August 29, 2016 Cannabis Legalization and Regulation Secretariat Address locator 0602E Ottawa, ON K1A 0K9
via email: email@example.com
Dear Members of the Marijuana Legalization and Regulation Task Force (the “Task Force”): Re:
Public Consultation: Toward the legalization, regulation and restriction of access to marijuana
On behalf of the Cannabis Trade Alliance of Canada (CTAC), we write to provide our responses to the public consultation on key questions related to the legalization, regulation and restriction of access to marijuana.
Minimizing Harms of Use
Do you believe that these measures are appropriate to achieve the overarching objectives to minimize harms, and in particular to protect children and youth? Are there other actions which the Government should consider enacting alongside these measures? General Comments: There currently exists a large unregulated market for recreational (adultuse) cannabis. The industry already exists. If government regulations are too strict and exclude the existing marketplace, or makes it unnecessarily difficult for adults to obtain legalized cannabis, the existing unregulated market will continue outside of regulation or oversight. Harm reduction will mean bringing in existing producers into the legal market and assuring that their product is tested and regulated, to ensure that the marijuana consumed by adults is safe. Minimum Age: We agree that a legalized cannabis regime should restrict under-age access (sales) to non-medicinal adult-use cannabis. However, while the issue of reducing harm and protecting children and youth is an absolutely crucial one for any new regulatory model surrounding legal marijuana, the government must be aware that pursuing a goal of not “normalizing” or “commercializing” cannabis will not be successful. Should the age limit be set to 25, well into the age of adult-hood, persons under that age (including teens), will continue to purchase from the unregulated market, as many currently do. It is important not only to protect youth, but also to listen to youth: https://news.lift.co/protecting-the-youth-but-not-listening-to-theyouth/
Page 2 of 15
Advertising and Marketing Restrictions: The legalized cannabis industry should resemble the wine industry. Similar to wine appellations, the Cannabis Trade Alliance of Canada (CTAC) recommends the creation of cannabis appellations (grow regions), allowing producers to indicate and certify the region in which their cannabis is grown. This may enhance the products’ provincial, as well as international (i.e. for exportation) appeal, and may generate tourism interest to a particular area. In addition, CTAC recommends the implementation of a certification standard for cannabis similar to the VQA designation for the wine industry. Through origin verification, laboratory testing and comprehensive label reviews, such certification would ensure precise adherence to rigorous cannabis production standards and to label integrity that consumers can trust. Cannabis should not be marketed to minors. Taxation and Pricing: It is important to ensure that any taxation structure maintains prices that are comparable to, or lower than, the illicit market. If pricing is not competitive, the unregulated (illicit) market would likely continue to flourish. See the document by the Cannabis Trade Alliance of Canada, dated May 24, 2016: “Cannabis Legalization in Canada: Creating a WorldClass Sustainable Industry Through Inclusivity, Transparency and Evidence-Based Policy” at page 11 ‘Taxation Structures’. Online: www.sustainablecannabis.ca/#papers Restrictions on Marijuana Products (potency): Proper testing, packaging and labelling, as is done in the wine and beer industries, allows consumers to make informed choices regarding their purchases. In Colorado, lawmakers rejected an initial effort to cap the THC potency of marijuana that consumers can purchase at recreational cannabis retailers. Capping potency will likely drive consumers to the black market, may lead people top attempt to make volatile concentrates at home, creating the risk of explosions, or, more simply, consumers will consume more of the lower-potency product. Securing safe cannabis products for sale and distribution to the public is imperative to the public health interest of Canadians. Cannabis consumers must have confidence in what they are purchasing and consuming. Just as food packaging must display the ingredients and nutritional information; wine, beer and spirits must list the alcohol content; and natural health products must monitor and disclose all ingredients; so too should cannabis products destined for sale possess reliable labeling of their ingredients, and the potency and quantity of active components. This is all part of the regulated supply. Restrictions on Marijuana Products (edibles): We reiterate our position regarding potency. Testing, packaging and labelling is imperative. Edible products can, and should be properly packaged to ensure they are not especially appealing to children – there is not one determinative factor that makes a product attractive to kids or clearly determinative of a danger to children with respect to cannabis edibles: https://www.sciencedaily.com/releases/2016/08/160825141908.htm
Page 3 of 15
CTAC asserts the importance of distribution of products which are quality controlled: properly analyzed, tested, packaged, sealed and labelled prior to release to the market. All cannabis products for distribution/sale through growers must have proper labelling and child-safe, air-tight packaging. Limitations on Quantities for Personal Possession: Policing possession limits will be a factor, therefore, as with alcohol, there may not be any reason to have possession limits at all. If the regulations are inclusive, then fears of diversion are diminished. Limitation on where marijuana can be sold: CTAC strongly believes that selling alcohol and cannabis products together sends the wrong message to Canadians, and in particular, Canadian youth, about responsible use. See the CTAC document, dated May 24, 2016: “Cannabis Legalization in Canada: Creating a World-Class Sustainable Industry Through Inclusivity, Transparency and Evidence-Based Policy”, at page 12. Online: www.sustainablecannabis.ca/#papers
What are your views on the minimum age for purchasing and possessing marijuana? Should the minimum age be consistent across Canada, or is it acceptable that there be variation amongst provinces and territories? A minimum age is suitable for purchasing recreational marijuana, however if the minimum age is set too high, this will not stop consumption of marijuana by young adults, only that they will continue to consume unregulated products. A minimum age of 18 or 19 is suitable, and if distribution has provincial control, then the minimum age may be set by individual provinces and territories. There is no disagreement that teen use must be regulated. However, as legalization is inevitable, we must engage in intelligent debate for the creation of proper regulation around the legalization of cannabis:
Page 4 of 15
Despite fears of increased teen-use, studies continue to show that legalization of cannabis yields no increase in teen use and may actually lead to a slight reduction in teen use. See the CTAC document, dated May 24, 2016: “Cannabis Legalization in Canada: Creating a WorldClass Sustainable Industry Through Inclusivity, Transparency and Evidence-Based Policy”, at page 27. Online: www.sustainablecannabis.ca/#papers. Also see: https://www.washingtonpost.com/news/wonk/wp/2016/06/21/colorado-survey-shows-whatmarijuana-legalization-will-do-to-your-kids/ The most important key to our new legalized frame-work regarding teen-use must emphasizes Education and Parental Guidance: http://www.sciencemag.org/news/2016/01/twins-study-findsno-evidence-marijuana-lowers-iq-teens Draconian prohibition laws and the propaganda that supported them must come to an end so that research and innovation can prosper. CTAC advocates for efforts to support and train private sector retail staff to detect underage purchasers (not difficult to do), and for efforts to educate young Canadians on responsible cannabis use. We also support programs that seek to discourage non-medical youth consumption.
Establishing a Safe and Responsible Production System
What are your views on the most appropriate production model? Which production model would best meet consumer demand while ensuring that public health and safety objectives are achievable? What level and type of regulation is needed for producers? Licensing under a legalized structure should not impose barriers that are arbitrary and overly restrictive – this would limit the ability of small or medium sized business-owners to enter the new legalized marketplace, and will continue to push segments of the industry into the unregulated ‘black’ market. Legalization provides an opportunity for evidence-based regulation through the use of rigorous studies about “what works”, as well as using the best available scientific research and systematically collected data. Commercial production and processing of medical cannabis was not contemplated under the MMAR. In addition, the application process to become a Licensed Producer under the MMPR / ACMPR is too cost prohibitive for the majority of growers, producers and entrepreneurs who wish to enter the industry, and the mail order distribution model under MMPR is one that consumers do not favour.
Page 5 of 15
A successful model for Canada's cannabis industry should be built upon a foundation of evidence-based regulations. CTAC recommends a legalized cannabis regime which:
integrates mandatory laboratory testing of all cannabis products (potency and contaminants) – a critical step in the seed to sale process when considering public health, and should be the main objective in the legalized framework
restricts under-age access to non-medicinal adult-use cannabis
facilitates and leverages the knowledge base of the existing adult-use cannabis industry
includes the right for individuals to grow their own cannabis
provides Canadians with equal access to an open, equal-opportunity, competitive cannabis market, that creates economic opportunities for Canadians across our country
fosters a landscape of support for legitimate businesses adhering to sensible and transparent regulations and works to undermine the profitability of unregulated market activities.
A healthy cannabis industry, like other sectors, is better served by a large number of small, medium and large businesses competing fairly (and regulated/taxed equally) in order for consumers, government and the general public to be best served. Small, independent farmers and artisans, whether or not they are currently involved in the cannabis industry, want to be given a fair opportunity to participate in Canada’s emerging regulated cannabis economy. The objective of any new legislation should be to allow legitimate businesses the opportunity to participate in the supply chain distribution of Canada’s newly legalized cannabis economy. To ensure the protection of the safety of Canadians, provincial regulations should allow for the issuing of cannabis distribution and sales licenses to businesses that are compliant with all applicable rules and regulations Different aspects of the cannabis industry require different forms of licences as they have different potential for public harm, criminal activity, and taxation. CTAC encourages a licensing structure which grants more – and more varied - licenses to increase the quantity and variety of the available supply chain. See the CTAC document, dated May 24, 2016: “Cannabis Legalization in Canada: Creating a World-Class Sustainable Industry Through Inclusivity, Transparency and Evidence-Based Policy”, at page 3, and Appendix A “Proposed Licensing Categories”. Online: www.sustainablecannabis.ca/#papers
Page 6 of 15
To what extent, if any, should home cultivation be allowed in a legalized system? What, if any, government oversight should be put in place? It is important for the new legalized structure to allow for the personal cultivation and production of cannabis. To restrict the personal production of cannabis in an otherwise legalized environment will have a negative impact on individuals, on the health and safety of those individuals, and on the health and safety of the public at large (by driving the activity back underground and into the black market). If the government intends on removing organized crime from the cannabis trade as much as possible, allowing cannabis to be grown at home should be a central part of the program. If people are allowed to grow their own cannabis, they will have absolutely no incentive to deal with the black market. If home cultivation is not allowed, then many will prefer to support the unregulated market.
Should a system of licensing or other fees be introduced? We believe that government revenue for the new cannabis from the implementation of a fee structure for licensing (including renewals); however, such a structure should be balanced so that it is modest enough for small businesses to afford, and sufficient enough for cost recovery for government to organize, implement, deploy and administer the new legalized regulatory structure. Such licensing fees would include funding for application processing, inspections and enforcement. CTAC encourages the imposition of new licensing categories, a structure which grants more – and more varied – licenses to increase the quantity and variety of the available supply chain, promoting affordability of the end product thereby impeding continuing sales from the illicit market. Different aspects of the cannabis industry require different forms of licences as they have different potential for public harm, criminal activity, and taxation. Such differences should be reflected in the licensing requirements in the same way that different categories of license exist in each aspect of the liquor, wine and beer industries. For example:
nurseries produce immature (vegetative) plants which do not contain the psychoactive properties found in mature (flowering) plants, and have less value than mature (flowering) plants. Therefore, nursery production does not need the same stringent security requirements or inventory control as would be needed for cannabis growers and processors.
processors that do extraction and refining have very different inventory tracking needs than a cannabis grower. Processors require much less space, less labor, only a fraction of the utilities and very little odor control in comparison to cannabis growers.
Page 7 of 15
CTAC recommends separate licensing categories for the following industry segments: Clone Production and Genetic Propagation (Nursery)
license for growing seeds, mother plants, and cultivation of clones.
Cannabis products derived from pest-free and disease-free plants are the biggest factors in ensuring a safe supply chain for consumers.
nurseries produce immature (vegetative) plants which do not contain the psychoactive properties found in mature (flowering) plants, & have less value. So nursery production doesn’t need same stringent security requirements or inventory control as needed for growers and processors
license for growing, cultivating, harvesting, trimming, drying, curing and packaging cannabis.
Farming / Agriculture
license converting cannabis into cannabis extracts, concentrates and cannabis-infused products
require much less space, less labor, only a fraction of the utilities and very little odor control in comparison to cannabis growers
processors that do extraction and refining have very different inventory tracking needs than a cannabis grower.
Third-party testing laboratories are a critical component of the cannabis supply chain.
Current problem with the current prohibition policy: cannabis products making their way into consumer’s hands are not properly tested.
As cannabis use expands and more products enter the marketplace, laboratories to analyze the available products are needed.
Ensuring purity, efficacy, and consistency of a finished product prior to release to the consumer is a crucial step in the supply chain process when considering public health.
Page 8 of 15
Licensed Retailers (Dispensaries)
Canada needs a diverse jobs base. CTAC advocates for government regulated, privately-owned cannabis retail outlet
Creating either a monopoly or oligopoly with respect to distribution is not needed in order to properly control cannabis access.
Cannabis retailers (‘dispensaries’) serve Canadian communities by offering safe, accessible spaces where consumers can obtain in-person advice, view and purchase a wide range of available cannabis products.
Licensed Resellers (Wholesalers)
licensed wholesale distribution allows sale of tested and quality assured cannabis products to licensed Processors and to any licensed cannabis retailer (dispensary).
Ensures variety and consistent supply of product
Having separate licensing categories also creates more opportunities for small businesses to participate instead of enabling a small group of large companies to dominate the market. This promotes economic stability by keeping small sustainable businesses viable and increases participation in the legal market, and away from the illicit market. Applicants should be allowed to apply under one, or more of the licensing categories. American states that have legalized cannabis - such as Washington, Oregon, Colorado, Alaska, and soon California - all have separate licensing categories. Cost Recovery through Application Fees: For the various licensing categories, fees could be in the form of a schedule (sliding-scale) that imposes a greater fee for premises with more square footage and could also be varied for those that processes (based on the solvents and pressurized equipment used). The more ‘industrialized’ the producer, the greater the fees. The organization, implementation, administration and enforcement of legislation and regulation should be a cost-recovery through the revenue received in licensing fees, and not through taxation. See also the CTAC Submission, dated August 9, 2016: “Inclusivity through Regulation: Weeding out Organized Crime”. Online: www.sustainablecannabis.ca/#papers
Page 9 of 15
The Marihuana for Medical Purposes Regulations (MMPR) set out rigorous requirements over the production, packaging, storage and distribution of marijuana. Are these types of requirements appropriate for the new system? Are there features that you would add, or remove? Creating a multi-faceted production licensing system will allow smaller business and producers to engage in the market. The barriers to entry under the current MMPR/ACMPR system are overly restrictive and costly for most small and medium-sized producers who wish to apply and operate under the current regulated structure, thereby encouraging the persistence of the unregulated market. By relaxing requirements, the government can bring the unregulated market under regulation and ensure safe, tested product being produced and distributed legally. A large key part of this will be creating a distribution system that includes a retail option, as the mail-order system under MMPR has proven itself an unmitigated failure. The transition from the MMAR to the MMPR in 2014 took cannabis production away from small and medium-sized growers, to the tightly regulated ‘Fort Knox’ commercial operations of today – a result of the strict and rigorous application process which became cost prohibitive for many applicants. At the time of transition, the MMAR licensed approximately 40,000 patients, of which approximately 30,000 held growing licenses. In contrast, under the MMPR, only 31 producers have been licensed (as at May, 2016), from a pool of over 1,800 applications. This is not inclusion, but rather the creation of a federal oligopoly. Security Clearance Process: CTAC advocates for transparent and accountable security clearance process, as the security clearance process under the current ACMPR is unjust and discriminates against individuals with alleged and speculative ties to current cannabis enterprises, those involved in predecessor Marihuana Medical Access Regulations (MMAR), and completely excluding individuals with cannabis related criminal prosecutions. The current ACMPR security clearance process completely lacks transparency and accountability, and takes much too long.
Reasons for refusing a security clearance should not be vague or based on opinions and conjecture, and rather, should be based on facts, evidence and the law. Rules should not exclude those whose only crime was getting caught doing something Canada will now be making legal.
Whatever form of security clearances required by the province or federal government agencies should not be based on the current federal model under the MMPR. Again, we urge government to look at the alcohol, wine and beer industries, as well as US states that have legalized cannabis, for guidance; in those industries a background and criminal records check must accompany any application for licensing.
Page 10 of 15
Testing Laboratories: CTAC encourages and emphasizes the importance of the licensing of testing laboratories. One problem with the current prohibition policy is that the cannabis products that are making their way into consumerâ€™s hands are not properly tested. As cannabis use expands and more products enter the marketplace, laboratories to analyze the available products are needed. Third-party testing laboratories are a critical component of the cannabis supply chain. Ensuring purity, efficacy, and consistency of a finished product prior to release to the consumer is a crucial step in the supply chain process when considering public health.
What role, if any, should existing licensed producers under the MMPR have in the new system (either in the interim or the long-term)? The current Licensed Producers can have a role in the new system, and they should be allowed the opportunity to apply under the new system, as would any other applicant for production, particularly under any one or all commercial licensing categories. Small Canadian businesses employing Canadian workers make up the largest portion of the existing cannabis infrastructure. Breeders, propagators, producers, harvesters, processors, laboratories, infused product makers, distributors, transporters, hydroponic and other retailers, healthcare professionals, caregivers, patients, biologists, pathologists, research scientists, biochemists, social scientists, engineers, and tradespersons constitute the fabric of the existing cannabis industry. The government must create a legal cannabis industry that will be sustainable, inclusive and transparent, without having to compete with the unregulated market. The most efficient way to impede and eradicate the illicit-market is to provide these existing market players (and their products) an opportunity to participate in a new and more regulated economy, transitioning into the emerging legitimate market, without fear of injustice or persecution CTAC advocates for the creation of an inclusive framework, allowing craft and small-scale growers, who produce high quality product and desire access to testing, regulation, and legal distribution. Like large commercial brewers and small craft breweries, the two can exist simultaneously in an open market.
Page 11 of 15
Designing an Appropriate Distribution System
Which distribution model makes the most sense and why? CTAC advocates a model of government regulated, privately-owned cannabis retail outlets. A distribution model that involves privately-owed retail storefronts is absolutely essential. Global patterns of cannabis consumption reveal that cannabis consumers prefer legal retailers that deal exclusively with a cannabis inventory. In cities like Vancouver, Victoria, and Toronto, retail storefronts for cannabis already exist and are regulated or are in the process of being regulated by municipal governments. These have proven very popular with Canadian consumers and medical patients, and creating regulation and incorporating these storefronts will help bring in the unregulated marijuana market and give Canadians access to marijuana products in a safe manner. See the CTAC document, dated May 24, 2016: “Cannabis Legalization in Canada: Creating a World-Class Sustainable Industry Through Inclusivity, Transparency and Evidence-Based Policy”, at page 6 and 12. Online: www.sustainablecannabis.ca/#papers See also the CTAC Submission, dated August 9, 2016: “Inclusivity through Regulation: Weeding out Organized Crime” at Appendix A ‘Proposed Licensing Categories’, at page 14. Online: www.sustainablecannabis.ca/#papers
To what extent is variation across provinces and territories in terms of distribution models acceptable? Provinces should be allowed to determine the distribution model that is most suitable for their own needs and the existing cannabis market in that jurisdiction. This will allow greater flexibility in the market and let provinces adapt more quickly to changing market demands than the federal government would be able to.
Are there other models worthy of consideration? To ensure better variety and consistent supply of product, CTAC also encourages legislators to create a licensing category for Licensed Resellers (wholesalers), allowing these entities to sell their tested and quality assured cannabis products to licensed processors and to any adult-use licensed cannabis retailer (dispensary).
Page 12 of 15
A model not to consider is retailing cannabis directly with alcohol in the same stores:
Many individuals have adverse reactions combining the two substances, and retailing two recreational drugs at the same point of sale encourages their consumption together. In terms of harm reduction, allowing sale of cannabis with alcohol only encourages potential harm.
Certain industry segments and politicians are advocating for the retail distribution of cannabis through existing government licensed liquor distribution outlets. Licenses to sell alcohol are extremely valuable in this country - there is little value in concentrating even more wealth into so few already privileged hands. The legal cannabis sector should complement our thriving craft beer and wine industries – with living wages, health benefits and a role in shaping its future.
CTAC strongly believes that selling alcohol and cannabis products together sends the wrong message to Canadian youth about responsible use. Many Canadians use cannabis as a treatment for alcoholism and addiction, thus selling these two products in the same storefront does not seem to be in keeping with public health and safety initiatives: http://harmreductionjournal.biomedcentral.com/articles/10.1186/1477-7517-6-35
In addition, and perhaps most important, there is good evidence of a synergistic effect (a significant increase in impairment) when alcohol and marijuana are consumed in tandem: http://www.scientificamerican.com/podcast/episode/marijuana-muddies-memory-andmixes-with-alcohol-to-make-trouble/
Given that most Canadians drive to liquor stores to buy alcohol, the wisdom of allowing “two stop” shopping in such a location seems highly questionable, both in terms of health-related harms, and the likely increase in impaired driving (See: H. Robbe, “Marijuana’s Impairing Effects on Driving are Moderate When Taken Alone But Severe When Combined With Alcohol”, Human Psychopharmacology, Hum. Psychopharmacol. Clin. Exp. 13, S70-S78 (1998))
CTAC believes that an inclusive distribution model will ultimately allow the customer, the most important stakeholder, to decide who succeeds within Canada’s newly legalized and regulated cannabis retail marketplace. See the CTAC document, dated May 24, 2016: “Cannabis Legalization in Canada: Creating a World-Class Sustainable Industry Through Inclusivity, Transparency and Evidence-Based Policy”, at page 6 and 12. Online: www.sustainablecannabis.ca/#papers
Page 13 of 15
Enforcing Public Safety and Protection
How should governments approach designing laws that will reduce, eliminate and punish those who operate outside the boundaries of the new legal system for marijuana? Governments should approach new laws to eliminate the unregulated market by bringing and including the existing unregulated market. Including small scale and craft growers, creating licensing categories to allow genetic propagation and testing, and including a retail distribution method will drastically reduce the unregulated market and will help stop organized crime from becoming involved in the marijuana industry. Establishing a legalized regime which is inclusive, sustainable and transparent, will encourage participation and discourage people from operating and supporting the unregulated market. However, if the new legalized structure continues to restrict production to those already participating in the industry, the illegal marketplace will continue. Once a modern and comprehensive regulatory regime is in place, government and local police will have more resources to:
identify and weed out bad practices and illegal operators,
Collect more accurate data than it has to date - this will give government even greater ability to make decisions more confidently and generate more public support for those decisions.
Enforcement of cannabis regulations can pay for itself through increased tax revenue and licensing fees.
What specific tools, training and guidelines will be most effective in supporting enforcement measures to protect public health and safety, particularly for impaired driving? Public engagement and education on the dangers of impaired driving is essential, regardless of the intoxicating substance involved. Encouraging research into a marijuana equivalent of a “breathalyzer” would also be valuable.
Page 14 of 15
There are many public health benefits to cannabis legalization and regulation. See the CTAC document, dated May 24, 2016: “Cannabis Legalization in Canada: Creating a World-Class Sustainable Industry Through Inclusivity, Transparency and Evidence-Based Policy” (online: www.sustainablecannabis.ca/#papers), at Appendix B, outlining the following:
Cannabis Legalization Leads to Reduction in Incarceration Rates and May Reduce Certain Crime Rates
Cannabis Legalization Leads to Decreased Dependency on Prescription Drugs
Cannabis Legalization Does Not Lead to Increased Youth Use
Cannabis Testing Without Strict Laboratory Standards Yields Inconsistent Results
Should consumption of marijuana be allowed in any publicly-accessible spaces outside the home? Under what conditions and circumstances? A factor that the government should consider is that there are different methods for consuming marijuana that may require different regulations. Many of these will have to be determined by the appropriate jurisdiction, usually municipal. Smoking dried cannabis should fall under smoking bylaws, vaping under e-cigarette laws, and consumption of edible products potentially under similar laws as alcohol consumption. However, it is also important to make sure that these regulations for recreational usage do not impinge on the consumption and use of marijuana by medical users. With the creation of Cannabis Appellations (as mentioned earlier), cannabis tourism in Canada could be a novel addition to regional tourism industries. Canadians take tours of craft breweries, of liquor distilleries, and engage in tours of wine country, sometimes bicycling from winery to winery. The cannabis industry might well be very similar. The development of appropriate provincial and local regulations for distribution, sales and consumption could take into account, and capitalize on the interest in the growing sector of cannabis tourism. In addition, under provincial and municipal laws, licensing should allow cafes, restaurants and bakeries to sell infused cannabis products – as licensed liquor establishments are able to sell mixed cocktails Such initiatives would foster a robust Canadian cannabis economy.
Page 15 of 15
Accessing Marijuana for Medical Purposes
What factors should the government consider in determining if appropriate access to medically authorized persons is provided once a system for legal access to marijuana is in place? With full legalization, it is critical to not forget patients who have very specific needs with respect to cannabis, including strains would be less profitable in the legalized marketplace. Medically authorized persons will require broader access and lower prices, and should not be left dependant on the recreational market for their medical cannabis. For example, a regulated system could include a registry to differentiate recreational users from bona fide medicinal users who could qualify for insurance/tax exemptions and group benefit plan coverage. Issues of cost and access were central to decisions like Allard and the creation of the ACMPR therefore the needs of medical patients should absolutely not be forgotten in the recreational market. Continuing to allow home cultivation for medical purposes is necessary, regardless of the recreational system of production and distribution. Itâ€™s an exciting time for the cannabis reform movement; however, it is extremely important that this movement does not leave patients behind. Thank you for allowing us to provide our input on this important initiative. Kindest regards,
Submission of CTAC to the Discussion Paper published by the Government of Canada’s Task Force on Marijuana Legalization and Regulation