary supplements. FDA has yet to respond substantively to any of them, citing the complexity of issues raised in the petitions.

FDA for years has proclaimed CBD cannot be marketed as a dietary supplement under the Federal Food, Drug & Cosmetic Act (FDCA) since it was first studied as a drug. However, CBD-containing “supplements” have been widely marketed in the U.S. following passage of the 2018 Farm Bill, which removed hemp as a Schedule I controlled substance.

In the most recent petition submitted in February, NPA requested FDA essentially set aside its conclusion that CBD is excluded from the definition of a dietary supplement and review the merits of cbdMD’s safety information as part of a new dietary ingredient notification (NDIN) to FDA. cbdMD, which reported second-quarter revenue of $8.59 million, has a representative on NPA’s board of directors.

Representatives of cbdMD and NPA met on Jan. 28 with FDA during a pre-NDI meeting.

Unless FDA agrees to substantively review cbdMD’s safety data, NPA’s petition argued, an NDIN to FDA would expose the company “to the risk of disclosure of the data along with potential misrepresentations of the data without any benefit to cbdMD.”

In her brief letter to Fabricant, Welch wrote FDA is “actively” reviewing NPA’s petition and intends “to respond when our review is complete.”

“FDA is not doing its job, plain and simple,” Fabricant, who oversaw FDA’s Division of Dietary Supplement Programs from 2011 until 2014, said in an email to Natural Products Insider. FDA officials have “stated for years that they want more scientific data and specific scientific data. In fact, FDA has repeatedly requested that industry provide specific data and scientific analysis and input. However, when they are provided the opportunity from a reputable company committed to doing good scientific research, they deliberately refuse to review it and instead throw the drug exclusion criteria as a blockade.”

Dan Fabricant, president and CEO of the Natural Products Association (NPA)

NPA requested, in part, that FDA exercise so-called enforcement discretion over CBD following a safety review of individual products. FDA has adopted an enforcement discretion policy in connection with another ingredient the agency has concluded is excluded from the definition of a dietary supplement since it was first approved as a drug: NAC (N-acetyl-L-cysteine). In recently published final guidance, FDA explained its “enforcement discretion policy applies to products that would be lawfully marketed dietary supplements if NAC were not excluded from the definition of ‘dietary supplement’ and that are not otherwise in violation of the” FDCA.

NPA and FDA have been at odds before over regulatory issues, including in connection with NAC. In August 2021, NPA filed a citizen petition with FDA regarding the ingredient, then sued the agency in U.S. District Court in Maryland. That lawsuit remains pending.

“The lack of FDA regulations on CBD and other hemp-derived food and nutrition products has caused confusion and an increase in misinformation across the country,” Fabricant said. “The agency is fully aware of the harm it has caused by doing nothing, but unfortunately chooses to deliberately sidestep and ignore it as seen in its purported ‘response’ to NPA’s petition.”

Reactions from CRN, CHPA

NPA’s request is not the only CBD citizen petition pending at FDA. The agency still has not provided substantive responses to petitions filed by CHPA in 2019 and the Council for Responsible Nutrition (CRN) in 2020.

FDA has raised concerns that CBD can potentially harm consumers. For example, the agency has stated CBD can cause liver injury, potentially cause side effects for consumers taking other drugs and has been the subject of animal studies showing male reproductive toxicity, or damage to fertility.

Asked to comment on the pending CBD petitions filed by CRN, CHPA and NPA, an FDA spokesperson said the agency “is reviewing these petitions and will respond directly to the petitioners.”

“While CRN is disappointed in FDA’s recent CBD citizen petition response stating it needs more time to evaluate the questions about CBD safety, enforcement discretion and rulemaking, we are not surprised,” Megan Olsen, senior vice president and general counsel with CRN, said in an email responding to FDA’s interim response to NPA’s petition. “This is the same response FDA has provided to the industry for nearly four years since the 2018 Farm Bill’s passage, including in response to a CRN citizen petition filed more than two years ago.”

“FDA simply continues its failure to not take action toward creating a legal pathway for CBD dietary supplements, leaving consumers vulnerable to unregulated products and companies subject to a patchwork of state regulations and an uncertain market for hemp-derived CBD,” she added. “CRN has highlighted this agency failure numerous times, including in a recent Washington Post op-ed.”

Duffy MacKay, senior vice president of dietary supplements with CHPA, suggested challenges facing FDA regarding CBD and other ingredients illustrate the need for reform to the Dietary Supplement Health and Education Act of 1994 (DSHEA).

“The fact that FDA is unable to navigate the ‘complex nature’ of laws pertaining to natural products also investigated as drugs is yet another reason why updates must be made to the 27-year-old law governing dietary supplements,” he said in an email. “The regulatory and market confusion with legitimate ingredients like CBD, hemp extracts, NAC, vinpocetine and others needs clarification because litigating one ingredient at a time under the current structure results in wasted industry and FDA resources. CHPA supports modernizing supplement regulations, including addressing the poorly written and often debated investigational new drug (IND) preclusion.”

‘Silver lining’?

Jonathan Miller, general counsel to the U.S. Hemp Roundtable, described FDA’s “continuing delay” on CBD regulation as “frustrating,” but he’s trying to find a “silver lining.” U.S. Hemp Roundtable has requested a meeting with FDA’s cannabis working group, and Miller found encouraging the agency’s response to the group’s request.

FDA officials advised U.S. Hemp Roundtable “they wanted to get back to us. They still have a lot of thinking to do and want to make sure when we meet … we can have a substantive discussion,” Miller said in an interview. “That’s a sign of encouragement because every time we’ve met in the past, they’ve just been in listening mode. I am hopeful that the delay of our meeting, as well as the delay to the response to the citizen petition, is reflecting the new [FDA] commissioner’s promise he made at that hearing a few months ago, where he said he wanted to have some movement on this issue.”

During a hearing on Capitol Hill in May, FDA Commissioner Dr. Robert Califf said he was committed to moving forward on a pathway for CBD. However, he suggested the agency doesn’t have the current authorities to do so today and will require collaboration with lawmakers on Capitol Hill.

Miller expressed hope that FDA’s scheduling of a meeting with U.S. Hemp Roundtable, which has yet to occur, will reflect “the beginning of a true real dialogue and discussion about how we’re going to get to regulation.”

Meantime, it remains to be seen whether FDA is inclined to create a path to market for CBD in supplements without an explicit directive from Congress.

Patrick McCarthy is CEO of Validcare, a contract research organization that spearheaded research to assess the effect of CBD on liver function, sleep and testosterone. Validcare representatives met with FDA’s cannabis working group in May and shared findings of the data.

In a news release issued in May, U.S. Hemp Roundtable concluded the data verified prior research that orally ingested CBD boasts “a strong safety profile.” The hemp group added the study suggested daily consumption across a range of typical retail products and serving sizes is not linked to daytime drowsiness, elevated liver tests or low testosterone levels.

FDA requested the data, and it was presented, according to McCarthy. “We asked if [FDA officials] needed any more [data] and they did not indicate that they do,” he said in an interview. Furthermore, McCarthy said, FDA did not provide “us a path by which to collect more data if they want it.”

His conclusion? FDA officials “still need to regulate, and from what I can see, they’re treating any cannabinoids as a drug,” McCarthy commented, “and they prefer clinical research to happen down the IND route.”

‘FDA needs to act now’

Some lawmakers remain concerned over the absence of U.S. CBD regulations. During a July 28 hearing examining the USDA Hemp Production Program and held by the House Agriculture Committee Subcommittee on Biotechnology, Horticulture and Research, Rep. Jim Baird (R-Ind.) said, “We’ve heard a lot of great recommendations for the 2023 Farm Bill here today, and one that I’d like to add is that the FDA hasn’t really had any kind of regulatory framework for hemp-derived CBD, so I would encourage us to include that in our discussions about the 2023 Farm Bill.”

“Thank you and I agree wholeheartedly with that assessment,” Rep. Stacey Plaskett (D-Virgin Islands), who chairs the Subcommittee on Biotechnology, Horticulture and Research, responded.

In testimony during the hearing, Kentucky’s agriculture commissioner Ryan Quarles suggested “a lack of direction from the FDA” is the biggest challenge facing the hemp industry.

“Without clear direction from the FDA regarding products containing hemp-derived CBD, large retailers will not carry CBD products, and many business leaders are reluctant to move forward with the development and manufacturing of these products,” Quarles testified. “The FDA needs to provide regulatory pathways for products containing CBD. The FDA needs to act now.”

Kratom, a drug that has been used in Southeast Asia for centuries, has been gaining ground in the U.S., slowly catching up to the commercial popularity of cannabidiol products.

While cannabidiol, or CBD, is extracted from marijuana, kratom is an herbal drug from the Mitragyna speciosa tree that can be chewed, taken as a capsule or consumed as a tea. CBD mostly acts as a pain reliever and relaxant, while kratom can act as a stimulant at low doses and as an opiate in higher doses.

Using national data, Joseph Palamar, an associate professor at New York University Langone Medical Center, estimated that 0.7 percent of the U.S. population has used kratom in the past year.

„Given that people who use opioids are underrepresented in national survey data, I further estimate that still only about 1 percent of the U.S. has used kratom in the past year,” he told Newsweek.

CBD is still more popular, however. According to a 2019 Consumer Reports CBD survey, 40 percent of people aged 18 to 29 have tried CBD in the U.S.

Uses of Kratom and CBD

Kratom has a thriving community of fans online. Jenn Lauder, the director of marketing and advocacy at kratom company PDX Aromatics, told Air Mail that there may be upward of 10 million kratom buyers.

While some take it as a stand-in for other drugs like Xanax or Adderall, others report that kratom helps to alleviate their opiate withdrawal symptoms and manages mental health problems.

„It seems to really have become pervasive across [New York] in the last year,” one kratom user told Air Mail. „I got really into it immediately. It’s just such a treat.”

The effects of the drug depend on the dosage and the type of kratom the user consumes. Kratom bars, which can be obtained in New York City and Los Angeles, come in red, gold, white and green colors, all with different types of high.

CBD is self-administered to treat a raft of different ailments, including chronic pain, anxiety, acne, insomnia, Parkinson’s disease and even cancer symptoms.

How Do They Work?

According to Albert Garcia-Romeu, an assistant professor at the Johns Hopkins University School of Medicine’s Behavioral Pharmacology Research Unit, the dosage-dependent effects of kratom are due to a variety of different alkaloids contained in the drug.

„Different drugs can have dose-dependent effects [such as] having a buzz from one or two drinks versus being passed out and vomiting from nine or 10 drinks. So this is part of the different effects people report based on how much they use,” he said.

„However, kratom contains varying levels of over 40 different alkaloids, each of which can have different pharmacological activity, including on the opioid, serotonin and adrenergic systems; can occur at different levels in different plants; and can degrade or become more potent over time,” Garcia-Romeu said.

Kratom is the agonist, or activating chemical, of adrenergic and opioid receptors, while CBD works on a different set of receptors in the brain, the endocannabinoid system.

Effects of Kratom and CBD

The long-term effects of kratom usage are not known, according to the National Institute on Drug Abuse, although it is an area of active research.

Other types of commonly used recreational drugs, like cocaine or nicotine, are known to be addictive and can be very difficult to stop using after a person gets hooked.

„There are reports of dependence development with high-dose and chronic kratom use,” said Oliver Grundmann, a clinical professor in the Department of Medicinal Chemistry at the University of Florida.

„Although this is not as well established as for alcohol, opioids or stimulants, some case reports suggest that kratom dependence and withdrawal resemble that of opioids. But the caveat here is that we do not have a lot of data to date,” he said.

However, according to Garcia-Romeu, experiences of drug tolerance (i.e., needing to take more to feel the effects) and withdrawal (i.e., feeling ill or uncomfortable after stopping use) happen less with kratom than with other drugs like opioid medications.

CBD, on the other hand, is recognized by the World Health Organization as a safe substance both for humans and animals. Humans are able to tolerate 1,500 milligrams of CBD daily for several weeks without any dangerous side effects.

Dangers: Do They Cause Seizures?

With increased drug usage comes the risk of overdose, especially with drugs like opioids. According to the U.S. Centers for Disease Control and Prevention, 91,799 drug overdose deaths occurred in the United States in 2020, of which 74.8 percent were the result of opioid overdose.

„To date, there is little data to suggest that consuming kratom itself, in the absence of any other substance such as alcohol, benzodiazepines, opioids, can lead to a fatal overdose,” Grundmann said.

Garcia-Romeu said that „people have died while taking kratom in combination with other drugs like alcohol, opioids and benzodiazepines, and we know because of the way it’s metabolized it can interact with these substances in ways that could cause risks.”

There are also fears that kratom may cause seizures. Studies have found that after a single exposure of kratom, seizures can occur, with an incidence of 6.1 to 9.6 percent.

If taken in too high a dose, CBD may lead to dry mouth, drowsiness, lightheadedness, nausea and vomiting. CBD is not associated with seizures and, in fact, has been used to treat them.

Legality of Kratom and CBD

The Food and Drug Administration (FDA) has not approved CBD for medicinal use, but 33 states have legalized it for medical purposes and 11 have approved it for recreational use by adults 21 and older.

Kratom is legal in the U.S. at the national level, but the Drug Enforcement Administration (DEA) considers it a „drug of concern.” It is also not approved as safe for consumption by the FDA.

„The DEA intended to ban kratom a few years ago but backed off after a lot of public pushback,” Palamar said. „Kratom is also illegal in some U.S. states. As of now, it seems like kratom will remain legal, but you never know what will happen in the future.”

Some say that making kratom illegal will only worsen the war on drugs and its effects on society.

„My sense is that banning kratom could lead to worsening of the current opioid epidemic, which is already at record high overdose levels, mainly by forcing people who are using kratom for pain or other health reasons to go back to using opioids or other substances with known risk of addiction and fatal overdose,” Garcia-Romeu said.

[Los Angeles, CA] August 31, 2022 — PRESS RELEASE — Hot off a record-breaking launch of Cookies in Miami, Fla., TRP continues its nationwide expansion on its home turf. Bringing one of the world’s most recognized cannabis brands to one of LA’s most exclusive and picturesque neighborhoods of Brentwood, TRP is excited to open a new Los Angeles location for Cookies with a gorgeous dispensary on San Vicente Boulevard on Saturday, Sept. 10, 2022. In an industry with complex rules and regulations that vary from state to state, TRP has been the engine behind the successful rollout of Cookies dispensaries in eight states (CA, NV, OR, WA, OK, CO, FL, MA) and counting, providing expertise and enterprise level infrastructure to exclusive partners including Cookies, Dr. Greenthumb’s, and Insane.

Regarded as one of the cannabis capitals of the world where hype and premium genetics reign supreme, it makes sense that TRP is best suited to take on the challenging task of spearheading the newest Los Angeles store opening for Cookies Brentwood. Situated next to the iconic Brentwood Country Mart, TRP was able to open the very first dispensary located in the Westside neighborhood, standing beside other high-profile retailers including James Perse, goop, and Christian Louboutin, beloved by the community for decades.

“TRP opening Cookies Brentwood just weeks after a successful Cookies Miami launch is exactly the challenge at which we excel,” says co-founder and CEO of TRP, Brandon Johnson. “Our team at TRP is experienced at operating in multiple markets. We encompass everything from adapting standard operating practices to complying with different regulations while catering to the unique customers in each market.”

The excitement generated from the Miami launch will no doubt create a halo as TRP meets the demand for a more accessible and updated storefront with the elevated customer experience that is expected from TRP’s owned and operated Cookies stores. The newest location will seamlessly capture a new and existing customer base with exclusive cannabis offerings as TRP builds strong relationships with the local community as well as serves as an educational resource for premium cannabis genetics. 

“Brentwood is one of the most exclusive and coveted neighborhoods in the country,” says president and co-founder of TRP, Daniel Firtel. “Securing real estate here is a challenge no matter who you are, let alone a cannabis company. It’s these types of challenges that set TRP apart as an operator in cannabis. We’ve been able to take one of our core competencies in real estate to achieve a small win for the industry.”

TRP’s expansive retail, cultivation and distribution network is imperative to the success of brands as they look to scale across the U.S. and the world’s segmented cannabis market. The greater Los Angeles community is invited to join and support TRP in breaking opening day records for their high wattage grand opening with a ribbon cutting ceremony on Sept. 10, 2022, at 9 a.m. PDT, further locking in its foothold in the cannabis space as the largest owner and operator of Cookies dispensaries nationwide. The TRP team looks forward to bringing the grand opening back to California to see Cookies loyalists and new customers explore the store, shop, and if they’re lucky, receive giveaways from the TRP team, as the entire crew gears up to meet their new neighbors and community members.

NOXX, a Grand Rapids-based vertical cannabis company, has announced plans for operational growth supported by a $15 million debt raise from Altmore Capital, a specialty firm that invests in the U.S. cannabis industry.

In August, NOXX announced a partnership with Forty Acres Enterprises, with a goal of helping to nurture Black cannabis entrepreneurs, open new Black-owned cannabis companies, and serve as an innovation incubator for Black involvement in cannabis in Grand Rapids and across Michigan.

“NOXX is committed to building one of the most innovative and inclusive companies in cannabis,” says Tommy Nafso, CEO of NOXX. “Whether people want to transact in-person, online or through delivery, NOXX creates a convenient and exceptional shopping experience through unmatched product pricing and selection, hospitality, and an industry leading loyalty program.”

The partnership’s first collaboration is a new cannabis dispensary now open in Grand Rapids.

“The cannabis market today is more competitive than ever, and as Altmore continues to evaluate opportunities for investment, we’re focused on finding operators with a growth strategy built around longevity and a proven track record of success in the market,” says Steve Ham, managing partner at Tysons, Va.-based Altmore Capital. “NOXX represents all of this, and we’re thrilled to add the company to our portfolio of top-tier cannabis operators.”

NOXX currently operates a dispensary at 2440 28^th St. SE in Grand Rapids, with a store each planned on Ann Street and Plainfield Avenue.

Statement by Col. Joe Gasper, Director

The Michigan State Police Forensic Science Division (MSP/FSD) is committed to providing the highest standard of forensic services to the criminal justice community. The MSP/FSD is accredited in toxicology and analyzes approximately 20,000 samples annually for the presence of alcohol and/or drugs pursuant to a forensic examination request. The men and women who work in the MSP/FSD strive to provide laboratory testing services that are timely, transparent, and scientifically accurate.  

The MSP/FSD has halted all THC toxicology testing due to a technical issue in which samples containing Cannabidiol, commonly known as CBD, may be converted to Tetrahydrocannabinol, commonly known as THC, during the testing process, leading to potentially inaccurate test results. 

CBD, which is structurally similar to THC, was illegal in Michigan until March 28, 2019. Since that date, however, CBD, which is reported to have no psychoactive properties, has been legal under Michigan law.

When the issue first came to our attention on August 19, 2022, the MSP/FSD immediately launched a significant evaluation of our testing process. The evaluation found the laboratory confirmatory method in use may cause 1) THC to be identified when the sample contains THC, 2) THC to be identified when the sample contains a combination of THC and CBD, or 3) THC to be identified when the sample contains CBD alone.  

Upon this discovery, the MSP/FSD immediately halted the processing of samples using the current THC confirmation test. Notification was also made to the Prosecuting Attorneys Association of Michigan on August 25, 2022, for dissemination to prosecutors statewide to prevent these reports from being used in any current or pending court cases. 

After further review, we now believe this discrepancy may impact cases that occurred on or after March 28, 2019, where the alleged violation is based on the finding of THC alone and there is insufficient evidence of impairment, intoxication, or recent use of marijuana to otherwise support the charged offense. 

Laboratory data indicates there are approximately 3,250 laboratory reports that may be impacted. These are reports in which there was a THC-confirmed result without other drugs present or alcohol detected above the 0.08% blood alcohol content legal threshold. These individual cases are being identified and will be shared with the prosecuting attorney of record for further investigation as to any potential impact to the individual involved.

In addition to temporarily halting testing of THC samples and disclosing the issue to prosecutors, the MSP/FSD has taken the following action steps:

• Reported the issue to our accrediting body, ANSI National Accreditation Board (ANAB), and requested they conduct an independent review.
• Temporarily halted the disposal of blood samples to preserve this evidence should re-analysis be required.
• Started validating a new cannabinoid confirmatory method that will be able to distinguish CBD from THC. This method will be validated before being put into use to ensure similar issues with drug interference will not happen in the future.
• Started the process to establish a contract with a private, accredited laboratory for processing THC samples in the interim before the new method is validated.

The MSP/FSD remains committed to providing the highest standard of forensic services to the criminal justice community. We have demonstrated this commitment through accreditation to ISO/IEC 17025 International Standards and voluntarily incorporating forensic standards from the National Institute of Standards and Technology (NIST) Organization of Scientific Area Committees (OSAC) into our laboratory management system, among other efforts. The MSP/FSD continues to strive to be timely, transparent and ethical in our response to this emerging technical issue.

New York’s Marijuana Regulation and Taxation Act (the Act) not only legalized recreational cannabis possession and use for those 21 and older, but also sent a message across the U.S. that New York was going to focus a great deal of its time and resources on “justice-involved” persons looking to start cannabis businesses. Since the Act was signed, it has been clear that New York is serious about ensuring its cannabis industry isn’t just for big businesses; the state intends for the industry to be flooded with applicants from underrepresented communities or areas negatively affected by the war on drugs. One example of this is the Cannabis Control Board’s (CCB) conditional adult-use retail dispensary regulations (the Regulations), which were approved on July 14 and filed with the state register on August 3.

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