Regulation in Cannabis:

A Primer for City Planners in Orange County

Presented By

Mitch Kulick

*California passes Proposition 215 in 1996

*a/k/a The Compassionate Use Act
*California -- from First to Worst
*No testing for Safety or Consumer Knowledge

Department of Justice Guidelines

The Department of Justice policy statements are widely understood as allowing states to enact the enforce
legalization systems so long as the state laws adequately address these guidelines with the goal of
preventing:

1)Distribution of marijuana to minors.

2)Revenue from the sale of marijuana going to criminal enterprises.
3)Diversion of marijuana from sales where it is legal under state law to
other states.
4)State authorized marijuana activity from being used as a cover for the
trafficking of other illegal drugs or other illegal activity.
5)Violence and the use of firearms in the cultivation and distribution of
marijuana.
6)Drugged driving and the exacerbation of other adverse public health
consequences associated with marijuana use.
7)Growing of marijuana on public lands and the attendant public safety and
environmental dangers.
8)Possession or use of marijuana on federal property.

BLUE RIBBON COMMISSION

Created in October of 2013 to think through issues needed to be
addressed to properly regulate a legalized marijuana program;
Issued report in July of 2015;
Acknowledged that marijuana is already accessible to many even
though it is illegal beyond medical use under California law. Therefore
the BRC recognizes that the health and safety of minors and adults are
key areas for policymakers to consider and improve upon the existing
legal and regulatory framework;
One of the major findings of the Blue Ribbon Commissions work is that
the legalization of marijuana would not be an event that happens in one
election. Rather, it would be a process that unfolds over many years
requiring sustained attention to implementation on a state and local
level.

58 General Recommendations
1. Develop a highly regulated market with enforcement and oversight
capacity from the beginning, not an unregulated free market; this
industry should not be Californias next Gold Rush.
2. Build ongoing regulatory flexibility and responsiveness into the
process, while ensuring regulatory agencies are engaged
constructively to ensure successful and faithful implementation.
3. Establish a coordinated regulatory scheme that is clearly defined with
a unified state system of licensing and oversight, as well as local
regulation.
4. Testing of cannabisfor potency as well as for pesticides, molds and
other contaminants should occur near the points of harvesting
and/or processing.

Source: http://www.safeaccessnow.org/the_medical_marijuana_regulation_and_safety_act

Medical Marijuana Regulation and Safety Act

Under MMRSA, government officials will institute a
comprehensive regulatory structure for the states medical
marijuana program, which is an issue that was left
unaddressed when Proposition 215 was initially established
back in 1996.
The new regulations are designed to make certain that
registered patients do indeed have safe access to clean
marijuana products, as well as to safeguard the
environment, public safety, and public health.
Today ushers in a new era for California,
Assemblymember Bonta proclaimed. Patients will have
assurances that their products are safe.

California Proposition
64, the California Marijuana
Legalization Initiative, will be
on the November 8, 2016,
ballot in California as
an initiated state statute.
Supporters refer to the
initiative as the Adult Use of
Marijuana Act.

ADULT USE of MARIJUANA ACT

SECTION 3. PURPOSE AND INTENT. The purpose of the Adult Use of Marijuana Act
is to establish a comprehensive system to legalize, control and regulate the cultivation,
processing, manufacture, distribution, TESTING, and sale of nonmedical marijuana,
including marijuana products, for use by adults 21 years and older, and to tax the
commercial growth and retail sale of marijuana. It is the intent of the People in enacting
this Act to accomplish the following:
LOCAL GOVERNMENTAL CONTROL: Allow local governments to ban
nonmedical marijuana businesses as set forth in this Act.
TESTING: Require non-medical marijuana to be comprehensively tested
by independent testing services for the presence of contaminants, including
mold and pesticides, before it can be sold by licensed businesses.
PACKAGING AND LABELING: Require nonmedical marijuana sold by
licensed businesses to be packaged in child-resistant containers and be
labeled so that consumers are fully informed about potency and the effects
of ingesting nonmedical marijuana.

Dr. Donald O. Lyman, former Chief of Chronic Disease and Injury Control
at the California Department of Public Health, Gretchen Burns, Executive
Director of Parents for Addiction Treatment and Healing, and Steven
Downing, former Deputy Chief of Los Angeles Police Department, wrote
the official argument in support of Proposition 64 found in the state's
voter guide. Their argument is as follows:

Proposition 64 finally creates a safe, legal, and comprehensive

system for adult use of marijuana while protecting our children.
Marijuana is available nearly everywhere in California - but
without any protections for children, without assurances of
product safety, and without generating tax revenue for the state.
California Medical Association supports Prop 64 because it
incorporates best practices from states that already legalized
adult marijuana use, and adheres closely to the
recommendations of California's Blue Ribbon Commission on
Marijuana Policy, which included law enforcement and public
health experts.

Contamination is Unacceptable!
Whether youre a healthy consumer or (especially) if you
are an immuno-suppressed patient,
your health can be put at risk by inhaling pesticides, bug
infestations, or mold in your cannabis.

Its time for accountability in cannabis.

13

TESTING IS
ESSENTIAL
FOR PATIENT
AND CONSUMER
SAFETY
Why do we hold Chipotle to a higher standard than the producers of high-CBD
medical cannabis used for epileptic children?

14

This is
unacceptable
!
15

Heavy Metals

Chemical contaminants
Biological Toxins

Lead
Cadmium
Arsenic
Mercury
Mycotoxins
Bacterial Endotoxins
Bacteria

Microorganisms
Fungi

Biological contaminants

Parasites
Insects
Animals
Frass and Excreta
Insecticides
Herbicides

Pesticide residues
Fungicides
Class 3

Residual solvents

Class 2
Class 1

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These products will be present and

detectable depending on when they are
applied. They may be used at any
point, but are most dangerous when
used closer to harvest, or thereafter.
Solvents to be avoidedKnown human
carcinogens
Solvents to be limitedcausative agents
of other irreversible toxicity
Solvents with low toxic potential

Polluted soil and water,

during cultivation/growth
Mold Excretion
Bacterial Excretion
Soil, postharvestprocessing,
transportationand storage
Soil and water,
duringcultivation/growth
Soil, excreta;
organicfarming/cultivation,
manufacturing - Postharvest
processing,transportation
and storage
Air, soil, water, during
cultivation/growth,
post-harvest
processing

Manufacturing process

Labs Offer Consumer Protection

The lab ensures consumers safety by providing quality control over supply chain.

2016 Steep Hill Labs, Inc. | All Rights Reserved | Private and Confidential

Who Has Access to Testing in US?

Fewer than 20% of US states offer some form of testing.

18

Conclusion

Testing is essential for patients and

consumers

Industry is evolving towards testing

Credibility, compliance, and testing

is what will drive adoption

Steep Hill is paving the way through

industry-leading science and an
aggressive global licensing platform

Thank You!
For more information and questions please email

mitch@steephill.com

2016 Steep Hill Labs, Inc. | All Rights Reserved | Private and Confidential