 and we'll go ahead and get started hopefully Ashley is able to join us at some point during our conversation but we do have Carrie and Ingrid here so Tom I'll turn it over for you to kick us off. Sure I call the compliance and enforcement advisory subcommittee meeting to order. We have Carrie, Ingrid, Kyle, any other board members in the room? That's it Julie's watching okay from a distance though so probably take her name down then we've got division our department of liquor and lottery is here in the room and then we've got two members of the public right now. Great and we also have from the NACB Mark Gorman, Junior Crannwinkel, Danika Scott, we've got our form we're all set to go. All right well thanks everybody happy Monday last Thursday I thought we had a really good presentation and conversation from the Department of Liquor and Lottery Brandon is here I think to answer questions of anybody I think we were we were rushed at the end of the meeting last Thursday a lot of information to get in and a very quick amount of time Department of Liquor and Lottery again good presentation I think they have a lot of capabilities that they could bring to this industry to help us on retail enforcement there's a couple other perspectives and options that the board could and should consider when it comes to retail enforcement before we arrive at any decision I've asked Kerry and Dave through Kerry to kind of give us a a quick overview of the experience that the agency of agriculture has from a retail enforcement perspective we're working with them or hoping to work with them through an outdoor and indoor cultivation inspection enforcement perspective so I thought it was prudent to hear how how you might round out that trifecta that's the decision that the subcommittee and the board chooses to go in so I'll turn it over to you Kerry and Dave and then provide an opportunity for questions from the subcommittee members and those hi Ashley glad you're able to join us and everybody else on the call and then Jen Flanagan is here she's with VS strategies you're on the strategy side of VS correct Jen I want to make sure I get that right and now I'm on the law firm side law firm side former regulator at the cannabis control commission in Massachusetts who is going to give us some thoughts and perspectives on on how Massachusetts brought a lot of her enforcement team in-house and then after that Jen and Tom are going to help us dissect this word security and what that means as an umbrella term in this industry and all the different types of issues as it relates to security in my head it means everything from securing an outdoor cultivation site to you know cash management etc so on and so forth and how this subcommittee might be able to start gaining some steam and some traction on what that word means for this industry in Vermont so with that kind of table setting I'll turn it over to Kerry all right well thanks Kyle and in terms of retail inspections that is pretty much the bread and butter what the agency does from a consumer protection perspective whether that's health and safety on the meat and milk side we we do the commodities that are grown here in Vermont that don't fall under the health department so meat milk eggs apples maple all that is inspected on the health and safety side but we're also in in every retail establish establishment in some other way whether that's checking scales or scanners or products themselves the pesticide feed seed and fertilizer inspectors checked to make sure products are registered to be sold in the state we're in facilities inspecting anything from cream machines to make sure they're sanitary to package weights and all that enforcement is in-house in the agency that's very brief and we can go in depth on any one of those do you have anything to add to that Dave and we went through the enforcement process which is administrative law yeah no I don't have too much to add from that introduction there Kerry aside from it is a is a really good I think approach and to enforcement and to regulation um with the agency of agriculture does employ a little biased but it does seem to work and it has worked across a broad spectrum of industries and other regulated entities from gas pumps to dollar general so scanners scales products packages weights cord wood you know all of those things that um all the consumer protection anything that has a sort of consumer protection piece where we're there to sort of deal with that um the only thing that's similar to what liquor and lottery does in terms of making some making sure somebody is licensed or registered is the pesticide program you can't buy restricted use pesticide without being licensed so we do check licenses the class a dealers are required to maintain a copy of everybody's license that they sold a restricted use pesticide to but it's not the sting operation though the tobacco sales issues that that they've been tackling so similar but but distinctly different it's mostly consumer protection not ensuring that somebody's not getting a hold of something it should well now it's a very quick overview ingrid Ashley from a from an ag retail enforcement perspective any questions for Kerry and Dave I guess my question is you know maybe this whole this whole span broader conversation you know at the retail enforcement perspective there's going to be a lot of IDs that need to be checked whether through your traditional dispensary security measures that are going to be in practice at a dispensary that's separate from more sting operations that that we heard about from the Department of Liquor and Lottery and Brandon if I've made any mistakes feel free to sure interrupt me just curious if the agency has any you know similar experience with how they check you know obviously not I'm trying to think of a way not IDs per say but license checks you know a more broad sense of what a license is but but I'm trying to help the committee envision what you would need not on the resource perspective we can get there but but what kind of training would your staff need on certain aspects of stuff that other agencies you know do it certain from certain perspectives to to ensure consumer protection here well I think we're not necessarily consumer protection like we usually use the term but the only thing similar is the fact that any class A restricted use pesticide need to be sold to somebody with a license and it is similar to the dispensaries if you walk into a dispensary in Colorado they take your license and take a picture of it same in Canada they take your license and take a picture of it so that is similar to what we do what you need a copy of the applicator's license and a and a record of that sale so basically what we're doing when we go to those facilities is reviewing records it's not alive and it's not a live sort of assessment and similar to what liquor liquor and lottery does with alcohol and tobacco sales that where the cashier has an opportunity with card or not this is ours is out of that you need to present that license the transaction needs to be recorded and those records are kept for three years and where and need to be made available to us and annually we get records of all our circuit use sales so there's a lot of catches in there for us and it's largely a record keeping piece we haven't sent people in and had them try to buy restricted use pesticides Ashley thinking about the meeting that we had last week from Brendan and talking about using that data collection I I agree with Kerry you know photographing licenses prior to purchasing um is a really great safeguard I also feel like if we are going to do this data collection a really great way to fractionate that data is who's selling to people on you know under the 25 if is that a you know obviously that would be someplace probably like Chittenden County where there's a lot more college kids but I mean that would be then a trigger for okay perhaps that's going to be an area that we're going to survey more because we know that there's more people of a certain age bracket that are purchasing but I feel like what's in place with liquor and lottery I mean I feel like the two could really marry each other well if we're going to be recording everybody's license and their age I think anyway I'm trying to pull what we talked about last time into today and use our limited resources of what we have established already with ag which I again think is a really effective way to um do the seed to sale so I don't know if anybody has any thoughts on that Kerry any thoughts no just a minor anecdote I my youngest daughter is 25 born on a leap year though and when she presented her ID in Burlington at a bar they didn't believe her that anybody could be born on February 29th if you waited there while they called the number there's a number apparently that you can call and it's a lifetime check of ID and that's a tool that I think liquor and lottery has in place so if you're photographing somebody's ID for a transaction the follow-up I don't know what what service that is or how it's done but that lifetime tracking it is an ID real um is probably a tool that could be employed jay let's see your hand up thank you Kyle I just wanted to piggyback on uh something that Kerry was talking about there um the agency of agriculture does have a quite a rich tradition of licensing in addition to checking for licenses in fact we we license pesticide applicators so for those who are going to be applying pesticides they have to come and take an exam and then they receive a certification from the agency that allows them to go out and apply pesticides on other people's properties so we not only have to verify that the person taking the exam is the person who really is working at that company and also will be receiving that license so it's sort of ingrained in staff not even an affiliation perspective but at the agency of agriculture check IDs anyway uh because we don't want to be giving the wrong credentials to somebody who is going to potentially have uh you know a pesticide is an economic poison it's how it's defined we want to make sure that ends up in the correct person's hands so even from the get go with the agency it's checking identification on top of that there's certified applicator record checks so anybody who is going to be a licensed applicator is going to and this is where Kerry was heading uh is going to also have to be inspected to make sure that their record keeping is up to date and so once again the agency's field agents will be going out and taking a look and making sure that the applicators are utilizing their licenses appropriately thanks Dave yeah and I was thinking as you were talking the only thing similar that we regulate similar to a controlled substance is are those restricted use products everything all our other retail inspections are for other things quality um you know we'll candle eggs to make sure they're fresh we'll inspect maple syrup to make sure it's labeled at the right grade and at the right density um all of our other components are really um consumer protection and quality control make making sure that they're right great and uh in addition to that you know while we don't do uh sting operations or undercover operations in the same sense that uh liquor control might do we do have a history of just being the consumer for enforcement cases and purchasing the product that you know city market healthy living doing the same sort of uh techniques that any citizen could potentially do and then we run lab samples and make sure that the products are going to be having that guarantee or making sure that that apple that's being sold as organic actually is organic and is not uh something that is going to be a non-organic sold as an organic and help rewrite the local definition when I was at the agency of acts I know a little bit about how that all works uh Ingrid I see your hands up yeah I think that's a question for new pile um just for clarification I should probably know this already but are we there's room for different entities to be doing different components of enforcement correct like we're not yeah yeah thank you for and I can clarify so you know within within 164 it asked the cannabis control board to to seek out and utilize all existing you know agent of sister agency expertise and I think that kind of gives us a broad charge to explore partnerships with different agencies to make up you know everything from inspection and enforcement to other facets of this program that are outside the the purview of this specific um subcommittee so I see a scenario where the agency of act could help us are you I guess Ingrid to zone in on your question when it comes to retail enforcement are you are you asking could we use both ag and dll for that or okay yeah I think I think if we can figure out a way to cleanly I want to hear if you have an idea on how to cleanly separate out the word or separate out the concept of retail enforcement or what you're what you're thinking I guess I was thinking in the context originally that we could um you know agency of acts using or we're gonna hopefully move in a direction the subcommittee voted on to help with outdoor and indoor cultivation and I haven't tried to parse out retail enforcement inspection in my head but if if we want to do that I'd like to hear what you're thinking I guess I was just thinking in terms of like this consumer protection or quality control type aspect versus you know more of the enforcement and compliance I mean they're obviously interrelated but so far as I'm listening to this it's just different emphases like so like what you're talking about are so like shelf life stability of a product and if it's still safe to sit on that storefront shelf could we utilize the agency of ag there and maybe fall back to dll when it comes to sting or undercover operations or some some combination there is that what you're thinking that initially that's what I'm thinking and also you know things like the pesticide thing and I don't know from beginning to end what it all involves but it's obviously incredibly important and I don't know what you know dll could bring to that that aspect of this but I kind of yeah and I kind of view that issue more on the pesticide dealer that ag already has jurisdiction over and and that application of that pesticide which agriculture would help us from outdoor cultivation and indoor cultivation perspective but I certainly could see the expertise that ag might have when it comes to what that product looks like from a consumer protection perspective on a shelf and how long that product should be on the shelf before it it no longer is is viable for consumers carry I don't know if you want to chime in at all no no you got it and that's sort of I mean I'm falling back on the previous the governor's cannabis control commission report that sort of broke that somewhere at the retail level that the department of liquor and lottery would deal with licensing and they already have the infrastructure to deal with towns and local zoning and illicit sales we took we currently list lists offer all sorts of retail licenses and we inspect those retail facilities but not at the sort of level of criminality and I know like the dairy team goes into some of our medical facilities now to do inspections is that true they have a license with dairy because they're offering butter okay and butter is a dairy product right so they do have a dairy processing license I was just thinking of other perforable ways that the agency of agriculture is already working within this broader market I can see I saw a lot of head shaking when Ingrid kind of proposed that idea seems like that might be a direction that the subcommittee is heading in at least extending retail enforcement to the the product itself to the agency of agriculture and leaving more of the purchaser consumer perspective charging the board to work with DLL to try to come to some type of understanding actually I see your hand up I just wanted to take the opportunity to echo that and I think that that's a really smart approach I think that we've also seen now five years worth of pesticides herbicides heavy metals being tested both on the medical side and also on the hemp side so we know what to look for we know what's common especially you know heavy metals being a big one is the plant the bio accumulator so I think we have a lot to work with as far as how to keep people safe okay on the pesticide herbicide heavy metal side so I think agriculture or ag is definitely equipped for that Tom yeah I agree with with the comments and questions I just wanted to take it back it's the same question I've had throughout this process and the background of it is I mean same question I had what I was trying to ask for enforcement and DLL and the background for my question is from the agency perspective what you're seeing nationwide including with the USDA with their hemp program sorry the questions always because I've spoken with with some USDA representatives and they've pretty frank and honest and said listen we've laid out the program but we do not have the capacity to do the enforcement and the investigation that we're saying is required and so that's what I'm trying to determine when we're talking to these other other agencies so I mean Karen David if you could give me like an idea of you know what your marketer what are you dealing with with now and then my you know my question last week for DLL you know they're able to break it down to yeah each each investigator or agent is dealing with X number of licenses and then I'm trying to envision how is that going to how much more are you going to be stretched when we're asking this particular agency or whatever respective agency to do even more once once adult use comes online does that make sense yeah Kara and I can I can phrase that with you know I think everybody's wanted to see what the size and shape of the market will look like with this October report that the the control board will be giving to the legislature but if you can speak to your capacity now how that might change from a resource perspective once once we all understand and have a little bit more direction I'd rather sort of hold off answering based on I mean we've heard from Lincoln lottery they've got a mandate to inspect every tobacco facility we don't know what the mandate here is is it every facility once a year or is it every grow so are you in that facility every eight weeks or are you in there annually so until we know what the charge is I can't really talk about what level of resource what the level of resource need is okay we have Dave do you know how many class B dealers we have I don't have my computer in front of me not off the top of my head I don't know how many class B dealers there are but you know anybody who's selling off mosquito spray you know is someone who's applying a pesticide and not only that we every retail facility every retail facility is licensed every scanner every gas pump and we have we cover the state with four inspectors but those gas pumps are only inspected once a year yeah and I'm not I'm not and I can I can do some research offline and talk to Tom and and the others offline from a I don't know what other jurisdictions are doing from a retail compliance and enforcement perspective of the product itself not the sting undercover operations to see if a business is conducting itself appropriately from a who's actually buying it but of the product how often you know what's the shelf life typically I know it varies depending on product but it could be months to about a year for for some products what would be a prudent amount of times you would have to visit each retail establishment to make sure that that consumer protection I'm interested not to cut the conversation short but the Massachusetts keeps this in house yeah it's a good segue and I know that there's a lot of decisions that you likely made at the beginning that that and trying to work with your fellow sister agencies in Massachusetts and I know it was some it's my understanding it was some work to get it all in house but if you could kind of you know walk us through why certain decisions were made especially as we consider resources and how much capacity other agencies might have it's going to factor into that cost-benefit analysis with how the board here does certain things so sure the one thing that I will say that is different between Vermont and Massachusetts is that we were not required to work with sister agencies on anything there was a stress of we should collaborate as much as possible and we did that with the Department of Public Health the Department of Public Safety and Security the Department of Agriculture in ways of guidance is public awareness campaigns and other like but when it came to enforcement we as a commission and for those of you that don't know I will I will give you a very small snippet of what it was like in the beginning we were five people in five cubicles with no staff having to create regulations in the span of two and a half three months and so the decisions were created and made by the commissioners we had advisory boards through the campus advisory board each one of those subcommittees presented to us once on what they believe were important to be in the regulations but you have a much more extensive subcommittee advisory board tight process than we did and so the decisions that were in and also by way of background each one of our commissioners had to statutorily have a specific background so we had a public health public safety finance social justice and regulatory commissioner one in each of those areas and I think really what happened was on day one each one of us kind of went into our silos and said all right I'll take the public health issues which is which came into my realm commissioner McBride took the public safety issues commissioner title took the social justice issues commissioner Doyle who had written the medical regulations was a resource to everyone but one of the other obstacles we had is that we had to operate under the open meeting law so everything we did was in public nothing that we did could be behind closed doors which as a former legislator that was my favorite place to be because those were the best negotiations that we ever had so having said that we felt it was important to have enforcement and compliance under our agency the cannabis control commission because we knew that as regulations changed our enforcement team could be brought up to speed as quickly as the regulations were changing they were there in real time when I tell you that our enforcement team is a is amazing we took a wide range of people we had inspectors that came from the gaming community from housing from the food and beverage industry you name it we encourage people to come and apply the commission and so what you have now the cannabis control commission is a number of inspectors that have a wide background and we we capitalized on that they are able to talk they're very mobile they're across the state all the time for in for terms of inspections you're inspected twice before your licensure and then once to twice annually after however if there are deficiencies and the investigations have to happen as to what exactly what compliance or enforcement regulation that you violated then the the the whole process plays out at the commission and so one of my biggest concerns would it would be that if it was not under the cannabis control ward is that now you're piece nailing right so now you have someone who might come from agriculture or someone who might come from alcohol they're they're looking at specific entities others are looking at the other ones what happens to the enforcement if something goes wrong I know that we talk a lot about protection of the consumer we're also protecting the facility we're also protecting the product it's not necessarily all about the consumer because in massachusetts we have a provision in our regulations that says you have to share your security plan with law enforcement so the local fire and police departments know about the layout of your facility what if you're doing extractions what if something goes wrong the fire department has to go in what if you know the security cameras are malfunctioning on the outside of the building you have to have 24-hour recordings that are saved for up to 90 days that law enforcement can ask at any time we do have a secret shopper program and so we can send anybody into any facility on any given day to try to obtain products and when it comes to the IDs in massachusetts we we have to show our IDs multiple times when you're in the dispensary you've got to show it to get into the dispensary and then just as you do in a bar or a club or whatever you can be asked for that ID again at point of sale and so one of the biggest concerns that i had having worked on our gaming legislation and having worked sort of in the alcohol legislation that we had in massachusetts is that just because the technology gets better does that's the way that the fake IDs are happening if you don't look at the person the technology is just really looking to see if they're in a database and so look at we wanted people to look at people just to know that's the person that's trying to enter the facility we don't keep any type of identifying information and so we would we may keep your age and your date of birth and your gender but we're not keeping who you are and where you were at any given time there was a really big concern that people didn't want to be put on a list which is one of the reasons why some people didn't want to be on our medical registry they didn't want to be on a list that was at a state agency that they felt they could be outed and that people would know that they're on the on the list so for us enforcement and compliance really was a big piece of this because in massachusetts the only establishment that are limited our dispensaries so each city in town is allowed a lot of 20% of their liquor licenses to then come in and be cannabis dispensaries we don't limit cultivation we don't limit manufacturing we have a testing license obviously everyone has to have the products tested and we also have a research license and so those aren't even limited in scope so as far as compliance and enforcement really we wanted to we wanted to own it we wanted as a cannabis commission to own it because we understand that unlike agriculture or or liquor we have a lot of obstacles with the federal government given that this is federally legal and so we want to make sure that we kept good records that we were ensuring that this product was you know in the vaults away from the general public you know if you had limited access areas there was only a limited number of people that could get in we do check and inspect all of the IDs for the people who work in the dispensary in any of the establishments because you have to have a vendor registration card so all of that is put into a database that our enforcement team can go and check actually that was amazing first of all thank you for that and how many dispensaries do you currently have in massachusetts oh when i left i don't have the number off top of my head i can get it on the website we have an open platform database in massachusetts on our cannabis control website but ballpark i want to save me a hundred i i wouldn't know i know that when we started in 2018 they sort of came fast and various we also had medical who changed to do both and so they were operating in one building but not everyone has not every city in town has maxed out the number of dispensaries that they're allotted and we as a commission made the decision that if you're a small town and you have two liquor licenses we'll give you the one dispensary or if you have three liquor licenses we'll give you one we really didn't we have a mandate in our statute that we can't exclude by zoning and so we didn't want to exclude because a small town doesn't have the capacity to have a large number of licenses our liquor licenses are at the local level and the cannabis licenses are at the state level Jen Jen do you do you also know how many growers and processors there are oh no not at the top of my head no no not even close no i guess question is wrong do you register or track those at the commission oh everyone's track everyone that gets a license from the cannabis control commission is tracked yeah i they all whether you're a micro business craft cultivator small business to the hundred thousand square foot indoor grows that we have everybody is tracked okay and so for outside when you talk outside cultivation which i know vermont really wants to to prioritize outdoor cultivation the one concern i would say is that you're very limited because of we live in no england and our climate isn't the same as it is out west but you have to have secure facilities you have to have fencing around this there needs to be um video cameras um one thing because it's federally illegal if you have children minors that are working on your farms they cannot work on that part of the farm so if they're under 21 they're not allowed to be on that land no one under 21 and allowed in the dispensaries unless they're a medical patient with their caregiver until you're 18 that you're allowed to be your own caregiver i will tell you that we also have a provision in our um regulations which i really think we were trying to be pro small business is that if you can't conform to the regulations that we've established then you need to come up with an alternative plan ask for the waiver and also talk to the local law enforcement um so if if you think you can't afford what we're making you do or you can't do what we are asking you to do then you can tell us that there's an alternative that is just as safe and you have to prove it and again the the process is to not only protect the public but to protect the product is to protect the business because at the end of the day in massachusetts and i'm assuming the same is going to happen in brahmine you have to reconcile the scraps compared to the planet that you're using that weight has to be reconciled everything has to be accounted for at the end of the day we also have a provision in our regs that if you don't sell up to 85 percent of your product in the six months preceding your renewal will drop you down a tier you don't get to keep the same tier because we don't want the extra product out there not being sold Jen i think i think you hit a um well it's i want to be cognizant of the time it's 238 i imagine we might have some or 239 i imagine we might have some some public comment but maybe i wanted to just say one or two things and then maybe we can move into how we can best start attacking a lot of the concerns that you just raised when it comes to security um around a lot of facets of this program and how we might start being able to attack that in small small chunks on starting on on thursday um but quickly i wanted to say you know i think it might be in the best um it might be best for the board long term to try and bring as much stuff as we can in house as possible just for a lot of the concerns that you raised you know in the short term i think it's it's challenging um because we would have to go to the legislature to request more positions and we need regulations ahead of you know hopefully by what Thanksgiving looking at David and we can't go to the legislature until january plus you know the way everything is supposed to work out we need to pay the operating expenses of the board with fees collected on licensing so the more positions we create the more expensive licenses could get so you know there's a lot of things to weigh and consider as we look to make relationships with other state agencies it might not be the cleanest um for the board um but we can install hopefully some safeguards to make sure that it doesn't take away from any consumer safety or protection um you know facets of what we're trying to do ashley i just wanted to ask quickly i really appreciate how flexible and nimble your crew is can you just walk through what like a typical enforcement would be like for instance like i'm not sure if delta eight is illegal in mass but like once something as quickly as the legislation just changed for something like that after it's already been released to the public like what sort of chain events happen to make sure that those sales are not happening that's hypothetical but so any type of regular type of legislative mandate would go to the cannabis control commission and we have options because our regulatory process is a year long so we wouldn't be able to change the regulations as quickly as we would be able to have the executive director establish a guidance or establish you know a mandate which he did quite frequently during covid i mean we had protocols that were put in place every time something happened last year during covid um even to the extent when the governor shut down the adult use cannabis dispensaries and so we have those type of actions that we can take but when our inspectors go in they're looking at everything from grow rooms to documents to financials to there's a checklist that they have that they're going to go in and look at from there they're allowed to talk to anybody that they want they are even allowed to subpoena at the end if there's really big problems that they see um you might have seen in the news or you can certainly google we've we levied some pretty hefty fines on some of the businesses for certain things that they've done um the one thing that I will say is that because the cannabis control commission in massachusetts did not need legislative approval for anything they we were able we were given the authority to create the to create the agency and set the program we have gone back to the legislature to ask them to do certain things but they have not turned around the delta 8 issue quite frankly that's going to probably be a conversation between the department of agriculture and the cannabis control commission because in massachusetts hemp is controlled by the department of agriculture so determining what happens at a federal level because i don't think the state has taken that on yet um or my former colleagues in the house and senate there can that's can be another one of the collaborations that we have right so for instance when i say we've had collaborations um we had an o u i commission and we had to look at operating under the influence it was a 15 person commission we collaborated with the department of public safety and security the executive office we have mandated public awareness campaigns i personally headed up that for the ccc we collaborated with the department of public health substance abuse portion of that so we've had collaborations i know that the department of agriculture worked very closely with commissioner former commissioner doile on the environmental side because she had a lot of environmental work that she did in the beginning um but those grew naturally from things we had to learn like there was we had no playbook quite frankly as commissioners we called everybody else in legal states and said would you do wrong so that we don't do it again um but i will tell you that the one misconception a lot of people have is that once the regs are in place they'll never be changed we we had to set our regs by christmas of 2017 for the next two years we went into two rounds of reg changes right so for three years we were changing regular we were creating and changing regulations because we didn't know what we didn't know when we got appointed so the the clean canvas control board in vermont is going to set their regulation there's nothing to say that's going to be set in stone for five years right if they find a problem i assume they have the authority to go in and change those rights later ashley uh if you wouldn't mind asking your question if it's if it's quick just because i want to be cognizant of of our time um thank you and it's just a quick anecdotal um you talked about collaborating with the local police force to protect the facilities we are insured and to be insured we needed an extensive security system um of which fortunately i'm actually the only one who's set it off a handful of time and um we have created a really lovely partnership with our local police officer like for that um getting here quickly making sure we're all safe making sure that it's not put into a stigmatized category or not showing up at all because they feel like they don't need to show up for a cbd company but um i just really love that collaborative spirit and i just want to echo that sentiment that that sounds really wonderful and it sounds like the best way to move forward here to utilize all these wonderful programs that we have in place for vermont all right well well recognizing that that the model massachusetts launched might be this perfect model for vermont recognizing it might not be practical for us at this point in time at least it sounded like that we were building to a consensus where the agency of agriculture could help us on the retail end of things from a product perspective but the department of liquor and lottery um we should the board should work with them um from a consumer protection perspective when it comes to um licenses so on and so forth and i can get some more specific language written up for our next meeting but i just want to make sure that that seemed to be a consensus that the that the whole subcommittee um would find a prudent direction for the board to pursue so i think one way that you could you could make that work and marry sort of the agencies is that if there is a specific training to the cannabis regulations once they happen right then it might be easier for the inspectors from ag and liquor to go in and look for what you're asking them to look for because absolutely your regulations could be very different than what they're what they're used to i don't think we're intending if through partnerships to put everybody out on an island i think we would still try and maintain some continuity um in-house and making sure that people are talking with each other and sharing information um maybe we can we can plan to vote on that first thing thursday if i can get some language written um that might make sense for how we decided to parse this retail enforcement um i'm fine with that kind of but um you know in the end we answered the same boss um at the top the agency of ag and the agency or the department of liquor and lottery and the presentation i heard was they're busy they're strapped and they have very limited resources already so before i support kind of want to hear if it's something that they're willing um yeah okay you can reach out once once more um because we we did hear what they can do but i don't want to support something that they're not willing to do okay that's all okay well maybe i mean considering that it might be you want to see the market structure analysis before you vote on this is that what you're saying or just hear from liquor and lottery um i know a previous uh deputy commissioner was enthusiastic um and i don't know what the temperature is at the department of liquor and lottery at the moment could i ask you and skylar to to give us your recognizing we got to do a lot of resource understanding of what might make sense but speak on thursday briefly if it's something that you have the capacity yeah i can get with skylar and see if we can come i mean i think our overall stance is that we are would be super supportive of of what you all are talking about at this point where we would break it up a bit between ag and us and that um you know i think he had some skylar had some conversations with you and and james about you know that we would want to see the number of licenses and stuff like that before we could come here to the same you know how many extra people we might need or if we would need any extra people and that kind of thing so okay yeah i can that's all i just didn't want to support something that a sister agency was not willing no absolutely i don't want to i don't want to volunteer anybody to step into the quagmire with me unless they're fully willing to go there um great well we can make some progress on this thursday i'm very hopeful for that um we've got only a couple minutes jen and tom i'm thinking what might make sense with our few remaining minutes is start to unpack this security word what make what would make sense for the the subcommittee to talk about on thursday as a starting point recognizing we're going to start writing regulations over the course of the next two months and we've got to get licenses out in a certain order where should we start from a security perspective to inform those regulations i think you need to really start thinking about what physical things that these establishments are going to have to do if you're talking outdoor growth do you want fences around it with you know locked fences with cameras do you want motion-censored lights do you want i mean start to think about how you see these facilities um would you be willing to perspective would you be willing to on thursday talk about outdoor cultivation and security and indoor cultivation and security if in what what happened in massachusetts and and tom and mark if you might be willing to do a broad scan of of regs and other states and jurisdictions and we can start to unpack a little bit about um what that looks like elsewhere and what might make sense for vermont i think that might be a good way to progress on thursday after we kind of hopefully can get some some buy-in and support from our sister and partner agencies on the retail enforcement end of things check thank you all right it's 251 comments hi it's dave solverman um so last week there was this great article in leafley about burner licenses in in california and scott me started to think about security in a different way uh these are licenses these are like the equivalent of vermont would be the wholesale license where they had product coming in from legal growers but then they were leaking it out to largely out of state uh parallel markets um and they were they were doing this by sort of just like losing cannabis off the books um and turned out that the state california didn't really have any sense in their seat to sail tracking system of of just how much cannabis a particular wholesaler could store uh so on the books they had you know so one of these licensees had you know hundreds of thousands of pounds of cannabis in in in their uh in in their like 300 square foot office uh with a safe that held you know 30 pounds max um and so it just occurred to me is as you're thinking about uh security regulations it would be nice uh if licensees who were going to store cannabis on their premises um you know would report to you not only on how much they take in and out but uh how much uh realistically they can securely hold in their compliant facility so you know if you you know have them report to you like you know the size of their product safe or something like that and that way you could actually use the seat to sail tracking system to you know automate some processes uh to see when things seem to be leaking um I think that would be a useful security tool uh I don't mean to get a little maybe deeper into this than than you might be ready to but uh you know it might be more interesting a more effective way to ensure security than just kind of layering on more cameras more fences and things like that that you know will just add a lot of cost and might not necessarily um you know protect anyone so thanks thank you Dave Nick any comments any further comments going once going twice okay well we're we're running somehow ahead of schedule Dave I see your hands up actually your hand is still up I don't know if it's still up or a new uh but we do have a couple minutes to continue um Dave I want you to start and then Ashley thank you Kyle uh and Jen thank you very much for your presentation and and all those uh questions and uh your answers that you provided I have one more question though would you be able to answer Tom's question that he had posed originally to me and Kerry about how many folks you have investigating inspecting the type of resources that are necessary to run this I assume that you did a market analysis on your own and that's where you wound up with doing things internally we did not do a market analysis we we've grown in four years um in fact the commission has just put on another cohort if you call them other inspectors and so we've we've been continuing to hire for four years we started off I want to say with uh we were in our makeshift offices there might have been six of them and I want to say now there's over 20 of them that are at the inspection uh an enforcement department we have an enforcement chief though we have someone who is the chief of the enforcement department we have an attorney who's the assistant chief and then all the enforcement officers and inspectors come under them so it's its own department sort of siloed from other things and there's a pretty big firewall between the enforcement department and the rest of the departments at the CCC given the sensitive nature of what they do and and and things like that um we honestly we're not sure what what it was going to look like in Massachusetts and quite frankly when we were appointed on September 1st of 2017 we literally put pen to paper and heads down and started to create we didn't have time to do any of the analysis that Vermont is doing um we didn't have a process that we reported to anyone we literally I want to say in terms of finances we received I want to say two to three rounds of supplemental funding from the legislature before we got to the next fiscal year budget and that literally was because we had to find office space we had to hire people and and what have you created an agency the resources that they have they have cars they have um I want to call them tough computers that they use I think you often see them in police cars as well in cruisers they have those they have now all the PPE that they need to go in and inspect anything there's a training process that they go through with the ccc the details of which I couldn't tell you and so they are their own entity they they do their own thing and it really it came about as the market got bigger we knew we had to hire and we had the budget to do so so they are all state employees of the commonwealth while they work for the ccc they're all state employees um they are made to be completely mobile if they have to but they do have workstations at the cannabis control commission in wister massachusetts uh their cars are tracked there's gps in their cars there's what have you we do not have a state police component like the the alcohol and beverage commission does in massachusetts so there is no law enforcement um that's part of the there's former law enforcement that might be working there but there's no law enforcement contingency to it thank you jan ashley i just wanted to see how much i appreciated dave's public comment um i saw that article as well and i think that we are maybe a little bit a few steps away from really honing on on that particular issue um i just don't want to gloss over it so i want to make sure that we all uh read that article i'm happy to share and circulate it with all of you and take that particular aspect of things into consideration because i don't know that we all think that way um about product leaking and how are we going to like would we weigh it would we then weigh it again and i don't know jan to put you on the spot that's something that you guys read or have considered or if you've had any issues with you like i said you have to reconcile everything at every point all of it is documented so the cannabis control commission can see it at any given time um when it goes from a cultivator to where it's going it's all tracked when it goes from the dispensary out it's tracked um as part of our seed to sale tracking we know at any given time where anything is so i will say that we have pretty tight control over what happens in massachusetts um and the goal was so that if anyone had a question law enforcement you know the legislature the ages anybody then we could go back and collect the data um to have that information for any given department um but the one thing that i will say and i know that you probably all know this is a subcommittee the board the commissioners have a very difficult job in the fact that while you have multiple subcommittees going on sort of simultaneously but on their own they're going to reconcile all of this at the same time so as they're thinking of enforcement they're thinking of the market if they're thinking of you know public safety consumer protection they have a pretty hefty job as they're listening to what's going on the subcommittees to be doing sort of in the back of their head trying to put some words to paper and get these regulations done it'll be very difficult to meet deadlines if it's being done in pockets thank you gen for making my monday a lot more you know feel like a monday no i'm just kidding that was our four that was our three and a half months when we got to the commission yeah absolutely um well thank you everybody i think we'll we'll come on thursday um hopefully with getting some more direction on retail enforcement and um and starting to crack this knot of of security and what that means here so appreciate everybody's time thank you gen for joining us i'm looking forward to having you um helping guide us um with your experience in massachusetts on this committee and and i'll take a motion to adjourn the meeting today all motion to adjourn second all right thanks everybody 259