The WSLCB Wants to Hear From You
The Washington State Liquor & Cannabis Board is taking public comment on new proposed rules.
Every so often, a government agency like the Washington State Liquor & Control Board wants to hear from the people who will be impacted by proposed rule changes. These moments, known as public comment periods, can be thought of like an ongoing town hall. The intent is to give the public and industry stakeholders the opportunity to argue their case for or against a proposed rule change. These public comment periods are open to all, via mail, e-mail, fax, for a specified period of time. If you feel strongly about any of the following issues, it is highly encouraged to make your voice heard during the public comment period.
Upcoming Proposed Rules For The WSLCB
From now until October 3, 2018, the Washington State Liquor & Cannabis Board has opened up the following proposed rule changes to a Public Comment Period.
- Quality Assurance Testing and Products Requirements: The WSLCB, in conjunction with the Washington Department of Health, is considering ways “in which [each agency’s] respective rules can be better synced to encourage testing efficiencies and remove barriers that may exist to the availability of compliant products.” The goal is to ensure that the cannabis industry in Washington state has proper testing and lab rules regarding quality assurance for medical and recreational cannabis buyers. They will consider the following topics for potential rulemaking changes:
- Lot and batch sizes
- Fields of testing and pass/fail level adjustments
- Potency testing requirements
- Pesticide testing requirements for all cannabis products
- Heavy metals testing requirements
- Sample deduction requirements
- General testing rule adjustments
- Product, THC serving limits, and packaging requirements
- Other related rule changes that may be necessary or advisable
- 2017 Cannabis Legislation and Technical Housekeeping Rules: The purpose of this rulemaking session is to ensure that the rules are consistent with changes to the law that the WA state legislature made during the 2017 Legislative Session. There is a robust list of rule changes being proposed, including but not limited to:
- Technical changes to the definition of “public school” and “secondary school”
- Clarifying changes to the definition of “financier” to make it clearer and consistent with WAC 314-55-035
- Defining terms including end product, harvest, immature plant or clone, intermediate product, lozenge, marijuana mix, marijuana mix packaged, marijuana mix infused
- Clarifying that products not ingested orally, but ingested into the body via absorption, fall within the definition of marijuana-infused products
- Adding language to state that the WSLCB will not issue marijuana licenses within the exterior boundaries of a reservation or federally recognized Indian tribe without the express consent of the tribe, as required by changes to RCW 65.50.331
- Technical changes regarding the co-location of licenses to reflect actual practices and allowances in co-location of licenses for research licenses and producers who also hold a processor license
- Add “licensees” to the list of people who must be 21+ to work in a licensed establishment
- Technical changes to add exceptions for “free products” including branded promotional items of nominal value
- Addition of subsection that expresses WSLCB authority to place licensing change applications on hold, withdraw licensing change applications, and examples of licensing change applications that may be affected
- Clarifying changes to the definitions of “true party(ies) of interest” and “financiers” to clearly differentiate the two
- New language to clarify that employees of producers or processors that receive commission-based compensation are not considered true parties of interest so long as the commission-based compensation arrangement does not create a default true party of interest relationship; the commission-based compensation arrangement between a licensee and employee is in writing, no more than 5% of the gross profits may be given to anyone employee under such an arrangement, and an employee receiving commission-based compensation is listed as an employee of the licensee with the Washington State Employment Security
- Changes to the fees for a processor license to reflect changes to state law increasing license fees to $1300 effective July 1, 2018.
- For an exhaustive list of all proposed changes, click here.
How to Submit A Public Comment to The WSLCB
You can submit public comment to the Washington State Liquor and Cannabis Board by mail, e-mail, or fax by OCTOBER 3, 2018. When submitting a public comment, include the rulemaking you are commenting on in the subject line.
Liquor and Cannabis Board
P.O. Box 43080
Olympia, WA 98504-3080
Fax: (360) 664-9689