Good morning Chair postman members, Garrett Vollendroff. staff and guests their lobbies are open recording has begun.
Thanks Dustin will convene the liquor and cannabis board caucus meeting for June 4 2024. Our first item is to review recently completed cannabis compact. And I'll turn it over to Dr. Marla Conwell Hart tribal liaison. Morning.
Good morning, everyone. Good morning, members Vollendroff and Garrett. I'm here to present the tribal cannabis compacts that we've recently completed with the Lummi. Nation. the Lummi Nation worked with us throughout the beginning of this year, part of last year, and we were able to reach a successful agreement in which they passed on their and via resolution number 2024 Dash 039 on April 22 2024. So I would like to ask the board to please consider authorizing this so that we can move forward with it.
We'll have it up for formal consideration tomorrow. Right and do that. It can you just give a sense of we've had a few over the last year or so generally follow the same it changes that we've seen in the others on Dispute Resolution and yeah, shoots. Okay,
this actually is a very strong dispute resolution process involved in it as well as the most favored nation process. And I think it's particularly important that the opportunities for both the agency and the tribe to be able to meet and come to agreement on issues, it's really important that this one pass through and I think it's a good example for other tribes when they're looking at the upcoming changes that we have been making to the dispute resolution piece.
Right. Any questions for Dr. Conwell on this? Okay, so we'll see tomorrow along with some members of the tribal council here. Okay, great. Thank you. Good work on this. Appreciate it.
Okay, our next item is briefing on a really interesting cannabis consumer education survey that we've done, and I'm gonna turn it over to our research program manager, Dr. Sarah okie, who can introduce our guests and the study. Good morning.
Good morning. Good morning board members and all others who are watching. It's a pleasure to be here today and I am joined by Dr. Sally Riggs and Jordan Arias to help me report on the findings from this cannabis consumer education survey. I will go ahead and share my screen. I get confirmation that you can see perfect, yep. Great. Okay, so this survey was done in collaboration with Department of Health where Sally is a research investigator. And Jordan is an epidemiologist. There have been several other key partners who have been involved in this survey since its start, who are not presenting today, including Nikki Meline DOH's social marketing and public health campaign manager as well as some of our own LCB folks, including Kristen Haley, who actually started being involved in this survey when she was at the DOH and now coming here to LCB and also Brian McQuay. So we are excited to share with you our findings. And with that, I'll hand it over to Sally.
Thanks so much. As Sarah pointed out, my name is Sally. And I'm a Research investigator with the Washington Department of Health. And so basically, we collaborated. This was a cooperation between our ECB and the Department of Health and it was developed out of an interest to improve public health and safety education for legal adults who use cannabis. The intent of the survey was to help us better understand what consumers do and don't what what they do and don't know about the products that they use. We also wanted to determine the extent to which cannabis consumers were interested in receiving educational materials and the best way to provide the information to them. For DOH this effort will help inform educational campaigns that provide scientifically accurate information about the health and safety risks posed by cannabis use.
Next slide.
The survey was developed using REDCap which is a HIPAA compliant online survey development tool. Survey the question survey questions or review of internal internally and externally before the final draft was completed. After developing the survey and receiving an exemption determination from the Washington Department of Health IRB, we send an email to all Washington cannabis retailers and mailed out recruitment letters. We asked retailers to post the survey near their registers or in highly visible locations around the store. All the survey was available between December 18 2023 and January 14 2024. And all survey responses were anonymous and participation was voluntary. There were a total of 437 respondents who participated in the survey. This is not a representative sample, but respondents lived across Washington. The respondents that lived across Washington and were similar to Washington's census demographic data. The average age was 40 years old, about half were women and the majority were White. This figure shows the distribution of respondents across Washington using the Accountable Communities of Health map. We show this breakdown because there were some locations with fewer responses and we wanted to maintain anonymity for participating stores and participants. However, the five counties with the highest population rates as you can see are King, Pierce, Thurston, Snohomeish, and Whatcom. On average survey respondents were frequent cannabis users over half reported using cannabis multiple times a day. Most use cannabis at home and at night or before bed. In general survey respondents prefer flower and use flower most frequently. The finding that flour is the most popular cannabis product is consistent with prior studies, and suggests that the sample may be similar to the broader population of legal adult cannabis consumers. Additionally, we asked survey respondents whether they were employees of the cannabis store and 38% said yes, a large proportion of respondents who were cannabis employees allowed us to better understand similarities and differences between these two groups of people. And now I'm going to hand it off to my colleague Jordan will discuss the main survey findings.
More morning, everyone, my name is Jordan Arias. I'm an epidemiologist with the Washington State Department of Health. And I'm going to go over our three top findings just we don't have time to go over all of them. So I'll get started now. The first important finding was that increase in cannabis knowledge across both consumers and employees is important. This can be seen from the knowledge check questions that we asked in the survey, which are shown here. Some of the knowledge check questions included things like true or false only medically compliant products are required to be tested for heavy metals. And where do you find lab test results for purchase cannabis. So in general, the overall accuracy scores on this knowledge check were low, with employee scoring on average 57% and consumer scoring 43% correct. Which we thought that these findings really highlighted the importance of increasing consumer knowledge not only for consumers, but employees as well. So our next finding is that people are interested in learning about the cannabis products that they use. So even though the knowledge scores were low, people are still interesting. Interested in learning more. About half of the survey respondents indicated that they were either interested or extremely interested in receiving educational materials when making a purchase. So this chart here shows the types of information that people may be interested in receiving. So this shows general interest across topics including safe use safe storage, and risk of impaired driving. The highest topics that people are interested in were how to read labels on cannabis packaging, the health effects, the availability of lockboxes and the consequences of driving under the influence. So the second main finding underscores that people are in fact interested and willing to learn more about their legal use. And then finally, our third finding relates to how we could provide education in the future. So we found that the two identified most popular points of education were through the packaging and labels as well as the blood tenders. So the last finding has those two points that will cover both of so in terms of packaging, we found that 84% of the survey respondents read the label on the packaging either often or always. And when we asked about the information that they looked for, the majority responded with the strain or cultivar name, THC content, total cannabinoids, the company name and CBD. Additionally, there was a free response option where people were able to write additional information that they would like to see. And the main topics that came up were the growing mediums, solvents and pesticides, whether the product was organic or not harvest and packaging date and terpenes. So these findings really emphasize that people are already looking at labels as a source of education and are still interested in more information being available on the labels. So regarding the next point, which was budtenders, we found that 91% of the respondents asked questions to budtenders when making a purchase. And most people found the bartenders to either usually or always be helpful. So we found this interesting because even though the bartenders did perform better than consumers on the on average, during the knowledge check, the scores were still low, which still highlights the need for bud- budtenders to gain further knowledge about safer use. And then finally, we asked respondents to tell us the most important information to know when buying cannabis. So this chart shows the level of importance for different factors that we asked about with employees and blue and consumers in green. So we found that the employees rated the following as statistically more important than consumers. So that included the the look or the appearance of the product, how the product was manufactured or produced to strip the strain or cultivar name, and the company or brand name. There was only one factor that was rated more highly for consumers than for employees, and that was the THC content. So this contrast contrast between the importance of the THC content for consumers relative to employees really highlight an important harm reduction point on de emphasizing THC that Sarah will cover No.
Thank you, Jordan and Sally. These survey findings underscore the need to increase knowledge for both cannabis consumers and retail employees. The finding that legal users have both limited knowledge and misinformation related to cannabis is consistent with prior research. And this knowledge gap really does make sense. There have been unprecedented changes that have occurred around legalization, there have been barriers to research and there have been rapid changes in cannabis products themselves like edibles. This is really a perfect storm for misinformation. But we also found that people generally do want to learn more. And this is really great news because that means people are likely to be interested if LCB or DOH develops effective strategies to increase informed decision making and encourage safer use. So given the results of this survey, what might some of these strategies look like? One potential future avenue towards increased knowledge is with budtender training. The this idea may be comparable to our mandatory alcohol server training program, which as context is a training program that covers topics like how alcohol affects body how to check IDs, signs of intoxication and current laws and rules around alcohol. A training program similar to our mandatory alcohol server training, but for cannabis retail employees may be particularly important, especially because unlike those who serve alcohol, there is emerging research showing that bud tenders regularly have to field questions related to health topics like sleep anxiety or pain, as well as specific product information and dosing. All of this is concerning because right now bud tenders are not required to have to have training to be able to appropriately field or answer these questions. In our survey, more than 90% of people asked questions to bud tenders to help them make a purchase. Standardized training for those who sell cannabis could allow for more accurate and reliable answers to questions that we know people are already asking. For example, product information like cannabinoids or harvest state, consumer safety information like how to read a label or consequences of driving under the influence, Community Safety like risks for pets and youth and where to find lock boxes. And current rules like checking IDs or deferring medical questions would likely be impactful to public health and safety. And our survey found that a large portion of people said they were interested in having more knowledge on these topics presented on the screen as well. A second potential future avenue for increasing knowledge is using labels as sources of information. Labels were the primary Avenue identified by consumers for learning more about cannabis products they purchase. And we already put information like the not for kids symbol to relay information on edible products. There are lots of additional ways we can use labels as sources of information. So to illustrate this point, let's just take the concept of high THC. high THC has been a particular area of concern recently given its heightened risks for harm relative to lower THC. However, consumers often currently equate high THC to mean high quality, even though research doesn't support that. So labels could be effective in ways such as having small education points printed on the packaging. For example, high THC does not equal best high or start low go slow. Labels could be also used to provide additional information about the cannabis product such as harvest date, or smell, to help provide a fuller context of the product quality and de emphasize THC as the leading purchasing decision. And this may be especially important given Jordan's earlier mention that consumers heavily weighed THC when making purchasing decisions. These two avenues that I briefly presented on are only two examples of ways we can promote health and safety within the legal cannabis market. Future avenues with the highest chance for success would be those that are evidence based and those that benefit public health, consumers and industry. So in the previous example of de emphasizing THC, if we were able to pull away from the incorrect assumption that high THC means better quality, risks of harm could be reduced, consumers may have a better overall experience with the products they purchase, and the highest quality products within the industry could be more readily recognized. Right. Thank you so much to our licensees who are willing to post our recruitment ads at the retail stores. And a special thanks to Mary Segawa, our former public health education liaison prior she worked on this survey prior to her retirement thank you to our communications team. Our Director of External Affairs Justin and our two new researchers Nick and Tyler, who helped finalize this survey and will be involved in next steps. As a quick note, we will be fat sharing our findings on our website. We will be sharing this on GOV Delivery. We have plans to share these findings with other researchers by presenting this. I'm at the Research Society on marijuana conference this summer. Brian McQuaid also hopes to discuss this at the Washington State Public Health Association conference this fall. And we will be additionally looking into a peer reviewed manuscript to disseminate these findings more broadly. And then finally, we'll also be looking into and supporting further research to better understand training opportunities for budtenders better characterizing the role of budtenders further understanding the best labeling practices and how to make those easy to understand and finding ways to promote public health and safety for legal cannabis users. So with that, thank you and we are open for questions and comments. Dave,
One from Member Garrett first.
Sarah years ago, the licensing presented the budtender training and suggestions about budtender chat training we've had we had that conversation. And we had that conversation with the industry. And the concerns at that time was they didn't like the fact that it was being made mandatory. Number one, and number two, some of the requirements under the mass program. And I don't know I don't recall if anyone ever get back to us with- There were things like must not owe back child support. There was a lot of different requirements. That was part of the MAST training that folks didn't agree with. Like they said, a lot of people that's taking on those jobs and part time jobs and things, it could read out earn extra money in order to pay child support. So can, is there, can you get for me the requirements in the mass training that does it include that the person can owe back child support and other things and what those things are. But this conversation was brought to the board years ago, we actually came up, we we were being proactive in coming up with a budtender training program, and it got shot down.
Well, one of our goals as our research program is to look into our MAST training programs. I know I've had conversations with Misty who, who manages that, and I'm happy to look into those requirements and get back to you on
right. Yeah, they were bringing up things like under alcohol, there's different things like over service, DUI drive, and just things that didn't apply in the cannabis arena and things. So if you can help me understand that mass training. Thank you.
Member Vollendroff.
I just wanted to thank member Garrett for the comments that she made, because I want to make I also appreciate, Sarah, your comments on looking at the current master training as well, so that we're not just replicating what we currently have in one area that we oversee. But we're actually looking at that and looking at ways to improve it. While we have these types of conversations. I think that the findings are strongly suggesting that we have conversations with industry and that we revive this conversation that it sounds like this board has had in the past. I think when you look at the 57% score of bud tenders, and they are 90 plus percent of the place, people are going for information, I think we need to have conversation. And I love to think of it as maybe this isn't the right term, but I call professionalizing the bud tender role, actually, it's maybe more affirming and recognizing the importance of that particular role, and how much opportunity we have to make sure that as we support business, and we try to make sure that we are getting good information out we're we're addressing public health potential concerns. So I really appreciate the work that went behind this. And I look forward to further conversations. And I look forward to hearing the plan to involve industry in these discussions and what that looks like and what their thoughts are and how we might come together to create something that will be helpful. Yesterday, I was in a meeting where we had somebody from traffic safety who participated. And the increased increase in impaired driving both on the alcohol side and the cannabis side is something that is concerning and getting that kind of education out there is another opportunity for so really appreciate the work and look forward to seeing where it goes in the future.
Thank you. This the first time we've done this, right. There's never been a consumer survey in the past 10 years, has there?
That's a good question.
I can chime in. This is Kristen Haley. We did do one at doh in partnership with LCB. I'm wearing my doh hat for a second. This was like 2016. But it mainly informed the consumer education campaign that we subsequently launched. It wasn't as in depth as this one.
Okay, interesting Thanks Kristen.
And that was and it was from then and there that all of the budtender training came up back in the past and things and it was our goal at that time. And now our thought process was something that would be able to help retailers coming into the industry knew if we have doubt with trading their bud tenders, but then there it wasn't just cut and dry. There was a lot of requirements put on it that they go. Here's government again telling us and making it mandatory. So it was things like that that came up.
I do wonder how that has shifted across time and part of when I was mentioning the future directions of doing more surveys or during more engagement and reach to figure out what the best solutions might be. Maybe one of the ways that we can tap in is really ask industry kind of what the best solution for increased education may look like. And we're kind of the barriers and advantages from their point of view, as well.
Right. And I think like what Jim said, I think will be good. One of the things that we didn't take to the next level was, what should and could that training look like not just automatically copy something that was in place for alcohol, like folks were saying, alcohol is and things they are sitting there on site premises, drinking, you're looking for over service, different things that don't apply in a retail cannabis environment.
Agree, so important to tailor whatever training or education or any outreach specific to the substance that that we're exactly when the different context vary,
right. And I think that that would make the difference. Yeah.
So since there was an early report, which I wonder it'd be worth looking at, just to see, are there any things from then and now that matchup, question wise, that might tell us anything about progress, or regression or anything of that sort? It would be interesting. And going? Well, you know, we have I think a lot of options available to us, it doesn't have to be a mandatory training to start, it could be something that you're able to get if you want, and then you get a little sticker that says we've got trained budtender at this location. We also could start any day, anytime sending information to retailers that we think is useful information for people, including, perhaps when we send this survey, putting a memo on it that says, here's our takeaway for retailers, here's what we would have you look at look at the importance of your employees here. And look at where the delta between the high THC thing in particular, so what does that tell you if we just can can, these are things that are very low cost, and I think, start that conversation with with people right away, which is we just want to have the engagement. And then I know, we all know this, but just we should say when we talk about engaging industry, we're also talking about engaging the public health and prevention people to make sure that these messages really work. And I think we had a, I think successful attempt, and Kristen can correct me if I'm wrong, but when we put some things on our website, well, you know, when we tried to move towards more kind of smart choices, education, and we did bring some disparate groups together, and were able to find some common ground. And so I think we've got people on both sides, on the industry in a public health who understand the need for that balance, and we get them going. But I do think maybe our first foray here is how we present this survey when we send it to the all licensees, but particularly to retailers and do that.
And one of the things like when I suggested I suggested to enforcement and to think about how they update it like, because we had started seeing an increase of selling to minors and things like that, to got increased the training that they're doing when it comes to ID Id check. And think about this, this industry we have now and and things and what can be effective training. Like we know mostly a lot of young folks work in these in this industry. They do everything is on their phone visual in their face, and to start thinking about creating things that help the young generation get the knowledge to have a training program that can be tailored to being on their phone live. I like I suggested to Chandra, alive, alive situation where a person and the ID everything went through and the person sold anyway and what it resulted into it. We could do some live things of that to put it right in their face. This is what happened. This is what you did anyway. And this was the consequences that we just started coming up with some training type things for this generation. Yeah,
I agree the training has to be engaging. And Kristen just gave me a heads up to that doh is in the development phase. of their next iteration of the consumer education campaign. So on both doh and LCB side, this timing of figuring out how to how to create more engaging trainings and education is, is perfect that timing.
Member Vollendroff.
is just you brought up doh and I just wanted to thank doh for your partnership in this particular endeavor and look forward to continued partnership. Cannabis is unique in the sense that we've got Doh, who's heavily involved. We've got the Health Care Authority, Division of Behavioral Health and recovery, we've got the LCB, we've got ag I mean, there's just a lot of people involved in this kind of collaboration, I think it's incredibly important. I think I'd like to lean heavily on the fact that one of our takeaways was people want more information, people want to learn more. So consumer literacy is something that's being asked for, and we should deliver on that and make sure and one final thing, Sara, and I don't know if I have if we if I can even see this data. But one thing that's interesting to me was the average age of respondents I think I heard was 40. And that the product that they were using the most was flour. And so I'm interested in I don't know if we have the data or if it's again, IRB prohibited, but like by age, I'd love to see what by age people are using. And do we have that? And can we get that? And does I mean, does it show anything different? If you can respond to that? I don't know if you know or not?
Well, I'm happy to look at this specific data. I know that on average flower is the most popular product historically and currently, but we do see concentrates ticking upwards within younger populations as well.
That's where I'm going that's what I want to know is in fact, if that's what it's showing here, as well.
I'll take a look at the data. I'll get back to you.
Okay, great. Thank you.
Thank you so much.
Great. Any other questions? Good. Thank you so much, Sarah. It's really It's and thanks to our doh partners, too. It's really what letter was? When will we, uh, sorry, you're done. But if you're there, when are we going to distribute this? When will this go on our website? Sorry, Sarah.
So hopefully this will go on our website, today, tomorrow, by the end of this week, we're just kind of just get talking with Communications by the end of the day, and the report has been finalized. So sooner rather than later.
Great. Thanks so much.
Thank you.
We'll move to our next item, which is policy and rules team update. And ice again, it becomes first so shall I just turn it over to you, Mr. Jacobs?
Yes. Good morning Chair, postman members, Garrett and Vollendroff. Cassidy West is out today. So I will be providing the update for for the rules and policy unit. And then I'll also be previewing two public hearings that we're having tomorrow, both of which I will err on my rulemaking projects. So I've got a few minutes. I've got a couple of minutes of Spiel here to go to so. The first is I wanted to give an update on the social equity rulemaking, an email was sent out yesterday to folks, but I guess we should just let folks know now that there's going to be a new CR 102 filing date, we are going to be pushing that out. We had initially stated that that was going to be filed on June 18. But following feedback that we received during the stakeholder engagement sessions, we think that there's more work to be done on these draft rules. We're going to be sending out a revised draft of the rules, and an accompanying survey will, we're going to be sending that out publicly posting it on the website in about mid June. And then once we get the feedback from that survey on these draft rules, we'll use that feedback to inform the draft rules. We're aiming to have the CR one or two filed in mid July, at the July 17 board meeting. But we're not quite ready for to move forward with the CR 102 At this time, so we're we're pushing that out. We sent that email out yesterday. I can answer any questions about that if there are any. All right, great. Um, so the next is that, like I mentioned tomorrow, we're going to be having two public hearings, one on the prohibited conduct rulemaking and the other on the medical cannabis endorsement rulemaking. I'll be giving a preview for those after I'm done giving the overall update. But assuming those go well, we'll be filing the CR one oh threes for those at the June 18 board meeting. The June 18 board meeting speaking of which is scheduled to be a busy one, because we're also going to be doing the CR one or two on both the medical Cannabis tax, excise tax implementation rulemaking, and the THC Bill rulemaking. As well as we'll be needing to address responses to cannabis related petitions. One of which is on the principle display panel, we got a petition requesting clarity on what the principal display panel is for cylindrical canisters, cylindrical containers. As well as we got several petitions on requesting social equity license mobility, these petitions are requesting that the previous round of social equity licensees be allowed to move there. So you're allowed to move their license from one county to another. Currently, they're only allowed to move within a county from one city to another. But we received three petitions asking us to allow them to move outside of the county, one of those petitions came in at the deadline. So we have to present it at the June 18. board meeting, the other two came in after a deadline. So we can present those at the July 17 board meeting. However, they're all really asking for the same thing, which is this social equity licensed mobility. So speaking of now, going into the July 17 board meeting, because to my understanding, we're not having one on July 3 Because of the holiday. And so with that the July 17 board meeting is going to involve a CR 101, for implementing second house bill 2151. And the lab accreditation. This is rulemaking that Department of Agriculture has already done a lot of but we need to do some cleanup on our end. As well as we're going to be filing the CR 102 on cannabis payment flexibility. I'll give an update on that. Once I'm done sort of giving the overall update, we'll also be hopefully then doing the CR one or two on the social equity rulemaking. And like I mentioned, there'll be those two petitions on the license mobility, although those might be addressed with the one on the 18th since they're all asking for the same thing. And then the last thing is we got to get another petition in asking to remove the 10 milligram limit on cannabis edibles. So we'll have to address that petition during July 17. There's even more after that, but um, that's already a lot. So I'll just pause there and see if there any, we got any questions on the timelines?
Yeah, no, I don't have questions on the timeline. But under the social equity rulemaking, isn't there something there on the mobility?
Yes, there is. So um, and that's going to be something that we have to address regarding the petition. Right. Yeah. So there is the possibility that we can address the concerns raised in the petition through the social equity rulemaking, however, because they were also submitted as formal petitions for rulemaking under the Administrative Procedure Act, we do we still have to respond to them.
Right. I get that, but it is being addressed already in the social equity. That was yes. Okay.
Yes, that's yeah, that's my understanding. Again, I'm not the social equity rules coordinator. So I don't have like a whole lot of details on that. But yes, part of our discussion is that is that because the social equity rules are open, and the topic of licensed mobility is being considered? I don't know that the language is necessarily going to be changed to address it, but it is part of that conversation. All right. Yeah. Yep. Oh, perfect. So then I'll give updates on my two rulemaking projects before I go into the public hearing. So first is the cannabis payment flexibility. This is again, so we received a petition that was accepted last March on addressing how cannabis licensees pay for cannabis from others. Using Chuck's a survey went live yesterday. It's currently on the website as well as some draft rule language. We sent it out in the cannabis and the rulemaking. GOV Delivery lists. That survey is going to be open till July 8. It's also on our rulemaking website, basically, we're asking folks hey, if the rules changed on, you know, paying via cheque, how would this if at all impact your business? It isn't. It's open to the public. So in theory, non licensees can answer the questions but really we'd like to hear from cannabis licensees on this. And again, since that survey is going to be open till July 8. After that, we'll look at those results and that'll help fleadh form RCW are 102. The next thing going on this week especially is on 1453 on the medical cannabis excise tax exemption. So that bill goes into effect on Thursday. And yesterday, we had a really good stakeholder engagement session on the draft rule, language, or draft, that the draft rule language has also posted it on the website. We're going to have another stakeholder engagement session on Thursday. And we have also issued out via GOV Delivery, two separate guidance documents. Those also have been added to the rules website under the rulemaking section, one of those documents is an infographic that's just sort of to help retailers understand what the elements are, what the requirements are to offer the exemption. The second one, which was released more, which was released last week is interim guidance on what sort of record keeping retailers should do in the gap between, you know, starting Thursday, and before formal rules are in effect, because as I've said before, the law goes into effect Thursday, but we're not going to have rulemaking done and on the books until at the earliest mid September. And we've gotten several folks asking well, what do I do in the meantime? Like what do I need to keep track of? And so we just an issued that guidance last week. That's been posted on the website, and I also linked to it on the rulemaking section regarding the medical cannabis excise tax exemption.
Daniel, in yesterday's session, did you get any feedback about that latest communication that that was sent out? Or are people now? Understanding better? What would be expected that because the question we got specifically was what records? Would I have to keep in that interim between law going into effect and rules go into effect? And I just wonder how that's being received.
So far? It's been received? Well, from what I could tell, I think there's still there's a little bit of concern and some questions about specifically the patient identifier. Because that patient identification data is sensitive and Doh, it's it's not something that can be freely released. There's some questions as to whether it counts as personally identifiable information akin to like a medical record number. So we're still exploring how LCB is going to go about, you know, verifying that data and verifying that someone is a patient in the database. But so there's still some questions about that. But for the time being the interim guidance and our draft rule language is asking retailers to hold on to that unique identification number. But there's still some sort of discussion about that and how that's going to work. But in terms of the doc, the records that retailers need to keep, once it was, once I explored that and sort of explained why we need each piece of data, it seems to be understood by the folks in the session. I will say also, just because this week is a busy cannabis policy week, there's both camera and the locker conference going on. We still had a healthy attendance at the session yesterday, but I expect Thursday's session to be should be more well attended.
Yeah, I just just to be clear, I think that interim period between Thursday and when we have rules is just it's really incumbent on us to make sure we've informed licensees enough to know what we're going to ask them for. If somebody needed to come up with, you know, audit documentation from from, you know, middle of May to middle of September, just really we're not trying to catch, you know, tricking. You want to lay it out there for him. So anything we can do to that end, I think would be helpful.
Sure. I mean, I can I can announce I can just go over those right now. We have four sort of key pieces of data that we recommended in the interim guidance. If it'd be helpful. I can go over it now or I can go over it tomorrow during the board meeting.
Yeah, I don't think you need to do it here. I really just anything we can do to communicate with licensees about that. And and I'm sure I'll hear from him if if there's something lacking and maybe we just take a look, I think that's okay.
All right. Oh, with that should I'll go to previewing the public hearings for tomorrow. Sure. So the first one is on the prohibited conduct rulemaking. Consistent within gross substitutes Senate Bill 6105. We are repealing the prohibited conduct rule at 314 1101. Five and removing cross references to it from other rules. This is also what's required in the legislation so really, there's just not a whole lot of there's not a whole lot of wiggle room here. For us for what we're doing. We see our one on one filed February 14, CR one or two filed April 24. We only received one written comment. We got it just over the weekend from Equal Rights Washington in support of our rulemaking. And tomorrow during the public meeting itself, I'm not, I'm not gonna be able to respond to any questions, if any questions do come up. After the meetings adjourned I can address them. But otherwise, I don't know if y'all have any questions on that one?
No, I think, yeah, we're well briefed on that one.
All right, and then the second one is going to be on the medical cannabis endorsement rulemaking. This is the one to amend the rules on 314 55. Alito, we accepted a petition on this back in March 2023. The 101 was filed in October, we found that 102 In April, after having to stakeholder engagement sessions and mid March, we've gone over the rule changes here. But the main ones are adding a requirement for cannabis consultant hours to be posted wherever store hours need to be posted. That's the oral alternatively giving a window of time during which appointments can be made. Second main change is that the in stock requirement, which requires endorsement holders to have medical cannabis in stock, you can also satisfy that by having it on order. So if you don't have any in your store, if you can show that you've had an order placed that just hasn't come yet. And then the third one is the cure period that I've talked about before, which is after being notified that you're not in compliance, you know, reach eight endorsement holders will be given a variable period of time from seven to 30 calendar days to fix the deficiency, the amount of time they're given is going to depend on what the issue is, if the issue is that you don't have a consultant on staff anymore, you'll be given more time to hire a consultant than if the issue is that the card machine isn't working or you don't have any, if you don't have an order placed. I don't know how long it takes to place an order. But you'll be given less time than if you need to hire and train new staff. And we've received a few comments on that already. We got we also got some suggested tweaks to the rule language, which all address after the public hearing. But the public hearing still gonna go forward on the rule language as filed back in April, I will save that's going to tie in to the medical cannabis excise tax exemption, because if folks get their endorsement, polled, they need they'll need to stop offering the excise tax exemption immediately. Because one of the requirements of offering the excise tax exemption is having an endorsement. And so is having the medical endorsement. So in that sense, those two rules making efforts aren't going to be tied into each other. And so it's going to be important for folks to pay attention making sure that they're complying with these new requirements. Otherwise, like I said, you know, that could be that could end up being very expensive. For excise tax exemption front. And those what I got, I'll you know, I'll give a little bit more detail to Spiel tomorrow before the public hearings, but otherwise, I'm happy to answer any questions.
Okay. Any board questions for Daniel on anything on that long list of issues? I just have one quick one. You talked about the survey for flexible payments. Is that the only survey we currently have on our website now?
Oh, no, there are lots of surveys right now on the website. That's that's the only survey. I believe that's currently from the policy and rules team. Okay. Yeah, no, lots of
okay. Yeah. Keep reminding people on the rules, surveys, they're there and and hope that licensees can go there and share their thoughts. And we're just gonna have to keep reminding them between now and July to to get as much feedback as we can on that. So if you can help me remember, and so we can remind everybody, that'd be great.
Yeah, certainly
Great. Okay, thank you. See you tomorrow.
All right. Thanks so much.
That takes us to board member and executive assistant reports. Anything to report from any buddy. I see none. Okay. We're adjourned. We'll be back tomorrow at 10am for board meeting. Thank you.
