One of our top priorities as we implement the AZ Medical Marijuana Act over the coming months is to ensure that we develop good Rules (called Administrative Code) so we can regulate medical marijuana effectively. Rules that are clear, objective, well-researched, and that balance competing interests are absolutely critical in order to effectively implement a responsible medical marijuana program. Our goal is to develop rules that’ll ensure qualified patients have access to marijuana for their medical condition while preventing (to the extent possible) recreational marijuana users from accessing marijuana through the Act’s provisions. In addition, we want to develop Rules that ensure that marijuana dispensaries act responsibly and have adequate security and inventory controls.
In order to achieve these goals we will need your help. Over the coming months we need input from all Arizona residents so that we’re able to balance all of the competing interests and come up with the most responsible set of regulations possible. I’m certain we’ll have plenty of comments from the people who intend to apply for a dispensary license or become a qualified patient, caregiver, dispensary agent, or provide medical marijuana recommendations. However, it’s more challenging to get input from residents who will have no direct interest in the industry but still want the law to be implemented in an effective way that minimizes abuse.
Please reach out to some of your stakeholder groups and ask them to check out our new website, review our informal draft rules and provide us with input so that we can make good decisions. Here are a few tips for people that would like to provide input:
- Use our comment website so that you can submit electronic comments
- Encourage folks to tell us what they like about the informal draft rule as well as what they don’t like. There’s a tendency for people to focus on things they don’t like and it’s just as important for us to know when something is on target.
- Encourage constructive comments and pragmatic alternative. It is even better if people submit alternate Rule language.
- Encourage people to focus on what’s good public policy rather than submitting comments that are designed to give themselves a competitive advantage or that are self-serving.
- Remember to remind stakeholders as they comment that the provisions of the Act limit our ability to regulate in many ways. For example, while the Act gives ADHS broad authority to regulate dispensaries but little authority to regulate caregivers or employer employee relations. You might want to remind folks to make sure that the Act provides the ADHS with the regulatory authority to act before spending a lot of time submitting comments.
Also, if you aren’t able to comment on this informal draft Rule between now and January 7, there will be additional time to comment in February and March.
P.S. The Governor signed the Proclamation that makes Proposition 203 law on Tuesday, so the 120 day implementation period will end on April 13.