centralized inventory tracking - recommendation · centralized inventory tracking - recommendation...

Centralized Inventory Tracking - Recommendation

Centralized Inventory Tracking v. 2 - Recommendation May 12, 2017

1. Working group name:

Operations - Production/ Manufacturing

2. Individual sponsor(s):

Anna Thornley – Department of Taxation

Bryan Hyun – Owner/Operator – The Grove

Jake Ward – Pure Tonic Concentrates

3. Describe the recommendation:

All marijuana facilities will have internal inventory control systems and movement of all

controlled substances between facilities will be closely monitored per regulation. It has been

proposed that a centralized seed-to-sale system also be put into effect by the Department which

would centrally monitor all inventory in the State. This data would potentially be used to not only

track inventory but also for tracking business transactions so that fair market values may be

established per NRS 453D.

Since inventory control systems are a very important part of how the industry interfaces with

regulators, it is recommended that the Department work closely with industry to decide whether

a centralized seed-to-sale inventory tracking system is necessary. If the system is deemed

necessary, then the Department should work closely with industry to develop system

requirements and implement the system.

4. Which guiding principle(s) does this recommendation support?

Guiding Principle 2 - Be responsive to the needs and issues of consumers, non-

consumers, local governments and the industry

Guiding Principle 4 - Propose efficient and effective regulation that is clear and reasonable and

not unduly burdensome

5. What provision(s) of Question 2 does this recommendation apply to?

- NRS 453D.200 (c) Requirements for the security of marijuana establishments;

- NRS 453D.200 (d) Requirements to prevent the sale or diversion of marijuana and marijuana

products to persons under 21 years of age

- NRS 453D.200 (g) Requirements for record keeping by marijuana establishments

- NRS 453D.200 (l) Procedures to establish the fair market value at wholesale of marijuana

6. What issue(s) does the recommendation resolve?

Centralized Inventory Tracking - Recommendation

Centralized Inventory Tracking v. 2 - Recommendation May 12, 2017

This recommendation resolves the issue of implementing an inventory control system which is

robust enough to allow for the gathering of pertinent data, but not redundant or unduly

burdensome on the industry.

7. Was there dissent in the group regarding this recommendation? If yes, please provide a

summary of the dissenting opinion regarding the recommendation.

No dissent.

8. What action(s) will be necessary to adopt the recommendation? Will statute, policy,

regulations, etc. need to be addressed?

The Department will have to reach out to industry to gain some knowledge as to how inventory

and transactions are currently tracked and industry will have to learn more about the needs of

the Department as final regulations are drafted. Inventory control systems are a very important

part of how the industry interfaces with regulators.

9. Additional information (cost of implementation, priority according to the recommendations,

etc.).

None

Local Government Regulation - Recommendation

Local Government Regulation – Recommendation May 12, 2017




Tommy Robinson, Deputy Police Chief, Reno Police Department

Alex Woodley, Director of Code Enforcement, City of Reno

Jacob Ward, Pure Tonic Concentrates

Jennifer Lazovich, Kaempfer Crowell


The intent of this recommendation is to ensure that there is consistency in regulation throughout

the State for certain matters involving recreational marijuana.


Guiding Principle 1 – Promote the health, safety, and well-being of Nevada’s

communities

Guiding Principle 2 – Be responsive to the needs and issues of consumers, non-

consumers, local governments and the industry

Guiding Principle 4 – Propose efficient and effective regulation that is clear and reasonable and


Guiding Principle 5 - Begin a discussion between the State and local governments regarding the

costs of carrying out Question 2

Guiding Principle 6 – Establish regulations that are clear and practical, so that interactions

between law enforcement (at the local, State and federal levels), consumers, and licensees are

predictable and understandable


1) NRS 453D.020 (3) (c) Cultivating, manufacturing, testing, transporting and selling marijuana

will be strictly controlled through State licensing and regulation

2) NRS 453D.200 Duties of Department relating to regulation and licensing of marijuana

establishments; information about consumers.


Local Government Regulation - Recommendation

Local Government Regulation – Recommendation May 12, 2017

This recommendation would provide guidance to local governments as to issues that should be

deferred to State regulation. Certain matters involving edibles, packaging, concentrates, product

types, dosing, potency and serving size limitations should be consistent throughout the State to

ensure consumer safety. Some other resolutions offered by this recommendation are:

Ensures uniformity for the industry & predictability with set regulations

Provides opportunity for State regulators to become subject matter experts

Reduces costs of regulation to local jurisdictions

Minimizes ongoing training of the local jurisdictions by the State

Minimizes possibility of contradictory regulations between the State and local governments

Provides for local and State interactions similar to that related to existing gaming

regulations



No dissent



A regulation should be adopted that makes it clear that local governments may regulate

recreational marijuana establishments on zoning, general business license matters, fire and

building code compliance. However, local governments must defer to State regulation on

matters involving edibles, packaging, concentrates, dosing, potency, serving size limitations, and

products types.

Essentially, the State should carry out the provisions outlined in 453D.200 and the local

governments should not add to or take away from the subject matter in those same provisions at

the local level. 453D.200 (1) (h) will be exempt from this regulation.


etc.).

None

Product Types and Their Equivalencies - Recommendation

Product Types and Their Equivalencies v. 3 - Recommendation May 12, 2017




Bill Erlach – City of Reno Fire Department

Bryan Hyun – Owner/ Operator – The Grove

Meg Collins - Good Chemistry

Jake Ward – Pure Tonic Concentrates


Due to the possession and purchase limits put in place by Question 2 for marijuana and

concentrated marijuana, there is some confusion regarding the difference between marijuana

flower, marijuana edibles, and marijuana concentrates. This recommendation is intended to add

clarity to the regulation of concentrated marijuana as it relates to other marijuana product

types.


Guiding Principle 2 - Be responsive to the needs and issues of consumers, non-consumers, local

governments and the industry

Guiding Principle 4 - Propose efficient and effective regulation that is clear and reasonable and


Guiding Principle 6 - Establish regulations that are clear and practical, so that interactions

between law enforcement (at the local, state and federal levels), consumers, and licensees are

predictable and understandable


NRS 453D.030 (2) - “Concentrated marijuana” means the separated resin, whether crude or

purified, obtained from marijuana.

NRS 453D.110 (1) - Possess, use, consume, purchase, obtain, process, or transport marijuana

paraphernalia, one ounce or less of marijuana other than concentrated marijuana, or one-eighth

of an ounce or less of concentrated marijuana;




The need to clearly define what concentrated marijuana is and how it relates to other marijuana

types for the regulation of retails sales and personal possession limits.



No dissent.



1. A regulation should be put into place that takes topical and edible marijuana out of the

possession and purchase restrictions outlined in 453D.110 (1).

a. Edible marijuana infused products will be regulated by stringent THC limits related to serving

size and packaging limitations as outlined in other Production / Manufacturing Work Group

recommendations.

b. Topicals should not be included in the possession and purchase limits outlined by Question 2.

The THC in topical preparations are not used or consumed in a manner that would activate the

psychoactive effects of the amounts of THC that may be in topical products.

2. Question 2 allows a consumer to “possess, use, consume, purchase, obtain, process or

transport…one ounce or less of marijuana, or one-eighth of an ounce or less of concentrated

marijuana. Since there will be cases where an individual may purchase and possess a mixture of

marijuana products (concentrated marijuana, marijuana infused edible products, and marijuana

flower) then equivalency factors should be developed and put into place so that decisions can be

made upon retail sale and in the field by law enforcement. (The Medical Marijuana regulations

found in Section 453A.704 contains guidelines for equivalent purchase limits for medical

marijuana patients.)

3. It is important that a comprehensive training program be developed and be administered to

law enforcement so that a clear distinction between product types can be made in the field.

4. Retail dispensaries should develop and administer training to management and their sales

staff that ensures that they understand the sales limitations of marijuana products and

concentrate, and the likely combinations thereof, to ensure that all sales are compliant with

respect to purchase and possession limits.


etc.).

The proposed Nevada equivalency chart is attached below.

centralized inventory tracking - recommendation · centralized inventory tracking - recommendation...

Documents