OHA update on extraction

Oregon Cannabis Association logo
OHA bulletin offers provisional licensing to processors beginning April 1
Good morning:
Today, the Oregon Health Authority has announced that beginning April 1, cannabis processors who submit completed applications for licensing through the OHA will be allowed to operate under a provisional license.This means that extractors who follow the OHA’s rules and submit completed applications on April 1 will be able to resume operations, and that dispensaries will be allowed to except transfers of extracts from these provisionally licensed processors.
The bulletin from OHA reads:
A medical marijuana processing site that has submitted a complete application for registration with OHA is exempted from criminal liability pursuant to ORS 475B.475. The registration process with OHA opens on April 1, 2016.
As you know, the Oregon Cannabis Association’s government affairs team has been working around the clock to bring leadership from the agency, the Attorney General, the Governor’s office and the Co-Chairs of the Joint Committee on Marijuana Legalization to resolve this issue. We very much appreciate the engagement of all parties and the OHA’s responsiveness in developing a timely and workable solution.
We are continuing to review the bulletin, but we wanted to make sure you have this information right away. Please check our website atorcannabisassociation.org for updates.
Thank you.
The Oregon Cannabis Association

Enemy of the State

Ladies and Gentlemen,

Where does gross ignorance stop and personal agendas and corruption start?  How are we to tell the difference when the conflicting interests are so blatant?

Recent changes in Oregon’s Cannabis laws this week have made unlicensed extractions a Class B Felony; until permits have been issued by the Oregon Health Authority and or the Oregon Liquor Control Commission.

OHA Medical processors applications are not expected to be available until April, 1 and the licensing process itself is expected to take several months because the people who make the rules are drug warriors who are still fighting the evil weed…

The only segment of the market this affects currently are medical patients; who until now, had safe access to their medicine.

Where did our rights to use medical cannabis, which us Oregon taxpayers voted for, and what provisions have been made by the rule makers to meet our medical needs until the rule makers find it convenient to issue license’s?.

The many Oregon “extract” companies now have to switch to using methods trivially defined as “concentrating” rather than “extracting”.

The basic breakdown of what is a “concentrate” VS “extract”

A “Cannabinoid concentrate” means a substance obtained by separating cannabinoids from

marijuana by:

(a) A mechanical extraction process;

(b) A chemical extraction process using a nonhydrocarbon-based or other solvent, such

as water, vegetable glycerin, vegetable oils, animal fats, isopropyl alcohol or ethanol; or

(c) A chemical extraction process using the hydrocarbon-based solvent carbon dioxide,

provided that the process does not involve the use of high heat or pressure; or

(6) “Cannabinoid edible” means food or potable liquid into which a cannabinoid concentrate,

cannabinoid extract or dried marijuana leaves or flowers have been incorporated.

So Dry sift, bubble hash, glycerin tincture, pot butter, ISO ALCOHOL and ETHANOL are considered concentrates and therefore legal to make at home without a license. However

the last two items on the list are by International Union of Pure and Applied Chemistry’s definition, hydrocarbon solvents.

() “Cannabinoid extract” means a substance obtained by separating cannabinoids from marijuana

by:

(a) A chemical extraction process using a hydrocarbon-based solvent, such as butane, hexane or

propane;

(b) A chemical extraction process using the hydrocarbon-based solvent carbon dioxide, if the

process uses high heat or pressure; or

(c) Any other process identified by the commission, in consultation with the authority, by rule.

Soo… Wait they classified CO2 as a hydrocarbon-based solvent?

That certainly opens the door for a  gross ignorance defense, because, CO2 obviously does not contain HYDROGEN!!! What do the rule makers think the letters CO2 stands for?

But wait, there’s more!  There appears to be more than gross ignorance going on here. If we were legislating based on safety; it would be logical to put alcohols (IUPAC defined as Hydrocarbons) into the “extract” category, while removing  CO2, which is not flammable or a hydrocarbon to the “concentrates” category.

Still explosions during prohibition are a matter of public record, so I don’t think the bill that Oregon Gov. Kate Brown signed was ever intended to be about safety…

It specifically excluded alcohols that are quite flammable and have a track record of blowing up, while including CO2 which has an excellent safety record and is NOT FLAMMABLE!.

So why would they exclude alcohol and include CO2? One could only conclude that there is someone profiting from this nonsense.

So lets follow the money; who would make a profit from removing BHO and CO2 oil from the shelves?

I know of only one, the OLCC, because they profit from the sales of 190 proof everclear that all the extract companies are buying up right now! It has also given the drug warriors a tool to start throwing people in jail again which again the OLCC profits from.The OLCC is headed by the Klamath County District Attorney (aka: chief drug warrior) who’s career is advanced by prosecuting people for drugs crimes and peddling booze. How can that not be a conflict of interest and what are a District Attorneys hands doing on OMMP patients medicine?  Didn’t Oregonians convey that measure 91 was NOT SUPPOSED TO AFFECT THE OMMP? But that was the OLCC’s rules commitee’s first order of business! They refused to move forward with making rules for adult use until the OMMP was thoroughly gutted! Transparency in Oregon’s government means more that openly rubbing abuse in our faces!

I think its high time to show the OHA and the OLCC the door where Cannabis is concerned! We should demand a new non biased regulatory authority that will make rules based on public safety, not profit and prejudice!

I encourage all of our Oregon Pharmers to start flooding the OLCC 541-210-8280, OHA 971-673-1234, and our State representatives with phone calls!

Joint Commitee on Marijuana legalization

Member         Senator Lee Beyer                       503-986-1706

Co-Chair Senate Majority Leader Ginny Burdick   503-986-1718

Co-Vice Chair Senate Republican Leader Ted Ferrioli  Capitol Phone: 503-986-1950    District Phone: 541-490-6528

Member : Senator Jeff Kruse                               Capitol Phone: 503-986-1701
District Phone: 541-580-3276

Co-Vice Chair : Senator Floyd Prozanski             Capitol Phone: 503-986-1704
District Phone: 541-342-2447

Member : Representative Peter Buckley             Capitol Phone: 503-986-1405    District Phone: 541-488-9180

Member : Representative Ken Helm                     503-986-1434

Co-Chair: Representative Ann Lininger               503-986-1438

Member : Representative Andy Olson                 Capitol Phone: 503-986-1415
District Phone: 541-967-6576

Co-Vice Chair : Representative Carl Wilson         Capitol Phone: 503-986-1403
District Phone: 541-476-7896

let them know that we aren’t going to put up with their shenanigans anymore!

Call Kate Browns office (503) 378-4582 and educate her about what she has signed and how sleazy and unprofessional the arrangement appears from this perspective!!

Pharmer Joe

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3-21-16

To the question of what is Graywolf’s reaction to all of this, it is, “Whoooooa!  What just happened?”

Taking away established OMMP patient resources, with no provisions to cover their medical needs,  bears public explanation.

Unless it can be shown that it was through ignorance, and is immediately corrected, I suggest it bears public investigation.

Let’s start with, “how can the medical needs of the OMMP patients be so casually brushed aside?”  Are illustrious rule makers ignorant of the medical properties of cannabis, or do they just not believe them?

If they are ignorant, let’s educate them, but if they don’t believe, what are they doing on a board making medical decisions, because that ship has already sailed and it is a matter of international record that cannabis does in fact work for what OMMP patients daily use them for!!!!!!!

My next would be how are such grossly uninformed decisions being made, even if they are honorable and well intended?

Clearly someone is grossly uninformed to believe CO2 to be a hydrocarbon, and not know that it is so inert as to commonly be used in fire extinguishers to put out fires.

It appears to be an issue of perspective to me, and if life has taught me nothing else, it is that believing is seeing, and that the fish trap exist only because of the fish.

Looking at it from a medical perspective, how much sense does it make to deprive OMMP patients of the medicine that has proven effective for them and so what is the fish being sought?

Certainly not the rights, best interest, or medical needs of the OMMP patients and what this intermittent cut off gain for the overall picture?

I can see from a District Attorney’s perspective how OMMP blurs the battleground for their war on drugs, includes some abuse, and be highly concerned about the number of hydrocarbon extraction explosions starting to mount.

The fish trap however makes a rookie mistake of classifying CO2 as a hydrocarbon, when an average middle schooler can correctly identify as one carbon and two oxygen atoms, with no mention of hydrogen.

It also ignores that virtually all SCFE systems are professionally built because of the extreme requirements, and that there are SCFE CO2 machines that are certified as safe for use in other medical states, and all states for extracting other materials.  SCFE CO2 extraction wasn’t invented by the cannabis community and is used internationally for extraction of a panoply of different food and pharmaceutical products.

Does this arm wave fiat include shutting down all of those operations as well, and laying off those folks???

The fiat further groups all hydrocarbon extractions together, ignoring that again there are professionally designed and built hydrocarbon extraction systems certified to meet ASME, NEC, IBC, and NFPA by 3rd party Registered Professional Engineers, certified by OR, WA, CO, NV, and MD.

Are rules makers unaware that it is the indoor open blasters that are blowing thing up, not the professionals using closed loop systems and operating them professionally.

That leaves open the question of what exactly is the District Attorney’s fish trap designed to do?

It certainly throws a monkey wrench into medical concentrate supplies.  Is that by intent or ignorance and poor design?

It opens the door to fill the jails and confiscate the property of felons, who are otherwise good citizens, but former OMMP patients attempting to make their own concentrates, because their supply was cut off.

If they are a high dosage cancer patient, it is a life and death issue!

Alas, it does an extremely poor job of reducing the number of conflagrations, because those folks will not be professional, nor are they likely to have the resources to use professionally designed equipment for extraction or subsequent finishing.

It blocks the development of an Oregon micro-brew type cannabises businesses, to play to big pharma, and makes the targets clearer for a war on drugs.

One aspect that Pharmer Joe touched on, that I see as highly germane, and that is that we now have the head of the OLCC, with no medical credentials, involved in OMMP, and given the decision to exclude hydrocarbon and CO2 extractions, while allowing alcohol. that begs further analysis as a conflict of interest.

Lets therefore look at the issue from the head of OLCC’s perspective and examine the fish trap.

As Pharmer Joe noted, it clearly improves the bottom line at OLCC by dramatically increasing the sales of 190 proof.

But wait, lets peel that onion!  So far only the ghastly price of highly taxed 190 proof has been mentioned, which I see as only the tip of the iceberg, because the assumption is made that it will be mostly recycled, but brothers and sisters I suggest you educate yourself regarding the Federal restrictions, and building codes for operating an ethanol still.

Apply for a permit to operate an ethanol still to emphasize my point.  A set up for More accidents, raids, confiscations, and citizens in jail, but also more dependence on fresh OLCC supplies.

I guess in summary, it is too hard to tell poor research from perspective and ulterior motives and agendas, but the results are so horrific, that I’m actually floored that Governor Brown would tolerate such an obvious conflict of interest, in her, “transparent government”, or the indifference to the abuse of so many Oregon voters.

Let’s start by giving them all the benefit of the doubt, by educating them and giving them an opportunity to correct their mistakes.  I agree with Joe that the best way to do that, is to call and write them, so they hear your voice and the sounds of reason.

That is what I’m doing!!

GW

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Update                                                                                                                     22 MARCH 2016

 

The Oregon Cannabis Association meeting last Tuesday revealed the first assault on Medical Cannabis in Oregon.   Not long into the Q&A session with OHA the bomb was dropped: processors and producers of hydrocarbon-based extraction products (including butane, propane, hexane, and– erroneously–CO2, as well as processes involving high heat or pressure), both pure and dilute, are now violation of state law–punishable as a class B felony–if we continue to sell (whether wholesale, retail, or directly to medical cannabis cardholders for which we are registered growers) effective March 1, 2016.

Wednesday morning I called Paul Loney, my business attorney. He petitioned OHA with a stopgap for resolution and implementation to current law and rules.  OHA implied they would not pursue extraction companies in this interim period, so, proceed with caution.

Thursday morning, however, an urgent email from Paul warned us to stay production immediately. Industry rumored that three businesses had been raided: one was a dispensary, one an extraction lab and the third unknown.  No names were mentioned, though I heard the same rumor from several sources. Since then, I have heard the dispensary may have had other pressing problems.

Lee Berger was the first to scurry from the OCA meeting after information dissemination, so was my next call Thursday afternoon.  By then, Lee surely had the wheels moving as an integral member of activism for the Oregon MMJ Community. Each of the team had contacted their sphere of influence and was pushing, but there was only the suggestion of the potential stopgap solution such as the one offered by the Paul Loney team (though I’m certain Amy Margolis also has input). The take away for us as a community is to call your Representative and Congressperson, as well as OHA and OLCC. Let’s give them nothing else to do. Print out the list of numbers provided by Joe in his post, Enemy of the State. That list is reprinted below for your convenience.

I spent Friday on the phone with Joe’s list in conjunction with my state Representative, Elisa Keny-Guyer and Senator, Michael Dembrow, and Governor Kate Brown as well as calling the active members of the medical community making explanation and encouraging others to do the same. Here is the link  http://gov.oregonlive.com/legislators/ to find your Representative and Senator. I am also leaving phone call lists with dispensaries to pass to their patients for increased presence. Please do the same.

Only Joint Committee on Marijuana Legalization member Ken Helm was available for discussion. He seemed genuinely surprised and interested in the points of concern (those points of discussion will be summarized at the end of this post for inclusion in your phone calls or emails or letters to your representatives). He promised to make calls.

Friday evening, Rob Partridge called in response to my message.  This was the first he had heard on the effects of the new rules on the medical community.  Furthermore, he did not understand the solvent/process classifications; that, he said, was the charge of the committee. I explained that they chose no representative with experience in the science of extraction and processing for the committee, but rather, only those with the money behind the science.  He did promise to get back to me this week.

Saturday was spent contacting everyone I knew to pass the word, and so many did.  I caused some misunderstanding in my enthusiasm to tell a good story (after raising our hands on camera, we were told we were felons! Meaning: we had all just come from our labs where we had been working and it was surely later than March 1).  With the handicap of the phone for loss of body language and my lack of checking for understanding, the word got out that I had been indicted! We were barraged with phone calls, emails and text messages with people worried about our welfare.  Thanks for your concern. I am not incarcerated.  It did sound an alarm getting many to call and write who might not have, otherwise.

Matt Jaqua, who is on the OHA inspection team, returned my OHA message Monday morning. He listened patiently, agreeing along the way as he assured me that he would do his best to hurry the applications along once received but could do nothing more for me no matter how correct I was.  I should call my Senator, Representative and the committee members.  Their contact numbers are available, but one would have to look.  So anyone good at finding viable contact information, please do.

This morning I spent a good hour on the phone with Marybeth Williams, Chief of Staff for Representative Peter Buckley (who withdrew from the marijuana legalization committee because of what he saw happening to the medical committee).  His staff is storm heading a nonprofit medical category, operating along with the current and future structure, which would minimize the restrictions and promote serving seriously, chronically and terminally ill patients as well as the destitute who cannot afford standardly-priced medications.

I received an email from Lee Berger, with a letter to OHA proposing an Oct 1 stopgap, which he believes is provided for in current interpretation of the law.  I added my company name and logo to the letter.  The same email went to all members of Oregon Extractors Association from activist and OCA board member Lindsey Rinehart.

Many have difficulty making phone calls of this nature as it is helpful to be all-inclusive, fluid, brief and to the point. Here are some dialogues I suggest to get you started.

Points for Patients

My name is________, I am a patient, card number_____.  I suffer from______, requiring ____mg doses as many as ___times per day.  These needs have been consistently met by the legal, currently registered medical cannabis grower/processor community until last Tuesday evening at the OCA meeting when my grower/processor was told they were not able to register as a legal processor until later this year, and thus were currently operating in violation of state law punishable as a class B felony, which would jeopardize their future license.

Measure 91, the measure passed by voters authorizing the recreational use and sale of marijuana by adults in Oregon reads, Section 4: Limitations: “….. this Act may not be construed: (7) To amend or affect in any way the Oregon Medical Marijuana Act.”  Considering its enactment, in order to follow Measure 91 and the will of the voters, you must have an alternative plan to provide my extracts.

  1. What is that plan and how do I get my meds?
  2. How are you correcting the problem such that my Processing source can continue to provide the meds that I must have to function?
  3. When will I have meds?
  4. What do you expect me to do besides call my lawyer?

Please call/email __________ _______ with the corrective stopgap measure that will be taken so I may continue with the medicine that works for me.

 

Points for Caregivers

My name is _____________. I’m a caregiver, card number___________. When we passed Measure 91, I felt a sense of precarious safety. It does say in Section 4. Limitations, “….. this Act may not be construed: (7) To amend or affect in any way the Oregon Medical Marijuana Act.” I will still be able to provide for my patients while they work out recreational laws.

We knew there would be bumps on the implementation journey, but section 4, item 7 were written to protect us from errors of the uneducated and non-medical population on the committees. How possibly, could the only major error effect only the most needy, vulnerable and ill? I provide meds for Cancer patients, children, and elderly, MS, ALS, and Alzheimer’s.  These patients cannot wait.

I spent the last few days contacting everyone I know and everyone they know to locate meds for my (chronic pain, bed-ridden, etc.) patient.  And when I am not calling to locate or advocate, others are calling me worried that I cannot get them their meds.  The dispensaries are pretty much cleared of extracts.

  1. What did you plan for me to tell my patients, the sick people I promised to help?
  2. Do you have a supply I might provide for my patients?
  3. Can you tell me when I may be able to legally resume providing medication to my patients?

 

Please call/email __________ _______ with the corrective stopgap measure that will be taken so I may fulfill my commitment to provide extracts for my patients.

Points for Processors

I’m __________, and a _______extraction processor.  My company is ________.  We provide equipment, training and extraction services and have done so as registered growers for ______ years.

 

As of the notification from OHA on the 16th, stating the operation of an unlicensed extraction lab is a class B felony, I have laid off_____ employees, am losing ______ dollars in revenue per month, will have to retool my lab as well as comply with upcoming regulations, while being denied the right to run a safe and legitimate business. Sure looks like you are stripping the craft industry that pioneered the safe and legal processing of cannabis into the forms needed by the sickest and most vulnerable patients in favor of big outside money, considering legislation in conjunction with rules. Those of us who have been growing and extracting cannabis since the Medical Marijuana Act of 1996 have made it our primary objective to provide a legitimate and needed medicine for sick patients within the limits of the law, not make money off of the “green rush” for the recreational and tourist market.

The classifications of solvents and processes you have used in your rulemaking do not have anything to do with modern extraction and processing science, and appear designed to benefit only those standing at the top of OLCC’s coordination with OHA. It certainly had no intent to help the medical patients, since they (and their medical extraction processors) are the most negatively affected, being denied the medicine that works for them, abruptly and without warning, and in clear violation of Measure 91.

Do explain to me how any of this complies with Measure 91, “….. This Act may not be construed: (7) To amend or affect in any way the Oregon Medical Marijuana Act.”

Please call/email __________ _______ with the corrective stopgap measure that will be taken so I may fulfill my commitment to provide for our patients, caregivers and dispensaries.  Let me rehire my staff before they are committed to another job to support their families.

Points for Dispensaries

I’m____________ with ____________. The implementation of the new rules has caused a _____% reduction in revenue without the sale of extractions to medical cardholders only, which is their right under the Oregon Medical Marijuana Act.  We have had to lay off _____ personnel.

The requests for product exceed the stock currently at hand and we have sold most of our concentrates to accommodate the need of those accustomed to using extracts, which many medical patients need because they have developed tolerance over time, just like many patients need high-dose, extracted forms of pharmaceuticals over many years of treating symptoms of a chronic illness.

What is your plan to obey Measure 91 which states “…..This Act may not be construed: (7) to amend or affect in any way the Oregon Medical Marijuana Act.” Dispensaries came to be for the needs of the patients and now their needs are being denied in favor of the potential complications of these extracts for the recreational market.

It does not matter that dried cannabis remains legal for both medical cardholders and recreational users 21 and over to buy at my dispensary. Many medical cardholders cannot or should not smoke dried cannabis flower. Many require high doses of cannabinoids to be inhaled or ingested several times a day, and this cannot be provided adequately by the dried herb form. Many patients are infirm or elderly, and neither they nor their caregivers can safely or effectively themselves create their own home “extracts” by steeping the dried cannabis with water, alcohol or oil. They risk both undertreating their symptoms this way, and unintentional overdose.

Moreover, I am afraid this will force patients to travel to Washington State in order to obtain and bring back certain types of extracted cannabis preparations; not only is this against the law in both states, but also the limits on recreational dispensing of these preparations in Washington is neither appropriate for a medical user nor an affordable option for them.

So, I ask you:

  1. What am I to do for the patients?
  2. Do you have stock I may purchase for my patients?
  3. What am I to tell them?
  4. When can they resume the standard therapy with the standard preparations that I have been providing for them so far?

Please call/email __________ _______ with the corrective stopgap measure that will be taken so we may fulfill our commitment to provide extracts for our patients.

 

Points for Growers

I’m an Oregon Medical grower, registration number _______. My name is ________. We have _____% of our garden extracted for medical use.  Much of that product is below par in quality of appearance, so we cannot sell it for use to medical patients or dispensaries as dried flower.  However, it remains a valuable source of cannabinoids for medications for cardholders if we can extract it properly and scientifically (for example, it is important that the product be extracted while it is still fresh).

  1. Because we cannot legally extract, we are stockpiling dry herb (which denigrates its quality for certain types of medicine) or are forced to do ethanol extractions only (which tends to produce a more sedative product, not ideal for day use by our patients)
  2. Patients are going without the medications that we have been providing them legally, safely and effectively for years.
  3. The excess weight is troublesome as it adds up in volume quickly, degrades in quality, and produces waste that could otherwise be used to make valuable medicines for legal medical cardholders.

Please do not disrupt the production of quality in our processing by forcing degradation of the product we intended for patient use.  Follow the letter of Measure 91, “….. this Act may not be construed: (7) To amend or affect in any way the Oregon Medical Marijuana Act.”

Please call/email __________ _______ with the corrective stopgap measure that will be taken so I may fulfill my commitment to provide extracts for my patients.

 

 

Don’t hesitate, make your voice heard today! Reprint of Joe’s phone list below.

 

I encourage all of our Oregon Pharmers to start flooding the OLCC 541-210-8280, OHA 971-673-1234, and our State representatives with phone calls!

Joint Committee on Marijuana legalization

Member         Senator Lee Beyer                       503-986-1706

Co-Chair Senate Majority Leader Ginny Burdick   503-986-1718

Co-Vice Chair Senate Republican Leader Ted Ferrioli  Capitol Phone: 503-986-1950    District Phone: 541-490-6528

Member : Senator Jeff Kruse                               Capitol Phone: 503-986-1701
District Phone: 541-580-3276

Co-Vice Chair : Senator Floyd Prozanski             Capitol Phone: 503-986-1704
District Phone: 541-342-2447

Member : Representative Peter Buckley             Capitol Phone: 503-986-1405    District Phone: 541-488-9180

Member : Representative Ken Helm                     503-986-1434

Co-Chair: Representative Ann Lininger               503-986-1438

Member : Representative Andy Olson                 Capitol Phone: 503-986-1415
District Phone: 541-967-6576

Co-Vice Chair : Representative Carl Wilson         Capitol Phone: 503-986-1403
District Phone: 541-476-7896

let them know that we aren’t going to put up with their shenanigans anymore!

Call Kate Browns office (503) 378-4582 and educate her about what she has signed and how sleazy and unprofessional the arrangement appears from this perspective!!

Respect,

Carla, aka Eloquentsolution

 

We will provide updates as information becomes available.

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Update                                                                                                                   23 March 2016

I just received a phone call followed by an email from Ken Helms of the Joint Committee on Marijuana Legalization, informing me of the following letter from the co-Chair Senate Majority Leader, Ginny Burdick.  This is a beginning!

Respect,

Carla aka Eloquentsolution

 

OREGON LEGISLATIVE ASSEMBLY
VIA ELECTRONIC TRANSMISSION: lynne.saxton@state.or.us
March 23, 2016
Ms. Lynne Saxton
Director, Oregon Health Authority
500 Summer Street, NE
Salem, OR 97301-1097
Dear Director Saxton:
We are writing to express concern over the possibility of a gap in the production of cannabis extracts that could deprive patients of medicinal marijuana and undermine the viability of numerous Oregon small businesses. Specifically, we urge the Oregon Health Authority (“OHA”) to find a path forward that would enable safe production of cannabis extracts to continue without undue interruption during the licensure start-up phase.
Background on the Problem In 2015, the Oregon Legislature passed House Bill 3400, which directed the Oregon Health Authority to license and regulate medical processors of cannabis extracts, concentrates, and edibles. The Oregon Health Authority has been working hard to implement the various pieces of 3400. The rule making process is still underway, and we understand there is currently no avenue available for licensing medical processors. We understand the opportunity to apply for licensure will begin on April 1st, 2016, and once an application is submitted, additional time will be required for inspections and review. This situation creates a potential gap in the availability of cannabis extracts for medicinal use. HB 4014 Sec. 39 defines extraction without a license a class B felony. Since there is not yet a process defined in rule making for commercial extract makers to obtain licenses, we understand that many extractors plan to cease operations rather than risk criminal and administrative penalties. This could cause a gap in availability of extracts for medicinal use, and it could drive extract makers out of business. This outcome would conflict with our legislative intent to provide a smooth transition into the
new regulatory system for medical marijuana patients and for small businesses operating in the legal cannabis space. It would also drive production and sales into the illegal market, conflicting with legislative intent to comply with the Cole Memo. Possible Solution There may be a way to resolve this situation by providing a provisional license or some other kind of temporary safe harbor for commercial extract makers that have been operating in compliance with the rules. Oregon has in some instances allowed cannabis sector participants that have applied for permission to undertake an activity to engage in the activity on a temporary basis. The rationale for that approach—to avoid undue disruption to patients and businesses—would be well-served here.
Oregon has allowed applicants to be considered rightful participants with respect to qualification as a “marijuana processing site” in ORS 475B.410(13). The statute defines “marijuana processing site” to include a site that has applied for registration. Similar logic allows Oregon Medical Marijuana Program cardholders to receive protection simply by retaining their certified application copies as part of their “safety packet.” The same approach allows growers seeking an Oregon Liquor Control Commission license or a grandfather determination from OHA to have a provisional stay on plant limit reductions.
We encourage OHA to find a path forward—perhaps using this logic or some other basis—to ensure that rule abiding medical marijuana patients and extract makers are protected from a harmful disruption as we move into our new regulatory system. Thank you for your hard work to protect patients and communities as we evolve our state’s approach to regulating legal cannabis.
Sincerely,
Representative Ann Lininger Senator Ginny Burdick
Co-chair, Joint Committee on Co-chair, Joint Committee on
Marijuana Legalization Marijuana Legalization
cc:
Mr. Jeremy Vandehey, Governor’s Health Care Policy Advisor
Ms. Heidi Moawad, Governor’s Public Safety and Military Policy Advisor
Ms. BethAnne Darby, External Relations Director, Oregon Health Authority
Mr. Jeston Black, Director of Government Affairs, Oregon Health Authority

 

Dissolving Acidic Cannabinoids for a THCA Tincture by CAT Scientific

Check this out!

Dissolving Acidic Cannabinoids for a THCA Tincture by Steve Gold

CANNABINOID CARBOXYLIC ACIDS THCA AND CBDA: THEIR POTENTIAL FUNCTIONS, APPLICATIONS, AND METHODS OF EXTRACTION

Wowza!  Check out what Dr Kate has been up to!

Introduction to a cold extraction method for hash oil that preserves carboxylic acid form of cannabinoids THC and CBD

By Kate Welch, Pharm.D

CANNABINOID CARBOXYLIC ACIDS THCA AND CBDA: THEIR POTENTIAL FUNCTIONS, APPLICATIONS, AND METHODS OF EXTRACTION

Emulsifying BHO and Vegetable Glycerine for E-Juice

For those coveting detailed instruction on how to emulsify BHO and Vegetable Glycerin for E-Juice, check out the report put out by CAT Scientific at:

Emulsifying Vegetable Glycerin and BHO for E-juice by CAT Scientific

Potential Fire Hazard Emulsifying Alcohol

Whooop, whoooooop, heads up for potential hazard!!!

The following caveat from the folks at CAT Scientific:

Hi JD!

I’m getting quite a few reports of folks using our Homogenizers to dissolve Absolute Oil in Ethanol. Our homogenizer drive units have brushed motors and the device is positioned right over the Ethanol. Given the temperature of the Ethanol while dissolving/homogenizing, 65°C, I think there is a possibility of a flash fire.

Our R20 Overhead stirrer http://www.catscientific.com/overhead-stirrers/overhead-stirrer-r20/ which has a brushless motor, is a safer device for dissolving.

Bob and I we’re wondering if you could post something on the Skunk Pharm Web Site letting folks know the potential dangers of using a brushed motor homogenizer and the benefits of an overhead stirrer, the R20, with a brushless motor for this application?

Steve
http://www.catscientific.com

Rebuilding the Haskel 59025-3 and EXT-420

Hee, hee, hee, this should gladden the heart of all ya’ll Haskel fans!  How about a video of Haskels Western Region Account Manager demonstrating how to service and totally rebuild a Haskel EXT-420??

Check this out:

https://skunkpharmresearch.com/haskel-ext-420-and-59025-1-maintenance-and-rebuild/

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