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SPECIAL LEGISLATIVE EDITION

6,496,157 FLORIDA VOTERS VOTED A MANDATE FOR MEDICAL MARIJUANA

ADDICTION

SOCIAL EQUITY

ARE YOU KIDDING ME?THE THC CAP AGAIN!

CANNABIS IS MEDICINE

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CANNABIS IS MEDICINE Cannabis IS Medicine...that’s where this article MUST begin. Medical Cannabis Providers both protest loudly when the Prohibitionist outcry includes “we need to prove what this “NEW MEDICINE” can do”...

ARE YOU KIDDING ME? THE THC CAP AGAIN? As 2020 rolls in and legislative session begins in Tallahassee,patients and advocates are concerned about the future of smokable marijuana in the Sunshine State....

OH, FOR THE LOVE OF EDIBLESIn November of 2016, the voters of the State of Florida overwhelmingly passed Constitutional Amendment 2 (Article X, Section 29 of the Florida Constitution)...

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More than 23 million Americans age twelve and older are affected by substance abuse or dependence—that’s nearly one in ten Americans. Smoking is the number-one preventable cause of death. Alcohol abuse is the seventh most common preventable cause of death. About 62 percent of high-earning individuals in the U.S. work more than fifty hours a week, which is the criteria for addiction to work, 35 percent work more than sixty hours, and 10 percent work more than eighty hours.

Americans over-65 only account for 14 percent of the nation’s population, but they use more than 30 percent of all prescription drugs. Medicare saved more than $165 million in 2013 on prescription drugs in D.C. and 17 states that allowed cannabis to be used as medicine. If every state in the nation legalized medical marijuana, would save more than $468 million per year on pharmaceuticals for disabled Americans and those 65 and older.

The Substitution effect using cannabis to treat pain, anxiety, depression has shown a 16% decrease in benzodiazepines, 12% decrease in antidepressants and 12% replaces cigarettes with cannabis. Cannabis is a potential treatment for opioid withdrawal. In 2015, a Canadian survey using 473 cannabis patients found more than 80% using cannabis substituted it for a prescription drug and has less risk of dependence. The International Journal of Drug policy stated 30% use marijuana as a substitute for opioids. Cannabis augments analgesic effect of opioids and widens the therapeutic window when used together. This combination may allow for opioid treatment at lower doses with fewer side effects (Powell, 2015).

Donald Abrams treated 21 patients in a hospital setting using high doses opioids for chronic pain. He received cannabis from NIDA (3.56%). The patients vaporized cannabis three times per day and pain decreased by 27%. The Hebrew University, in 2016 found that cannabis is effective for treating chronic pain. They studied 176 participants, who had been previously unresponsive to conventional medicines and treatments, who inhaled a monthly amount of 20 grams of cannabis for six-months. Sixty six percent experienced improvement in their pain symptom scores after cannabis therapy, and most reported “robust” improvements in quality of life.’ Patients also reduced their consumption of opioids by 44 percent! Univ of Michigan studied 185 chronic pain patients and discovered a 64% reduction in opioid use after increasing their cannabis consumption. Patients also reported a 45% improvement in quality of life since using cannabis. A study published in the international Journal of Drug Policy from researchers at FIU found people are less likely to turn to opioids for pain relief in medical marijuana legal states.

Substance abuse treatments like suboxone and methadone exist however these options are more addictive. Cannabis can minimize withdrawal symptoms, reduce anxiety, agitation, improves sleep, normalize digestive tract, spasms, and sweating. When using cannabis with naltrexone for heroin addiction or cocaine addiction a higher treatment retention was seen. Cannabis prevents opioid tolerance and need for dose escalation.

Scientists in China used a synthetic CBD, called JWH-

133, to see how mice given regular doses of cocaine might respond. Cannabidiol (CBD), turns down a receptor in brain that is stimulated by cocaine (July 2011 Nature Neuroscience). Mice dramatically reduced their IV cocaine intake (60%) after given JWH-133. This would lead to new drug replacement therapies for cocaine addicts. Further evidence that marijuana is an “exit” drug, and anti-addiction therapy.

Illicit cannabis use has been shown to cause dependence, but it is likely that appropriate medical use does not carry the same risk. The Cannabis addiction rate is nine percent which is overinflated as this number stems from the alternative being incarceration as well as the fact most are self-medicating and the desire to continue treatment partly due to the increase in dopamine, desire and outcome. Cannabis use can also cause withdrawal symptoms when abruptly stopped. These symptoms emerge 1-2 days after cannabis cessation and resolve in 1-2 weeks. Most patients compare the severity of cannabis withdrawal to caffeine withdrawal.

Harm reduction offers safer options. The success rate of rehabilitation is 30%. A treatment center in California uses marijuana as a substitute for more potent dangerous drugs. This has shown to decrease relapse and readmissions and offers a sense of emotional control.

We are facing an opioid crisis, non-opioid alternatives are minimally effective adjuncts for chronic pain, no data supports safety or efficacy of long-term opioids for chronic noncancer pain and millions of people around the world are using cannabis for pain which is the top indication for cannabis usage. CB1 receptors in the limbic system are responsible

for the affective elements of pain perception helping bring the mind into the body. In 2017 the National Academics of Sciences, Engineering, and Medicine reported that there’s substantial evidence that cannabis is an effective treatment for chronic pain in adults.

For those concerned about the growing prevalence of mental illness, including addiction, as well as its associated human, social and economic costs, plant based and alternative options exist. Ongoing research and clinical trials are taking place with a number of psychedelic drugs and cannabis; perhaps the future of medicine. For example, In the past decade there’s been a renewed interest in “psychedelic medicine,” including MDMA, psilocybin and LSD especially at it relates to treatment-resistant forms of addiction, anxiety, post-traumatic stress-disorder (PTSD) and depression. The U.S. Food and Drug Administration (FDA) continues to approve studies and, in some cases, new drugs like Spravato, a ketamine like nasal spray for treatment-resistant depression. These options may be able to help with our opioid epidemic while treating chronic pain, depression, PTSD, addiction and helping us return to balance.

Dr. Michelle Weiner, is an Interventional Pain Management Physician board certified in Physical Medicine and Rehabilitation. She completed her residency and fellowship training at the University of Miami. Her specialty is focused on prevention, treatment, reversal of health deterioration, increasing function and managing pain. Dr. Weiner focuses on diagnosing and treating spine and musculoskeletal pain as well as chronic migraines.

BY DR. MICHELLE WEINER, DO, MPH

ADDICTION AND CANNABIS

LIGHT UP YOUR LIFE!™

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BY DR. BARRY GORDON, MD

Cannabis IS Medicine...that’s where this article MUST begin. Medical Cannabis Providers both protest loudly when the Prohibitionist outcry includes “we need to prove what this “NEW MEDICINE” can do”. We all know that the Cannabis plant is ANCIENT medicine at its best, from the earth itself. Throughout every ancient society, the Shamans or medicine men were the most respected members of every tribe for their knowledge of plants as nature’s healers. It was the OIL BASED NATURE of cannabis that removed it from the “Black Bag” of western medicine. It was FINANCIAL, period, for as the 1900’s dawned, the hypodermic needle (water-based meds only!) became the new delivery method, the new CASH COW for what was already a corrupt pharma world.

The miracle on earth that was the Cannabis Plant was sent to the wasteland of Prohibition. It took about 40 more years to fully outlaw cannabis, and the Doctors of the time actually staged a nationwide “strike” for a few days when it actually happened. Most everyone knows the story of “Reefer Madness” and how post Alcohol Prohibition leaders and government officials exploited cannabis for their needs. Richard Nixon further ignored DOCTOR Schaeffer and his Commission’s recommendation to NOT EVEN PLACE cannabis on the schedule, and instead for his political reasons insisted it be placed into Schedule 1; perhaps the GREATEST disaster in medical history. No research value?!; similar social consequences to LSD, Heroine, and Methamphetamine!?; NO WAY! We all are aware of the obvious disasters from this failed policy, the insistence of treating cannabis strictly as a drug of ABUSE, and not as a substance to be utilized for the BENEFITS of society and healthcare. It is the COMPLETE lack of American RESEARCH that is the more hidden tragedy to this horrible corruption. Over 100 years of lost science can not be recovered, and Doctors like myself, and many others, are not willing to wait while patients suffer and die. The safety of cannabis has been established from it’s historical use, we MUST work to DESCHEDULE ASAP to establish further effectiveness and protocols.

We thank Israeli researcher Dr Raphael Mechoulum for his discovery of the ECS, the ENDOCANNABINOID SYSTEM. Literally now regarded as the 13th organ system in the human

body, it may be the MOST IMPORTANT, as it essentially is the “HOMEOSTATIC MODULATOR” of ALL of the systems. The science continues to develop, and it is fascinating both in what we are learning and what we clearly still do not know. This once again points to the complete lack of American research. Fortunately, other countries have not had similar restrictions, and work is being done. Florida arrives to this historical battle for Cannabis as Medicine at a CRITICAL point, and the program has been somewhat unique in implementation. In contrast to the earlier programs where “flower products” were initially introduced, Florida Doctors were charged with introducing PROCESSED MEDICAL CANNABIS as MEDICINE to Florida. At the time that I started my cannabis practice, I had no idea how important this timeframe progression “from adult use marijuana to truly useful MEDICINAL CANNABIS” would become to both myself and my patients.

My ER training, plus the ensuing 32 years in busy American Emergency Departments, had armed me with a keen knowledge of the LACK of social impact from cannabis in society. Alcohol of course has always been THE major player, along with opioids which kill daily as the more recent destroyer of lives. Methamphetamine, cocaine, LSD, and mushrooms have also been constant actors in the drug war. Cannabis use was everywhere, I being a “child of the 60’s” as well, but it had only been law enforcement and job related consequences of “weed” use that I had seen in my personal life or career in the ER. I had never lost a friend, partner or patient to a MEDICAL issue from cannabis. Meanwhile the others continued to physically destroy lives daily. Point is, my early passion towards Medical Cannabis was based on the reversal of this social injustice, and I still fight for expungement and the reversal of social consequences and inequality as a part of my mission. However, it’s been the DISCOVERY of cannabis as the TRUE MEDICINE that it is that now drives me forward with even more gusto! As I had mentioned earlier, it’s been a unique time, and Florida is a UNIQUE STATE, to have become a Medical Cannabis provider. For those of use who practice here in the Sunshine State, sometimes it’s been pretty darn stormy! Governor Scott was always opposed to cannabis in all forms, and he had a Legislature that agreed with him. Only by the will of the citizens of Florida, those 71.3%

of the voters that approved Medical Cannabis, do we have it now. Governor DeSantis has been more open, but we still have very negative leadership in the Legislative bodies. In the recent Legislative Committee season, we witnessed a procession of Prohibitionist speakers from Law Enforcement, Drug Testing, and Medicine itself. MOST DISTURBING, however, was the focus on the implications of “impending, oncoming Legal Adult Responsible Use”, and the harms and danger that this will bring to Florida. MISSING HOWEVER, was the needed focus on what still needs to be done to FIX and IMPROVE Florida’s Medical Program. THIS IS WRONG ON MANY LEVELS!

We have a most unique opportunity in Florida to LEAD the way in a manner that other states have not. Doctors in Florida began our practice in this era of CANNABIS as MEDICINE. We now have the limited research from other countries, that has completely debunked the idiotic Schedule 1 designation that doctors in the USA still must operate under. It’s a tough landscape; some call myself and my fellow CannaDocs courageous for even navigating it, but morally it’s the ONLY thing that I and others can do. I look at it from a different viewpoint, as one of the few who has the ability to promote massive changes in how we view this unique plant as medicine. We have seen other states LOSE the quality of their Medical Cannabis program as they have progressed towards cannabis reform. We can’t allow that to happen in Florida, we know too much now to allow that happen, and Florida can be the MODEL medical cannabis program in the country. We now understand that it’s not about the THC alone, but the combination of all the cannabinoids, or what is called the entourage effect. We now have the ability to better administer the medication not only by inhalation but also by topicals, tinctures, edibles and even suppositories. This ability, plus CONTROLLING the ratio of THC in combination with the other cannabinoids in the plant are what makes the “pot, weed, grass, etc.” of yesterday, the medicine of today. There are terpenes, flavonoids and other chemicals in the plant that we are still discovering their medicinal effects. The point is, we need to focus on the medical program, and use what we learn from our medical program to aid in the implementation of Adult Use in Florida. We have experts here, just ask us, we are ready to appear in front of any panel or forum. The focus now should be on the critical issues in the Medical program, they are easy to identify. Job protections for Florida’s card holders should lead the way, joined by reciprocity for out of State card holders, and ease of Veterans access. We need added qualifying conditions such as opioid use disorder and many others. In hospital use, nursing home and assisted living access need to be discussed. Edibles and appropriate testing standards have not yet been accomplished. I could add many more, but the point is, I had a HUGE learning curve in order to become the best Medical cannabis provider that I can be. The patients of the state of Florida deserve the same vigorous approach at the state leadership level. The Medical Cannabis provider and advocate community are ready to help, and we have the experience to lead the way. We have grown up in the modern era of Medical Cannabis, we surely can’t go backwards to the days of misinformation and misunderstanding, the patients can’t wait!

G O T O O U R W E B S I T EH I G H L I F E M A G A Z I N E . U S

A N D O R D E R T H I S C O O L F L O R I D A I N S P I R E D S H I RT

CANNABIS IS MEDICINE


As 2020 rolls in and legislative session begins in Tallahassee, patients and advocates are concerned about the future of smokable marijuana in the Sunshine State. For medical patients, the ban on smokable cannabis flower was lifted by the signature of Governor DeSantis in March of 2019. Since the ban was lifted, patients have clamored for better and more reliable access to flower from all of the state’s operating Medical Marijuana Treatment Centers (MMTCs). In fact, the demand for whole-bud cannabis is so high, a recent study estimated that more than half of patients in Florida prefer to medicate with unconcentrated, whole marijuana flower. Unsurprisingly, MMTCs are struggling to keep up with the demand for smokable cannabis, with many patients complaining about low stock and a lack of options for relief. Subsequently, operators are supercharging their efforts to massively scale cultivation facilities.

Despite issues with inventory, flower-dispensing MMTCs have been growing and developing a multitude of strains, varieties, and cultivars with distinct cannabinoid profiles. Different strains contain different ratios and potencies of cannabinoids, and are formulated with specific effects and individual patients in mind. Although there are well-over 100 known natural cannabinoids found in marijuana, the most salient are THC (delta-9 tetrahydrocannabinol) and CBD (cannabidiol). Although more studies are needed and the issues are very nuanced, generally speaking, THC is the chemical most responsible for the psychoactive effect or “high” that a patient experiences while smoking. Conversely, CBD does not have the same psychoactive effect, but researchers and patients alike are hopeful for purported benefits of calming, anti-inflammation, sleep assistance, and more. However, along with the psychoactive effect, high-THC cannabis specifically has been shown to be the only method

for some patients to obtain the relief they need. Cancer patients have credited high-THC products for improvements in appetite, mood, discomfort, as well as for reducing or slowing the growth of cancerous cells in the body. Similarly, patients with chronic pain from other conditions simply need high-THC medicine to effectively alleviate their symptoms without resorting to opiate use.

So, what’s the problem? If MMTCs are now free to cultivate

and dispense whole-flower cannabis, what’s the issue? The answer: Ray Rodrigues and the arbitrary 10% THC cap. Originally, smokable flower was not allowed in Florida, and the smokable ban itself was a result of legislation implementing medical marijuana that was written by Rodrigues himself. Less than a month after Governor Desantis lifted the ban on smokable marijuana, Florida House Republicans began a campaign for restrictions on flower despite complete lack of concerns from doctors, patients, and other citizens. Specifically, Rodrigues, the House Majority Leader out of Fort Myers, sponsored a bill that would cap all smokable marijuana at 10% THC (HB 7117). Luckily, the bill did not pass, despite many Republicans voting in favor of the 10% cap, and most Democrats voting against. Currently there is no restriction on THC percentage for cultivators of licensed MMTCs, with some strains testing at nearly 30%.

Born in of Pensacola, Ray Rodrigues received his education at Berry College in Georgia under a scholarship from the WinShape Foundation – a conservative charitable organization founded by Chick-fil-a mogul Truett Cathy. Originally, the scholarship was only awarded to those that were deemed righteous by Cathy, and were required to sign a contract that included Christian-based rules to abide by. Ray Rodrigues continues to legislate as an evangelical Republican,

but has been accused by some of cloaking his true intentions behind his “classical” views to boost his own interests. In the past, Rodrigues’ top political donors have come from some of cannabis’ largest detractors: the alcohol, tobacco, and sugar industries. Even as of late 2019, Rodrigues’ campaign has raised over $357,666, second most of any 2020 Senate candidate. The kicker – Rodrigues has raised all this money with no opponent, as he is currently running unopposed with no one willing to challenge his Senate seat.

Rodrigues has remained resolute throughout his political

career to espouse anti-marijuana rhetoric regardless of public opinion and relevant research, but he is not alone in his quest to install “reefer madness” style policies for regulation of medical marijuana in Florida. Rep. Cyndi Stevenson out of the 17th district has routinely, and without supporting facts, asserted specifically that the THC in marijuana increases the propensity for an individual to become more violent. In April of 2019, she told Associated Press that “The idea that we would put a stamp of approval on something that enhances violence, perhaps, even if it’s a small fraction of the community, is something that should give us all pause.” Additionally, Speaker of the House Jose Oliva of Miami has voiced similar concerns, however hollow. Oliva worries about people breathing cannabis smoke into their lungs, citing “I’ve never heard anyone say its good for you.” Despite his concerns for lung health and the well being of the general populace, there are no indications that Oliva plans to shut down or further regulate his own family-operated cigar company.

After unprecedented growth of the medical cannabis industry in Florida over the past two years, many citizens are worried that regulation of the program is headed in the wrong direction. Rodrigues, who also chairs the House Health and Human Services Committee, has oft- cited a controversial study which posits that cannabis with more than 10% THC can induce psychosis. The study, published by Swedish company Lancet over 30 years ago, has been highly criticized due to its reliance on patient-submitted data, limited scope, and lack of data that can be applied to marijuana users without high-risk conditions. Nonetheless, Republicans have conducted hearings in Tallahassee to parade the old troop of prohibitionist doctors, clinicians, and “experts” to regurgitate the same outdated, unsupported, anti-marijuana vitriol in hopes of introducing a new bill to cap THC in 2020. Bertha Madras, a Harvard professor and one of the nation’s oldest marijuana prohibitionists, was among the experts summoned to Tallahassee for hearings on potential implementation of new marijuana policies. “Marijuana is not benign. It is not safe. It is addictive,” said Madras, a member of the Commission on Combatting Drug Addiction and the Opioid Crisis.

The overarching effect of such a bill in Florida could a devastating blow to a cannabis industry that is just getting its feet wet in the state. Chiefly, patients are worried that if a 10% THC cap were installed, they would need to purchase more than double their current amount of medicine to receive the same level of relief. With Florida medical marijuana prices already alienating many current patients, such a cap would undoubtedly drive more to the black market. In addition,

ARE YOU KIDDING ME? THE LOOMING THC CAP: SHOULD FLORIDIANS WORRY? BY JOSHUA NAVARRO, ESQ. PA | FLORIDA FOR CARE

current state regulations only allow for 2.5 ounces of smokable cannabis flower to be consumed by a patient every 35 days. With some patients already stretching their allotment as it is, many say that a 10% cap in conjunction with the 35-day rule would irreparably undermine their right to medicate effectively under the Florida Constitution. Moreover, many opposed to the THC cap point to the sheer lack of common-sense rationale in such proposed legislation. Rodrigues’ previous bill attempted to limit THC in marijuana to 10%, in a plant that produces naturally-fluctuating cannabinoid concentrations. Asking cultivators to grow cannabis that contains any specific cannabinoid requirement is problematic (just ask a hemp farmer), and efforts to boost flower production could be put in a stranglehold.

Furthermore, when previous attempts to cap THC have

been proposed for whole flower, Rodrigues has been silent in addressing the incongruence of his stance toward smokable and other forms of medical marijuana. Since his early attempts to curtail Florida’s medical marijuana program in 2014, Rodrigues has been vocal in strongly opposing the idea of smoking marijuana, citing that it is not a “proper” way to consume medicine. A THC cap on smokable marijuana flies directly in the face of this position, as it implicitly sanctions smoking, and also requires a patient to smoke more than double what they would have previously. Similarly perplexing, Rodrigues and other House Republicans have been silent on the availability, efficacy, or any potential “dangers” of highly-concentrated cannabis oils, vape cartridges, oral solutions, and more (that can contain over 90% THC).

Regardless, the threat still remains real–now is the time to contact your legislators, make your voice heard, and not to fall for decades-old scare tactics. A 10% cap on THC levels of smokable cannabis would undoubtedly harm patients and threaten the sustainability of the medical marijuana program in Florida. If Tallahassee Republicans have their way, Florida would become the only state in the country with a THC cap for smokable medical marijuana whatsoever.

Joshua Navarro is a South Florida attorney with practice areas focused on cannabis, hemp, and criminal defense. He serves as the Operations Director of Florida for Care, a patient advocacy group, as well as for the Florida Hemp Council, a hemp & CBD trade association for promotion of responsible hemp enterprises.


In 2017 the state of Florida passed SB8A a significant bill supporting the use of medical marijuana for individuals suffering from debilitating diseases and medical conditions. During this time several groups advocated for legislation supporting patient access, safe medicine, and a open and fair market. The 2017 legislative season was a flurry of activity the buzz word in the state capital was “marijuana”. Anxious stakeholders wanted to make sure the program rolled out right.

One major area of concern was the inclusion of minority and diverse businesses into the marketplace. At the time Florida was one of the very first states to agree on the concept of social equity and thus created legislation supporting diversity and Inclusion. One bill in particular gained significant traction because it would award a license to a black farmer(s) which specifically addressed racial discrimination against a specific group which has been harmed or discriminated against in past history. During this time legislators came together and agreed on a creating a opportunity for disenfranchised black farmers who were apart of the Pigford vs. Glickman lawsuit. The Lawsuit against the USDA alleged racial discrimination against black farmers in its allocation of farm loans and assistance between 1981 and 1996.

The black farmers license gave hope to many who felt the industry would only give an opportunity to large white owned companies who do not reflect the needs of underserved communities. Fast forward to 2019 we currently have over 415,000 patients in the system, 22 license holders, 209 dispensary retail operations, 2600 qualifying physicians, and 0 (zero) black operators in the State of Florida. Licenses have come and gone with a value of $50 million or more with some however the black farmers license is still in limbo because the application process has not been open due to lawsuits that unfortunately affect the opportunity to act on this license. Florida Governor DeSantis reinvigorated the conversation shortly after being elected, speaking out against the cartel-like system created by law makers. He called on the legislature to fix the MMJ program and in a bold move he awarded 8 new licenses in order to settle one of the many open legal challenges at the time.

Perhaps a similar remedy is inline for the single set-aside license for a black farmer in the state. Many stand in solidarity together hoping this situation gets rectified. The current lawsuits against the Department of health hamper progress however, there’s legislative action that can be implemented to fix the problem. In 2020 Minorities for Medical Marijuana will work diligently to make sure these changes get considered. “In 2018 and 2019 we saw the rest of the country place social equity and minority participation as priorities in the development of a cannabis industry, while Florida is still grappling with awarding a single set-aside license for a black farmer.

When the set aside was signed into law in 2017 it made Florida a leader in the conversation surrounding diversity and equity, however failure to award that license has cast a dark cloud over the State. Instead of states following our lead they seek to avoid our mistakes.” states Erik Range, M4MM Board Chair. Can you imagine if the Black farmers license was awarded as intended in 2017 at the same time when the other licenses were awarded how things would be so much different? Something has to get done in 2020.

WE WANT ACTION NOW!

BY ROZ MCCARTHY | FOUNDER OF MINORITIES FOR MEDICAL MARIJUANABLACK FARMERS LICENSE

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THE LACK OF SOCIAL EQUITYIN FLORIDA’S CANNABIS INDUSTRY

BY DUSTIN ROBINSON ESQ. P.A. | MR CANNABIS LAW

As a Florida cannabis attorney who has worked on social equity applications in other states, I have seen the good and the bad of social equity programs and am hopeful that Florida can learn from the mistakes and the successes of other states. Florida currently has four provisions that arguably provide for social equity in the marijuana industry: (1) reserving one of the ten licenses that were supposed to be available in 2017 for a black farmer that was a class member of Pigford v. Glickman 185 F.R.D 82 (D.D.C. 1999); (2) requiring applicants to have strong diversity plans; (3) requiring applicants’ management, ownership, and employment to reflect an involvement of minorities and veterans (a similar provision is included in SB210, a bill recently proposed by Senator Thurston); and (4) allocating $10 of the identification card fee to the Division of Research at Florida Agricultural and Mechanical University for the purpose of educating minorities about marijuana for medical use and the impact of the unlawful use of marijuana on minority communities. While each of these provisions are steps in the right direction, all of these provisions (individually and collectively) fall far short of fulfilling any social equity purpose.

DEFINING THE PURPOSE OF A SOCIAL EQUITY PROGRAM

In order for any program to be successful, it is important to first define what exactly the program sets out to achieve: the purpose or the goal. Rather than me providing my personal opinion (which I couldn’t help but to do at the end of this section), let’s look at what some other states provide as their purpose or goal:

• Illinois: In the interest of establishing a legal cannabis industry

that is equitable and accessible to those most adversely impacted by the enforcement of drug-related laws in this State, including cannabis-related laws, the General Assembly finds and declares that a social equity program should be established. - Cannabis Regulation and Tax Act, H.B. 1438, § 7-1(b) (2019).

• Massachusetts: The commission shall, in accordance with

chapter 30A, adopt regulations consistent with this chapter for the administration, clarification and enforcement of laws regulating and licensing marijuana establishments. The regulations shall include: procedures and policies to promote and encourage full participation in the regulated marijuana industry by people

from communities that have previously been disproportionately harmed by marijuana prohibition and enforcement and to positively impact those communities - An Act to Ensure Safe Access to Marijuana, 2017 Mass. Acts. 55 § 26 (a 1/2)(iv).

• California: It is the intent of the Legislature in enacting this act

to ensure that persons most harmed by cannabis criminalization and poverty be offered assistance to enter the multibillion dollar cannabis industry as entrepreneurs or as employees with high quality, well-paying jobs. Sen. Bill 1294 § 2(f) (Reg. Sess. 2017-2018) 2018 Cal. Stat. (aka California Cannabis Equity Act of 2018)

• Pennsylvania: It is the intent and goal of the General Assembly

that the department promote diversity and the participation by diverse groups in the activities authorized under this act. - Medical Marijuana Act, 2016 Act 16 § 615(a)

• Michigan: The department shall promulgate rules to implement and administer this act pursuant to the administrative procedures…including: a plan to promote and encourage participation in the marihuana industry by people from communities that have been disproportionately impacted by marihuana prohibition and enforcement and to positively impact those communities. - (MCL 333.27958, 2018 IL 1) (aka Michigan Regulation and Taxation of Marihuana Act)

As seen above, the common theme for most Social Equity Programs is the goal of repairing the damage caused by prior cannabis criminalization that had long term, adverse effects on low income and minority communities. Unfortunately, Florida’s laws are devoid of any clearly stated purpose. As a result, we are left with spotty provisions that do not fulfil a broader, clearer purpose. For example, while the Pigford preference certainly rights-the-wrong of previous discrimination to one black farmer, it has nothing to do with helping those adversely impacted by cannabis criminalization and it is extremely underinclusive of the rest of the minority and veteran population.

My recommendation is that we add the following provision to our Florida Statutes: “Florida Statute Section 381.986 hereby establishes a Social Equity Program with a goal to achieve

equity in ownership, management, employment, opportunity, and accessibility in the cannabis industry to minorities and others adversely impacted by the enforcement of drug-related laws in this State, as well as to veterans.” This type of clear and concise statement in the Florida Statutes would set a tone for equality and would breathe life into the substantive social equity provisions to follow.

ALLOCATING SPECIFIC POINTS FOR SPECIFIC CRITERIA

The Illinois Cannabis Regulation and Tax Act explicitly provides that an applicant receives 50 points out of the 250 available points for qualifying as a Social Equity Applicant, which is determined on a binary basis. In other words, a Social Equity Applicant automatically receives 20% of the available points simply for qualifying as a Social Equity Applicant. This means that it is practically impossible for an applicant to be awarded a license if such applicant is not a Social Equity Applicant. As a result, I predict that nearly every application submitted for an Illinois Conditional Adult Dispensary Organization License on January 2, 2020 will be a Social Equity Application, which will practically guarantee that some sort of social justice will be served.

In a way, the Pigford preference at least guarantees that there will be one minority applicant that wins a Florida license. But, as for the remaining Florida licenses and the remaining minorities, the requirements in Florida Statute Section 381.986 of a diversity plan and involvement of minorities and veterans are too general to ensure that minorities and veterans will have the opportunity to be owners, managers, and leaders of Florida marijuana businesses. Experienced cannabis-application-drafters will be able to draft applications satisfying such general criteria while knowing that the OMMU will likely have too few resources to actually enforce compliance to such criteria once a license is awarded.

Instead, Florida law should allocate specific points for achieving

specific criteria. For example, Florida law can provide 20% of the points for applicants that have 10 full-time employees that have been adversely impacted by cannabis criminalization or are veterans. To qualify, the employee would need to either (1) reside in a “disproportionately impacted area” (to be defined by certain criteria demonstrating a certain poverty level or unemployment rate); (2) have been arrested for, convicted, of, or adjudicated delinquent for a minor marijuana-related offense; or (3) be a veteran with a DD Form 214. This is extremely similar to the Social Equity criteria provided in the Illinois Cannabis Regulation and Tax Act with a few tweaks for my veteran buddies. By having specific points for achieving specific criteria, Florida would be providing a clear pathway for success for veterans, minorities, and others adversely impacted by the cannabis criminalization.

OWNERSHIP/CONTROL AND VARIANCES I hate to admit it, but smart attorneys can easily draft documents

around all the above recommendations. This is how it works: 1) A client, who is probably a marijuana licensee in another

state, hires a cannabis attorney;2) The client finances the entire application process, often costing anywhere from $100,000-$500,000;3) The client or attorney finds a person whom satisfies the criteria of a Social Equity Applicant or a Pigford Applicant; 4) The attorney selects a menu of documents, depending on

the state’s particular statute, which may include: a) An Operating Agreement (to establish ownership

and control by the Social Equity Applicant or Pigford Applicant); b) A Buy-Sell Agreement (providing the client an option to purchase the interest of the Social Equity Applicant or Pigford Applicant); c) A Management Agreement (providing rights to profits to a management entity owned by the client); and/or d) Loan Documents (providing various covenants and warrants that significantly limit the control of the Social Equity Applicant or Pigford Applicant). While in front of the curtain it appears that the Social Equity

Applicant has ownership and control, behind the curtain there is probably a wealthy, non-minority/veteran male ready to enforce the covenants under Loan Documents; exercise his option under the Buy-Sell Agreement; and/or suck out the profits through a Management Agreement.

Just to be clear: there is nothing illegal or even improper

about the above scenario. In any industry, the person or entity putting up the money is going to want to have protections through options, covenants, warrants, profit-sharing, or other provisions. Indeed, such a person or entity would not put up the money if they were not able to get such protections. Afterall, would you finance a $500,000 application if you were not able to ask for equity or have a loan that allows you to foreclose on the license in the event of default? Absolutely not! As long as the applicant is honest in the application and discloses everything requested, there is nothing wrong with protecting an investor’s investment.

The money-challenge doesn’t end with the application. Once a Social Equity Applicant or Pigford Applicant is awarded a license, they now need to operate the license. In Florida, with the vertically integrated structure, the applicant will need about $20,000,000 to make it operational. Do Social Equity Applicants adversely impacted by cannabis criminalization have that kind of money? No! So now the Social Equity Applicant or Pigford Applicant is forced to either sell the license or raise debt or equity to finance the operation. This comes with additional legal documents that include options, covenants, warrants, preferential distributions, profits-interest, and other provisions that will significantly restrict the Social Equity Applicants ownership and control. On the one hand, the stated purpose of the Social Equity Program is not served if the Social Equity Applicant is allowed to simply sells its license. But, on the other hand, without allowing for transfer of interest or raising of debt, the Social Equity Applicant or Pigford Applicant is left with a license that cannot become operational due to lack of financing.

Thus, it is imperative that the legislature: (1) clearly establishes what type of loan/equity/control arrangements are permissible for Social Equity Applicants (perhaps even provides state financing for Social Equity Applicants); (2) requires documentation of such arrangements during the application process; and (3) establishes a variance standard that balances the goal of the Social Equity Program with the realistic financial needs of a Social Equity Applicant.

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Michael M. had Crohn’s disease. At its peak, he had lost 50 pounds from his usual 145, had portions of his intestines removed and was placed in hospice. His wife, who frowned on cannabis use, had asked him years ago to give up smoking weed because she worried that it would affect his job as a heavy machinery driver in the construction industry.

But he was clearly dying, and she had read clinical reports that showed people having significant improvement in Crohn’s cases. So, she met with his old supplier, since these were the days before medical cannabis was legal in Florida, before the voters passed Amendment 2 and got him the medicine that she hoped would save his life.

She brought him cigarettes that she carefully emptied of their tobacco and substituted ground cannabis and brought them to the hospice and had him partake in the outside garden area.

His appetite increased immediately, and the inflammation in his remaining intestines died down. He began to gain weight. As he improved, he switched from smoking to taking capsules of cannabis oil. After less than a month, he was released from hospice and sent to a rehab center, then to outpatient treatment. In a matter of months, he was back to 1450 pounds, feeling stronger and ready for work.

“I was done being a burden to my family and was ready to work again,” he told me. He called up his old boss and told him he was ready to return to work. He didn’t tell his old boss what his “miracle cure” was, but he knew that he may have to eventually tell him, since it was company policy to randomly drug test employees, even though they rarely did them, unless the employee showed signs of impairment.

So, he kept his secret from his employer. His work evaluations showed excellent work habits. He always came to work on time, always put in a full day, and never had any accidents.

When Amendment 2 passed, he got his Medical Card, but kept it at home, worried that someone may see it. But he was back to work, making a decent salary, paying taxes and getting health benefits again. But the fear of testing positive for THC was and still is weighing heavily on his mind.

His coworker who had back injuries came to work on pain killers – opioids, with the full acknowledgement of his employers. Others came to work hung over from drinking the night before, and sometimes had a beer or tow at lunch, with no blow-back. But he knew that his situation was different, and he had to be vigilant.

Now that 40 states have medical cannabis laws and 10 have responsible Adult Use, the topic of cannabis use and workplace law

has been brought up more often. Many businesses have drug-free workplace policies, but testing has become an issue, because heavy users can test positive for weeks after use and even weekend users can test positive days later, even if they come to work completely sober, and totally unimpaired.

Many people in medical and legal use states use cannabis during off-duty hours. Many, like Mike, have lives that depend on their off-duty use. Paul Armentano, from NORML, noted, “Most of these people use cannabis responsibly and hold jobs and go to work like everyone else.”

Many companies have even found that barring people from getting employment, due to a positive THC test of blood, hair or urine, affected their ability to get employees. Last year, Caesars Entertainment, based in Las Vegas, Nevada, stopped marijuana screening for prospective employees. “We believed we were losing too many otherwise qualified candidates,” says Richard Broome, the company’s executive vice president of communications and government relations. “We still screen for marijuana if we have reason to believe an employee is under the influence at work.”

And that makes perfect sense. People should be judged by their performance, not their use of cannabis during off-duty hours. The courts have weighed in on this, as well. In 2017 case (Barbuto v. Advantage Sales), the Massachusetts Supreme Judicial Court said a registered medical marijuana patient could sue her employer for disability discrimination after being fired for a positive marijuana test. The court determined that employers must explore reasonable accommodations if an employee is registered for medical marijuana use to treat a condition that’s covered under the state’s anti-discrimination law.

According to the National Council of State legislators, “When it comes to off-duty medical marijuana use, the states are divided. About a dozen states prohibit employers from discriminating against medical marijuana cardholders or from firing employees for testing positive for marijuana due to off-duty use. Some of these states also require employers to reasonably accommodate an employee who needs medical marijuana to treat a medical condition—for example, by allowing an employee to start work later in the morning because she uses medical marijuana at night to treat glaucoma. Several other states, on the other hand, explicitly allow employers to fire employees for off-duty medical marijuana use. And some states don’t clearly address the issue—but courts in several of these states have sided with the employer, holding that employers can fire employees for off-duty use of medical marijuana.

Where does Florida stand? As of December of 2019, Fla. Stat. Ann. § 381.986 notes: Employers are not required to accommodate the use of medical marijuana in the workplace or allow an employee to work under the influence of marijuana. For an employer that has federal contracts, or one that has positions deemed safety-related, such as truck drivers, first responders, airline workers, drug testing can be mandatory, and those with Drug-free workplace policies can fire an employee, just for having a medical cannabis card.

But that is about to change. Bills filed in the House and Senate, HB595 and SB962 address the issue for the first time. Last year, an amendment that would protect employees was filed on the bill that allowed whole flower use, but withdrawn to assure the bills passage, which was mandated by the governor. But this year, the state legislature will try to join the dozen other states that now have employee protection laws. They include accommodations for people

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who need to use cannabis for debilitating conditions, like Mikes, but still have exceptions for safety-related positions, like transportation of hazardous materials.

There is be arguments on both sides. Reports from the Rand corporation, which note that cannabis users may have higher rates on absenteeism and workplace accidents, but don’t verify that correlation is the same as causation. For some, it is the debilitating disease that causes the absenteeism, and the lack of access to proper dosage has blocked treatment.

The there is the issue of First Responders – Police, Fire and EMS workers, who have much higher rates of PTSD from exposure to traumatic situations on their jobs. In the Tampa bay area, there were three tragedies in a three-month period. A decorated police officer, who came back to work as resource officer after the Parkland shooting demanding greater police presence, took his own life after killing members of his family, and firefighter and an EMS worker with years of service and histories of PTSD committed suicide. The current programs of meditation, therapy and other attempts did not work, but sheriffs and fire chiefs and supervisors are reticent against cannabis use during off-duty (and times when not “on call”) hours, despite research which has shown great promise in treating severe PTSD. Even the VA is now changing policy to allow cannabis therapy, even though workplace policy make block its use.

These bills will allow employers to gain and retain good employees, and employees whose lives and quality of life were regained through cannabis use, will be able to return to work or gain new employment and support their families and lead productive lives, once these bills hopefully pass.

Tourist Reciprocity to protect Florida’s VisitorsThe term reciprocity wasn’t one that very many people outside of

lawyers and police used until folks watching the evolution of cannabis laws started using it. Before that time, it normally meant adhering to the golden rule – “do onto others as others would do onto you.” But in the law, it has a deeper meaning – “a recognition by one of two countries or institutions of the validity of licenses or privileges granted by the other.” In this case, in a world where cannabis is federally illegal, but states have a crazy quilt of individual laws, it means that you can use a medical card from your state to purchase and possess cannabis in another medically legal state.

But not all states have medical cannabis reciprocity. In Florida, reciprocity currently only applies to part-time residents who live at least 4 months in the Sunshine state. Prior to the passage of SB8A, even they could not purchase medical cannabis in Florida, and after SB8a, because the application for a medical card required a Social Security card, our Canadian neighbors who stayed here for part of the year were excluded as well.

The results of a lack of reciprocity could be fatal. A woman from Michigan who has breast cancer that was being successfully treated went to visit her daughter in the Chicago area only to have her life-saving medicine thrown out when she went into Cook County hospital for treatment of a long-standing ulcer that had ruptured from the standard cancer treatment she was taking, and her tumors, which had been reduced from 2 ½ centimeters down to a ¼ centimeter, metastasized and she passed away in a few weeks, as chemotherapy hastened her demise. That was my mother.

Several states have reciprocity laws that allow visitors to purchase,

possess and use medical cannabis. Arizona and New Hampshire have a peculiar law that allow visiting patients to use medical marijuana (with a state-approved card); however, non-residents are not permitted to purchase cannabis from a dispensary.

States with legal Responsible Adult Use allow purchase and use, but due to the federally illegal status, you still cannot travel across the state border with your purchase. Does that mean that there are DEA officials waiting to grab those that dare try? Attorney Allison Malsbury has noted,” From a legal perspective, it’s very cut and dried. In practice, however, it’s very ambiguous. In practice, the chances of feds or the DEA sitting at the border waiting to catch someone – that’s just not happening. It’s not practical or worth their time.” But, Americans for Safe Access have stated, “The best law enforcement encounter is the encounter that never occurs.”

But, of the 120 Million tourists that come to Florida each year, many who have family members in their party with debilitation conditions like Cancer, MS, ALS and others often take their chances crossing into Florida by car with their medicine stowed away or take a chance with the TSA at the airport to have the chance to take a vacation and enjoy the warmth and sunshine. That includes kids from Make a Wish foundation who have been given a chance to go to Disney World, who has strong policies against cannabis use on the Disney property.

This is a great loss to the tourist and to Florida. If only 6 percent (the average amount of people who are medical users in medically legal states) it would be a huge boon to the dispensaries here. And those who forgo a Florida vacation because grandma has cancer and is using cannabis to treat it but is afraid of coming to our state on vacation and leaving on probation? That is Florida’s loss in revenue as well.

Last year, two bills were filed, House Bill 557 / Senate Bill 1238, but never got into committee. This year, for the third year in a row, I attempting to file a Tourist reciprocity bill that asks our visitors to pay a one-time $10 reciprocity fee, that would allow those with legitimate medical cards from other states to make a one-time purchase at one of Florida’s MMTC’s, for enough product to cover their time here. Such a bill could generate $70M, enough to fund VISIT Florida, the state tourist advertising program, and protect our ill and treated visitors from arrest.

Its time for our nations vacation capitol to welcome medical cannabis users from other states just as they welcome the rest of the world to visit and enjoy our Sunshine State.

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Advertising is a unique element of the business world, and advertising spend is an important decision for a business to make.

For some companies, advertising is the most fundamental part of

running a successful and profitable business. Consumers must know you exist before they can be your customers and acquiring customers is the cornerstone of growth. Alternatively, some companies have concerns about keeping their expenses low, and therefore struggle to see advertising as an investment in increasing revenue.

How then, must we view conversations about cannabis advertising in the context of government regulations?

Premise: Advertising is a fundamental element to a successful business.

Discussion: Current Florida law requires cannabis advertisement approval by the Department of Health.(1) I’d like to ask:

■ How many other businesses does the Department of Health regulate the full scope of advertisement? ■ How many people are on the team to review the applications?■ What is the transparent criteria for success?■ What are the qualifications of the people on the application

review team? ■ What are the timelines for turnaround in the decision-making

process? ■ What are the equity components to avoid monopoly and

insure equal opportunity?

A major challenge we are seeing is that a bottleneck has created an unnecessary delay in the turnaround time from application to approval. In addition, the responses that companies are receiving seem to be subjective in nature, rather than criterion referenced, opening the doors to equity questions.

Premise: Cannabis is a new industry, but advertising isn’t.

Discussion: It’s true that this is a new industry for Florida, and there is no Federal standard by which Florida might guide itself. It is essential for the growth of this sector, however, that we apply lessons learned in

other regulatory situations! Identifying problems early is essential, as is creating and implementing solutions in a timely fashion in order to maintain a free market economy.

First and foremost, it is well established that we want protections in place to avoid advertising or marketing to children. Second, we want truth and verifiable facts over misleading information or rhetoric. Third, ads should maintain respect for competitors and opponents.

Florida already has a successful, profitable industry with a similarly age restricted product: Alcohol.

Alcohol advertising is regulated by the Alcohol and Tobacco Tax and Trade Bureau, which sits under the US Dept. of Treasury - not the Dept of Health and Human Services, and not the Food and Drug Administration or Drug Enforcement Agency. Alcohol ads are not required to be pre-approved--however, it is required that ads only run to audiences that are 70% over the age of 21.(2) The Federal Trade Commission released a study within the past five years stating that 93% of all alcohol advertising is compliant.(3)

Solution: Florida state law simply says that the state regulations may

not conflict with or be more stringent than the TTB regulations.(4) This has worked successfully for alcohol advertising in Florida for decades. Let’s replicate this for the cannabis industry.

The biggest question heading into this legislative session is: why are

we allowing the government to inhibit the free market?

It’s time to implement regulating cannabis like alcohol and let our businesses make their own decisions.HL

Sources:(1) 2017 Legislature SB8-A, 3rd Engrossed(2) Advertising Laws and Regulations - TTB(3) FTC Releases Fourth Major Study on Alcohol Advertising and Industry Efforts

to Reduce Marketing to Underage Audiences Study Shows Over 93 Percent Compliance with Placement Guidelines

(4) The 2018 Florida Statues: Title XXXIV Alcoholic Beverages and Tobacco

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In November of 2016, the voters of the State of Florida overwhelmingly passed Constitutional Amendment 2 (Article X, Section 29 of the Florida Constitution), expanding the class of persons eligible for medical us of marijuana in Florida and directing the Department of Health to issue reasonable regulations for the implementation and enforcement of the Amendment.

In accordance with the Amendment’s language permitting the

legislature to enact laws consistent with the Amendment, the Florida Legislature amended Section 381.986, Florida Statutes (“Medical Use of Marijuana”) in June of 2017 to, among other things, impose standards for the production of edible products. Accordingly, edibles have been allowed under Florida law for over 2½ years, but Medical Marijuana Treatment Centers cannot produce or dispense the products until the Department of Health issues its rules.

Since the passage of Amendment 2, patients have sat by

the sidelines, waiting for the Department to issue its rules for the production of edibles, but have seen little progress beyond a “Notice of Development of Rulemaking,” with no proposed text of the actual Rule. Understandably, this has caused considerable frustration among patients, particularly in cases in which recommending physicians believe edibles to be the most effective method of administration. Licensed Florida Medical Marijuana Treatment Centers share that frustration – for obvious reasons.

So where are we; what limitations can we expect; and when do we anticipate edibles to be available to Florida marijuana patients?

Here’s what we know for now:

There has been some recent activity on the part of the Department of Agriculture and Consumer Services and the Department of Health, signaling progress despite strong opposition from anti-marijuana interest groups1 . In early 2019, the Florida Department of Agriculture and Consumer Services finalized its rules on how Medical Marijuana Treatment Centers

can obtain a license to make edibles, focusing primarily on safety from food poisoning and allergen contagion. Then on December 11, 2019, the Florida Department of Health issued a Notice of Development of Rulemaking, announcing that it would be developing rules to establish criteria for edibles to be produced in the State.

Although a draft of these rules has not been released,

some of the baseline criteria for edibles has already been set forth in Florida statutes. For example, based on the definition of “Edibles” in the Statute, we know that edibles will only be allowed to be made with marijuana oil, and no other form of marijuana. In addition, the amount of THC that can be contained in an edible is capped at 10 milligrams per serving and 200 milligrams per package.

Section 381.986 also establishes rules to prevent edibles from

being attractive to children. Specifically, edibles may not be in the shape of a human, cartoon, or animals. Edibles may also not be in a form that bears any reasonable resemblance to products available for consumption as commercially available candy, and they may not contain any color additives. Prohibiting edibles in the shape of a human, cartoon or animal seems like a reasonable standard for the prevention of childhood consumption and is not uncommon in other markets; however, the restriction on “any reasonable resemblance to a commercially available candy” might be difficult for manufacturers to meet given the thousands of types of candies currently existing. Moreover, the proliferation of candy-like edibles in state-legal markets other than Florida may pose problems for MMTCs seeking to distribute national brands. If interpreted strictly, generic shapes such as gummy rings or jelly beans will be prohibited. Manufacturers may have an easier time with other types of edibles, since foods such as brownies, crackers and cookies may be made in the same shape as other commercially available products. It remains to be seen how restrictive the Florida Department of Health will be, as the DOH have been given the authority to further determine what shapes, forms and ingredients will be allowed.

Unlike in some other markets, don’t expect to see fancy packaging and brand names on edibles sold in Florida. Florida

law requires that edibles be sealed in plain, opaque wrapping marked only with the state’s universal warning symbol. Packaging will not have any depictions of the product or images other than the Medical Marijuana Treatment Center’s logo.

Despite delays and restrictions, Florida companies are already positioning to pair with out-of-sate edibles companies to bring in already known brands that have tried and tested products once the rules are in place to do so. For example, popular edible maker Wana Brands forged a partnership with AltMed to sell Wana products exclusively in their dispensaries, and Trulieve has reportedly partnered with out-of-state edibles companies, Love’s Oven, Bhang, and Binske. These partnerships will allow Florida MMTCs to get a head start, but don’t expect a truckload of your favorite infused cookies to head this way. Given marijuana’s continued status as a Schedule I controlled substance under federal law, products may not be transported across state lines and each Florida MMTC will be responsible for the manufacture of edible products, even if under a license agreement with a recognized brand.

Additionally, only a licensed Medical Marijuana Treatment Center with a food establishment permit will be allowed to produce edibles, that is, once the rules are finally promulgated. Edibles producers will need to comply with food establishment regulations, just as any other food business would, meeting certain standards for health and safety. Although applications aren’t yet being accepted, the application is available and the steps to apply have been posted on the Florida Department of Agriculture and Consumer Services website.

While the Department of Health might attempt to speed the process along by looking to other states with established edibles programs to formulate its rules, it will also likely hear from opponents attempting to derail or slow the process even further. History with Florida’s medical marijuana program tells us that the draft rules – if we ever see them - will invariably be subject to multiple legal and procedural challenges. Nevertheless, the State’s mandate for the Department of Health to promulgate rules for edibles production means that it is only a matter of time - the question is how much longer will patients have to wait? We wish we could say.

1Opposition groups frequently point to the high potential for overdose of edibles, as well as consumption by children given attractive packaging or candy-like products. Florida Statutes address these issues with dosing, packaging and labelling requirements in additions to restrictions on the products themselves, including shape and color additives.

BY JONATHAN ROBBINS ESQ. & KRISTEN MORRIS ESQ. | AKERMAN LLP

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INGREDIENTS:4 Yellowfin tunaBlack and white sesame seeds1 14-1/2- ounce can wholepeeled tomatoes2 tablespoons soy sauce1 tablespoon wasabi powder1 tablespoon rice wine vinegar1 teaspoon onion, finely diced1 teaspoon ginger, minced1/2 teaspoon garlic, finely chopped1 teaspoon sesame oil1 tablespoon cilantro, chopped3 ounces sweet chili sauce2 Tbsp. Cannabis Infused Butter

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DIRECTIONS:Directions: Whisk together coconut milk, infused butter, curry paste, fish sauce, lime juice, tamarind liquid and sugar in medium saucepan. Bring mixture to boil over high heat. Add pineapple and shrimp and boil for 2–3 minutes, or until shrimp are cooked through. Serve hot inside pared-out pineapple half.

DIRECTIONS:Directions: Sear tuna in nonstick pan coated in sesame seeds. Refrigerate. Drain liquid from tomatoes. Finely chop tomatoes. Combine soy sauce, wasabi powder, vinegar, onion, ginger, garlic, sesame oil, infused butter, cilantro and chili sauce. Refrigerate.Thinly slice tuna. Drizzle red chili wasabi sauce over tuna.


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