My Blog

"Immature Plants"

12/12/2011 13:00:00

CRS 12-43.3-104 defines "Immature Plant." There has always been a debate as to how these are counted against an MMC's plant count. Currently, MMED counts them.

Proposed rule 1.410 (f) appears to limit that to plants being grown for the purpose of sales. Does this mean that those plants that are being grown to be cured don't count? We will see.

MMC sales to MIPS

10/11/2011 17:43:00

Despite previous statements and interpretations, MMED is now making it quite clear that MMJ sales by MMCs to MIPS DOES count against your 70/30. I repeat, it DOES count towards the MMCs 70/30. There is one exception...... if the MIP sends back ALL the product made from the MMCs MJ. All.

Regulation 2 E: WTF #1

08/16/2011 09:36:00

The first WTF moment comes with Regulation 2(e). It says that patients may change their primary care-giver or primary MMC every 30 days. Yes it really says every 30 days. This is in direct contradiction 1.200 of the MMED rules. When questioned about this contradiction MMED indicated that "both rules apply."????

Regulation 2(d) 60 day renewal issue

08/16/2011 09:23:00

Regulation 2(d) indicates that patients should not renew their registry card sooner than sixty days prior to the expiration date. If they do, CDPHE considers it a request for a replacement card and NOT a renewal. They keep you money and make you reapply, and pay again, when the card expires.

Significant Responsibility: Regulation 2(iii)

08/16/2011 09:20:00

One of the first things that jumps out, and something that had to be expected, is that the Department adopts the basic caregiver standards from People v Mentch in Regulation 2(iii). Mentch is a California case that decided that a caregiver needs to provide more services to their patients than medical marijuana.

5 CCR 1006-2

08/16/2011 09:13:00

5 CCR 1006-2 is a Colorado Department of Health regulation. It can be found on our "MMED AND CDPHE FORMS" page or at the CDPHE website. These regulations have gone largely unnoticed but will have a major effect on patients, caregivers and MMCs.

Holder Clarification Memo

07/01/2011 06:27:00

Ok....... does this make it a whole lot clearer?

Holder Clarification Memo

Occupational Licenses

06/28/2011 13:18:00

As you know, employee apps have been sidelined for a while - HOWEVER, you MUST have all employee apps filled out COMPLETELY and in your store/grow or IPM. They will also want to see the "employee list" in your grow, IPM or MMC

Occupational Licenses

06/28/2011 13:16:00

Julie from MMED says:

Hello All,

Would you help us get the message out to the industry that we are asking them not to send employees to our office for Occupational Licenses until July 5th or after. The MMED will not be issuing sanctions against those businesses whose employees do not meet the July 1, 2011 Occupational License requirement until individuals in the area where the business is in operation have had a reasonable time to obtain their licenses.

Thanks,

Julie

Julie Postlethwait

Public Information Officer

Medical Marijuana Enforcement Division

Colorado Department of Revenue

455 Sherman Street, Suite 390

Denver, CO 80203

303-205-2360

jpost@dor.state.co.us

Waste Disposal

06/28/2011 06:29:00

Waste disposal: after rendering the marijuana unusable, you must then dispose of it at a dump (not approved or certified) and get a receipt for your waste disposal.