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California's three cannabis regulatory agencies issued updated proposed regulations recently with a very short 15 day comment period ending 11/5.

We submitted updated comments (available here) and also resubmitted the comments previously submitted in August (available here) to the three agencies tasked with state cannabis regulation on October 30, 2018.  We noted their continuing, and disappointing, lack of public-health focused provisions and attention to social equity concerns. We highlighted particular concern over the BCC's decision to allow unfettered delivery in disregard of the needs and desires of local jurisdictions, the lack of any limitation on youth-enticing products such as cannabis infused beverages and flavored products, and the failure to place limitations on cannabis potency.

On the positive side CDPH did move to reinstate child resistant primary packaging, something we requested in our earlier comments along with pediatricians and others. We encourage continuing statements of support so that this does not backslide again. 

As a reminder, the 15 day period to comment on the proposed modifications ends at 5pm on November 5, 2018. Please do submit comments. If people concerned about public health don't speak up they will only hear from industry. 

Good news! We are beginning to see some movement among local jurisdictions to use cannabis tax dollars (or other funding) for public health and prevention purposes. For instance, we are watching the November 2018 Ballot Measure B in In San Joaquin County which, if passed, would impose a special tax "To support early childhood education, drug prevention, literacy, and other programs for children and youth; public health; public safety and enforcement of cannabis laws.”

In Stanislaus County, local rules require that permittees of commercial cannabis activities “develop or contribute to a county approved public outreach and educational program for youth organizations and educational institutions that outlines the risks of youth addiction to cannabis, and that identifies resources available to youth related to drugs and drug addiction.” (6.78.220).

We are monitoring tax and funding developments and adding them to our table of forward-thinking ordinance provisions (available here). If you are aware of adopted special taxes, or pending ballot measures, that put tax revenues into public health and prevention, please email Amanda Naprawa at amanda.naprawa@phi.org.

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We collaboratively develop and test models of optimal cannabis policy (retail practices, marketing & taxation) with the goal of reducing harms, youth use & problem use. These models are based on the best scientific evidence and guided by the principles of public health, social justice, and equity. 

We also provide technical assistance to jurisdictions considering legalizing cannabis. Please contact us for more information.