THIS PETITION IS ENDORSED BY THE FOLLOWING

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As California cannabis manufacturers and organizations advocating on behalf of patients and consumers, we support practical, effective regulation that will encourage innovation and ensure that you as patients retain safe, affordable access to your favorite infused products.

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We applaud the California Department of Health, the Bureau of Marijuana Control, and the Department of Pesticide Regulation for their work on the proposed regulations for medical cannabis, as well as all of the other organizations and individuals that have worked so tirelessly on laws for both medical and adult use.

Although many of these proposed regulations are well-considered and advance our shared goal of a regulated industry, a few specific rules threaten to reduce your product choices, limit your access, eliminate your dosing options, significantly increase your costs, negatively impact the environment, and stifle innovation in the largest cannabis market in the world.

We have come together to encourage the state to reconsider these proposed regulations. Our efforts will ensure that you have continued safe, affordable access to both new and existing products that meet your needs as patients and consumers.

We have worked closely with the state throughout this process and have every expectation that productive dialogue will continue.  However, we need to show the state that we have your support as patients and consumers.

By signing this petition, you are letting the state know that you support our efforts to ensure the products you have come to depend on will remain accessible, affordable, and economically and environmentally viable.

PETITION FOR CONTINUED SAFE ACCESS FOR PATIENTS & CONSUMERS

As a California resident, I support cannabis manufacturers in their efforts to ensure effective regulation that will protect our rights as consumers to retain safe, affordable access to our favorite infused products.

The proposed regulations listed below affect me directly and I support the efforts of manufacturers to formulate alternative rules that will ensure our access to medicine, protect public safety, and preserve a competitive and innovative marketplace.

1. Patients should have access to doses that meet our medical needs.

The proposed regulations ban edible products with more than 10 milligrams of THC per serving, or 100 milligrams of THC per product, despite cannabis’ safety and non-toxicity even at high doses. As many current patients rely on access to higher potency medications, we need to retain access to the doses that have helped them meet their medical needs for the last twenty years. This regulation will establish an unfair financial burden on patients and have no meaningful impact on public safety.

2. Patients should have access to a wide range of fresh, edible products that meet food safety standards.

The proposed regulations ban all edible products that require refrigeration and any products containing dairy, meat, and vegetable or fruit-derived juices and extracts. One of the benefits of living in California is access to organic, fresh dietary options. The proposed restrictions would eliminate these healthy options and instead replace them with synthetic, preservative-filled processed foods. We believe that products that can be accurately dosed and produced according to existing food and safety regulations should be allowed in the infused marketplace. Keeping these restrictions in place would eliminate a large number of existing products that have been accessible for years, and severely curtail innovation of new products.

We are also concerned about the proposed prohibition on caffeine additives. If this rule is to stay in place, it should apply only to additive or supplemental caffeine and not the caffeine naturally occurring in ingredients that are commonly used in products patients have come to rely on.

3. Edibles companies should have access to commercial kitchens for shared use.

As in other sectors of food industry, small and medium-sized edibles companies will rely on shared access to commercial kitchen space to stay viable. Access to commercial kitchens is even more important for cannabis businesses, which have to pay an enormous premium on real estate compared to other businesses. The proposed regulations effectively ban this practice, creating an insurmountable barrier of entry to new and artisan companies and encouraging monopoly control of the industry. This reduction in competition will result in higher prices and less selection for us as patients. California can model its rules after states like Oregon that have allowed for cannabis businesses to occupy shared space.

4. Regulations should minimize unnecessary costs to patients and businesses.

We support strong and sensible regulations that can be shown to protect patients and the public. However, regulations that are unnecessary and burdensome will make medicine unaffordable for patients, shut down small businesses, incentivize the black market, and encourage wasteful and environmentally harmful practices. The proposed rules include expensive and duplicative packaging standards, burdensome testing requirements, and a ban on remediation that will add significant cost to products without benefiting public safety. For instance, under the current rules, any failure of a test will require an entire batch of product to be destroyed – even if the test failure was due to too much or too little THC or CBD and could easily be remediated by the manufacturer. In some cases requirements go well beyond the standards required for tobacco, alcohol, or pharmaceutical drugs. Regulators should make sure that all rules are truly necessary to protect the public before making decisions that place additional burdens on patients, small businesses, and the environment.

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