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More Tracking for Medical Grows 

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July 3 is the third anniversary of the enactment of Measure 91, our adult use cannabis program, aka, why you can legally buy recreational weed in Oregon. But since 1998, we've had the Oregon Medical Marijuana Program. I've been a caregiver for numerous patients for the past 10 years. Recommending and obtaining cannabis for medical needs is some of the most important work I will ever do.

But when Oregonians passed Measure 91—although assured there would not be any changes to the OMMP—there were many. Some big ones are going into effect right about now. The biggest change is the need for (most) OMMP growers to become part of Metrc, Oregon's cannabis tracking system. It's what all facets of the recreational cannabis industry use for "seed to sale" tracking.

"I love using Metrc!" said no one, anyplace, ever, and as I have literally seen attempts to navigate it make grown men weep, this will be... interesting.

Beginning in April 2016, OMMP growers began to pay an annual $200 "Grow Site Registration" fee. Under the new rules, by July 1, a grow site with more than three patients must designate a person as the "Grow Site Administrator," who registers with the CTS and pays an annual $480 "User Fee."

The grower then needs to buy cannabis "plant tags" (45 cents each) and "package tags" (25 cents each) to tag each and every plant through harvest, and every package of leaf, trim and bud from that plant. Growers need to account for everything they are growing by, and per the OMMP: "Prior to entering start-up inventory, CTS requires that an "item category" or "strain" be created for each item that will be in the inventory." Growers then need to take an inventory of everything they have, per OMMP: "Seeds, clones, plants in any growth stage, harvested plants, usable marijuana (flower and trim), and cannabinoid items of any kind" Cool, have fun with that. Oh, and they need to buy/own a "commercial scale," for which you will need a license, which runs $41 to $800.

Per the OMMP, the GSA is "responsible for reconciling on-site and in-transit cannabis inventory by no later than the close of each business day. This means at the beginning of each day of operation, inventory recorded in CTS should be 100 percent accurate, with adjustments recorded as needed to account for waste, loss, previous entry errors or other inventory variances." Yes, 100 percent accurate every day. No problem, on it!

Growers who want to destroy plants will need to file a "Marijuana Item Destruction Request" and include their "Destruction and Disposal of Marijuana Plan." It may be as simple as grinding them up and placing them into your compost pile, or you may need to take them to a "Landfill, Transfer Station or Incinerator." To keep growers honest, OMMP "will make every effort to have staff directly witness and document destruction at the registrant's premises and to be available to witness offsite disposal. (If) ...staff are not available to witness destruction, the registrant will be required to make the marijuana items undesirable, unusable and unrecognizable...then secure and hold the destroyed marijuana material for three days during which time OMMP staff may arrive to confirm destruction" Awesome.

There is a bright spot. After July 1, eligible grow sites can sell 20 pounds annually to a processor, who may make dabs, edibles, vape cartridges, etc., or sell it to a wholesaler, who can sell to a dispensary. So, they got that goin' for them, which is nice. And Lord knows there's no excess weed on the market. Just kidding. There is.

All these steps are being implemented as a way to make sure the OMMP cannabis produced is accounted for, and most importantly for the feds, that it stays within our state's borders. But the costs and effort now required to produce cannabis for patients too ill or otherwise unable to grow their own plants will likely move more growers to leave the OMMP, which has already seen its numbers steeply decline. (In January 2015, there were 46, 601 OMMP Growers. As of January 2018, there were 25.615 in the state.)

It's yet another reason all medical and recreational users should support rescheduling, or better yet, descheduling of cannabis on the federal level.

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Speaking of Oregon Medical Marijuana Program, Measure 91

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