 Is that how many new games for serving? Yeah, you're right. I have a wonderful suggestion. I'll be the first to admit, I don't know one of these, and one of the appropriate serving is I just would like to err on a cautionary note, because we've heard, and it makes a lot of sense to me, that edibles are a delayed reaction, and it's easier to overdose if you're taking, you know, you're waiting for that buzz or high or whatever you call it, and have consumed several. So, perhaps Massachusetts went five, perhaps that doesn't mean down the road that the board can't recommend we change it. So, I just, that sounds high. I'm talking medical. I'm in recreational marijuana. Medical comes with all kinds of individual advice. It might be some position or action. I think five makes, Rome wasn't built in the day. I agree with you, but I don't need to talk about five. That's what it says for sure. And a total quantity of 50 or 100 or 500 who knows. Unless you have some kind of reference, it says five milligrams is going to react this way in this amount of time. I don't know that. You may be right, but I probably wouldn't sit down and eat 10 brownies, because it would feel kind of baldy. Would it be that or it should be unpacked? No, he now said. Well, I think about this. Can we want to require something to be on the package? It warns people about eating more than one or something. That's in here. And the 10 is maximum. The board could choose. You guys are setting a feeling there, so the board could choose to go lower if they wanted to. I agree with you, but it's not a product. I think it could quickly come up with the appropriate limitations to what other states and Canada have done with respect to product limitations. Because I hate to jump into this without having enough knowledge and expertise to make the right call as to what the right product limits are. And I think the product limits could vary depending on what the product is. For example, an animal versus a distiller. So for example, Canada has a limit maximum THC concentration for cannabis oil of 30 milligrams of THC per milliliter of oil, and then has another one or 10 milligrams of THC per dose or a minute for any cannabis product intended for ingestion. So I think it's not a simple thing, but I agree that there should be limits. We'll work on that. So next you just talked about page 38, requirements of products are labeled with the date the product was manufactured, the date the product was best used by and the ingredients contained in the product. And then Nelson, you'll see under, sort of, been in the film, came over from the Senate, on line four requirements that they're labeled with information on the length of time typically takes to take effect for both warnings concerning the risk. The requirements are labeled with a standard symbol and you saw that. A product. Consider that, yes, ingredients contained in the product. So somewhere on the product packaging, it's probably already in here on the left. Information about marijuana, kind of, care, concentration, coordination, if you don't operate the vehicle, there may be health risks associated with exception of the product. So if you look at the talks about that there has to be appropriate warnings about potential risks and remember this is just, this is what they're developing rules on. This isn't like the end all be all of everything that is going to be said. This is just direction to the board. You're going to develop rules that have these warnings about the risk, that talk about length of time, you know, educational materials, all of that kind of stuff. So this is just direction to the board. Okay. So again, as that relates to the amount, how many milligrams is what you guys have said in here, is that your adopting rules and the rules shall provide for how the limits on these and they can have no more than 100 milligrams per overall product and no more than five. So they can do anything from zero to ten and zero to 100 with regard to the product. Subdivision F, I think I just highlighted that because on some of these, I think people were wondering about the, around what was there for testing. And so this is just, again, still under the products manufacturer rule. So procedures and standards for testing, campus products for contaminants, public safety and quality assurance and control. I don't think I changed anything of that. I think I was just highlighting it because I think people had raised it before about questioning about whether they felt that there was language in there. So rules competing for retailers, so subdivision four, moving down to page 39. And this is elsewhere on other things having to do with the other licensees but I thought I needed to kind of bring it through is just the retailers that requirements for opaque child resistant packaging of all cannabis and cannabis products that are sold by retailers. Subdivision five on testing labs. Procedures and standards for testing cannabis and cannabis products. So just before the contents of cannabis for contaminants, public safety and quality assurance and control. So the next one is just a couple of technical on suspension and revocation of licenses. I think actually I would like to, also on the next draft, just on the header there, I think I'm going to say it's that civil violations, civil penalty, civil violations, and it could just be for me because I'm usually dealing with the criminal law and civil stuff that goes to judicial bureau. This would be an administrative penalty that they could assess in addition to just one of the things in their toolbox so that they don't have to automatically give a suspension or revocation that they could assess civil penalty. So just clarifying that the board has the ability to suspend or revoke a license of cannabis established for violations and that they have the authority to issue civil citations for violations and the importance of rules adopted for some of the factors. So when you think about all the different places where they, you know, all the rules that they have to adopt, everything that they have to comply with is that they can basically set up a violation schedule. So if you, you know, maybe also an important thing is making sure that they don't sell to anybody who's underage and that they're carting up and getting proper identification. You know, they can have a whole create a whole system there. So if that happens maybe once you get, you know, if you get assessed, you're in violation, you get a certain civil penalty, it happens twice, you can get a, you know, 10-day suspension and you can't sell to the public, whatever it is, and so it will create that and be able to do the internal enforcement there. Something that's related, and I just wanted to mention, I'll tell you if you don't want me to talk about this now, but you had mentioned on the appeals process before what we talked about yesterday about whether or not being, we were concerned whether or not the ability to appeal any decision that somebody felt agreed by the board, you know, might be too broad and so I was trying to think about the things that people might appeal to the board and talk with that demand a little bit about it and I think we feel like it's okay that the language is okay the way it is and people, it's mostly just going to be because of the board's authority is that they're just going to, people are able to appeal, you know, maybe, you know, a suspension or a reputation or a denial of license or maybe, you know, the assessment of a penalty or once the medical program is under there somebody who maybe applies to be on the registry would appeal that but other than that kind of license stuff or somebody's admission onto the registry we don't really see other issues that might come for appeal and so I just kind of raised in the context of this so we kind of thought about it we didn't have much concern about that You said you're going to add language here I'm just going to add, so just in the header instead of saying civil violations I'm just going to say civil penalties Okay, are you going to put a language below could you just refer to violations except in the second sentence in the video where you say show them the full minimum waiver of penalty amounts and that's the first time penalty Yep, I mean, maybe it's I mean, it is technically a civil, I think you know, call it a civil violation of the traffic but just for me, I was just putting it in the header made it seem to me like it was something that is like a generally applicable to capable offensive district judicial bureau and so I was just thinking that it would be better Should we say and be in the board show authority to issue civil citations because the citation could be a suspension Okay, I'm just, because the first time penalty comes up is in the second sentence and be I think it's like Sure Can you give me a brief example of what the difference would be between civil, say, citation and something that would be arguably criminal where public safety would have some co-view I'm assuming That's great So generally, you know, like in so you have your things that are crimes they're divided into misdemeanors and felonies anything that is two years or under is a misdemeanor everything over and through the felonies we don't subdivide So then we used to have traffic traffic work, essentially because we're like, you know, speeding and things like that then a number of years ago the legislature created the judicial bureau which kind of reconfigured what was trafficked for and you started to shift things that were formally criminal into judicial bureau that they would be civil violations so these were things that the legislature decided we don't want people to do these things but we don't think that there should be the potential for jail time or criminal conviction on someone's record and so over the years that list of things that go to judicial bureau has grown very, very long and there's all sorts of things in there and in the context of like marijuana that was when you guys decriminalized possession of an ounce or less in 2013 what you did is you took something that used to be criminal and could potentially result in jail time and would be on somebody's criminal record and you guys made it a civil offense where basically an officer could just hand someone a ticket and say you're in violation of this law the legislature sets up and then there's a waiver penalty that's usually set by the judicial bureau it's like a speeding ticket you can just decide to admit it law enforcement these are more administrative internal agency penalties that would be established so say like if I'm a retailer that's a civil issue I would imagine but let's just say hypothetically that I'm a retailer and I make a sale outside of the establishment to an underage minor I would imagine that would be more of a criminal that's going to fall under your criminal law the bottom page 41 goes to the top of page 42 it's in the definition section that this section because that term is used in multiple places throughout the chapters put it out there so you don't have to do it every time it's in the definition section subsection B I don't know if you remember but the language and the license which is they all use in this context so it's all licensed it should be valid for one year and expire at midnight on the eve of the anniversary of the date the license was issued about the tiers so the board shall develop tiers for cultivator licenses based on plant canopy size or plant count for breeding stock and for retailers for other types of license I've had a change that's going to change so I need to page 44 so this is going to be what's going to be in D is going to be a reference to the appeals process that I already walked you through so that you agree to from the commerce committee you guys have already approved those with regard to the priorities just added the word that's really not so we may I mean there's some indication that we're you know encouraging like small growers but do we need to spell that out because we have this list priorities but it's unclear one of more of those priorities what does that actually need for an applicant I understand your point provided in this legislation that does not mean that the board won't decide how they determine how they're going to issue application you know licenses you know the issue of like if all of applications come in in Chittenden County in collaboration with suggested that change yeah so I mean this is a priorities for who ACCD an ag may work with right we need to we need to change that so that we are talking separately about the business and technical assistance but then also talking about the priority suggestions for the board question under I think it's around the one around the business and technical assistance here as far as some of the criteria that these folks are going to be evaluated by does this all apply to the cultivators as well as far as like you know well it looks like most of the criteria you know whether the applicant would foster social justice and equity and the cannabis industry by being a minor or your women own business that that might to every single license background structure and again it's not these aren't anyway it's more just the factors and going to utilize this list of priorities I as somebody who would be able to see what principles am I going to be held to and we're going to make the determination as to whether I'm meeting those or not we were meeting with Michael Grady yesterday morning we needed the language around after the board to consider what they want to set energy efficiency and environmental standards and tiers are and activities that would be subject to active 50 versus what might have an agricultural so that would be based on interaction the work of the appropriate agencies and their advisory I believe they're going to report that in January but something like that just on the environmental resiliency sustainability in their application and say you know I'm going to utilize two months for Vermont has nice weather and we can grow outside sometimes I'm going to be utilizing that a greenhouse that has the little I mean I don't know what else I'm going to do and they can they put all that in their application and colleges right now I think you know she's trying to put all the applications so these are things that the legislature are saying important they'd like to see in the industry and some of the big team that might look good on your application thank you so but I you were correct in that this I think if you want to you get back to the original intent of 903 you have to go back and add some language in there around the board and the development of the rules not just the not just the the dispensaries and I see dress it in the room but the issue around being whether those both need to be mentioned or maybe it's just a variety and not strain strains are basic cancer they're kind of not in between so there's a science and technology out there that if you have a grower that is a little uncertain of their you know you can now do DNA then you can actually see where it falls into the universe of canvas strains and what it's related to now they're doing those tests it's probably around $300 right now that's not something to say a processor necessarily do on a regular basis but exactly is there something in the process that you know the THC content is just standard as you for us it has been just to know what we're offering and so you do want that you know potency test of the strain or the cold bar and then it's nice to know what might be similar you know it doesn't have as much potency to it becomes more important especially when you're going to be growing you're going to be wanting to grow there's probably specific things that they call if I'm a small grower let's say that I happen to grow a couple different strains there's any cross-pollinization let's say from an outdoor grower and is that did it grow in canvas legally because like we grow canvas right now you would grow a mail plant but then you got this mail plant in your facility and you have to be very mindful about what stage of growth these in that's what they focus on that's not like oh boy surprise that's what they focus on thank you fascinating so the question that I was coming down to is that so I think that from a consumer standpoint they want to know is it indica is it a hybrid should it just be that has to be which would be indica is it a hybrid or should it be or a strain of variety okay knows what name it is at least but a strain of variety is that an okay or is that not where is it so on cultivation so for right so this is on the packaging for canvas and then I have other stuff around later on about for product which may be strain or cold part that there's no there's no reason that consumers need to know that and I would that if there's certain properties that are associated with an indica and certain properties associated with sativa and somebody saying well I would like something actually because I have you know trouble sleeping or I want something at night instead of my glass of wine I don't want something that should be on the label and those are very broad developing some things are on it because it's probably the true beings that are creating the sleepiness versus the energizing effect so do you think this is too limiting or I miss something because we're talking about the cultivator right yes so how's the cultivator going to be able to all that stuff I would assume they know what they're growing that is worse hopefully if you send a sample of something that needs to have that test it's a THC they should also send okay but then again if I'm a cultivator I mean isn't this kind of information what we're looking for more for the retail yes end of things so why if I'm just a cultivator why would I be doing those kind of things because there's going to be a few steps between me and the retail anyway well the retailer needs to know in order to purchase so they're saying as a retailer I'm let's say I want to carry six because six sativas and a couple hybrids so they need to know from the cultivator in order to choose what products they want and how's the cultivator going to demonstrate that just based on the stream testing testing right and that's my point is that there's going to be a testing in between sorry if the cultivator has started they've started with and so they're going to relay that information to the retailer saying hey this is rural it is this I've been growing ever you know this is what I've been growing growing this because they're very selective about you know which ones they're going to grow you know what's popular what's an Arabian variety so I guess the question is that I recognize it's the testing but we're saying that the cultivator is going to bear the case of differentiating what truth in packaging well basically here yes they're going to they're going to be required to identify what the product is for whoever is going to be purchasing it okay so on the potency I mean that's something that is later on but actually I did instead of the cannabis represented by the amount of CBD and milligrams total back to the Indica I mean the industry right now that's the go-to terminology and so if that's in there I think everybody will understand that it's just going to be evolving over time though right so yeah I understand the suggestion that Cary made and I would support making that change just everybody else understand what she just and that's a recommendation to hear from the agency but I'm going to leave the stream of variety yes stream of variety sounds good so new section here for small cultivators so most of this was already alternative bills is kind of like just I created the youth section by pulling in and aggregating information one location for folks can see it so this is on small cultivators so it's intent to the regulated market for purposes of consumer protection and policy also the intent to encourage participation in the regulated market by small local farmers and further into these goals the board shall consider policies to promote small cultivators and then defining small cultivators as a cultivator not more than 500 square feet so section B during the initial application period for cultivator licenses the board shall prioritize licenses for small cultivators so it doesn't limit them so it doesn't say that they can't consider applications for additional tiers but that there should be a focus on getting the small cultivators going and licensed so I mean so are the small cultivators going to be held to the same standards the ones that we just spoke about as far as the packaging that's an awesome segue into subsection C sorry so board shall consider the different needs and risks of small cultivators when adopting the rules and shall make an exception or combination to such rules for cultivators of this size where we're just mind melt there mind melt that's pretty subpar in subsection D so upon licensing a small cultivator meets cell cannabis to a licensed dispensary at any time for sale to pages of caregivers pursuant to a dispensary license to temporary license including the time period before retail sales are permitted for licensed retailers so this is like in thinking about the timeline just generally but if you have the early sales going on by the dispensaries and then the remember the cultivators are the first ones they get to apply for licenses under the new system and then there's a priority to license the small cultivators first so they get out of the gate first they start growing the reach the new retailers don't come online until later and so if cultivators are able to have some product and ready to sell that product to someone before either the newly licensed product manufacturers or newly licensed retailers are going then those small cultivators can sell directly to dispensaries that are doing the early sale so that gives a window there for cultivators to be the small cultivators to be selling their product before the the adversary as well so while dispensaries are vertically integrated during a certain product that's under the commercial system that a dispensary may want to carry for their medical patients packaging so I'll make the same change here by its internet ordering and not sales over the internet or section on the recording so that the board's supposed to come back and issues around recommendations for internet dependent testing labs under the new commercial system to also test for dispensaries or for any of the public who might be growing under 511 CBD again this is the thing that they may try to offer as many services as possible but it doesn't require them to offer all of those services but those are things that they're authorized to do under their license on the testing where it says THC and CDE and the testing has to prove it with a certain potency you know subsection F in here I didn't change to you and I defined independent this is just on the we've already kind of gone over the exception of I'm gonna try to move in we just saw it in the other place there but subsection D we just shall be permitted on an after September 1 so you'd be licensing retailers in July to do that is on the next what we should do application for on page 56 I just added some language applications they're required to do it for the dispensaries as well but I was wondering whether or under the commercial system and also have it under here provisions for registry and for patients and the registry line seven I'm just curious to know those that represent the dispensaries raise funds yeah I can get it for a year which is different going to the fund but then I thought that you guys were then subsequently having no we I'm sorry no idea I'm sure if you guys recommendations we want to send a clear message about the private where this revenue is going into prevention but we don't need to do contortions I think to to this language because we know that many committees are going to work on it so that's that I still need to because I need to change a ton of stuff in the tax law but now I know so I will do that in the next round so I haven't changed the tax provisions yet so there's a music section section 18a this is I've talked to y'all about this this is an S117 giving the language for the ag lab which is akin to testing for hemp and hemp-infused products right now and this is adding this marijuana because the bill across the hall uses marijuana so I'm going to well no I mean they offer the services for testing that they yes is responsible for cost of the test that a registered dispenser and this is kind of so this would be like in the future the board is doing testing using ag lab to do compliance testing in the commercial market then they would be responsible for that it's based on 54 does not exist and so those are the terms that are used in current law so I will I will true it all up verification that food manufacturing establishment or food processor is currently defined product manufacture some substance abuse ones through this project I think they should take on this responsibility I mean it's that was your birthday present discussion JP I was always discouraged when I heard a lot about that department we have a question that I'm not saying that I know there's no word it's Jim's birthday so I agree for the most part but I'm sensing that we would help them to have that robust conversation I would be happy to make that request yeah you're so confident we appreciate hearing what they say with them if you're making brownie and putting ice cream as opposed to brownie to infuse with cannabis it's it would wonder if this language was originally foreign oil but might be an attitude to something that I suppose better than this food product they have never regulated the kitchens in medical dispensaries no I'm happy to see if we can get the health department in to have a conversation with us about that so section 20b is the change language that was in a bill two years ago but it was in session law and simply says yeah this is just changing it so that it's a change one or more and that's the only change is that it's putting it in statute under the current the session law and remind me again this is in 170 Harrison made a motion last week to include it this draft and I explained the concept to everybody and folks seemed to be moving across the hall significant to take place we've changed July 1 days to a fine pass the running center don't think so and Michelle can correct me if I'm wrong on this but there is typically a significant amount of fine fine tooth comb that the hill goes through after it passes that the you know what happens is once you guys pass it and then comes back to me and I have to go through and look at it and approve it before it goes to the governor and then there's that time but in terms of you know the passengers when the governor signs it so that could be May you know or June or whatever so there you know could be a few weeks in there but in terms of you think about the board and those things going into effect it's not that they don't know that like if it passes not that they don't know that they're going to have to appoint members and that they don't you know they're not going to start looking for people until July first or something like that I don't I don't think that with regard to things like