The amended versions of California’s Assembly Bill 266 and Senate Bill 643 containing California’s take on medical marijuana may seem complex – but at least this time everything is neatly set out in Regulation AB 266 the Governor signed into law on October 9, 2015. However this is no guarantee that they are practical).
The regulations really are little more than a bureaucratic shove to get participants past the corncob-chewing era, and out in the open behaving like the rest of the food and drug fraternity. Cutting out the legalese (the authors must be paid per word) here is the bottom line on rules for packaging under Article 7 (Licensed Distributors, Dispensaries, and Transporters) at Section 19347(a).
- While MMJ products must be labeled and be in tamper-proof packages, these may not attract interest from children.
- Packaging must prominently display the following in clear and legible font (could be problematic when supplying individual doses)
– Date and place of manufacture
– The words “SCHEDULE I CONTROLLE SUBSTANCE.”
-“KEEP OUT OF REACH OF CHILDREN AND ANIMALS” in bold print
– The restriction “FOR MEDICAL USE ONLY.”
- Packaging must also display the following warnings, again in clear and legible font.
– A notice that “The INTOXICATING EFFECTS OF THIS PRODUCT MAY BE DELAYED BY UP TO TWO HOURS.”
– The statement “THIS PRODUCT MAY IMPAIR THE ABILITY TO DRIVE OR OPERATE MACHINERY. PLEASE USE EXTREME CAUTION.”
4. Packages containing only dried flower must record the weight of medical cannabis.
5. If the product uses nuts or another known allergen, there must be a suitable warning.
6. Only generic food names may describe edible medical cannabis products.
7. Milligrams per serving, servings per package, and package total of pharmacologically active ingredients including – but not limited to – tetrahydrocannabinol (THC) and cannabidiol (CBD) must be listed.
8. An admission (as if this were necessary) that the product contains medical cannabis. Surprise, surprise!
9. A statement about the source, and date of cultivation and manufacture.
10. Any other requirement set by the Bureau of Medical Marijuana Regulation.
11. Information about the unique identifier issued by the Department of Food and Agriculture.
The only thing lacking is where to fit all this information on a single-serving brownie in a transparent cellophane package. The jury is still out on this one, with no clear direction, and traditional farmers no doubt thoughtfully chewing on their corncob pipe stems.