Medical Marijuana Enforcement Division rules for moving MMJ extreme, says Wanda James
It's a crazy time for Wanda James, co-owner of Simply Pure Products, a medicated edibles company. Not only is she in the midst of introducing a bold new initiative -- Simply Home Cooking, for people who want to make their own edibles -- but she's readying for tomorrow, when Colorado's medical marijuana regulations officially go into effect. And she admits that many of them strike her as extreme.
James stresses that Simply Pure "has passed all the rules. All our products are compliant -- they're sold in opaque, childproof packaging -- and we've already gone through our final interview with MMED" -- the Medical Marijuana Enforcement Division, which is charged with making sure the regs are followed. "But getting there was extremely difficult. And then there's everything with the manifests..."
The manifests? "Every time you're moving marijuana, whether it's from a grow facility to a dispensary or our kitchen, or we're moving any of our infused products to a dispensary that's going to sell our products, there has to be what MMED is calling a manifest," she explains. "We have to e-mail MMED 24 hours in advance and let them know what the person's name is who'll be moving it and where they're going with x-amount of product. Everything has to be labeled and accounted for."
That may not seem onerous on the surface, but consider the complications. Simply Pure products are currently sold at 278 dispensaries in Colorado, and the firm typically employs between five and seven sales reps, each of whom is likely to make multiple deliveries per day. At this point, James thinks one e-mail will have to be sent for each rep, rather than for each of the rep's stops; if MMED insists on the later, it could bring the number of manifests from Simply Pure alone to thirty or more every day.
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And even if the total winds up closer to five, James remains uncertain "that MMED is going to be able to handle the onslaught of paperwork on a daily basis," especially in light of the difficulties inherent in the ongoing employee licensing process. MMED had to push back its July 1 deadline for workers in Denver a month, and those elsewhere in Colorado even longer, because staffers were overwhelmed by applications, resulting in long lines and some people who'd driven for hours being turned away.
That's not all. What if dispensaries run out of a certain item and want more? Are they forced to wait a minimum of 24 hours for a manifest to be sent to MMED, even if it hurts business? James doesn't know. And there are also questions about reps taking samples they can use to promote Simply Pure products at dispensaries that aren't currently carrying them. "Can the rep go in with a box and show them what they've got and move the product there and then? MMED hasn't given us an answer on how they want us to handle that," she says. "So we've added another line on the manifest saying, 'Rep A has x-amount of extra edibles they may be using throughout the day.' And we hope they're going to be okay with that.
"In our conversations with Dan Hartman," the head of MMED, "we're doing our best to show good faith in how we're attempting to do this," she continues. "But there's got to be some give in these rules, because the cost they're putting on individual businesses is somewhat extreme. They have to purchase cameras, POS systems, the type of computer system that can download into the MMED system -- but they're not allowing outside investment, and we can't go to a bank. So that puts on a lot of pressure to hit the goals MMED needs us to hit and still be a successful business."
Not that James is planning to dial back the ambition. Look no further than Simply Home Cooking, a new line of sauces, spreads and oils. "First, we're releasing the marinara sauce, the green-chile sauce and the mango salsa," she says. "Our spreads are peanut butter, apple butter and strawberry jam. And coconut oil and olive oil will come out later in the month, along with a cookbook showing people how to infuse almost anything they want and do their own dosing at home."
Couldn't this potentially cut into Simply Pure's sales of pre-made edibles? James doesn't look at it that way. "What's important to us is for people to be able to cook at home," she says. "We want to make sure patients are always taken care of. We started working with a hospice program and people with young families, including one of the forty kids on the registry under the age of eighteen. His family said, 'We'd like to have the opportunity to have dinner together,' and this will let them do it."
On top of that, they'll be able to make sure the doses are consistent, just as Simply Pure does with its own edibles. Right now, Simply Pure is producing videos -- they should be available soon -- to show people how to do it.
At this point, James would love to focus entirely on such projects rather than worrying about the vagaries of the new regulations. But she understands why that's not possible quite yet.
"I think what a lot of the activists in the industry don't realize is that we've got years to go before all the rules will even be close to set," she maintains. "If they legalized marijuana next month, it would take years for the business world to totally adjust -- and the laws will keep changing. So we need to be responsible, be professional and be able to show people that we know we're asking to sell a Schedule I drug -- and we're going to do everything we can to show the patients and the people who live in Denver and surrounding cities that this is a safe business, a good business, a viable business that's bringing a good product to market."
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