medical marijuana: 5 steps to successfully walking the workplace tightrope tommy eden, partner...

Medical Marijuana: 5 Steps to Successfully Walking the Workplace Tightrope

Tommy Eden, Partner Constangy, Brooks & Smith, LLPSAPAA Board MemberJosephine Elizabeth Kenney, JD, MBA -HRSenior Compliance Counsel First AdvantageSAPAA Board Member

Medical Marijuana: 5 Steps to Successfully Walking the Workplace Tightrope

Legal Disclaimer

This presentation is for educational purposes only and is not intended as a substitute for the legal advice of an attorney knowledgeable of the issues covered as they relate to a user’s individual circumstances or a medical practitioner. The presenter makes no assurances regarding the accuracy or completeness of the following information. Legislative, regulatory, case law and medical developments regularly impact on general research and medical information.

When Cheech and Chong Go to When Cheech and Chong Go to WorkWork::5 Steps to Dealing with Marijuana in 5 Steps to Dealing with Marijuana in the Workplacethe WorkplaceConstangy, Brooks & Smith, LLP

VisionarieVisionaries?s?

Constangy, Brooks and Smith, LLP ©2013 All Rights Reserved 5

Legal DisclaimerLegal Disclaimer

This presentation is for educational This presentation is for educational purposes only and is not intended as purposes only and is not intended as a substitute for the legal advice of an a substitute for the legal advice of an attorney knowledgeable of the issues attorney knowledgeable of the issues covered as they relate to a user’s covered as they relate to a user’s individual circumstances or a medical individual circumstances or a medical practitioner. The presenter makes no practitioner. The presenter makes no assurances regarding the accuracy or assurances regarding the accuracy or completeness of the following completeness of the following information. Legislative, regulatory, information. Legislative, regulatory, case law and medical developments case law and medical developments regularly impact on general research regularly impact on general research and medical information.and medical information.

Constangy, Brooks and Smith, LLP ©2013 All Rights Reserved

The first Cheech and Chong The first Cheech and Chong movie, “Up in Smoke” movie, “Up in Smoke” Released September 1978 Released September 1978 followed by 11 other followed by 11 other movies from 1980 to 1990movies from 1980 to 1990

First States to legalize marijuana First States to legalize marijuana for medicinal purposes:for medicinal purposes:

•California: 1996California: 1996

•Alaska: 1998Alaska: 1998

•Oregon: 1998Oregon: 1998

•Washington: 1998Washington: 1998

•today 20 states and DCtoday 20 states and DC


The State Business of PotThe State Business of Pot


As Marijuana Goes Legit, Investors As Marijuana Goes Legit, Investors Rush InRush In

““Pot entrepreneurs have high Pot entrepreneurs have high expectations for a future expectations for a future

market in legalized market in legalized marijuana.”marijuana.”

http://www.usatoday.com/story/money/business/http://www.usatoday.com/story/money/business/2013/04/07/medical-marijuana-industry-growing-billion-2013/04/07/medical-marijuana-industry-growing-billion-dollar-business/2018759/ dollar-business/2018759/


Investors: Marijuana, Inc.Investors: Marijuana, Inc.• Hemp, Inc. is a publicly traded company (Stock Symbol HEMP) that is Hemp, Inc. is a publicly traded company (Stock Symbol HEMP) that is

working to expand its infrastructure while investing in profitable, legal, and working to expand its infrastructure while investing in profitable, legal, and diversified ventures, bringing reward and value to its shareholders diversified ventures, bringing reward and value to its shareholders

• Marijuana, Inc., a division of Hemp, Inc., is working toward a green future Marijuana, Inc., a division of Hemp, Inc., is working toward a green future with HEMP and is working to expand it’s infrastructure in preparation for with HEMP and is working to expand it’s infrastructure in preparation for possible legalization of marijuana and hemp.possible legalization of marijuana and hemp.

• Marijuana, Inc. foresees and recognizes the possible benefits that may be Marijuana, Inc. foresees and recognizes the possible benefits that may be derived from the many uses for industrial hemp and recognizing the profits derived from the many uses for industrial hemp and recognizing the profits that could be madethat could be made


Marijuana Candy Bust Prompts Drug Marijuana Candy Bust Prompts Drug Education Education

•Cheeba Chews, chocolate taffy Cheeba Chews, chocolate taffy infused with the active substance in infused with the active substance in marijuana, that were found on a marijuana, that were found on a Kansas State student on spring Kansas State student on spring break in Gulf Shores on March 23, break in Gulf Shores on March 23, 2013, has raised concerns with 2013, has raised concerns with drug education advocates. drug education advocates.


The War on Marijuana: Is It Going, Going, The War on Marijuana: Is It Going, Going, Gone?Gone?

August 29, 2013August 29, 2013

U. S. Department of JusticeU. S. Department of JusticeMEMORANDUM FOR ALL UNITED MEMORANDUM FOR ALL UNITED STATES ATTORNEYS:STATES ATTORNEYS:

Guidance Regarding Marijuana Guidance Regarding Marijuana EnforcementEnforcement


5 Steps an Employer can 5 Steps an Employer can take to Successfully Walk take to Successfully Walk the Tightropethe Tightrope

1.1. Understand the laws on Medical Marijuana Understand the laws on Medical Marijuana that are specific to their State;that are specific to their State;

2.2. Adopt a pre-duty prescription medication and Adopt a pre-duty prescription medication and impairing effects substances safety policy;impairing effects substances safety policy;

3.3. Update employee job descriptions;Update employee job descriptions;4.4. Adopt an ADA complaint handbook policy on Adopt an ADA complaint handbook policy on

reasonable accommodations; andreasonable accommodations; and5.5. Let employees know your stance on Medical Let employees know your stance on Medical

and Recreational Marijuana use.and Recreational Marijuana use.


What does falling off “the Tightrope” What does falling off “the Tightrope” look like?look like?

1.1.Impaired forklift operator misgauges Impaired forklift operator misgauges distance and injuries fellow employee distance and injuries fellow employee with forks;with forks;2.2.You open the mail and employee (who You open the mail and employee (who was about to be fired) files discrimination was about to be fired) files discrimination complaint under state Medical Marijuana complaint under state Medical Marijuana law;law;3.3.Impaired painter using propane torch Impaired painter using propane torch to remove paint forgets to turn off flame to remove paint forgets to turn off flame and burns down your factory;and burns down your factory;4.4.You are notified by a state EEOC agency You are notified by a state EEOC agency that you have been served with an ADA that you have been served with an ADA Charge for failure to reasonably Charge for failure to reasonably accommodate; oraccommodate; or5.5.Worker with Medical Marijuana permit Worker with Medical Marijuana permit feels empowered and smokes during feels empowered and smokes during lunch break to “ease the pain,” etc.lunch break to “ease the pain,” etc.


State Medical Marijuana Statutory State Medical Marijuana Statutory Considerations:Considerations:

1.1. Who the law applies toWho the law applies to2.2. Quantity of Marijuana PermittedQuantity of Marijuana Permitted3.3. How the Marijuana may be obtained/access – How the Marijuana may be obtained/access –

Medical Marijuana Dispensaries/variationsMedical Marijuana Dispensaries/variations4.4. The liability protectionsThe liability protections5.5. The statutory requirements for authorized The statutory requirements for authorized

use and the illnesses/medical conditions use and the illnesses/medical conditions covered by each statute as applicablecovered by each statute as applicable

NOTE: Each state law varies significantly and a NOTE: Each state law varies significantly and a short summary and the full text of each short summary and the full text of each state law can be found at:state law can be found at:

http://www.sapaa.com/page/wp_statelaws_glancehttp://www.sapaa.com/page/wp_statelaws_glance


AlaskaAlaskaSections 17.37.010-.080 (2002)Sections 17.37.010-.080 (2002)

Applicability:Applicability:Law applies to patient, caregiver Law applies to patient, caregiver and alternate caregiver and and alternate caregiver and physicianphysician

Quantity Allowed:Quantity Allowed:Less than or equal to 1oz. Usable, 6 Less than or equal to 1oz. Usable, 6 plants with only 3 able to produce plants with only 3 able to produce usable product. usable product.

How Obtained:How Obtained:Growing permitted, otherwise not Growing permitted, otherwise not specifiedspecified


Alaska (cont.)Alaska (cont.)

Liability Protections:Liability Protections:Patient Patient and caregiver have defense if criminally and caregiver have defense if criminally prosecuted if registered and in compliance with the lawprosecuted if registered and in compliance with the law

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry Card required and obtained from State Registry Card required and obtained from State Department of Health and Human Services. Statement Department of Health and Human Services. Statement signed by physician, sworn application from patient, signed by physician, sworn application from patient, statement form parent or guardian and annual renewal.statement form parent or guardian and annual renewal.


ArizonaArizonaAn initiative measure amending Title An initiative measure amending Title 36, Arizona Revised Statutes. By 36, Arizona Revised Statutes. By adding Chapter 28.1; Amending adding Chapter 28.1; Amending Section 42-201, Arizona Revised Section 42-201, Arizona Revised Statutes.Statutes.

Signed by the Governor. Signed by the Governor. Implementation period will end April Implementation period will end April 13, 2011. Rulemaking has been an 13, 2011. Rulemaking has been an ongoing process. Regular program ongoing process. Regular program updates are provided on Arizona’s updates are provided on Arizona’s Website:Website:http://www.azdhs.gov/http://www.azdhs.gov/medicalmarijuana/medicalmarijuana/Retrieved October 25, 2012.Retrieved October 25, 2012.


Arizona (cont.)Arizona (cont.)

Applicability:Applicability:Physicians and qualifying patients, visiting qualifying patients and Physicians and qualifying patients, visiting qualifying patients and designated caregiversdesignated caregivers

Quantity Allowed:Quantity Allowed:Two and one half ounces of usable marijuanaTwo and one half ounces of usable marijuana

How Obtained:How Obtained:Through dispensaries which will be taxed and started to open in July Through dispensaries which will be taxed and started to open in July 2012.2012.


Arizona (cont.)Arizona (cont.)

Liability Protections:Liability Protections:Numerous protections including a Numerous protections including a discrimination prohibition discrimination prohibition with limited exceptions.with limited exceptions. Protects patients with debilitating Protects patients with debilitating conditions, their physicians and providers, from arrest and conditions, their physicians and providers, from arrest and prosecution, criminal and other penalties and property prosecution, criminal and other penalties and property forfeiture if such patients engage in the medical use of forfeiture if such patients engage in the medical use of Marijuana.Marijuana.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry Card required identifying person as a qualifying Registry Card required identifying person as a qualifying patient, registered caregiver or a registered non-profit patient, registered caregiver or a registered non-profit Medical Marijuana dispensary agent.Medical Marijuana dispensary agent.


CaliforniaCalifornia

Cal. Health and Safety Code Sections 11362.5-Cal. Health and Safety Code Sections 11362.5-8383

Applicability:Applicability:Law applies to physicians, patients and Law applies to physicians, patients and caregiverscaregivers

Quantity Allowed:Quantity Allowed:8oz. or less dried; or 6 or less mature; or 12 or 8oz. or less dried; or 6 or less mature; or 12 or less immature plantsless immature plants

How Obtained:How Obtained:Growing permitted – otherwise not specifiedGrowing permitted – otherwise not specified


California (cont.)California (cont.)

Liability Protections:Liability Protections:Physicians:Physicians: protected from criminal prosecution when protected from criminal prosecution when recommending Marijuana for medical userecommending Marijuana for medical usePatients and Caregivers: Patients and Caregivers: protected from arrest for protected from arrest for possession, transportation, delivery or cultivation possession, transportation, delivery or cultivation if if patient or caregiver has a valid I.D.patient or caregiver has a valid I.D. (NOTE: I.D. card is (NOTE: I.D. card is voluntary).voluntary).

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:No Registry Card required. I.D. Cards issued by State No Registry Card required. I.D. Cards issued by State Department of Health. I.D. Cards are voluntary and must Department of Health. I.D. Cards are voluntary and must be renewed annually. New information must be verified by be renewed annually. New information must be verified by County Health Department Efforts to improve California County Health Department Efforts to improve California Medical Marijuana laws thwarted in 2011.Medical Marijuana laws thwarted in 2011.


ColoradoColoradoColo. Const. Art. XVIII Section 14Colo. Const. Art. XVIII Section 14


Quantity Allowed:Quantity Allowed:Less than or equal to 2oz or 6 plants with only 3 Less than or equal to 2oz or 6 plants with only 3 able to produce usable product. Patient may able to produce usable product. Patient may raise an affirmative defense if greater amount is raise an affirmative defense if greater amount is needed for debilitating condition.needed for debilitating condition.

How Obtained:How Obtained:Growing is permitted but details not specified.Growing is permitted but details not specified.


Colorado (cont.)Colorado (cont.)

Liability Protections:Liability Protections:Physicians:Physicians: protected from criminal prosecution when protected from criminal prosecution when recommending Marijuana for medical userecommending Marijuana for medical usePatients and Caregivers: Patients and Caregivers: have an affirmative defense if physician have an affirmative defense if physician diagnosed and advised use of Medical Marijuana permitted diagnosed and advised use of Medical Marijuana permitted quantity and if registered with I.D. Card.quantity and if registered with I.D. Card.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry Card required. Must be Colorado resident and registered Registry Card required. Must be Colorado resident and registered with Colorado Department of Public Health and Environment. with Colorado Department of Public Health and Environment. Current Colorado physician diagnosis required (2 physicians Current Colorado physician diagnosis required (2 physicians diagnosis required for minors). Annual renewal with written diagnosis required for minors). Annual renewal with written documentation provided.documentation provided.

Update:Update:Medical Marijuana Dispensaries Near SchoolsMedical Marijuana Dispensaries Near Schools


ConnecticutConnecticutHB 5389 (Effective October 1, 2012)HB 5389 (Effective October 1, 2012)

Regulations to be published.Regulations to be published.

Applicability:Applicability:Law applies to patient, guardian of patient, caregiver, Law applies to patient, guardian of patient, caregiver, dispensary producer and physiciandispensary producer and physician

Quantity Allowed:Quantity Allowed:Amount reasonable necessary to ensure the Amount reasonable necessary to ensure the uninterrupted availability for a period of one month, as uninterrupted availability for a period of one month, as determined by the Department of Consumer determined by the Department of Consumer Protection. Specific amounts to be provided no later Protection. Specific amounts to be provided no later than 1/1/2013 by Department of Consumer Protection.than 1/1/2013 by Department of Consumer Protection.

How Obtained:How Obtained:Through Dispensaries and producers.Through Dispensaries and producers.


Connecticut (cont.)Connecticut (cont.)

Liability Protections:Liability Protections:Qualifying patient, guardian and caregiver protected from arrest for Qualifying patient, guardian and caregiver protected from arrest for possession, transportation, delivery or cultivation of Medical possession, transportation, delivery or cultivation of Medical Marijuana if foregoing has a valid registration certificate from the Marijuana if foregoing has a valid registration certificate from the Department of Consumer Protection – Validation is not to exceed Department of Consumer Protection – Validation is not to exceed one year.one year.

Law includes a restrictive and detailed provision that states that no Law includes a restrictive and detailed provision that states that no employer may refuse to hire a person or may discharge, penalize or employer may refuse to hire a person or may discharge, penalize or threaten an employee solely on the basis of such person’s or threaten an employee solely on the basis of such person’s or employees status as a qualifying patient or caregiver. Some employees status as a qualifying patient or caregiver. Some exceptions may apply.exceptions may apply.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Valid registration certificate from the Department of Consumer Valid registration certificate from the Department of Consumer Protection required for physician, patient, dispensary and producers.Protection required for physician, patient, dispensary and producers.


DelawareDelaware

Title 16 Chapter 49A Delaware Code (2011)Title 16 Chapter 49A Delaware Code (2011)

Applicability:Applicability:Law applies to physician, patient and caregiver 21 Law applies to physician, patient and caregiver 21 years or older.years or older.

Quantity Allowed:Quantity Allowed:Patients 18 years or older may possess 6oz. of Patients 18 years or older may possess 6oz. of MarijuanaMarijuana

How Obtained:How Obtained:Growing not permitted at home. State Regulated Growing not permitted at home. State Regulated Non-Profit Distribution System by Compassion Non-Profit Distribution System by Compassion CentersCenters


Delaware (cont.)Delaware (cont.)

Liability Protections:Liability Protections:Physicians: Physicians: protected when recommending Marijuana for protected when recommending Marijuana for medical use.medical use.Patient:Patient: no arrest for possession of Medical Marijuana if they no arrest for possession of Medical Marijuana if they have a valid I.D. card.have a valid I.D. card.Caregivers, visiting patients under certain conditions and Caregivers, visiting patients under certain conditions and compassion centers and their employees protected.compassion centers and their employees protected.Discrimination prohibited by school, landlord or employer, with Discrimination prohibited by school, landlord or employer, with limited exceptions.limited exceptions.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Identification card required, copy of physician state required. Identification card required, copy of physician state required. Identification cards issued by State Department of Human Identification cards issued by State Department of Human Services.Services.


HawaiiHawaii

Stat. Ann. Sections 329-121-128 (2004)Stat. Ann. Sections 329-121-128 (2004)


Quantity Allowed:Quantity Allowed:Less than or equal to 3 mature or 4 immature Less than or equal to 3 mature or 4 immature plants with yield of 1oz if usable.plants with yield of 1oz if usable.

How Obtained:How Obtained:Growing is permitted but details not Growing is permitted but details not specified.specified.


Hawaii (cont.)Hawaii (cont.)

Liability Protections:Liability Protections:Physicians:Physicians: protected from criminal prosecution when protected from criminal prosecution when recommending Marijuana for medical use in writingrecommending Marijuana for medical use in writingPatients and Caregivers:Patients and Caregivers: have an affirmative defense if have an affirmative defense if physician advised use of Medical Marijuana, explained the physician advised use of Medical Marijuana, explained the risks/benefits of use, and if registered with I.D. card.risks/benefits of use, and if registered with I.D. card.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry Card required. Must be registered with Hawaii Registry Card required. Must be registered with Hawaii Department of Public Safety. Patient needs written Department of Public Safety. Patient needs written documentation from physician that use outweighs risks documentation from physician that use outweighs risks and that the amount permitted will not be exceeded.and that the amount permitted will not be exceeded.


IllinoisIllinois

625 ILCS 5/11-502.1 Compassionate Use of Medical Cannabis Pilot Program Act – Effective January 1, 2014 – Act Repealed 4 years after its effective dateApplicability: Physicians, person diagnosed by a physician as having a debilitating medical condition, primary caregiverQuantity Allowed:No more than 2.5 ounces of usable cannabis during a 14-day period that is derived solely from intrastate sourceHow Obtained:22 Cultivation Centers authorized with associated taxation and security program


Illinois (cont.)Illinois (cont.)

Liability Protections:Liability Protections:Protection from arrestProtection from arrest

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry Identification Card issued by the Department of Registry Identification Card issued by the Department of HealthHealth

Note: The law does not prohibit an employer from Note: The law does not prohibit an employer from enforcing a policy concerning drug testing, zero tolerance, enforcing a policy concerning drug testing, zero tolerance, or a drug free workplace provided the policy is applied in a or a drug free workplace provided the policy is applied in a non-discriminatory mannernon-discriminatory manner


MaineMaine

ME Rev. Stat. Ann. Tit. 22 Sections 2383-B (2004)ME Rev. Stat. Ann. Tit. 22 Sections 2383-B (2004)

Applicability:Applicability:Law applies to physicians, patients and caregiversLaw applies to physicians, patients and caregivers

Quantity Allowed:Quantity Allowed:Less than or equal to 2.5 oz of usable product or 6 or Less than or equal to 2.5 oz of usable product or 6 or less plants with no more than 3 mature and less plants with no more than 3 mature and flowering.flowering.

How Obtained:How Obtained:September 2010 Legislation – Medical Marijuana September 2010 Legislation – Medical Marijuana Dispensaries established – 8 Dispensaries now listedDispensaries established – 8 Dispensaries now listed


Maine (cont.)Maine (cont.)

Liability Protections:Liability Protections:Physicians, patients and caregivers – Liability protections Physicians, patients and caregivers – Liability protections not covered in statute.not covered in statute.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:No state patient registry based on 2010 legislation but No state patient registry based on 2010 legislation but documentation of use is required.documentation of use is required.


MassachusettsMassachusetts

Applicability:Applicability:The Massachusetts Medical Marijuana Ballot The Massachusetts Medical Marijuana Ballot initiative passed (63% voted in favor) and is effective initiative passed (63% voted in favor) and is effective January 1, 2013. (An Initiative Petition for a Law for January 1, 2013. (An Initiative Petition for a Law for the Humanitarian Medical Use of Marijuana Petition the Humanitarian Medical Use of Marijuana Petition Number 11-11)Number 11-11)

Quantity Allowed:Quantity Allowed:Amount permitted for 60-day supply to be Amount permitted for 60-day supply to be considered by Department of Public Health within considered by Department of Public Health within 120-days of the law’s effective date.120-days of the law’s effective date.

How Obtained:How Obtained:Through “Treatment Centers” cultivation/growing by Through “Treatment Centers” cultivation/growing by exceptions for patient and caregivers.exceptions for patient and caregivers.


Massachusetts (cont.)Massachusetts (cont.)

Liability Protections:Liability Protections:Protection for qualifying patients, caregivers, physicians Protection for qualifying patients, caregivers, physicians and health care professionals, and “Dispensary Agents.”and health care professionals, and “Dispensary Agents.”

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Written certificate from doctor/bona fide relationship with Written certificate from doctor/bona fide relationship with the patient and full patient assessment required. the patient and full patient assessment required. Registration card required – issued by the Department of Registration card required – issued by the Department of Public Health.Public Health.


MichiganMichigan

Voter ballot driven legislation.Voter ballot driven legislation.

Applicability:Applicability:Qualified patients and primary caregivers.Qualified patients and primary caregivers.

Quantity Allowed:Quantity Allowed:12 plants in an enclosed, locked facility or 2.5 oz 12 plants in an enclosed, locked facility or 2.5 oz usable Marijuana. Primary caregivers may keep usable Marijuana. Primary caregivers may keep up to 60 plants (12 for each of 5 patients and up to 60 plants (12 for each of 5 patients and 12.5 oz of usable Marijuana in an enclosed, 12.5 oz of usable Marijuana in an enclosed, locked facility).locked facility).

How Obtained:How Obtained:Law does not address.Law does not address.


Michigan (cont.)Michigan (cont.)

Liability Protections:Liability Protections:Qualifying patients and caregivers – not subject to arrest, Qualifying patients and caregivers – not subject to arrest, prosecution or penalization in any manner.prosecution or penalization in any manner.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry Card required and issued through Bureau of Registry Card required and issued through Bureau of Health Services.Health Services.


MontanaMontana

Authority:Authority:A Medical Marijuana initiative vote expanded the A Medical Marijuana initiative vote expanded the restrictions on the use of Medical Marijuana per restrictions on the use of Medical Marijuana per SB0423 on November 6, 2012. Reaffirmed SB0423 SB0423 on November 6, 2012. Reaffirmed SB0423 which was effective July 1, 2011.which was effective July 1, 2011.

Applicability:Applicability:Law applies to physicians, patients and caregiversLaw applies to physicians, patients and caregivers

Quantity Allowed:Quantity Allowed:Less than or equal to 6 plants and/or 1oz of usable Less than or equal to 6 plants and/or 1oz of usable marijuana.marijuana.

How Obtained:How Obtained:Qualifying patient may grow Marijuana or designate a Qualifying patient may grow Marijuana or designate a provider (limited to three patients).provider (limited to three patients).


Montana (cont.)Montana (cont.)

Liability Protections:Liability Protections:Qualifying patients and caregivers – not subject to arrest, Qualifying patients and caregivers – not subject to arrest, prosecution or penalization in any manner (this section requires prosecution or penalization in any manner (this section requires review and interpretation relative to new qualifying patients). review and interpretation relative to new qualifying patients). Marijuana growers may not accept anything of value in exchange Marijuana growers may not accept anything of value in exchange for services and products. Local governments authorized to for services and products. Local governments authorized to regulate Marijuana providers.regulate Marijuana providers.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry Card required. Patient must have written documentation Registry Card required. Patient must have written documentation from physician. Patients and physicians must register with the from physician. Patients and physicians must register with the Montana Department of Health. Registration must be renewed Montana Department of Health. Registration must be renewed annually.annually.

NOTE: Confusing law – requires additional review and NOTE: Confusing law – requires additional review and study.study.


NevadaNevada

Nev. Rev. Stat. Section 453A (Supp. 2001)Nev. Rev. Stat. Section 453A (Supp. 2001)

Applicability:Applicability:Law applies to physicians, patients and caregivers.Law applies to physicians, patients and caregivers.

Quantity Allowed:Quantity Allowed:Less than or equal to 1oz of usable Marijuana or 3 Less than or equal to 1oz of usable Marijuana or 3 mature or 4 immature plants.mature or 4 immature plants.

How Obtained:How Obtained:Growing is permitted through Department of Growing is permitted through Department of Agriculture – may also grow to provide and Agriculture – may also grow to provide and establish a seed bank.establish a seed bank.


Nevada (cont.)Nevada (cont.)

Liability Protections:Liability Protections:Physicians: Physicians: protected from criminal prosecution when protected from criminal prosecution when recommending Marijuana for medical use – written recommending Marijuana for medical use – written documentation required.documentation required.Patients and Caregivers: Patients and Caregivers: have a affirmative defense if physician have a affirmative defense if physician diagnosed and advised use of Medical Marijuana, explained the diagnosed and advised use of Medical Marijuana, explained the risks and benefits to patient and if within quantity permitted by risks and benefits to patient and if within quantity permitted by statute.statute.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Written documentation from physician and Registry Card Written documentation from physician and Registry Card required.required.

Physicians and patients must register with the Department of Physicians and patients must register with the Department of Agriculture. Documentation from attending physician must be Agriculture. Documentation from attending physician must be updated annually.updated annually.


New HampshireNew Hampshire

New Hampshire HB492: An Act relative to the legalization and regulation of marijuana – Regulations expected for marijuana distribution by October 1, 2013

Applicability:Legalization for personal use by persons 21 or older.

Quantity Allowed: Up to one ounce legal

How Obtained: State Licensed and Taxed distribution system.


New Hampshire (cont.)New Hampshire (cont.)

Liability Protections: Liability Protections: Protections similar to alcohol and regulated similar to Protections similar to alcohol and regulated similar to alcoholalcohol

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Licensing of marijuana wholesale, retail, cultivation. And Licensing of marijuana wholesale, retail, cultivation. And testing facilities. Associated taxation requirements testing facilities. Associated taxation requirements authorized relative to sale of marijuanaauthorized relative to sale of marijuanaSpecial provisions relative to employers, driving Special provisions relative to employers, driving Employers, Driving, Minors, and Control of PropertyEmployers, Driving, Minors, and Control of Property


New JerseyNew JerseyN.J.S.A. 24:61N.J.S.A. 24:61

The New Jersey Medical Marijuana Law was signed into law The New Jersey Medical Marijuana Law was signed into law in January of 2010. the Department of Health and Senior in January of 2010. the Department of Health and Senior Services has established a process to register qualified Services has established a process to register qualified patients, caregivers, and alternative treatment centers and patients, caregivers, and alternative treatment centers and has begun to approve alternative treatment centers.has begun to approve alternative treatment centers.

Updates are available from:Updates are available from:

The Department of Health and Senior ServicesThe Department of Health and Senior Services(600) 292-7837 and by checking:(600) 292-7837 and by checking:

http://www.state.nj.us/health/medicalmarijuana/http://www.state.nj.us/health/medicalmarijuana/Retrieved October 25, 2012Retrieved October 25, 2012


New Jersey (cont.)New Jersey (cont.)

Applicability:Applicability:Law applies to physicians, primary caregivers, and those Law applies to physicians, primary caregivers, and those authorized to produce Marijuana for medical purposes.authorized to produce Marijuana for medical purposes.

Quantity Allowed:Quantity Allowed:90-day supply of usable Marijuana.90-day supply of usable Marijuana.

How Obtained:How Obtained:New type of pharmacy – called alternative treatment centers – New type of pharmacy – called alternative treatment centers – centers starting to open.centers starting to open.


New Jersey (cont.)New Jersey (cont.)

Liability Protections:Liability Protections:Protection from arrest, prosecution, property forfeiture, and Protection from arrest, prosecution, property forfeiture, and criminal and other penalties for patients, physicians, primary criminal and other penalties for patients, physicians, primary caregivers, and those who are authorized to produce Medical caregivers, and those who are authorized to produce Medical Marijuana for medical purposes.Marijuana for medical purposes.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry Identification cards will be issued by the Department of Registry Identification cards will be issued by the Department of Health and Human Services which will identify a person as a Health and Human Services which will identify a person as a registered qualifying patient or a primary caregiver.registered qualifying patient or a primary caregiver.


New MexicoNew Mexico

Senate Substitute for Senate Bill 523 Effective July 1, Senate Substitute for Senate Bill 523 Effective July 1, 20072007

Applicability:Applicability:Law applies to physicians, patients and caregivers and Law applies to physicians, patients and caregivers and licensed producers.licensed producers.

Quantity Allowed:Quantity Allowed:66oz of usable medical cannabis is allowed at any oz of usable medical cannabis is allowed at any given time.given time.

How Obtained:How Obtained:Department of Health licensed producers.Department of Health licensed producers.


New Mexico (cont.)New Mexico (cont.)

Liability Protections:Liability Protections:Physicians and Licensed Producers: Physicians and Licensed Producers: not subject to arrest, not subject to arrest, prosecution, criminal or other penalties or property forfeiture.prosecution, criminal or other penalties or property forfeiture.Patients and Caregivers:Patients and Caregivers: not subject to arrest, prosecution, not subject to arrest, prosecution, criminal or other penalties or property forfeiture.criminal or other penalties or property forfeiture.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry ID card required. Written certification from practitioner, Registry ID card required. Written certification from practitioner, registered with Department of Health and renewed annually.registered with Department of Health and renewed annually.

Program Information and details available at:Program Information and details available at:

http://www.health.state.nm.us/idb/medical_cannabis.shtmlhttp://www.health.state.nm.us/idb/medical_cannabis.shtmlRetrieved October 25, 2012.Retrieved October 25, 2012.


OregonOregon

OR. Rev. Stat. Sections 475.300 to .346 (2003 & Supp. OR. Rev. Stat. Sections 475.300 to .346 (2003 & Supp. 2004)2004)

Applicability:Applicability:Law applies to patients and caregivers.Law applies to patients and caregivers.

Quantity Allowed:Quantity Allowed:Less than or equal to 1oz of usable Marijuana or 3 Less than or equal to 1oz of usable Marijuana or 3 mature or 4 immature plants.mature or 4 immature plants.



Oregon (cont.)Oregon (cont.)

Liability Protections:Liability Protections:Patients and CaregiversPatients and Caregivers – have an affirmative defense if – have an affirmative defense if physician diagnosed and advised use of Medical Marijuana, physician diagnosed and advised use of Medical Marijuana, explained the risks and benefits to patient and if within quantity explained the risks and benefits to patient and if within quantity permitted by statute.permitted by statute.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Written documentation from physician and Registry Card Written documentation from physician and Registry Card required. Patients and caregivers must be registered with Oregon required. Patients and caregivers must be registered with Oregon Department of Human Resources, Health Division. Department of Human Resources, Health Division. Documentation from attending physician must be updated Documentation from attending physician must be updated annually.annually.


Rhode IslandRhode Island

2005 H.B. 6052, RI GEN. LAWS Section 2005 H.B. 6052, RI GEN. LAWS Section 21-28.621-28.6

Applicability:Applicability:Law applies to physicians, patients and Law applies to physicians, patients and caregivers.caregivers.

Quantity Allowed:Quantity Allowed:12 plants and/or 2.5oz of usable 12 plants and/or 2.5oz of usable Marijuana.Marijuana.

How Obtained:How Obtained:Not specified.Not specified.


Rhode Island (cont.)Rhode Island (cont.)

Liability Protections:Liability Protections:Patients and Caregivers -- Patients and Caregivers -- not subject to arrest, not subject to arrest, prosecution, criminal or other penalties and property prosecution, criminal or other penalties and property forfeiture. No school, employer or landlord may refuse to forfeiture. No school, employer or landlord may refuse to enroll, employ or lease, or otherwise penalize solely for enroll, employ or lease, or otherwise penalize solely for his/her status as a registered, qualified patient or his/her status as a registered, qualified patient or registered primary caregiver.registered primary caregiver.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registry card required. Written certification from Registry card required. Written certification from practitioner registered with Department of Health practitioner registered with Department of Health required and must be renewed annually.required and must be renewed annually.


VermontVermont

VT. Stat. Ann. Tit. 18, Sections 4472-4474 (2004)VT. Stat. Ann. Tit. 18, Sections 4472-4474 (2004)

Applicability:Applicability:Law applies to physicians, patients and caregivers.Law applies to physicians, patients and caregivers.

Quantity Allowed:Quantity Allowed:Less than or equal to 1 mature or 2 immature plants or Less than or equal to 1 mature or 2 immature plants or 2oz of usable Marijuana.2oz of usable Marijuana.



Vermont (cont.)Vermont (cont.)

Liability Protections:Liability Protections:Physicians, Patients and CaregiversPhysicians, Patients and Caregivers – have an affirmative – have an affirmative defense if physician advised use of Medical Marijuana if within defense if physician advised use of Medical Marijuana if within quantity permitted by statute. State level criminal penalties on quantity permitted by statute. State level criminal penalties on use, possession and cultivation of Marijuana by patients use, possession and cultivation of Marijuana by patients removed effective July 1, 2007.removed effective July 1, 2007.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Written documentation from physician and Registry Card with Written documentation from physician and Registry Card with photo required. Patients and Caregivers must be registered with photo required. Patients and Caregivers must be registered with Vermont Department of Public Safety (Three Physician Review Vermont Department of Public Safety (Three Physician Review Board involved in issuance process).Board involved in issuance process).


WashingtonWashington

Wash. Rev. Code Ann. Section 69.51A (Supp. Wash. Rev. Code Ann. Section 69.51A (Supp. 2003)2003)

Applicability:Applicability:Law applies to physicians, patients and Law applies to physicians, patients and caregivers.caregivers.

Quantity Allowed:Quantity Allowed:No more than a 60-day supply.No more than a 60-day supply.

How Obtained:How Obtained:Not specified in statute.Not specified in statute.


Washington (cont.)Washington (cont.)

Liability Protections:Liability Protections:Physicians and Patients have an affirmative defense if Physicians and Patients have an affirmative defense if diagnosed, physician advised use of Medical Marijuana diagnosed, physician advised use of Medical Marijuana and patient and licensed physician (M.D.) are Washington and patient and licensed physician (M.D.) are Washington residents.residents.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:None, but documentation of use is required.None, but documentation of use is required.


District of ColumbiaDistrict of Columbia

D.C. Law 13-315; 57 DCR 3360 as AmendedD.C. Law 13-315; 57 DCR 3360 as Amended

Applicability:Applicability:Physicians, patients and caregivers.Physicians, patients and caregivers.

Quantity Allowed:Quantity Allowed:Maximum amount is 2oz of dried Marijuana. Maximum amount is 2oz of dried Marijuana. Mayor has authority to change quantity through Mayor has authority to change quantity through rulemaking.rulemaking.

How Obtained:How Obtained:From “Cultivation Centers” as defined in the From “Cultivation Centers” as defined in the statute.statute.


District of Columbia District of Columbia (cont.)(cont.)

Liability Protections:Liability Protections:Protections from sanctions for physicians, patients and Protections from sanctions for physicians, patients and their caregivers, otherwise not specified.their caregivers, otherwise not specified.

Statutory Requirements for Authorized Use:Statutory Requirements for Authorized Use:Registration with the Mayor pursuant to statutory Registration with the Mayor pursuant to statutory requirements.requirements.


Federal Law v. State LawFederal Law v. State Law

Federal Law and theses state Federal Law and theses state laws conflict due to Federal Law laws conflict due to Federal Law and Policy – especially 21 United and Policy – especially 21 United States Code Section 812 (b)(1) States Code Section 812 (b)(1) Schedule I c (17) prohibiting Schedule I c (17) prohibiting tetrahydrocannabinoids.tetrahydrocannabinoids.

Medical Marijuana is not a Medical Marijuana is not a legitimate medical explanation legitimate medical explanation under DOT although Marinol is.under DOT although Marinol is.


DOT’s Position – October 22, 2009:DOT’s Position – October 22, 2009:

The Department of The Department of Transportation’s Drug and Transportation’s Drug and Alcohol Testing Regulation – 49 Alcohol Testing Regulation – 49 CFR Part 40, at 40.151(e) – CFR Part 40, at 40.151(e) – does not authorize “medical does not authorize “medical marijuana” under a state law marijuana” under a state law to be a valid medical to be a valid medical explanation for a explanation for a transportation employee’s transportation employee’s positive drug test result.positive drug test result.

-- -- Jim L. Swart, Director Office of the Secretary Jim L. Swart, Director Office of the Secretary of Transportation, Office of Policy and of Transportation, Office of Policy and Compliance, Department of TransportationCompliance, Department of Transportation


DOT’s Position – December 3, DOT’s Position – December 3, 2012:2012:

Recently, some states passed Recently, some states passed initiatives to permit use of marijuana initiatives to permit use of marijuana for so-called “recreational” purposes. for so-called “recreational” purposes. We want to make it perfectly clear We want to make it perfectly clear that the state initiatives will have no that the state initiatives will have no bearing on the Department of bearing on the Department of Transportation’s regulated drug Transportation’s regulated drug testing program. The Department of testing program. The Department of Transportation’s Drug and Alcohol Transportation’s Drug and Alcohol Testing Regulation – 49 CFR Part 40 – Testing Regulation – 49 CFR Part 40 – does not authorize the use of does not authorize the use of Schedule I drugs, including Schedule I drugs, including marijuana, for any reason.marijuana, for any reason. -- -- Jim L. Swart, Director Office of the Secretary Jim L. Swart, Director Office of the Secretary of Transportation, Office of Policy and of Transportation, Office of Policy and Compliance, Department of TransportationCompliance, Department of Transportation


Marijuana:Marijuana:Marijuana is Classified as a Schedule I Drug by the DEAMarijuana is Classified as a Schedule I Drug by the DEADrugs are classified as Schedule I Drugs if:Drugs are classified as Schedule I Drugs if:

(A) The drug or other substance has a high potential (A) The drug or other substance has a high potential for for abuse.abuse.

(B) The drug or other substance has no currently (B) The drug or other substance has no currently accepted medical use in treatment in the United States.accepted medical use in treatment in the United States.

(C) There is a lack of accepted safety for use of the (C) There is a lack of accepted safety for use of the drug drug or other substance under medical supervision.or other substance under medical supervision.

Smoked Marijuana v. Dronabinol/Marionol v. SativexSmoked Marijuana v. Dronabinol/Marionol v. SativexNOTE: No drugs administered by smoking have been approved by the FDANOTE: No drugs administered by smoking have been approved by the FDA


Medical Marijuana Case LawMedical Marijuana Case Law

Gonzales v. Raich 545 U.S. 1 (2005)Gonzales v. Raich 545 U.S. 1 (2005)

Roe v. Teletech Customer Care Management, Roe v. Teletech Customer Care Management, 060607 WAWDC, C07-5149 RBL (W.D. Wash. 2007) 060607 WAWDC, C07-5149 RBL (W.D. Wash. 2007)

Ross v. Ragingwire Telecommunications, Inc., Ross v. Ragingwire Telecommunications, Inc., 42 Cal. 442 Cal. 4thth 920, S138130 (Sup Ct. Cal 2008) 920, S138130 (Sup Ct. Cal 2008)

Johnson v. Columbia Falls Aluminum Co., LLC, 033109 MTSC, DA 08-0358 (MT Sup Ct 2009)Johnson v. Columbia Falls Aluminum Co., LLC, 033109 MTSC, DA 08-0358 (MT Sup Ct 2009)

Emerald Steel Fabricators, Inc. v. Bureau of Labor and Industries, 348 Or. 159 (Or. 2010) Emerald Steel Fabricators, Inc. v. Bureau of Labor and Industries, 348 Or. 159 (Or. 2010)

Beinor v. Industrial Claim Appeals Office of Colorado (Ct of Appeals of CO, 7Beinor v. Industrial Claim Appeals Office of Colorado (Ct of Appeals of CO, 7 thth Div.) (CO. 2011) Div.) (CO. 2011)

Casias v. Wal-Mart Stores, Inc., 764 F. Supp. @d 914 (W.D. Mich. 2011)Casias v. Wal-Mart Stores, Inc., 764 F. Supp. @d 914 (W.D. Mich. 2011)

Coats v. Dish Network LLC, (CO Ct Appeals April 25, 2013) Coats v. Dish Network LLC, (CO Ct Appeals April 25, 2013)




2.2. Adopt a pre-duty prescription medication Adopt a pre-duty prescription medication and impairing effects substances safety and impairing effects substances safety policy;policy;





•Requires employees working in safety-sensitive classification to pre-duty disclose that they have taken an impairing effect prescription or other substance;•Define safety-sensitive and list job classifications if possible; •Make it part of the employer’s safety policy;•Employee does not have to disclose drug or medical condition to comply with policy;

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Step 2: Adopt A Pre-duty Prescription Step 2: Adopt A Pre-duty Prescription Medication And Impairing Effects Medication And Impairing Effects Substance Safety PolicySubstance Safety Policy

•Once disclosed, employer reserves right to send employee for fitness-for-duty evaluation with copy of job description;•Encourages employees to first provide their own physician a copy of their job description and make a fitness-for-duty determination; and•Employer reserves right to make final fitness-for-duty determination, maybe using Medical Review Office (MRO).


Step 3: Update Employee Job Step 3: Update Employee Job DescriptionsDescriptions

•Every job description to be in Every job description to be in compliance with the Americans compliance with the Americans with Disability Act (ADA) should with Disability Act (ADA) should list “Essential Job Functions.”list “Essential Job Functions.”

•If the employee works in a If the employee works in a safety-sensitive job category, one safety-sensitive job category, one of the essential functions listed of the essential functions listed should be “the ability to work in a should be “the ability to work in a constant state of alertness and in constant state of alertness and in a safe manner.”a safe manner.”

•Educate yourself on the Educate yourself on the workplace related impairing workplace related impairing effects of Marijuana.effects of Marijuana.


Step 3: Update Employee Job Step 3: Update Employee Job Descriptions (cont)Descriptions (cont)

•Decreased cognitive reasoningDecreased cognitive reasoning•Decreased motor coordinationDecreased motor coordination•Inability to concentrate or remain focused Inability to concentrate or remain focused on a single thought or ideaon a single thought or idea•Increased drowsiness, fatigue and lethargyIncreased drowsiness, fatigue and lethargy

Workplace Related Impairing Effects of Marijuana Include:Workplace Related Impairing Effects of Marijuana Include:

•Inability to accurately gauge Inability to accurately gauge lengths of time and distance as lengths of time and distance as well as impairment of hearing and well as impairment of hearing and vision and short term memory vision and short term memory •Inability to cope with sudden Inability to cope with sudden changes in surrounding and/or changes in surrounding and/or emergency situationsemergency situations•Loss of balance Loss of balance •Visual and/or auditory Visual and/or auditory hallucinationshallucinations•Non-caring, uncommitted, Non-caring, uncommitted, unconcerned attitudeunconcerned attitude


Step 3: Update Employee Job Step 3: Update Employee Job Descriptions (cont)Descriptions (cont)Workplace Related Impairing Effects of Marijuana Include:Workplace Related Impairing Effects of Marijuana Include:Marijuana: Causes an inability to concentrate or remain focused on a Marijuana: Causes an inability to concentrate or remain focused on a single thought or idea. Increased drowsiness, fatigue and lethargy. single thought or idea. Increased drowsiness, fatigue and lethargy. Inability to accurately gauge lengths of time and distance as well as Inability to accurately gauge lengths of time and distance as well as impairment of hearing and vision and short term memory. Inability to impairment of hearing and vision and short term memory. Inability to cope with sudden changes in surrounding and/or emergency situations. cope with sudden changes in surrounding and/or emergency situations. Loss of balance. Visual and/or auditory hallucinations. Non-caring, Loss of balance. Visual and/or auditory hallucinations. Non-caring, uncommitted, unconcerned attitude. C. B. Thuss, Jr., M.D., MRO SAPAA uncommitted, unconcerned attitude. C. B. Thuss, Jr., M.D., MRO SAPAA Board MemberBoard Member


Step 4: Adopt an ADA Compliant Step 4: Adopt an ADA Compliant Handbook Policy on Reasonable Handbook Policy on Reasonable AccommodationAccommodation

•State in your pre-duty prescription State in your pre-duty prescription medication and impairing effects medication and impairing effects disclosure policy that you do not disclosure policy that you do not accommodate the use of medical or accommodate the use of medical or recreational Marijuana by safety-recreational Marijuana by safety-sensitive employees;sensitive employees;•Having ADA reasonable Having ADA reasonable accommodation handbook language accommodation handbook language that discusses the typical interactive that discusses the typical interactive steps is a good risk reduction practice;steps is a good risk reduction practice;•The linchpin of the ADA is an The linchpin of the ADA is an individualized assessments based on individualized assessments based on essential job duties; andessential job duties; and•Suggest use of consulting Suggest use of consulting MRO/Occupational Physician to guide MRO/Occupational Physician to guide you through the ADA reasonable you through the ADA reasonable accommodation dance steps.accommodation dance steps.


Step 5: Let Employees Know Your Step 5: Let Employees Know Your Stance on Medical and Recreational Stance on Medical and Recreational Marijuana UseMarijuana Use

•Include clear information about the Employer’s position on Medical Marijuana in its Drug and Include clear information about the Employer’s position on Medical Marijuana in its Drug and Alcohol Testing Policy.Alcohol Testing Policy.•In your employee awareness session, go through the workplace related impairing effects of In your employee awareness session, go through the workplace related impairing effects of Marijuana.Marijuana.•Make it all about safety.Make it all about safety.•Watch the state laws carefully and do not take adverse action or impose disciplinary consequences Watch the state laws carefully and do not take adverse action or impose disciplinary consequences against an employee or applicant that makes a Medical Marijuana claim without consulting against an employee or applicant that makes a Medical Marijuana claim without consulting knowledgeable legal counsel.knowledgeable legal counsel.•Treat medical and recreational Marijuana like any other impairing effect prescription medication or Treat medical and recreational Marijuana like any other impairing effect prescription medication or substance.substance.


Five Action Plan Puzzle PiecesFive Action Plan Puzzle Pieces

The issues surrounding medical and recreational Marijuana use The issues surrounding medical and recreational Marijuana use are complex and will continue to “grow.” Fitting together the are complex and will continue to “grow.” Fitting together the following puzzle pieces now will keep your business from “going following puzzle pieces now will keep your business from “going up in smoke.”up in smoke.”

““If it wasn’t for marijuana there wouldn’t be any pot”If it wasn’t for marijuana there wouldn’t be any pot”


5 Action Plan Puzzle Pieces5 Action Plan Puzzle Pieces

1.1. Adopt a pre-duty prescription Adopt a pre-duty prescription medication and impairing effects medication and impairing effects substances safety policy;substances safety policy;

2.2. Update employee job descriptionsUpdate employee job descriptions

3.3. Adopt an ADA complaint handbook Adopt an ADA complaint handbook policy on reasonable accommodation;policy on reasonable accommodation;

4.4. Let employees know your stance on Let employees know your stance on medical and recreational Marijuana medical and recreational Marijuana use; anduse; and

5.5. Adopt a state specific legally Adopt a state specific legally compliant Drug-Free Workplace Policy compliant Drug-Free Workplace Policy and Forms which cover medical and and Forms which cover medical and recreational marijuana.recreational marijuana.


Success:Success:Because you can own this Because you can own this

face of pure accomplishmentface of pure accomplishment


Future for “Up in Smoke”Future for “Up in Smoke”

You're not hallucinating (but they are)... You're not hallucinating (but they are)... It's the legendary tokers jokers Cheech & It's the legendary tokers jokers Cheech & Chong as you've never seen them before Chong as you've never seen them before -- in their very first Animated Movie. -- in their very first Animated Movie.

•10 States with Pending Legislation to Legalize Medical Marijuana

(as of Apr. 3, 2013)•Alabama

•Florida

•Illinois Illinois •Iowa

•Kansas•Kentucky•Missouri

•New HampshireNew Hampshire•New York

•West Virginia


Contact Information and Contact Information and QuestionsQuestions

Josephine Elizabeth Kenney, J.D., MBA – Human ResourcesJosephine Elizabeth Kenney, J.D., MBA – Human ResourcesSenior Compliance CounselSenior Compliance CounselFirst AdvantageFirst [email protected]@fadv.com

Thomas (Tommy) M. Eden, III AttorneyThomas (Tommy) M. Eden, III AttorneyConstangy, Brooks & Smith, LLPConstangy, Brooks & Smith, LLPManagement Labor and Employment Law FirmManagement Labor and Employment Law Firm““The Employers’ Law Firm Since 1946The Employers’ Law Firm Since 1946www.Constangy.com www.Constangy.com Email: [email protected] : 205-222-8030

medical marijuana: 5 steps to successfully walking the workplace tightrope tommy eden, partner...

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