 We get started here. My name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is February 14th, 2022. And I will call this being order. So the big news today really is that we are announcing that we will be opening our pre qualification intent to apply process in 30 days. We're doing that 30 day notice today. So for everyone watching, you can do the pre qualification process starting March 16th. We're going to roll out much more information on this within the next 30 days. We do have some information up on our website. And Nellie will be kind of communicating with people through our website over the phone and on our social media in the coming weeks about the kind of nuts and bolts of pre qualification. Just a few just quick overview or high points though, that getting pre approved really is not a license to operate. It's an initial approval by the board that your business, including all of your investors that you submit to the board during the pre approval process have been clear that they don't have anything in their criminal history record or in their other kind of ownership interest that would disqualify them from being a licensee. So our rules do not require anyone to get pre approved prior to applying for a full license. This is a voluntary process that we created as a board to help facilitate the licensing process for both the board and for perspective licensees. We think that there are benefits to the pre approval process. First, of course, is that you can know that you are not disqualified from being a licensee for any reason. And earlier you know this the better before you make any sort of investments or before you sign any leases, you know, getting pre approved is probably a good idea. So we've also heard that because this is such a new industry that many towns and financial institutions and insurance companies, et cetera, really want to see something, some approval by the board that you know your business could operate in this one. You could, you know, you're somewhere in the process of getting a license. So there's another benefit to getting pre approved. And then this essentially splits the application process into two steps, meaning that your final application process will necessarily be shorter and the board can review it much more quickly because we're really just kind of filling in the parts of the application that we haven't looked at during the pre approval process. So just to reiterate this process is voluntary. It's not required. If you want to wait until the full application window for your specific license type opens, of course, that's your prerogative. This pre qualification process is something that we created because it helps the board with some of the more time consuming aspects of the application process. And we think that there actually are genuine benefits to prospective applicants. But everyone who's thinking about this should really take a close look at the guidance that we put out and what's in our rules to make sure that this makes sense for you as a business. Anything that anyone would like to add on the pre approval process at this point noting that we will have guidance on our website. I don't think so. Very exciting. Okay, so again, this is the announcement of the beginning of the 30 day notice window. So the actual date is March 16. So we also last week had our second social equity and economic empowerment networking event. Julie, would you mind just kind of updating us on how that went? Yeah, we had somewhere between 40 and 44 people that came in and out throughout the event. The chat is always very active, which is great. People connect there. And we have been, I've been sharing with Nellie any contact information that's shared in that chat. And then she emailed it out to all of the registered participants. So there's a, you know, people are sharing resources. That's a way that we're sort of sharing those back out so that people can have those in their inboxes. We had Cheryl Murray Powell speak who she's an attorney, but she's also a hemp farmer. She has an extensive resume. I won't go all over it now, but and she's agreed to share her PowerPoint slide. So we'll have those. We also had Reginald Stanfield from Justin, just incredible cultivation in Massachusetts who, you know, very nicely after Cheryl sort of talked about, you know, how to set up a business plan, talked about what his direct experience was like as did Ashley Reynolds, who is one of our advisory community members talked about what her kind of local experience setting up a plan was like, and shared a lot of her like, if somebody had told me what to do, this is what would have been nice to know from the get-go. So I think it was really helpful for folks. There was a lot of conversation about insurance and banking. So if perhaps that's our next round, I think that would be really helpful. And there were some resources I think that we'll be able to leverage that were shared there. So I think that is pretty much everything from that session. Thanks for doing that. Yeah, they are, I should say this, they are intended to be all online right now. We have had one person show up in person at the last each of them, which is fine or has been fine because there's been somebody here, but if one of us wanted to do this from home, there would be no one here to let them in. So they are intended to be entirely remote. That's great. Thanks for doing that. I think it adds a lot of value for sure. And we're trying to do them once every two weeks. So the next one I think would be the 24th of February. Okay. This reminder also that rules three and four are in their official comment period, which runs, I believe, through February 25th. David, is that? That's right. Yeah. February 25th is the official close of the comment window for rules three and four. Please, if you have an opportunity, please read through them and send us your thoughts, your comments, anything that you think the board needs to hear about rules three and four, we will be holding our public hearing for rules three and four this Friday at 11 a.m. So other than that, just need to approve the minutes. Julie Kyle, you had a chance to review them from February 7th. Yes. All right. I take a motion to approve. Tim? Seconded. All in favor? Aye. Aye. Okay. And then moving to the agenda, today we're really again trying to fill out our rules with the guidance document and so we're kind of taking it one issue at a time and trying to kind of make sure that what we're saying in the rules is clear and that people have a way to kind of follow what they all mean. And so we're going to start today with looking at our safety information flyer. Again, this is a document that's required by law to be handed out at the point of sale or at least offered at the point of sale to kind of really supplement the health warning. You know, not a lot can fit on a tiny little health warning. And so this is designed to kind of give people some additional information. So Julie, I'll turn things over to you on this. Yeah, I don't have a document to share just yet because I think this is one of those things that needs to be added through a variety of different entities and people including Department of Health. So I'll just share the process that I'm working through. So I went through, you know, our rules. I went through what's in the law. I went through what we talked about in the Public Health Subcommittee and what I proposed related to this back in October created some words to go along with that and share them with the prevention community to kind of get a sense of, because I was trying to look for people who had a good sense of like how to communicate information in a way that that people would be receptive to and easy to find on the document and so forth. So I'm getting some feedback from the prevention community on that. When it's a little bit more put together, I'll share it with the Department of Health and get their feedback as well to do that conversation with them and also probably circle around with our Public Health Subcommittees to just get some of their thoughts as well. So that's kind of the process that I'm working through this week. Just some high points on it. We did, you know, in my conversations with the prevention community, it really is intended to be written for folks who've already decided that they're intended to purchase or consume. So it's not meant to, you know, shame someone who has made a purchase and also to make some safety information clear. Like once you get cannabis home and you have children in the home where you place it, what are the recommended things to do and that sort of thing. Yeah. I mean, the importance of this document needs to be vetted. So, you know, just, I think that's a good strategy. Okay. Next is the inhalable additives. So I did put together a little but you're a little Valentine. Oh, you got that. Well done. So I'm not going to full screen X. It makes it tough to use my notes because I have notes, but I think everyone can see that fine. Okay. So just anyone thought we had kind of made it through all the difficult issues. This one certainly can get tricky quickly. Okay. So here, just a reminder of what we said in rule. This is from rule two, 2.6.4 additives. So the first sub A is really about oral or edibles, you know, additives for ingestible, orally ingestible items. The B and C really apply to, well, C applies everything, but C is really about additives for products that are intended for inhalation. So we said that we would maintain an improved ingredient list. They'll be ready available to the public. Not positive that that's the best approach, but we'll see. So just wanted to pull up quickly what, you know, you saw in sub C that manufacturers shall buy by any prohibition contained in 868A4. So that here's 868A4. So this is the prohibitive product section of the law. And just jumping down to four, sub four, flavored oil cannabis products sold pre-pagasus reuse battery power devices and any cannabis flower that contains flavors, characterizing flavor that's not naturally occurring in cannabis. So that's just an general overlay for all cannabis products, including oils. And that includes products that are sold for medical use or just the adult use? This is just adult use. So just some general background. So additives for vape cartridges. I'm mostly thinking about vape cartridges here. They're usually flavorings or these, you know, are intended to kind of mimic the flavors and effects of certain cannabis cultivars, like, you know, Blue Dream or Oji Kush or something like that. Or dilutants. Dilutants are used for a variety of reasons. You know, two of the kind of common ones really are to kind of, I guess, water down in oil so it's not so thick and it helps kind of with the process of heating it up. It kind of overcomes some of the hardware limitations in certain types of vaping devices. And then also, you know, it helps to increase profit margins. And so additives can be derived from natural sources or produced synthetically. Natural flavor usually indicates cannabis or other plant derived, but it can also mean kind of any natural source. He used animal, animal byproducts or fermentation. Artificial just means it's not natural. It's a synthetically produced flavor. There's another distinction that starts to come in just in the kind of vape world. Just either it's a cannabis-derived additive or non-canabis-derived additive. And just the kind of common dilutants, MCTPG, PEG, those are all acronyms. I don't have what they stand for right now. You know, just as a general point, Oregon, after the Evoli scare really did a deep dive into all of their vaping products. And they just, one statistic of many in this report that they recently released is that over 50% of the additives in their vape products that are on their shelves right now have both natural and artificial additives. So a huge number of them use both. So prior to the Evoli or Voli, kind of there's roughly 3,000 hospitalizations and almost 70 deaths. Very few states regulated additives. They had very general types of warnings like, you know, cannot be a known carcinogen or something along those lines are very general, but that was the kind of limit of what they said in their rules around additives. And really, it comes from the fact there are no reliable studies on the effects, especially the long-term effects of inhaled additives. There's plenty of food additives. There's starting to be more about smoked additives, but it's really this process of kind of heating up and then impaling that there's very few long-term studies that have been done. Usually, you know, they come after a major event like the Evoli. And even then, you know, vitamin E acetate was really kind of the main suspected cause of the kind of voli symptoms, but the CDC is not willing to say that it was conclusively vitamin E acetate. It was vitamin E acetate was fine and kind of 94% of the ones that they tested, but so are a list of other things. And then another complicating factor to trying to, you know, regulate additives is that the vast majority of additives are produced by companies like third-party companies like flavorhouses that are not regulated by any government entity to provide products meant for inhalation. You know, they're essentially creating food additives and all the regulations are designed around flavors that are legal to ingest, but not inhaled. So, you know, you're buying this, you know, this serum of flavor in bulk and you're not, you know, everyone's saying that it's safe for food, but it's not safe for vapes, but everyone's kind of just tiptoeing around that. And then a lot of these flavorhouses, these companies protect the ingredients. They say that they're trade secrets, even from regulators in, you know, even cannabis regulators. They're not disclosing what's in that concentration. And then again, I mentioned they really, you know, I hate to say they're hiding behind this, but they're saying things that are actually accurate, but they know that, you know, they're selling these tinctures, these kind of flavor additives or vape cartridges, but they're labeling them saying that they're FDA approved, or they're RAS approved, you know, generally recognized as safe. But that does not mean safe for inhalation. And the FDA is very clear on that. So that just makes things a little bit complicated. As I mentioned, post-Jewali or volley, a number of states began to really take this issue seriously around vape cartridges and what's in them. And there's a number of strategies that are starting to emerge as kind of best practices around the country or in the legal states. First strategy is to ban the ingredients that are starting to be known as at least causing short term or acute safety risks. Top of the list, vitamin E acetate, MCT oil is one of the dilutans and the PEGs and other dilutans that we looked at. So Oregon also prohibited squalene, which is a terpenes, and it's actually found in cannabis plants. So, you know, you'd think that you could just say only naturally occurring terpenes, or even go a step further, only cannabis derived terpenes. However, they're finding that even squalene and squalene, which is a hydrogenated version, is toxic when inhaled. So, you know, it's not just as simple as kind of like, well, let's just stick to the kind of cannabis derived terpenes. Washington has banned synthetic terpene additives, you know, allowing only terpenes from the cannabis plant or other molecular identical to terpenes. Other states require labeling and a product manufacturing process or a pre-approval process. And then Nevada says that any additives need to be less than 10% of the whole product, the whole package. So just for a point of context, terpenes naturally occur at about 6% in the cannabis plant. So that's kind of in somewhat of a natural ceiling or an average ceiling about how much terpenes are kind of in flower. And yet, a lot of vape products in totally unregulated states have greater than 40% of the terpenes and other additives put in. And so Nevada kind of said, you know, we don't know if there's a negative health effect of having 40% or greater terpenes ratio, but you know, for now, let's limit it to 10%. So this is kind of the one basic strategy, our best practice. Two is having a product ingredient packaging pre-approval process. We are pushing for this. Currently, as we all know, we have a product registration fee, where we will kind of require people that are creating new vape cartridges to kind of put them before the board, let us know what's in them, review, have us review the ingredients, see if there are known public health or consumer safety concerns, and then also take a look to make sure that all the labeling and packaging reflects those. Four states, and I think this is soon to be five or six, require ingredient disclosures in their track and trace system. I know all the major kind of, the big track and trace systems have kind of a drop down menu now for product manufacturers to enter specifically their additives, and it really helps for kind of product recalls. So strategy three is kind of a related point, ensure that your track and trace systems have the capabilities to quickly recall products that present consumer safety risks. I think what happened in Massachusetts as a governor, I think called the state of emergency and put a stop sale on all vape cartridges, but this could be more along, this could be a more targeted approach. If we find that some specific diluting is causing hospitalizations that you don't have to kind of take the broad approach, you can really just limit it to the products that have that ingredient as one of their, I want that additive as one of their ingredients. And then, I mean, this is just another related point. Just don't let companies hide behind trade secrets. You can have a confidential reporting to the board of trade secrets. It's not a public document if we want to go that route. But essentially just we need to know what's in these things. And then finally, just, you know, this is about ensuring that the actual vaping device is not kind of leaching heavy metals into the cartridge or into, you know, or arming people. Again, there's a number of states that have these strategies, you know, it's hard to really know the best language to use on this, but there are some kind of suggested strategies in this. Just inert materials, coil doesn't touch the vaping liquid, temperature controls. So those are four strategies that we can think about. I thought what would be good also just because, you know, one of the complications here is that it's really hard when you have literally thousands of products on the shelves to go back and change the rules for people. You know, you essentially, it's hard to kind of after the fact recall, you know, hundreds and hundreds of products. So I thought it might be beneficial for us to look at New Jersey, which has not fully come online yet, but they, you know, they wrote their rules post-Evoli with this concern very much in mind, and they did it, you know, they wrote their rules, you know, obviously before products are on the shelves. So they kind of have a very comprehensive approach, I feel like. It might be instructive for us. They have a list of banned substances, which you can see, which is part of the strategy that's kind of being adopted. Then they also link to any ingredient that's on this FDA, potentially harmful for tobacco and tobacco smoke. So again, it's not a perfect corollary between cigarettes. And this is not e-liquids. This is not like tobacco vapes. This is things that are banned from cigarettes. And it's a list of probably about 30 substances that have been, you know, deemed harmful or potentially harmful. And, you know, whether we can pull it up and take a look, but it seems to me that that's a pretty common sense approach. I noticed that they didn't include MCT in their ban list, you know? So it might be... Where is it in that? Is it in the sort of catch-all number? It's probably in the catch-all. I think that's one that's pretty universally noted to be potentially harmful. I included this. This is about active ingredients that, you know, cannabis intended for inhalation and vaporization have to be cannabis-derived or botanically-derived terpenes. So this is essentially saying they have to be natural. And some kind of oils and fats, like animal oils and fats, would be excluded. And then they also have this kind of 10% rule. No, you know, the additives cannot exceed 10% of the product. And then finally, there's a waiver provision, which kind of allows for new additives to be approved by the board. But they really kind of shift the onus to the product manufacturer to say that you have evidence that this is safe, essentially, or not harmful. So, you know, it's kind of... They have a catch-all in there, too, which is great. So that's the end of the presentation. There's no, like, conclusions in this. I thought it would be just good primer for us to start thinking about which approaches we want to adopt, you know, whether we want to have kind of a prohibited list or we want to have an approved list. It's really... Those types of questions are kind of, you know, ones that we're going to have to settle, but it's probably worth taking some time and thinking about this. I'm just looking at some of the reports that are starting to now to be published from people states. Oregon, I mentioned, just did a really comprehensive review. Massachusetts has a research team that I'm sure has done something on this. I'm not sure. Colorado has a whole kind of medical committee that's looking at additives. So that's probably good for us to do, to not decide anything here today, but to really kind of recognize this tricky subject and evolving subject and that, you know, there are strategies out there. So, good. Thank you. All right. Okay. So just a little bit of background. So we did say in our role that we would put a lot of testing parameters and action limits into a guidance document, board policy, what have you. And the reason for that is it allows the board to be a little bit more nimble and flexible. Should we, you know, kind of related to what you're talking about? Should we need to respond to a public health issue? Something isn't working. Testing is too onerous. You know, a lot of this was created to kind of allow us to move quicker than the regulatory process can sometimes move on its own. And another, you know, by way of background right here, we have microbiological parameters and limits, metal parameters and limits, pesticide parameters and limits and residual solvent parameters and limits. Potency is not in here. Obviously, that's in statute. So it's not, it's referenced to in our rules, but it lives and breathes and, you know, by the letter of the law in statute. And then moisture isn't really here. Don't necessarily expect that to change or for us to respond as readily for moisture content purposes and what we set those specific levels at. So, you know, this comes 100% from my notes and reviewing the lab subcommittee from our advisory committee's discussions on certain very interesting points and issues that were developed over the course of the fall. A lot of this comes already from the pesticide program at VAFM, also what the current HEM program has done from a residual solvent perspective and a metal parameter and limit perspective. Dr. Han, I'm sure everybody here remembers our friend Dr. Han. He's a renowned expert in microbiological testing, and these were his suggestions. And even in talking with him a little bit further, trying to understand these action limits because I am not a chemist and I do not work in a laboratory. You know, I think we're trying to balance what is the appropriate public health level for us to really be looking at things that versus, you know, is this practical in effect? Will plants continuously fail some of these parameters? Will labs be able to, with certain instruments, be able to test to a certain degree? For lack of a better phrase, I'm sure I'm getting some terminology wrong. So that being said, you know, this is kind of where the committee shook out. I did run this by Kerry. I'd like to send it to the VAIL lab, the Vermont Ag and Environmental Lab to make sure they fully understand things. But this was pretty much, had already been kind of vetted out, and I think we just decided as a board when we were looking at forming our proposed rules to take all of this information and put it into guidance versus putting it in our rules. So this has not changed at all, even dating back to November when we were first making those considerations. It's great. Yeah. And so just again, just for my clarity here, we put this into guidance so that we can change it. We can add to it. We can subtract from it. We could change the action levels because based on whatever the new science is. Yeah. And David keep correct me if I'm wrong, but I believe there is kind of a trigger in our rules where if we are going to change something, we'll give 90 days notice. So everybody has clarity that action levels are changing. I'm sure that there's some exemptions to that if we need to respond to a specific incident or something like that accordingly. But we won't be looking to change these like the stock market fluctuates, so to speak. So they'll be static until we see the need to change them. Okay. And I do have one more document that I have been working on. This one kind of kind of in line with Julie's first presentation. This is still a very much a work in progress, and I'll try and blow this up a little bit. But this is a lot of the waste language that the sustainability committee settled on. And what you're seeing here is the star of a guidance document that will get way more specific over time. I'm still needing to run a lot of the way that this fits together from a puzzle piecing perspective with the ANR DEC Solid Waste Program in the Agency of Agriculture. We're still in this kind of weird go-between between this not being a farm product but a plant and DEC having control because it's not technically farming. So one of the things that we did kind of settle on in that committee when we did hear from folks in the Solid Waste Program is that DEC would look to consider cannabis to be what they call leaf and yard residual material meaning it can be composted just like all other vegetative content in the state. And there is some triggers in there where if a compost hauler is not willing to take it you can then dispose of it via landfill. But I think what we're trying to do here is provide some type of comfortability to composters that they're not hauling high THC cannabis around the state that could result in other public safety concerns for the composting company but also allowing certain exemptions recognizing that not every part of the cannabis plant can result in THC being activated without being decarboxed live and stuff like that. So we did have some language in our role saying that cannabis or cannabis products must be rendered unusable and unrecognizable for disposal. A lot of that has to do with again the comfortability of certain composters to take it. Other states have required that it be mixed with almost every other state honestly has required that it be mixed with 50 percent organic material. That's going to be an option here the sustainability committee kind of and Jacob had presented that that was something that was found in the early stages of Colorado and like Washington's programs that turns out to be more of a waste generator than people actively digging through certain compost facilities, landfills to try and smoke some flower that's been already disposed of. But it still could be an option. That being said what the sustainability committee wanted to do was provide an exemption for rendering something unusable and unrecognizable depending on the plant the part of the plant that it is. So root balls, the growing media that you're growing this plant out of you know depending on your grow style thoughts of the cannabis plants and leaves and branches removed from and I should say cannabis. I'm going to make sure we sorry enough to myself. Leaves and branches removed from cannabis clones seeding seedlings and other I'll just fix that one later and other cannabis plants and then there is some language in here that even if you do have flower and it tests below 0.3 percent THC meaning it's you know it could be considered hemp even if you weren't I'm sure if you're you're meeting under that threshold and you're growing high THC cannabis plants you've got the wrong seeds first of all that's such a low percentage of THC but that flower does not need to be unrecognizable and unusable and that's just providing some clarity to folks that might be looking to grow hemp and high THC cannabis as part of their diversified operation. So there are some methods that we're going to put in here around rendering it unusable and unrecognizable again this does not mean that it needs to be mixed with 50 percent again it's a huge waste generator to do that because then a company might need to bring on food waste in order to mix it and you know I mean I don't I think what we're trying to do is continuously improve our waste streams. You can mix it with paper waste cardboard waste food waste grease and other compostable oil waste I have heard that some composters that pick up this material around the country this is their least preferred way to do this so we can have a discussion if it belongs here maybe we take it off just for the sake of clarity. The bakashi and I've actually done a little research into this it's almost like you know putting cannabis into a fermentation tank or barrel and it kind of through like anaerobic digestion processes kind of looks to break down that way I don't think it's used very often but you know other states have allowed it as an option to render something unusable and unrecognizable soil sawdust manure I think the other things that we want to allow are on site composting if you have the ability to do this yourself at your site that's awesome. A lot of folks do that and have contacts right now anaerobic digestion I don't know how familiar everybody is with that term but that's allowing it to break down with the absence of oxygen. There's a lot of other kind of circular economy concepts that can really take root from that digested process whether it's agricultural inputs you can form some biogas you can use the heat and power this takes a lot of more complicated processes that you can really do on farm but maybe you know some other industries that are already doing some of these practices in state will look and want to take some of this bio content and really use it for their own operations. I wrote or burning you know I know I know the agency of agriculture wants or the hemp program needs to burn stuff depending on its THC content sometimes I think I think we had talked about this it's just allowing it as a very low cost option for getting rid of some of your cannabis waste. I realizing into biochar essentially this is special ovens that essentially turn into charcoal and it can be used as you know soil amendments for your next cannabis grow and biomass gasification that's almost like another step in a certain sense in the anaerobic digestion context and I mean if somebody has the tech to take this and look to make a fuel source out of it that sounds great to me I don't think it'll be like a commercially viable you know option but hey people are good at taking taking oils and and figuring out a way to make use of them. So those are just options again to render it unusable and unrecognizable they're in talking with compost companies some might want you to have some type of mix but we want to make sure that you have a lot of options and you don't need to call a compost company depending on the you know the way you choose to really dispose of your non-hazardous cannabis waste meaning you know flour other high THC kind of components of the cannabis plant recognizing that you don't need to do the same thing for you know the other parts of the plant. So hazardous waste so the hazard and this is where I really need to still speak with members at DEC but let's follow Vermont's Department of Environmental Conservation's hazardous waste management program I kind of gave some examples of what would be considered hazardous waste and I can you know there there'll be other non-hazardous and hazardous waste in general buckets so to speak at different parts of the supply chain and we can when I look to finalize this and put some more polish on it give some examples at the manufacturing level what would be non-hazardous and what would be hazardous the wholesale level at the lab level at the retail level we can really dive in this is just kind of the broad parameters of it being disposed of from a public safety perspective one of the one of the things that in my conversations with DEC they still need to create more parameters on and it's not specifically for this but as different vaping alternatives really are present in the state is defective return to expired or non-compliant disposable cannabis bait pens with internal lithium ion batteries they're trying to figure out practical waste stream you know methodologies for ion battery disposal they don't have that completely figured out or they didn't in October and it's another thing that I'm trying to follow up on other than that you know a lot of stuff that has solvent residuals on it will be considered hazardous you know chemical residues that type of stuff so it's really just trying to signal what's non-hazardous in the context of the plant versus all the other extraneous processes that are that are present in delivering you know a consumer or a consumer oriented product that's really where I'm at now it really needs to be vetted through our sister agencies some of our consultants to make sure again the puzzle is fitting together correctly but you know this is kind of the the foundation so to speak right um you might not know the answer but for hazardous waste is there a different standard for farmers versus non-farmers or you know do people that are kind of growing vegetables have to follow the department the DEC hazardous waste management program so I don't know if DEC has any jurisdiction over anything considered farming that being said I would imagine you know that might be taken you know through the some of the pesticides you know there's other again I don't know the clean answer to your question there's a lot of puzzle pieces that just need to fit together because we're straddling multiple agencies that take care of waste and everybody recognizes that we're rocking a hard place so it's just making sure everybody's comfortable with where we land on certain requirements okay that's all I got this is great yeah um all right thank you yeah thank you Kyle um okay well I think that that's probably that covers what we set out to cover today and I know that that was kind of a high level drive by on the on these issues we need to put some final touches on them but again these are very complex issues friend thank you for getting us started on the trickiest ones um so why don't we move to public comment we are well ahead of schedule but I think that we are through the agenda so why don't we move to public comment um we'll start with people that join via the link um and if you join by a link and you'd like to make a comment please just raise your virtual hand um and once uh we get through those comments then we'll move to um the people that have joined via phone all right I'm not seeing any any comments um Evo I just had a comment about the the flavors and the terpenes I I do agree with that like I know I'm I'm sure the point is is to like not have like kids have bubblegum flavored vapes right I mean we don't want to like don't want people to like whatever we're not trying to like advertise to the youth or anything but the way it's worded saying that only terpenes that occur in cannabis really leaves a huge I mean there's so many different terpenes you know there's like a lemon or like a sweet you know bubblegum flavor um it's just going to leave a lot open to like how you how you interpret the rules um I do think it's important not to have those that you know candy flavored vapes and stuff like that necessarily so I just wanted to like make that point um and then you know the PEG and the additives like in my opinion those are those are bad I know there's not enough testing as to like what they really do for your health um but any any like limitations on those I think is a great choice great thank you Evo thanks Evo any other comments from people that joined by the link um if so just go ahead and raise your virtual hands brand yeah a question comes up as to what the uh integrators are being doing with the uh big cartridges that they're using now what they're being allowed to have so I'm curious about that if anybody can answer it but that would be interesting to see how at that parallels what you're doing right now thank you thanks friend um Jesse oh yep there you go honey hello there um my name is actually Shane um but uh I appreciate everything you guys have been doing for sure um in terms of the vapes I think that uh you know I don't I don't know enough about the propylene glycol and the vegetable glycerin and all that I know that like uh someone else just commented you know um a lack of things that we know little about is nothing but good um I don't know the route that should be taken but more so I think that um we have an opportunity to not so much allow just terpenes that exist in marijuana because like it was just discussed there's hundreds of them that yes they exist in marijuana but you can pull them from so many other sources so I think that you know it's a good opportunity to set um the base work for having it just extracted from marijuana right I feel like there's a lot of things going on in the country with um these vape cartridges that are essentially a distillate with zero terpenes from the actual marijuana plant now they have terpenes that mimic them but I think we're at a good place here where we could you know maybe have it be that you have to extract the terpenes from that marijuana um we don't know what the other ones do but I don't I just see it as unnecessary um I don't you know so I think that in the future if we find out those added terpenes are bad for you it's far more likely they're gonna be bad for you than what you're actually pulling from the marijuana plant um and that's about all I think thank you guys thank you and uh I just want to say um this is such a so much progress that um we just had uh someone from the legacy market speak and I've been seeing it more and more as you guys have been having more meetings and the social equity and the way you guys have been holding yourself has been making people feel comfortable to speak I just want to say a good job because I was sitting here listening as usual and my partner was here this time and he was so impressed by you guys the way you were talking about it and then he even wanted to say something and that is uh that's a reflection of you guys because uh when I first met him he would not even go like take a picture with me so anyway you guys are doing so good thank you for your time thank you thank you so um if you if you join via the phone and you like to make a comment um you can hit star six to unmute yourself there's we have two people that I can see that join via the phone I'll just give that a second and of course if anyone joined via the link please just raise your virtual hand um oh thc analytics um yeah so I just want to uh comment on a little thing we came to mind and this is for everybody in the forum we need to get the general public involved in this not only us the ones who are going to be in the market but also the general public because ultimately they're the ones who're gonna end up voting yes or no on anything that we come up with here um so one thing for everybody here in the forum is let your friends your family your neighbors you know know that this is happening Vermont is moving to legalize cannabis and we need to let them know that the meetings are happening to be involved thank you yeah thank you um I would echo that anyone that has networks out there please share the work that we're doing share our rules know that um we have meetings at least weekly um and that uh there's also our rules are being approved in the legislature as we speak um anyone else friend I'd see your hand up again if you wouldn't mind just kind of maybe emailing us so this is in this format we don't do repeat comments um we we will have our um meeting on Friday which is a public hearing where we will allow repeated comments um or feel free to email us um and if I don't give it just one more second anyone who wants to make a comment virtual hand um or hit star six to unmute your phone all right um I guess we'll close the public comment window right now um and I guess before we adjourn just a quick reminder again this morning we announced that in 30 days uh meaning March 16th we will open our pre-qualification application process and that we do have another meeting um on Friday uh to hear public comments on rules three and four so um thank you all for joining thank you Julie and Kyle and uh I will adjourn the meeting thank you my question thank you