ADULT-USE CANNABIS PRODUCER LICENSING REQUIREMENTS (REVISED)

ADULT-USE CANNABIS PRODUCER LICENSING REQUIREMENTS (Revised)

The purpose of this rule hearing is to consider proposed draft rules regarding the processing, approval, and denial of license applications for cannabis producers in New Mexico. The rule hearing will also consider the regulation of cannabis licensees, proposed fees for corresponding license types, the plant count, canopy or square footage limit for each license type, and per-plant fees applied to licensees that are growing more than 200 cannabis plants.

Notice of Proposed Rule Making

Proposed Draft Rules

Reference Materials Used in Drafting the Proposed Rule Making

The rule hearing will be held both virtually and in-person at the New Mexico State Capitol, 490 Old Santa Fe Trail, Room 307, Santa Fe, NM 87501 on Friday, August 6, 2021 starting at 9:00 a.m.

We are now accepting public comments on the proposed draft rules. There are four ways to provide public comment on the proposed draft rules:

  • Use the text box below to enter your public comment
  • Email your public comment to ccd.publiccomment@state.nm.us
  • Submit your public comment via postal mail to:Public Comment
    c/o Robert Sachs
    P.O. Box 25101
    Santa Fe, NM 87504
  • Participate in the August 6, 2021 public hearing and present your public comment via video conference or via telephone

The deadline to submit public comment is at the conclusion of the public hearing on Friday, August 6, 2021.

Please know that all public comments will be posted on this website.

Any individual with a disability who is in need of a reader, amplifier, qualified sign language interpreter, or other form of auxiliary aid or service to attend or participate in the hearing should contact Nicole Bazzano, Executive Assistant for the Office of the Superintendent, rld.cannabiscontrol@state.nm.us or (505) 469-0982 at least seven days prior to the hearing.

To submit public comment, please enter your first name, last name and your email address along with your public comment. Required fields are marked *

You can enter your public comment in the box below or upload your public comment as an attachment. All public comments will be posted on this website. Your name will be included with your comment but your email address will not be published.

60 Comments

  1. It would be really nice to be able to walk into a bar or louVnge and be able to eat meals, mingle, and be able to consume marijuana. Social settings would be useful and I think it would allow consumers an alternative to parking lots or such places.

  2. This bill could use some more verbiage that restricts what local jurisdictions can and can’t do. Watching the last two San Juan County commission meetings, SJC commissioners are all butt hurt because “the bill is 172 pages long and only 2 pages are dedicated to local control”. These ego-maniacs don’t need any more control.

    So SJC plans to put an ordinance into effect (Ordinance 120 – Cannabis Regulation Act) which prohibits any cannabis establishment from existing less than 1000 feet from any residence, religious assembly or church, library, community center, park or government facility because “cannabis production creates a pungent odor” and “people might complain about the odor” and “I think 1000′ will eliminate or reduce the odor”. They base this not on fact, but on hearsay. Everyone who lives in the county already lives less than 1000′ from a stinky natural gas well and no one complains.

    The kicker is the way that SJC defines the term “measurement”. Apparently in San Juan County this distance is measured from “the nearest point of your property line to the nearest point of the other property line”. This means that I can’t grow 200 or less plants anywhere in my 5 acre yard because my property line, not the boundary of my grow area, is less than 1000 feet from my neighbors property line, not their home. If you do the math on this, based on a square acre with 208′ sides, this will prohibit anyone from growing that lives in a neighborhood or subdivision who lives on less than ~120 acres of land.

    This is obviously an overt method of restricting potential small businesses from popping up and attempting to make a living. I was excited about the opportunity to give it a shot, now thanks to SJC, it seems that the only way to do it is to buy a piece of commercial property with no residences or any of the other places on their list. This is yet another example of the little man being restricted from running their own small business without the need for tens of thousands of dollars in capital.

  3. S. Provisional license with contingencies: Upon written request of the applicant, the division may issue a provisional license letter with defined contingencies that the applicant must obtain documents that may be pending approval of a cannabis establishment license or must be obtained from other state agencies or local jurisdictions for the application to be considered complete. The provisional license letter shall list the remaining items necessary for the application to be complete and shall expire 3-months from the date the provisional license letter was issued to the applicant. Final approval or denial of a license shall be stated on the provisional license letter as contingent on the applicant submitting all remaining items. Such a provisional license letter shall not authorize an applicant to begin licensed cannabis activity.
    During the New Mexico Cannabis Conference, June 30 – July 1, 2021, it was communicated that the provisional license would enable companies to secure a license without the large capital outlay required for constructing a cannabis cultivation facility. Three (3) months is not enough time to build a clean, safe, and secure indoor cultivation facility. We estimate, with supply chain impacts from Covid on materials and travel, it will take a minimum of ten (10) months to complete our facility for certification inspection. I believe it best to extend the time limit to twelve (12) months to give everyone ample time to complete their facilities. During the IvestiNM Webex, July 29, 2021, Bobby Sachs talked about promoting the cannabis industry in New Mexico. He assembled a panel of SMEs to provide the needed information for starting a cannabis business in New Mexico. I truly believe the collective sentiment was to assist, in all ways, individuals looking to enter the cannabis industry in New Mexico. Time is one of the most valuable commodities in the business world. As such, please consider extending the time limit for satisfying the provisional license requirements. This would in fact, assist all citizens of the great state of New Mexico who wish to enter the cannabis industry.
    Thank for the opportunity to voice my opinion on the proposed Cannabis Control Board rules.

  4. Hi, I was unable to participate in the last meeting regarding Santa Fe’s zoning rules; I just want to say keep these things out of the plaza and downtown areas in SF. It’s too iconic and historic and beauitfully traditional. Anywhere else is fine, but not in the areas that define NM. You wouldn’t have a weed shop at the Taos pueblo, and you shouldn’t allow ANYONE to open one downtown Santa Fe.
    Thank you!

  5. To “Mystery X” – I would suggest before providing advice to a business that is clearly and intentionally trafficking without a license, you should actually read the law:

    Pursuant to the CRA at § 26-2C-28 NMSA 1978, the unlicensed sale of cannabis is defined along with related criminal penalties and includes the following: “A. As used in this section, “traffic” means the:

    (1) distribution, sale, barter or giving away of cannabis products; or(2) possession with intent to distribute, sell, barter or give away cannabis products. B. Unless otherwise provided in the Cannabis Regulation Act or the Lynn and Erin Compassionate Use Act [Chapter 26, Article 2BNMSA 1978], it is unlawful for a person without a license to intentionally traffic cannabis products.. . .D. Except as otherwise provided in[26-2C-14NMSA 1978] of the Cannabis Regulation Act, a person eighteen years of age or older who violates Subsection B of this section is guilty of a misdemeanor and shall be sentenced pursuant to the provisions of Section 31-19-1NMSA 1978.E. A person eighteen years of age or older who violates Subsection B of this section and who conducts unlicensed cannabis product sales from a building, room or other area open to the public in a manner that would lead a reasonable person to believe that the area is a cannabis establishment licensed pursuant to the Cannabis Regulation Act is guilty of a fourth degree felony and shall be sentenced pursuant to the provisions of Section 31-18-15NMSA 1978.”g.

    The CCD has not yet permitted the sale of commercial cannabis products. See § 26-2C-6(K) (“The division shall determine when retail sales of commercial cannabis products begin[.]”).h.

    § 26-2C-25, detailing “personal use of cannabis,” only permits “transferring,
    without financial consideration
    , to a person who is twenty-one years of age or older not more than the amount of cannabis lawfully purchased and obtained pursuant to the [CRA] or the [LECUA].” (Emphasis added).i.

    “Financial consideration” is defined as “value that is given or received, directly
    or indirectly
    , through sales, barter, trade, fees, charges, dues, contributions or donations”. § 26-2C-2(BB) NMSA 1978 (emphasis added). j.

    The CRA currently requires that all cannabis products shall be derived from a source originating within New Mexico. § 26-2C-37 NMSA 1978.

    Man up and spend the time and effort to get licensed and be a legitimate business. We do not want nor need bad actors in this space.

  6. The fact the New Mexicans have been waiting for the legalization for years in hopes of economy regeneration, the regulations for an entrance entrepreneur are ridiculous and therefore will only cater to those with money and who are already established in the industry. Once again neglecting the chance for local New Mexicans to get on their feet and gain access to new industry. The sections in this proposed draft are directed more towards a state that is economically stable with population to support. New Mexico is the exact opposite with no thought process on how to individually and specifically go about marijuana legalization. Extremely disappointing for native New Mexicans trying to get a foot in the door. I truly hope the drafts are revised especially for start out companies with no grounds for competition with some of the states largest producers. Without revisions, not only are you shutting down dreams of many to start their own business but encouraging the illegality to rise and pushing the market to outside states. Once again, not aiding the state of New Mexico. We, the state, rank last in everything for a reason, let’s make a difference and do good for the state.

    Respectfully,
    McKenzie Ulibarri
    07-29-2021 17:07

  7. Hi – I’m hoping to get a little clarity on the requirements listed in section 16.8.2.15. Could you please go into more detail around what steps should be taken or what documentation should be provided in order to become certified and/or meet the requirements?

    For example, section (16) states: certification the applicant will adhere to cannabis transport requirements pursuant to the Cannabis Regulation Act, the Lynn and Erin Compassionate Use Act, or division rules, including the transport of unprocessed cannabis or cannabis products to other cannabis establishments;

    How should we best prove we are certified to adhere to transportation requirements?

    Thanks,
    Cole Terry

  8. July 27, 2021

    Linda M. Trujillo
    Superintendent
    New Mexico State Regulation and Licensing Department

    Dear Superintendent Trujillo,

    As industry leaders in cannabis and pathogen genomics, we have spent decades working with quantitative polymerase chain reaction (qPCR) and culture-based methods for the detection of microorganisms. We are experts in the field with over 40 patents related to PCR and DNA sequencing based methods for detecting microorganisms. Kevin McKernan, Chief Scientific Officer at Medicinal Genomics Corp. (MGC) managed the Research and Development team for the Human Genome Project at the Whitehead Institute of MIT. He has over 41,097 citations related to his work in this field. Our scientists recommend the microbial testing specifications that will ensure that cannabis manufactured products are safe for patients and/or consumers. Due to our concerns for public health, we feel that the Cannabis Control Division (CCD) should consider modifying your present draft quality assurance testing rules to include a specific list of required microbial tests to reflect ongoing efforts at the AOAC, USP, CDC and FDA, which are consistent with our findings at MGC.

    The presence of microorganisms is common in natural products, such as cannabis flowers. One must be able to differentiate between harmless microbes ubiquitous in nature and those that are human pathogens that have contaminated the cannabis plant and/or manufactured products. Examples of species specific human pathogens that have been detected in cannabis are Shiga toxin producing E. coli (STEC), Salmonella spp. (all species are pathogenic), Aspergillus flavus, A. fumigatus, A. niger, and A. terreus. Total microbial count tests (“indicator tests”), such as Total Aerobic Microbial Count (TAMC) and Total Yeast and Mold Count (TYMC), do not test directly for the presence of species specific human pathogens. The American Herbal Pharmacopoeia’s Cannabis Inflorescence Cannabis spp. monograph [1] states that total count tests with their corresponding action levels, such as TAMC and TYMC, must never be used to pass or fail a cannabis sample. The total count result does not provide any information on the presence of any pathogenic microorganisms in the cannabis sample, which may cause harm to patients.

    Current required tests for microbial contamination in states that have adult-use and/or medical cannabis programs vary among the states. Many states require a combination of some of the following tests: TAMC, TYMC, total coliforms, total bile-tolerant Gram-negative bacteria, and total E. coli or total pathogenic E. coli with various maximum allowable limits for each test and each cannabis product type. All microbial tests have maximum allowable limits as colony forming units (cfu/g), which is the number of colonies that grow on the surface of an agar medium plate. Lastly, other states, such as California, require species specific tests for Shiga toxin producing E. coli (STEC), Salmonella spp., Aspergillus fumigatus, A. flavus, A. niger, and A. terreus with a maximum allowable limit of zero (0) cfu/g of product.

    Title 16, Chapter 8 (Commercial and Medical Cannabis), Part 2, Section 16.8.23(A) Quality assurance testing by the division states that “The division or its representative may conduct quality assurance sampling and testing of cannabis or cannabis products, and may require a licensee to provide samples of cannabis or cannabis products for this purpose.” Moreover, Subsection (B) Complaints states “If the division receives a verified complaint regarding the presence of mold, bacteria, or another contaminant in cannabis or cannabis products, or if the division has reason to believe that the presence of mold, bacteria, or another contaminant may jeopardize public health and safety, the division or its representative may conduct an inspection and may require a licensee to provide samples of cannabis or cannabis products for testing by the division.”

    Medicinal Genomics suggests that the CCD modify the draft rules to include a list of required microbial tests that will protect public health and safety. We recommend that the Cannabis Control Division modify the regulations for required microbial testing for adult-use and medical cannabis and cannabis products to include only specific pathogen species tests. These six tests are:
    1. Salmonella species
    2. Shiga-toxin producing Escherichia coli (STEC)
    3. Aspergillus flavus
    4. Aspergillus fumigatus
    5. Aspergillus niger
    6. Aspergillus terreus

    Since these microorganisms are harmful to humans and the CCD wants to ensure safe products for patient and consumer consumption, the action levels for all six tests should be “None detected/gram”. The states of California and Alaska have either required the species specific human pathogen tests listed above or have drafted regulations to replace Total Count tests with the species specific pathogenic tests noted above.

    Medicinal Genomics also recommends that the the required microbial testing for adult-use and medical cannabis and cannabis product rules should include a statement concerning allowable methods to read:
    1. A validated method using guidelines for food and environmental testing put forth by the USP, FDA, and AOAC Appendix J and cannabis as a sample type; or
    2. (i) Another approved AOAC, FDA, or USP validated method using cannabis as a sample type.”
    NOTE: “Another approved AOAC, FDA, or USP validated method using cannabis as a sample type” may include molecular methods, such as qPCR.”

    The reasons for this recommendation are outlined below.
    Currently there are limited AOAC, FDA, or USP approved species specific pathogen testing methods for cannabis. Medicinal Genomics released the first version of our SenSATIVAx® (DNA extraction) and PathoSEEK® (qPCR assay) Manufacturer Validation Document in 2017. These method validations use cannabis as the sample type. At that time, there were no official guidelines published by any regulatory body describing how to validate a method for detecting microbes in the presence of a cannabis matrix. Due to this lack of available guidelines in the cannabis industry, our scientific team referenced guidelines for food and environmental testing put forth by the USP, FDA, and AOAC Appendix J. We continually add data to this document as we release new assays or make improvements to current assays. We are currently on version 31 of this document[2]. In addition, MGC’s methods are currently going through additional validation according to AOAC’s Standard Method Performance Requirements (SMPRs). AOAC has released 3 SMPRs for species specific testing for the species specific pathogens listed above (see #1-3 below).
    Detection of Aspergillus in Cannabis and Cannabis Products
    https://www.aoac.org/wp-content/uploads/2019/10/SMPR-2019_001.pdf
    Detection of Salmonella species in Cannabis and Cannabis Products https://www.aoac.org/wp-content/uploads/2020/07/SMPR-2020_002.pdf
    Detection of Shiga toxin-producing Escherichia coli in Cannabis and Cannabis Products
    https://www.aoac.org/wp-content/uploads/2021/02/SMPR-2020_012.pdf

    Medicinal Genomics is a member of AOAC’s Cannabis Analytical Science Program (CASP) Microbial Contaminants Working Group. The goal and objectives of this working group are to
    Develop Standard Method Performance Requirements (SMPR) for cannabis and hemp
    Extend a Call for Methods for each of the completed SMPRs
    Empanel an Expert Review Panel to review candidate methods
    Deliver consensus-based validated Performance Test Methods (PTMs) & Final Action Official Methods for the cannabis industry
    NOTE: Medicinal Genomics will have a single AOAC Certified qPCR PTM for the detection of the 4 Aspergillus species by August 2021 and a single AOAC Certified qPCR PTM for the detection of Salmonella spp. & STEC by September 2021.

    The primary advantage of using qPCR detection assays are that they are designed to identify unique specific DNA sequences either shared by an entire “group” of bacteria, such as all Salmonella species or a specific genus and species, such as STEC or the 4 different pathogenic Aspergillus species. If the unique sequences are present, then the qPCR test will detect it. Therefore, a qPCR test is very specific, very sensitive, and possesses a rapid turnaround time (6 hours) vs. plating methods that are less specific, less sensitive, and has a very slow turnaround time of days for colonies to form on a plate.

    Furthermore, there are additional major disadvantages of using plating methods to detect species specific bacterial and fungal pathogens.
    The cannabinoids, which represent 10-20% of the cannabis flower by weight, have been shown to have antibiotic activity. Antibiotics inhibit the growth of bacteria in plating methods. Salmonella and STEC bacteria are very sensitive to antibiotics, which may lead to a false negative result.
    Plating methods cannot detect endophytes, which are fungi that live a part or all of their life cycle inside a plant. Examples of endophytes are the species specific Aspergillus pathogens and Fusarium. Methods to break open the plant cells to access these fungal endophytes for plating methods also lyses these fungal cells (killing these cells in the process). Therefore, these fungal endophytes will not be able to form colonies in a plating method.
    Selective media for fungal plating methods, such as Dichloran Rose-Bengal Chloramphenicol (DRBC) reduces fungal growth; especially Aspergillus by 5-fold. This may lead to a false negative result for this pathogen. Moreover, DRBC medium is typically used to reduce bacteria; it comes at the cost of missing 5 fold more yeast and molds than PDA + Chloramphenicol or molecular methods. Please see study results from the AOAC emergency validation. [3]

    Respectfully,

    Sherman Hom

    Sherman Hom, PhD
    Director of Regulatory Affairs
    Medicinal Genomics

    References
    American Herbal Pharmacopoeia’s Cannabis Inflorescence Cannabis spp. Monograph
    https://herbal-ahp.org/online-ordering-cannabis-inflorescence-qc-monograph/

    MGC Validation Document
    https://1280717.app.netsuite.com/core/media/media.nl?id=5910362&c=1280717&h=6e4d1cce15d1eae41733&_xt=.pdf&fcts=20191014094610&whence=

    AOAC TYM Study: Whole genome sequencing of colonies derived from cannabis flowers & the impact of media selection on benchmarking total yeast & mold detection tools
    https://help.medicinalgenomics.com/hubfs/White%20Papers/WGS_of_colonies_derived_from_cannabis_flowers_5-14-21.sbmt.pdf

  9. To the guys who are getting hassled down south, you don’t do trades in the same building. If you are going to do trades, you have to have a separate place that does the trading, different from the place that does the selling of merch or trinkets. Sell the trinkets, and tell them some guy down the way really loves them, and then have that guy gift bud to those with the purchased gift. That’s how the Japanese get through the gambling laws in the pachinko parlors. I dare the law to go after you with that… because you aren’t breaking any laws or going against anything written. If they try to attack you, just turn around and sue them. Believe me, the public will be on your side after these bogus restrictions. Not your fault they suck at writing bills.

  10. Public Comment
    By Shanon Jaramillo
    Founder of SeedCrest, LLC
    shanon@seedcrest.io

    7/26/2021
    Attention: Robert Sachs & Superintendent Linda Trujillo
    P.O. Box 25101
    Santa Fe, NM 87504

    Dear Mr. Sachs & Superintendent Trujillo,

    My name is Shanon Jaramillo. I am the Founder and CEO at SeedCrest, LLC, formerly known as Cannabis NM Staffing, LLC. We are Software as a Service or SaaS company providing solutions for the workforce and licensed cannabis businesses in special skills workforce training, safety, and health training, as well as a reporting mechanism for licensed cannabis companies to provide virtual compliance and brand training to their employees. We offer the ability for the licensed cannabis producers and the state CRAC/CCD to access reports on all employees across the state through our training and tracking capabilities and are positioned to help with the gaps of this type training needed to help with the infrastructure and capacity building needed to produce safer outcomes in the community. We also develop and license curricula through colleges, you may have heard of our partnership for the state’s first accredited curricula now offered through Northern New Mexico College.

    As a former Marijuana Working Group Member under our Governor, Michelle Lujan Grisham and as a partner with college and state officials I come to you to ask you to address the regulation of cannabis licensees and the language about employee safety and health training. As the marketplace grows the demand for a safer workplace grows along with the need for more standardized special skills industry safety and health training
    I want to flag Superintendent Trujillo, the CCD and the CRAC and ask that you prioritize the safety and health of New Mexico as well as the safety of the small businesses and their employees by putting mechanisms in place that allow a more streamlined or virtual process of reporting of Safety and Health for those employees working with Cannabis Producers per the regulations. In an at will hiring state such as New Mexico we have many people who will blindly enter the field without education or standard safety training. With limited funding and manpower behind this effort at the state level technology can play a big part in providing solid DATA on the safety and health over the 11,000 PLUS jobs that we will create in the next 5 years. Putting this in place now will save the state and many of these companies from accidents and license losses or litigations from harmed employees who are privy to in house training from these companies only per the regulations. I find that for the past 14 years the grandfathered cannabis establishments have only been able to offer little more than HIPAA, Point of Sale or Brand training save 1-2 brands that I can officially point to who have full training programs and that the cost of doing business and paying taxes and government fees often supersedes these companies’ ability to hire Compliance Officers who can create materials standard to the process. When you combine that with the quickly growing marketplace the need becomes glaring for the workforce and small businesses to have guidance and state support.

    Below are my suggested cost neutral solutions for you to consider.

    Revisions proposed around this HIGH RISK & LIABILITY ISSUE:

    16.8.2.10 SECURITY AND LIMITED-ACCESS AREA: Licensees shall comply with the security requirements set out in this rule to ensure that licensed premises and limited-access areas, including a vault, are secure.

    K. Licensee identification badge requirement: Licensees shall issue a laminated or plastic-coated identification badge to all agents, officers, or other persons acting for or employed by a licensee, which shall, at a minimum, include the licensee’s “doing business as” name and license number, the individual’s first name, an employee number exclusively assigned to that employee for identification purposes, and a color photograph of the employee that clearly shows the full front of the employee’s face and that is at least 1 inch in width and 1.5 inches in height.

    NOTE: The Medical Cannabis Industry had a workers permit that they needed up until last month, called the MCP Id Card + Requirements and an application that can be added to this regulation so that we do in fact have people working in the field licensed to work for patients and to work in recreational simultaneously. Topics and Certificates are needed in various states engaging in Medical and Recreational Cannabis Sales and Jobs.
    – Please consider that this is your mechanism to add the authority over this tracking where OSHA and NMED are not involved yet due to Federal Status of Cannabis and lack of funding.

    16.8.2.20 Cannabis Producers Policies and Procedures
    Notice parts 1 (a) and (b) Employee Health and Safety Training materials

    Please Clarify: what does that language mean to the producers? Is there a standard of topics or trainings coming from you or the CRAC that you are looking for them to have or is every producer going to do whatever they can afford then show you? This requires more clarity. ***

    *** Needed according to the research for Producers is Farm or Indoor Grow Safety, Security and Health Training (the plant can cause several reactions and some workers find this out the hard way and have to be replace but yet were never informed about this before taking the job – we have to provide the risks to these people), Courier Safety, Robbery and Active Shooter Training, Sexual Harassment, Lynn and Erin and Cannabis Regulations Act, Plant Biology, Ethics for Cannabis Growers and Trimmers. Sometimes these people fill their gloves with product and go home for example. I ask you to prompt a standard and standard set of trainings that are needed to empower a more successful economic outcome from the ecosystem & Marketplaces we are creating through cannabis ***

    The CRAC can add that into things so that standards can appear through 3rd party trainers, educators and those who have the capacity to train and report or give capabilities for your Licensees to train, track and report for to you or your government to have an easy log in to just pull the records on these systems.

    The training requirements in this section can be reported on or tracked by the 3rd party educators that you have doing the Cannabis Server Permits. When the CRAC writes this part up they can add that in and if you amend how this is monitored then you will have created a safer industry with just those few prioritized revisions.

    Section 16.8.2.28 Monitoring of Licensee to include a section I. Quarterly Employee Safety & Health Training Reports. This or something like this can become the “mechanism” or the “authority” of how you will monitor and track the safety and health of this exploding workforce and marketplace on behalf of the state and from there you can add in the Training more clearly through the CRAC and further council as things set up.

    A. Monitoring (of compliance)
    B. Record access and review
    C. Access to premises
    D. Monitoring to law enforcement
    E. Report to law enforcement
    F. Financial records
    G. Audit
    H. Quarterly producer reports
    I. Quarterly employee safety & health training reports

    I want to propose that the RLD, CCD, and CRAC come clear on a plan to use one or several 3rd parties who have tracking and learning management capabilities to oversee the outcomes and the training for Safety and Health of this industry just like you do with the Seed-to-Sale software like Bio-Track and Metric for example.
    Refer to the outcomes in these articles that we want to avoid going forward. I had placed some of these people in the field through my brand Cannabis NM Staffing. So, trust me when I say the training needs streamlined oversight and tracking mechanisms. A lot of long-time employees will tell you that they never took a safety course or an ethics class, but that they had to self-review the Lynn and Erin Compassionate Use Act. As a community educator I do not view this as a means of training nor providing outcomes for safety and health.
    – New Mexico rules for security at marijuana businesses less strict than other states
    – Explosion rips through medical marijuana facility
    – October of 2020 our state made High Times article for injuring 2 in a lab explosion
    – NM leaves med. cannabis security specifics up to producers

    I wish you well on your efforts to work with the community on these regulations.
    Thank you for allowing and considering my comment and solutions for the cannabis producers and workforce of New Mexico.
    Sincerely,
    Shanon Jaramillo
    CEO SeedCrest, LLC
    http://www.seedcrest.io
    shanon@seedcrest.io

    Public Comment from Shan Jaramillo for August 6th hearing with CCD on Cannabis Producer Regulations

  11. Im curious as to why Medical users needed at obtain a license to grow plants in the past, and now the general public is allowed to grow up to 12 plants per household without a license or fee? Why didnt the state take this opportunity to charge a small fee for a personal grow license? It looks like the state missed out on a huge revenue stream! Or was it that the state felt that the business side of producers should bear the brunt of the fees?

  12. In regards to section 16.8.8.8 A. (4) flowering stage begins when a cannabis plant starts blooming, including preflowers with pistols that are visible, and lasts 6-8 weeks.

    I suggest you strike the word preflower and replace with flower formation or another appropriate phrase indicating the flower formation itself that implies bloom rather than a ‘preflower’. A preflower by definition can show up during the vegetative stage of any cannabis plant and are often seen on clones. This could lead to confusion on what makes up a ‘mature’ plant count. A single preflower on several nodes or intersections with pistols showing by this language could imply bloom when the plant is still vegetative or a clone. Seeing as how mature plant count is based off this language I believe the need to be clear is appropriate.

  13. Why are the requirements for licensing the same for microbusinesses as they are for others? Wasn’t the intent of a microbusiness to promote entrepreneurs and allow average new Mexicans a chance to get into the industry?

  14. Yeah I got a comment, maybe even two, right here between my index and ring fingers

  15. With 5 weeks to submit, Where are the applications?

  16. Ultra Health worked with MPG Consulting to produce the study for New Mexico. Who do you think will get the biggest benefit package? As stated in the Cannabis Business Times, Ultra Health will be spending $20 million to expand, and in the past years purchased 200 acres with 1000 acre feet of water rights and added 150 acres with 750 acre feet of this year in Tularosa, NM. They are building a 225,000 square ft. building in southern part of the state for production, R&D and distribution. They plan to have 50 retail dispensaries by the fall of 2022. Do you think this was a done deal? The state presently has 33 producers for medicinal. What percentage of plant allocations for adult usage will be for small farmers and individuals who want a retail location. As usual, in the land of Billy the Kid, the state had a plan, but unfortunately it did not include New Mexicans, that have been in the state for a long time and struggled, paid for water and never received during drought times. Small farmers have a difficult time competing with large farms, and now when we believed their may be a chance of making a decent living, the State of NM has a bigger plan, that will not include many of us.

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