Greenway Magazine - June/July 2019 by Greenway

WOMEN MAKING WAVES From every corner of this emerging industry, women are making waves.

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GET TO KNOW

LYNDALL FRAKER A former state representative was tapped to lead the creation of one of the largest state divisions in recent history - and he's doing it all with a smile on his face.

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P.19 RULES FINALIZED

RULEMAKING ISSUE ISSUE #1 JUNE/ JULY 2019

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Calendar events can be emailed to calendar@mogreenway.com M OGREENWAY.COM

PH OTO OF TH E M ON TH Ashley Markum (a Greenway Woman to Watch) with her son, Ayden. Ayden is the namesake of Ayden's Alliance. In a mogreenway.com story about the upcoming Super Hero Meet Up benefit on June 24, Karin Chester says Ayden "changed everything" for her activism. This photo is from a MoCannTrade Monthly MeetUp. PHOTO/CHRIS SMITH.

CO N TEN TS

IN THE NEWS

10 SEED -TO -SA L E: W H AT' S GO I N G O N ?

14 SECU RI N G TH E L EGA L M A RK ET Data and security systems, oh my. Security systems may seem like sci-fi, but they're far from it - and required by rules and regulations. You might just be amazed by what they can do.

13 CST and Cova form part nership

17 18, 58 B Y TH E N U M B ERS

34 GET TI N G TO K N O W LYN D A L L FRA K ER The state rep turned division director sits down with Greenway, talking JFK, prayers, hanky-panky, and teambuilding.

44 W O M EN M A K I N G W A V ES A closer look at the Women to Watch series and some of the women leading the development of the industry.

57 V I SI TI N G A CA N N A B I S CL I N I C A patient's guide from two doctors

Key considerat ions when choosing a POS

19 TH E RU L ES Read the emergency rules shaping the industry Content manager Brandon Dunn highlights his most referenced lines. Included: bonus point map.

36 TH RO U GH H I S L EN S: CH RI S SM I TH

56 W H AT IS TH E D IFFEREN CE B ETW EEN H EM P A N D M A RIJU A N A ? Hemp oil guru Leigh Zarda Carr breaks down the basics.

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in t he news 250 0 year old t ombs suggest hybr ids gr ow n t o incr ease THC

Cont r act r eleased for facilit y applicat ion scor er s

Cannabis is one of the oldest cultivated plants in Eastern Asia,where it has been grown for grain, fiber, medical, recreational, and ritual purposes for thousands of years. Earlier this month the American Association for the Advancement of Science published a paper authored by Meng Ren, Zihua Tang, Xinhua Wu, Robert Spengler, Hongen Jiang, Yimin Yang, and Nicole Boivin. The paper details an analysis of an archeological site where ten wooden braziers, containing stones with obvious burning traces, were exhumed from eight tombs at the Quman Cemetery (also known as Jirzankal Cemetery) on the Pamir Plateau in Central Asia. The cemetery itself dates to approximately 2500 years ago and contains material culture that links the occupants to indigenous peoples further west in the foothills of the mountains. Wild cannabis grows freely across many of the cooler mountain foothills from the Caucasus to western

The Office of Administration posted a request for proposal for bidders to submit their proposals in an effort to secure an entity to grade and score facility applications for the medical marijuana program in Missouri on behalf of the Department of Health and Human Services. The state describes the RFP as an attempt to, "obtain the services of an independent contracting firm to blindly review and score Medical Marijuana Facility Applications for the Missouri Department of Health and Senior Services?Medical Marijuana Regulatory Program." The application contractor is required to The state asks for contractors to have experience complete the evaluation and provide scoring working with Medical Marijuana Programs in other results for the facility applications in the states within the last three (3) years and to have following order and by the dates shown for the completed three (3) projects within the past five (5) first round of Medical Marijuana facility years that involve providing one or more of the applications. following on a similar scope and scale with other organizations of a similar size: - Lab Testing Facilities ? September 15, 2019 a.General consulting services, b.Facility application scoring or review, - Cultivation Facilities ? October 30, 2019 c.Audits, d.Rate setting, - Manufacturing Facilities ? November 30, 2019 e.Actuarial valuations, and/or f.General procurement management services. - Dispensaries ? November 30, 2019 Perhaps the most important parts of the document for those in the industry were a detailed explanation of the state's Scoring Requirements and an outline of exactly when and in what order facility applications will be scored.

China, but cannabinol (CBN) levels in most wild plant populations are low.

Proposals will be accepted by the state until June 21 at 2:00 p.m.

An approximately 20-mg sample of wood was

Highlights are listed online at mogreenway.com. You can view the full 77-page PDF online.

collected from each fragment of the wooden braziers, the outside was used as a control and contained no signs of interaction with the cannabis plant. The burnt

Ret ail chains and gr ocer s br ing

residue inside the braziers was tested separately. According to the researchers that made the discovery, relatively equivalent amounts of tetrahydrocannabinol (THC) and cannabidiol (CBD) would be expected for

CBD sales t o Missour i

wild cannabis plants, but were not detected in the

Dierbergs, Kroger, GNC, and Ulta are among the growing list of retailers bringing CBD into retail locations

burning residues. Instead, the cannabinoids detected

and online sales, but separating them from the pack is their presence in the Show-Me State.

on the wooden braziers are mainly CBN, showing a much higher level of THC and little to no CBD presence.

Dierbergs, owned and operated in Missouri (with two locations in the Greater St. Louis area of Illinois), rolled out sales starting early in June, while Kroger the nation?largest grocer, announced plans in mid-June to begin rolling out topicals onto shelves later this year, with no firm date set in the initial announcement.

This suggests that the cannabis used in the Quman Cemetery samples may have been domesticated and hybridized to maximize the desired traits in the plant. Researchers stated that while other recent discoveries from burials in the Turpan Basin in northwest China,

GNC and Ulta are two of the most identifiable brands offering CBD sales online and in retail spaces including Missouri. Other well known brands including: Rite-Aid, Walgreens, CVS, Urban Outfitters and others, offer CBD sales in select locations, but do none of those retailers have crossed into Missouri yet.

suggest medicinal uses these discoveries do not

New York investment bank Cowen & Co. released a study on the CBD industry estimating the CBD market to

reveal how the cannabis plant was used.

grow to $16 billion by 2025.

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in t he news (cont inued)

Cit ies dr ag feet on set back r educt ion week s befor e applicat ions can be submit t ed A public listening session in Kansas City Wednesday left potential medical marijuana facility license applicants uneasy, looking at a calendar with barely 8 weeks left for the town to act on reducing buffer zones from churches, schools, or daycares. Article XIV, created by Amendment 2 in November 2018, sets a 1,000-foot maximum limit statewide for facilities to be set back away from churches, daycares, and schools. Local governments can reduce the distance. Kansas City municipal staff showed an interactive map of Kansas City with church, daycare, and school locations, demonstrating what a 1,000-foot vs. 750-foot setback would make available for applicants to target for potential facility locations, including dispensaries. A 1,000-foot setback left a rare few regions city-wide to open a facility in the state's largest city, while 750 feet made few more available.

Banker s associat ions plea for r efor m The Missouri Bankers Association joined 50 other state bankers associations in a banner call for the Senate Banking, Housing and Urban Affairs Committee to find legislative solutions for legal cannabis businesses. In their letter to the committee the associations stress urgency stating, ?there are broader public policy questions surrounding cannabis legalization that merit debate, but we ask that you focus narrowly on the urgent banking problem at hand, which is within your power to resolve.?

On facility applications, the state asks applicants for addresses of facilities, including binding documentation that the location is arranged to house a facility. This can come in the form of purchase documentation, letters of intent, or lease agreements with licensing contingencies. Attendees of the Wednesday session were told that a reduced setback could get out of the planning commission by July 18 perhaps even later, which would leave applicants barely two weeks to secure a legal location for their application(s) before the Saturday, August 3 opening of applications. Some of the 70+ attendees of the Kansas City session told Greenway they were concerned that city staff was unaware of the incredibly tight timeline facing applicants hoping to develop their medical marijuana facilities in the city. Applications will be accepted by the Department of Health and Senior Services from Saturday, August 3 to Saturday, August 17, before the applications are assessed by state-contracted application scorers. Scorers will complete the assessments in phases per each facility application type (cultivation, manufacturing, dispensing, or testing). Licenses are to be awarded by December 31, 2019. Kansas City is primarily in Congressman Emanual Cleaver 's district. Parts are in Congressman Sam Graves' district, which also encompasses Lee's Summit and most of north Missouri. Each congressional district has approximately 710,000 residents. Amendment XIV specifies that there must be at least 22 dispensaries in each congressional district. With 24 dispensaries set to be licensed by the state to operate, that leaves at least 24 Missourians scrambling in Kansas City for two weeks selecting facility sites for development. Manufacturing and cultivation facility location restrictions are based on population, as opposed to the congressional district, per the constitutional amendment. Most municipalities, like Lebanon and Jefferson City, are still in the committee and public comment period of their setback planning, like Kansas City. Several cities, including Joplin, have ordinances before the city council to be determined by a council vote as of the writing of this article. However, other towns, such as Kirksville, St. Louis, Blue Springs, Trenton, Chillicothe, and Nixa, have already approved some stage of setbacks at the municipal level. If a daycare, school, or church moves into a setback buffer zone, thought leaders say a facility would not have to relocate due to grandfathering policies.

USPS publicly r olls out new policy t o mail hemp The U.S. Postal Service (USPS) released an expanded policy update last week stating that hemp products are legal to mail. While the agency remains cautious in its wording and specifies conditions to the mailing of hemp derived products, it remains a large step forward. While USPS officially began accepting hemp items in March after the release of an internal memo, it made public its guidelines on what can be legally mailed this month:: ?Hemp and hemp-based products, including cannabidiol (CBD) with the tetrahydrocannabinol (THC) concentration of such hemp (or its derivatives) not exceeding a 0.3 percent limit are permitted to be mailed only when: a. The mailer complies with all applicable federal, state, and local laws (such as the Agricultural Act of 2014 and the Agricultural Improvement Act of 2018) pertaining to hemp production, processing, distribution, and sales; and b. The mailer retains records establishing compliance with such laws, including laboratory test results, licenses, or compliance reports, for no less than 2 years after the date of mailing.?

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in t he news (cont inued)

Legal bank ing bills and not es Missouri-based Triad Bank has publicly announced its support of and intent to permit banking for marijuana businesses in the state of Missouri. President and CEO Jim Regna, has stated that logistically it won?t be possible for Triad to serve all of the cannabis businesses in Missouri and will be selective about who it selects as clients. Choosing mostly to deal with clients with established history in business and compliance fields. The House Appropriations Committee approved the fiscal year 2020 Financial Services and General Government bill which includes a provision protecting banks serving lawful cannabis businesses in states with legal medical and recreational use programs from federal financial regulators, but does not

Agr icult ur al Omnibus await s Gover nor ?s appr oval

offer any protection from the U.S. Department of Justice. The bill was approved by a vote of 30-21. Unlike the SAFE Banking Act, the provision would be in effect only for the next fiscal year. The SAFE (Secure And Fair Enforcement) Banking Act now has the support of nearly half of the members of the House (206 representatives) and enjoys broad bipartisan appeal, but lawmakers are considering

A bill that cleared the legislature just prior to the end of session sits on Governor Parson?s desk awaiting his signature.

introducing amendments to garner more support from traditional conservatives by extending banking

The bill, championed by state Reps. Rick Francis

protections to hemp and CBD businesses. Other amendments may include blocking regulators from

and Dan Shaul and Sens. Denny Hoskins and Mike

pursuing the gun and payday loan industries.

Cunningham, modifies laws related to hemp production repealing much of Missouri?s prior statutes regarding hemp, bringing state statute in

MoCannTr ade host s medical mar ijuana r ules seminar

line with the federal farm bill, and repeals all acreage limitations from the Industrial Hemp Program, and also creates the ?Pesticide Education Fund?, which shall be used to provide funding for pesticide applicator certification programs, pesticide education programs, and pesticide waste and container disposal programs. This provision was especially interesting to potential medical marijuana cultivators who were

With aspiring medical marijuana patients, caregivers and business owners soon able to apply for state licenses, the Missouri Medical Cannabis Trade Association (MoCannTrade) invites the public to a June 25 seminar at the KCI Expo Center in Kansas City.

concerned with pesticide drift. The bill becomes law regardless of the Governor ?s signature on August 28th.

The daylong event will feature regulatory updates on the emergency rules enacted on June 3 to implement Article XIV, a constitutional amendment Missouri voters overwhelmingly approved in November. Lyndall Fraker, director of the state?s medical marijuana program, will deliver the keynote address and answer questions about the application process. Two tracks are planned: one for prospective owners, operators, managers, investors and industry service providers, the other for caregivers and patients, including those interested in cultivating their own medical cannabis. ?There?s intense public interest in medical marijuana in this state, and the fast-moving regulatory and compliance landscape demands we pay close attention,? said Andrew Mullins, executive director of MoCannTrade.? As Missouri exponentially ramps up its program in anticipation of awarding nearly 350 medical cannabis licenses by year ?s end, we?re committed to sharing our collective knowledge and expertise with applicants.? Missouri physicians can now recommend cannabis for patients with serious and debilitating illnesses, with the state accepting medical marijuana patient applications beginning on June 28. Applications, instructions and scoring criteria for prospective owners and operators of cultivation sites, manufacturing and testing facilities and dispensaries are also now available and can be submitted over a two-week period beginning in early August. The constitutional amendment requires the state to award its initial cannabis business licenses by Dec. 31, with sales expected to begin in early 2020. Registration information and additional details about the event can be found online. A portion of the registration proceeds will be donated to Ayden?s Alliance, a patient advocacy organization that helps low-income and special needs families afford their children?s medical cannabis expenses. Participants will also be able to attend an industry meet-up and fundraiser for the group on June 24, the night before the seminar, at The Guild KC in the Crossroads Arts District.

MCIA t o host business seminar in Spr ingf ield The Missouri Cannabis Industry Association will host a one day event on Saturday, July 27 in Springfield. The event, to be held at University Plaza Hotel, will feature speakers include Medical Marijuana Program Director Lyndall Fraker as the keynote speaker. Tickets are available for purchase

The seminar is organized by the event production company Midwest Canna Expos, which previously collaborated with MoCannTrade on the MoCannBizCon + Expo, a medical marijuana trade show that attracted more than 2,200 attendees to St. Louis?Union Station in March.

online in advance at mocia.org

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SEED TO SALE

What is going on? By Rachael Dunn

Over the past month, quick headlines have caused quick confusion in the medical marijuana industry about Missouri's medical marijuana seed-to-sale contract award, protest, and denial. The bulk of the current confusion comes from a seemingly contradictory, but immediately irrelevant, rule included in the finalized rules that the Department of Health and Senior services has delivered to the Secretary of State's Office for printing, along with the announcement of another public comment period. WHAT'S NEXT FOR THE PROGRAM RULES? The Department of Health and Senior Services released its finalized rules on May 24, ahead of schedule, with an emergency clause. Emergency rules - allowed by Article XIV - take effect June 3, 2019. The rules will be entered into the Missouri Register, published by the Office of the Secretary of State. The rules lastly go before the Joint Committee on Administrative Rules, a joint group of legislators from both the state senate and house that provide oversight to executive departments on internal rulemakings. Rule changes can be proposed by the Department at any time. Changes go through the Secretary of State and legislature again. The emergency rules, which were submitted to the Secretary of State for publication in the Missouri Register on May 24, are set to be printed on June 17, 2019. They will then be printed in the Code of

State Regulations on June 30, 2019, and become effective July 30, 2019. In those rules, is a provision. A provision being amplified by mainstream media as ?another ? bump in the road for the medical marijuana division of DHSS. Unless otherwise addressed or prohibited by contract or law, an entity holding a contract with the state of Missouri for a statewide track and trace system and any affiliates of that entity may charge a price to a licensed or certified facility for plant/product tracking labels, but no such price shall exceed the cost of producing the label in an amount that would create more than thirty (30) percent net profit on each label. That provision has led to a losing bidder of a contract offered by the State for information solutions - computer programs, including seed-to-sale - to contact the Secretary of State asking them to not print the rules, advertently causing the rulemaking process to halt. A representative from DHSS said that "the 30% rule is meant to protect the industry as a price cap in the event a vendor for the statewide track and trace system is someday allowed to charge for plant tags." ?DHSS has introduced substantial uncertainty by issuing an emergency rule that appears to permit Metrc to do exactly what OA said it could not,? Chuck Hatfield wrote on behalf of seed-to-sale programmer BioTrackTHC in a letter to the office of Secretary of State Jay Ashcroft.

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A representative from the Secretary of State's office said they are still reviewing the emergency rule along with the Hatfield letter. The rule was filed on May 24, and may not be published until 10 days have passed.

THE BACKSTORY Amendment 2, passed in November 2018, specifies that DHSS "shall certify, if possible, at least two commercially available systems to licensees as compliant with its tracking standards and issue standards for the creation or use of other systems by licensees.? The possibility for two systems is currently very low, with industry thought leaders sharing that two can?t share the same database because they have their own structure. In order to meet some of the requirements to keep people from looping, such as real-time updates on purchases and checking amount purchased per month, it made it impossible to have more than one and still meet the timelines set in the amendment. Choosing one system limited the potential for system abuse. Licensees include cultivators, manufacturers, and dispensaries of medical marijuana. Those required to use the seed-to-sale tracking software include ?Cultivators, Dispensary, Testing, Transportation, and Infused Product Manufacturers, Qualifying Patient, Patient Minor, Patient Caregivers and/or Patient/Caregiver Cultivators.? The Department issued a Request for Proposal on

March 4, 2019, asking for an information solution for three different programs: seed-to-sale, patient registry, and facility licensing application. The seed-to-sale program portion of the RFP has received the bulk of the controversy. The seed-to-sale program itself was asked by the Department to allow qualified facilities to acquire the system that integrates with the state systems to upload inventory information for near-live monitoring (within 15 minutes). The Department asked the State be able to see facility inventory at any time and that inventory is able to be monitored going from acquisition to sale/transfer. Additionally, the program would be integrated with patient registration and qualified facility programs. Three main companies made bids for the contract: Metrc, BioTrackTHC, and MJFreeway. The companies each corresponded with the Division of Purchasing and Materials Management (DPMM) under the Office of Administration. This is typical. There were some revisions to proposals from the companies. Metrc alone was awarded the contract. BioTrackTHC and MJFreeways protested the award towards the end of April. The BioTrackTHC protest made headlines quickly, primarily protesting the cost of RFID tags Metrc requires of licensees for tagging and tracing plants and plant product. But the protests were denied by Purchasing, announced on May 20, who shut down the protests with a 14-page letter reinforcing their stance that there would be no variable costs to the state - and Metrc clearly understood the terms of the contract. In an email to Stacia Dawson toward the end of March, the buyer for this RFP, Metrc emailed by stating, unequivocally, that the ?amount on Line Item 11 is our firm and fixed pricing.? BioTrackTHC opposed the confirmation of the pricing to Dawson, saying in the protest letter, ?[d]espite Metrc?s reassurances to Ms. Dawson, it is far from clear that it intends to charge a firm, fixed licensing fee to the State rather than a $40 per month fee to licensees. Because Metrc?s BAFO pricing response is wholly ambiguous on this issue, it failed to provide all relevant information related to its pricing in violation of Section 2.1.2." Metrc had 10 days from the protest to respond. ?The RFID tag prices charged by Metrc were initially disclosed by Metrc,? the Metrc response reads, saying it further amended its bid to disclose only ?firm, fixed fees that would be charged to the state.? ?Metrc did so." ?In an effort to be fully transparent, Metrc did not amend Exhibit B of its proposal, which had previously indicated that such commodity prices would be charged on a per plant and per package basis to users of such tags within the industry,? wrote Husch Blackwell attorney Lowell Pearson in the response on behalf of Metrc. "Notably, Exhibit B remains a part of the Contract, and at no time was the State misinformed as to Metrc?s intention to sell such RFID tags to industry licensees required to use such tags to identify their plants and processed products.?

TAGS!? For seed-to-sale programs to operate, each plant is physically tagged from seed...to sale. These tags typically either have an RFID or a barcode used for identification that are generated by a program and printed and attached on-site. In some states, programs charge a fixed price per tag code. The winning bid from Metrc included a $40 per month fee to licensees to use the program. Metrc operates seed-to-sale programs in 10 other states on 11 other contracts. BioTrackTHC, another seed-to-sale leader, has 9 contracts doing the same in other states. Through those contracts, they track plants by the use of tags. Tag codes - RFIDs for Metrc, barcodes for BioTrackTHC - are generated by a program that facility licensees subscribe to. Licensees must also buy tag readers, tag printers, tag paper, and other equipment needed to tag plants and plant products. The codes generated by the program are used to trace the plants, from seed? to sale. Tags are placed with seedlings, attached when plants get larger, and when it comes to harvest, more tags are printed to go with each plant?s processed product. Again, when the processed plant is broken down for manufacturing or sold as the whole flower, each part of that plant keeps the same tag. Each step along the way is tagged. Weights are entered at harvest and manufacturing. At any point, the plant?s information is updated in the program and its journey from seed to sale can be traced. States use these programs for several reasons, ranging from recall control to limiting diversion (product making its way to the black market for illegal sale). The cost for the tag subscription is something BioTrackTHC called variable, because of cost per plant for RFID tags, and unconstitutional, ?because it imposes unauthorized fees on licensees and limits their ability to use other commercially available tracking systems.? From cost alone of the tags, BioTrackTHC contends they should have won the contract based on the points not included in the scoring rubric for the contract. ?Assuming a relatively low estimate of 3,600,000 plant tags generated per year and the same number of package tags, this would result in roughly $2,500,000 in tag fees every year, or $12.5 million over the life of the contract,? reads the BioTrackTHC protest. "In short, the costs to Missouri licensees would be astronomical. As a result, Metrc was obligated to clearly disclose this element of its pricing for consideration. Even if Missouri generated only 10% of this already conservative estimate of plants and packages, that would increase Metrc?s firm, the fixed price by $1,250,000, resulting in Metrc receiving 27 points for solution cost rather than the 34 points it was awarded. BioTrack thus would have been the winning bidder by 3 points."

non-state entities. Rather, Missouri courts have endorsed contracts let by the State wherein a non-state entity was charged for the use of a state-contracted service, for which even a ?fee?to the non-state user was allowed.? The Metrc response letter cites a case, PSC v. Simmons, where a contract awarded for prison telephone services incurred a fee to users of the service, not the State. ?The court found 1) that the fees were legal, and 2) that the fees were not required to be scored in the objective cost analysis.? Metrc fired back further at BioTrackTHC, including their catalog for equipment needed for BioTrackTHC?s program offering in Nevada. A catalog from a company called Stover distributed on behalf of BioTrackTHC titled, ?BioTrack Core System Supported Hardware,? updated in 2019 - curated hardware necessities for facilities in the state of Nevada gives a closer look of how the RFID tags work. Stover, among others such as MainStem, ComputerEvolutions, and Rocky Mountain Business Products, sells label printers and other hardware direct to facilities in other states. Label printers run around $330 and up. Tags are printed by on-site label printers, such as Zebra Direct Thermal Label Printers. These printers have a tear-off mode for printing individual tags with some traceable identifier like an RFID or barcode, similar to a receipt printer. Some printers are for cultivation facilities only, while others are used for cultivation, processing, and retail. Cultivation hardware denoted as needed by a checklist in the BioTrack catalog lists categories of hardware for the grow terminal, harvest terminal, and processing terminal. Each terminal needs a barcode scanner and label printer. Harvest and processing terminals require scales. Fingerprint scanners are available optionally. For labels and tags, facilities are required to have special printers, wrap tags, paper roll, and traceability tags. Would the variable costs of paper needs be an unconstitutional variable cost? The same catalog also includes a checklist for point-of-sale, including barcode scanners, receipt printers, cash drawers, scales, label printers, mag-stripe readers, and fingerprint scanners. Metrc can be integrated with other point-of-sale systems, such as Cova and others. Additional cables and adapters are referenced throughout. The tag cost is something that caused drama during the implementation of Washington state?s seed-to-sale tracking for medical marijuana. Metrc withdrew their bid in the state when contract negotiations fell through a month after being chosen by the state for programming.

Metrc disagrees that the tag costs or program subscriptions are fees or taxes, calling them commodity costs.

BUT WHERE?S THE CONFUSION?

?To the extent that BioTrack asserts that those commodity costs (which it deceptively refers to as ?fees?) are somehow illegal, BioTrack is again incorrect,? reads the Metrc response. "In fact, BioTrack cites no provision of Missouri law wherein the State is required to score, in its objective cost assessment, costs that may be imposed upon

Amendment 2, not Article XIV of the Missouri Constitution, states: ?The Department shall not have the authority to apply or enforce any rule or regulation that would impose an undue burden on any one or more licensees or certificate holders, any Qualifying Patients, or act to undermine the purposes of this section." BioTrackTHC protested Metrc?s bid, saying the cost of tags would be an

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undue burden.

adjusted accordingly.

But Metrc says the tracing cost is not a burden.

"Its BAFO converted the previously-variable pricing of industry-paid subscriptions for access to the seed-to-sale solution?s software component into firm and fixed State-paid pricing for subscriptions to the same. Metrc?s BAFO replaced, with zero dollar figures, its previously-variable industry-paid pricing for the seed-to-sale solution?s equipment in the form of RFID tags.

?We are unaware of any accurate inventory control process that does not rely upon an identification number attached to each applicable inventory system,? reads the Metrc response. "Every state using a seed-to-sale tracking system has at least a bar code tag attached to each inventory item. Metrc?s system adds substantially more accuracy and efficiency to such inventory tracking by including RFID transponders in the bar code tags. By ignoring these fundamental details, BioTrack?s constitutional argument is an attempt to fit a square peg into a round hole.? ?[W]hether the costs of the RFID tags are an undue burden - and they are not - is beside the point; since, again, the Missouri Constitution does not prohibit the required purchase of identifier tags necessarily required by the provider of the selected seed-to-sale track and trace system. Moreover, Section 1.3(25) only applies to rules or regulations imposing an undue burden. There is no rule or regulation involved here. ?In essence, BioTrack attempts to take a commodity cost that is imposed in all states in which both BioTrack and Metrc operate, and to recharacterize and pigeonhole that cost into its constitutional argument. Once again, BioTrack cites to no provision of the Missouri Constitution that prohibits these costs. If these costs were, in fact, prohibited under Article XIV, it would say so directly.?

"The parties?written communications prior to award, including the issuance of the RFP, Metrc?s proposal in response, the Division?s BAFO request to Metrc, and Metrc?s BAFO in response, constitute persuasive evidence of their understanding of the integrated contract?s relevant terms." The contract itself states, ?[o]ther than the payments and reimbursements specified on Exhibit A, Pricing Page, no other payments or reimbursements shall be made to the contractor for any reason whatsoever.? Boeger goes on to say, ?But the single reference to licensee RFID tag purchases found there? does not serve as contractual authority to charge prices to licensees in excess of the firm, fixed amounts found on Exhibit A. The organization fo the RFP, ant he proposals submitted in response to it, assists this analysis." The firm, fixed amount? The $40 monthly subscription cost to licensees.

NEW CONFUSION: THE RULE So does the State think that the tag cost is variable? The protest denial letter from Purchasing says that the awarded contract makes it very clear with Metrc that there will be no variable costs to the industry. ?Metrc?s proposal and [Best and Final Offer] display an understanding of the RFP pricing provisions? proper scope,? writes OA Division of Purchasing Director Karen S. Boeger. "In Exhibit A of its initial proposal, Metrc disclosed prices to be charged to licensees for access to the seed-to-sale solution?s software component and for that solution?s equipment in the form of RFID tags. However, that initial proposal expressed these prices as variable. In response, the Division?s BAFO request to Metrc noted the need for firm, fixed pricing in order to comply with the RFP?s requirements. Metrc

In DHSS?s medical marijuana divisions final rule proposal, sent to the Secretary of State?s Office for printing along with an announcement for further public comment, was one rule that has many scraping their heads.

plant/product tracking labels, but no such price shall exceed the cost of producing the label in an amount that would create more than thirty (30) percent net profit on each label. Seemingly contradictory to the Boeger letter and the information solution contract itself, its immediate relevance is unknown, but concerns BioTrackTHC, as they now protest the printing of the rules. The St. Louis Post-Dispatch insinuated the rule may be grounds for a potential lawsuit, but the direct application of the rule in light of the program contract is uncertain. Indeed, the rule itself is not relevant to the current contract. A representative from DHSS said "the 30% rule is meant to protect the industry as a price cap in the event a vendor for the statewide track and trace system is someday allowed to charge for plant tags."

HOW TO PREPARE TO WORK WITH M ETRC For those looking to obtain a license to grow, process, transport, or sell medical marijuana, there are a few things to take into consideration as timelines and plans are made. Metrc requires employees to complete online training. Training can be scheduled directly with Metrc by phone or through their website after a license is obtained. After training is completed, a dispensary API key will be issued for integration into any third-party programming for program access. Once sales begin, a successful set up will give live reports to Metrc for state use. Reporting is done automatically.

WHAT?S NEXT

(7) Statewide Track and Trace System. (A) No entity holding a contract with the state of Missouri for a statewide track and trace system or any affiliates of that entity may sell seed-to-sale services or services related to compliance with seed-to-sale tracking regulations to a licensed or certified facility.

As far as the rule about tag costs goes, the Secretary of State?s Office can be predicted to make a statement on why they will not print the proposed emergency rules from DHSS or will print the rules. Within the past decade, at least one Secretary of State - Robin Carnahan - refused to print rules after a protest.

(B) Unless otherwise addressed or prohibited by contract or law, an entity holding a contract with the state of Missouri for a statewide track and trace system and any affiliates of that entity may charge a price to a licensed or certified facility for

As far as Metrc goes, the company has met with DHSS several times to begin work on state programming. Greenway will continue to keep readers updated about the required seed-to-sale software.

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By Rachael Dunn Gr eenway

CST and Cova for m par t ner ship, t out incr eased ser vices for facilit ies

CST Solutions, a Springfield-based security

companies, it?s rare to find a Seed-to-Sale

use both services or either separately to suit their

company, is partnering with Colorado-based Cova

compliant POS like Cova with a proven record. Cova

business needs. Working with both partners

Software to provide clients with increased service.

doesn?t only meet minimum seed-to-sale POS

ensures an all-around best-in-class experience for

requirements set by Missouri?s DHSS, but also goes

the dispensary and ultimately the customer. The

above and beyond to deliver software that?s easy to

combined experience and high standards of both

use and learn, which is highly valued by a new

companies offers a comprehensive solution that

dispensary and staff who are not tech savvy.?

adds to the probability of cannabis retail success

?We have negotiated special pricing with Cova for CST customers and we have been working with them constantly on regulation changes,? Kevin Ellison, CEO of CST Solutions, said. ?As the process moves forward, we have worked with them to build

The partnership may start the day a facility decides

out some truly amazing standard operating

to use them, but they?re ready to be physically

procedures around inventory, recalls, and patient

present and available on opening day.

management.? Not sure who Cova is? ?Cova designs and builds retail software solutions specifically for the cannabis industry,? Faai Steur, Director of Marketing at Cova, said. ?We?re relentless with our goal of creating the industry?s first lovable point of sale ? but we?re not stopping there. Our full retail suite, coupled with our

?When licenses are awarded, we will be on-site with Cova on the customer ?s opening day and we will provide any and all the support and training to the

Missouri dispensaries.?

partnership will provide confidence and trust in a system for facilities.

software in the computer that is the point of sales.

?Confidence and trust

The modern day cash register.

that their launch and

20,000 retail stores of all sizes and tout virtually no downtime.

Solutions at http://cstsolutionsgroup.com.

the best solution for

the growth for our clients.?

compliance and ease of use. They are currently in

https://www.covasoftware.com. Learn more about CST

hours working with Cova to make sure it is always

Steur shared the

market leaders on cannabis POS, prioritizing

Learn more about Cova at

amazing company and Tahnee has spent many

simply a software provider, is a powerful recipe for

Cova is award-winning and one of the national

dispensary ecosystem.?

customer long term,? Ellison said. ?They are an

dedication to being a strategic partner rather than

Point-of-sale, POS, is just as it says - it is the

without worry. CST And Cova have created a

operations will be carried as smoothly as possible without unexpected glitches and interruptions. Cova works exclusively with

?Running a successful dispensary has many

best-in-class companies

challenges beyond a normal retail store,? Steur

that not only offer

said. ?On top of typical operational items like

experience and

managing inventory, product, and staff, cannabis

expertise, but also share

retailers have to deal with complex and constantly

our values of integrity,

changing regulations. To protect their license and

trustworthiness, and

stay compliant, they need technology partners that

reliability. CST is the

have expertise so they can focus their time on

partner we trust. We

running a successful dispensary.?

share the same values to drive the success of

Both companies, focusing on making facility

our customers.?

management easier - and, in turn, more successful - believe their partnership will make them a great

Not sold on the partnership, but sold on one or the

ongoing partner for facilities in Missouri.

other? Facilities can work with CST and Cova separately, or together - but together sure has

?This is a partnership between two high profile

some perks.

technology companies that have over 20 years experience in their respective fields,? Steur said.

?Cova and CST form a valuable but non-exclusive

?With so many start-ups and unreliable POS

partnership,? Steur said. ?Retailers can choose to

13 M OGREENWAY.COM

Secur ing Missour i's medical mar ijuana mar ket

By Rachael Dunn Gr eenway

Data and security will impact every medical

?Security for a commercial business of any type is

upon request - and at the expense - of facilities.

marijuana facility. Not only does security represent

way more complex than most people think,? Ellison

What would have been a room of servers less than

a large percentage of scoring on facility

said. ?The good news is that it is a very mature

two decades ago for that much footage from the

applications, the rules are clear and strict on what

industry and any possible issue has been solved, it

specified equipment is now able to be physically

is expected to be available at all facilities. The

just may take experience in other industries to

stored in less space than a computer CPU tower.

concept of data may seem pie-in-the-sky, but

know how similar issues have been dealt with.

advancements and strategy have made following

When selecting a security company, two things

and exceeding the rules in an effective manner a

have to be at the top of the list; 1) It needs to be a

realistic and accessible goal.

Missouri based company because those of us in

To better visualize what kind of security Missouri?s medical marijuana industry is looking at, Greenway Magazine spoke to three gentlemen who focus on

Missouri know the regulations and the history behind them, 2) The company needs to have experience in more than just cannabis.?

?It will require about 50 Terabytes of storage and cultivation will be roughly 200 Terabytes,? Ellison said. ?A lot of retailers have similar requirements so most camera manufacturers have storage device the size of a large desktop computer that can hold that much video.? Additionally, Ellison said the regulations allow

security: Kevin Ellison, CEO at CST Solutions; Mac

The rules specify a variety of equipment, starting

Johnson, CPP from Ceres Management Group; and

with a monitor and cameras. Cameras must

Matt Buydos, sales representative from Elliott Data

capture footage in 1920x1080 pixel resolution at a

?We feel that it is preferable because it allows

Systems.

rate of 15 frames per second in all lighting levels

keeping the critical video off-site in case there is

with remote access for the state and law

any physical building destruction such as a fire or

enforcement in real time, upon request.

natural disaster,? Ellison said. ?Using cloud storage

Security systems themselves have developed greatly over the last decade, implemented primarily

virtual - ?cloud? - storage.

though does require a large internet connection

for safety and liability purposes. With the advances

The cameras must cover all entrances and exits -

in analytics, Buydos said systems themselves are

including windows, the perimeters and exterior,

proactive.

including at least 20 feet of space around the

The rules specify notification be set up in the event

perimeter of an outdoor grow area, all point-of-sale

of failure - both audible and visual. Additionally,

locations, vaults and safes, and all marijuana itself -

facilities must have battery backup capable for

from two angles - where cultivated, cured,

cameras and other equipment for 60 minutes in

trimmed, processed, rendered unusable, and

the event of a power outage.

?Even though you may not have someone staring at a monitor of live video, with analytics, unusual motion or activity can trigger alerts to direct attention,? Buydos said. Video surveillance is vital for auditing purposes and overall state compliance. A variety of programs and equipment can make an effective system seem unattainable.

which is not always an option.?

disposed. Controlled access with electronic card access Sixty days of footage must be able to be stored on-

systems or biometric identification systems

or off-site with on-demand recording access. Copies of recordings must be able to be provided

All external doors must be equipped with a locking mechanism in the event of power failure.

14 M OGREENWAY.COM

A way to immediately and automatically alert local

unappealing to criminals. My security background

package at the point of origin. This means that the

law enforcement of a breach in security is required,

is working with large companies such as banks,

weakest link in the chain is the cultivation site

in addition to a manual, silent alarm at

national retailers, etc. How many people try to

based on ease of access and lack of product

point-of-sales, reception, vaults, and the

break into casinos every year vs. convenience

accountability prior to transfer. However, many

monitoring station able to immediately notify local

stores? Casinos have learned how to give the

Marijuana Infused Product (MIP) manufacturing

law enforcement in the event of an unauthorized

impression that the risk is not worth taking the

sites will likely by co-located with cultivation sites.

facility security breach.

chance. Because of this I always start with asking

Without a sufficient effort to compartmentalize the

myself 'what about this facility would be the most

two operations, the risk shifts significantly to the

intimidating in regards to breaking in?' I enhance

MIP site.?

Buydos said modern systems can take video, controlled access, and notifications a step further by using integrated products.

what will be intimidating and make sure that any weak areas look extra fortified.. That means putting

But why?

?Look for integrated products,? Buydos said. ?It

cameras in the places that criminals will look, it

?Stealing $10,000 in raw flower cannabis poses a

allows facilities to have a more proactive approach

means making sure every employee knows the

logistical problem that stealing $10,000 in extracted

when it comes to compliance, safety, and auditing.?

product vault would take over an hour to break

compound simply does not,? Johnson said.

into, and it means using the right equipment. Most

?Without having a verifiable change of

people don?t know that there is a camera that can

accountability, the risk of theft/diversion from MIP

detect concealed weapons using radar, and those

sites increases drastically. On a venn diagram, this

cameras have a distinct colored ring around the

would be a crossing point between value per

lens. Anyone thinking about robbing a dispensary

volume, and ease of access. Mitigation efforts

will know about the color ring and seeing it in the

would need to start with implementing a total

dispensary serves as a good indicator that the

change of accountability between the cultivation

security company is already watching them.?

site and the MIP manufacturing site to insure the

Buydos shared that modern systems can have programs that work together in a way that controlled access cards will trigger video recording logs so that every card swipe has an image. Additionally, if integrated further, a system can recognize if a person swiping a card to gain access is indeed the authorized person. ?Find out what their integration capability with other platforms,? Buydos said. ?We always suggest,

This strategy is vital to execute in real life - and to communicate on facility applications.

refined flower harvest can be measured against an estimated extract yield.?

rather than put all our eggs in one basket, to look at products that integrate with other parties.? Buydos said that it isn?t always about top of the line

?Inabilit y t o ident if y t he exact or igin of a pr oduct loss w it hin t he allot t ed

across the board, but what works best together to

24-hour r epor t ing per iod could r esult in an 'all-st op invest igat ive audit '

provide a top of the line system as a whole. ?Picking

essent ially halt ing t he ent ir e supply chain unt il t he loss is account ed for.

an integrator that has a strong product portfolio is super important.?

This t ype of disr upt ion could end up cost ing gr oups not

Systems can also be designed to track contractors

only t ens of t housands of dollar s in lost pr oduct ion and

and visitors separately from employees through electronic logging. This can go a step further, allowing users to input into a ?banned? list in the event a former employee, or even a former contractor, is terminated and attempts to seek access to a facility. Though the security section of the rules doesn?t specifically talk about audits, other parts of the rules do. With required seed-to-sale tracking and live updates to the state, this state?s medical marijuana market will be a tight closed loop system focused on limiting diversion to the black market. The security rules in-place set up a great environment for a quick and efficient audit of inventory - and of the workings of a security system.

sales, but possibly t heir oper at ing licenses.? MAC JOHNSON, CPP ?The security section of your application holds

Loss could shut down a business for an

immense weight as reviewed and scored by DHSS.

undetermined amount of time.

All of the expertise and detail that goes into the rest of your submission should be reflected in equal measure in your security plan,? Johnson said. ?From a business continuity perspective, it is vital that ownership groups leverage third-party security consultants throughout the development, integration, and perpetual implementation of full-spectrum security programs. This ensures deliverables from vendors (guards & technology) are up to standard and offered at a competitive

?Compartmentalization measures are especially important for fully integrated operations upon loss of accountability of product,? Johnson said. ?Inability to identify the exact origin of a product loss within the allotted 24-hour reporting period could result in an 'all-stop investigative audit' essentially halting the entire supply chain until the loss is accounted for. This type of disruption could end up costing groups not only tens of thousands of dollars in lost production and sales, but possibly

?We treat security audits as a task similar to how

price. These professionals should also be able to

mechanics handle engine rebuilds,? Ellison said.

provide risk reduction inputs to your insurance

?We will check and test every sensor, every camera,

brokers and/or underwriters to maximize savings

The seriousness of security cannot be understated,

and every access door module to make sure that

from a risk transference standpoint."

which can be made or ruined by going with the

every single piece of equipment works 100%. The security system we sell has a test feature that allows us to create a report for everything that passed as well as everything that fails.? Overall, working with a security company to develop an overall strategy is vital - not only for compliance, but for customer and employee safety.

Johnson said different facilities will have different security demands to consider. ?With the integration of regulated product tracking measures, such as the Metrc system approved here in Missouri, we are now seeing attempts to offset the risks of theft and diversion by establishing accountability at every point of transfer. This helps

?Employees and customers have to be a top

assign accountability through the supply chain, but

priority and have to always feel safe,? Ellison said.

it does not provide accurate tracking and

?The best way to do that is by making the facility

management of harvest yields from plant to

M OGREENWAY.COM

their operating licenses.?

right company for a facility - and the choice of a security provider goes beyond just providing a system. Ellison said this is a heavy consideration for CST. ?Our goal is to be the one company that customers need to call for any technology and security needs,? Ellison said. ?Each of us have at least 25 years of experience in our respective fields and in that time we have gained a lot of real world knowledge, but we also have built relationships with other

companies that we have worked with in the past.

?Security is a team effort. Even a well-trained and

economics, illicit trade also manifests itself based

Any areas that we do not have expertise in

dedicated security professional requires constant

on two main inputs; transferable value, and

ourselves, we have partner companies that we

interaction with business operations, and

accessibility,? Johnson said. These metrics allow

reach out to so they can help us. For example I

communication from all levels of functioning staff,?

security-risk analysts to identify weaknesses and

have never installed razor wire, but I know the best

Johnson said. ?As with all regulated markets,

develop plans to mitigate the risk that those

fencing company in southern Missouri that I call

security must be viewed as an asset essential to

weaknesses will be exploited. Unlike most other

anytime we need high security fence. It still is one

operations, not an overhead expense essential to

industries where raw materials with a closed

call for the customer so they can focus on the rest

your baseline compliance. That said, all security

market value eventually converge to make an

of the business.?

programs are not created equally. It is important to

openly valued end-product, cannabis holds openly

know where and when to spend, and to save.?

transferable value at every stage from seed to sale.

Not only will every facility have to implement a

A successful criminal enterprise would understand

complex security system, all facility employees are

Being mindful and deliberate about what staff

required to be trained.

does, and how, is vital.

?The training is broken up into three pieces,? Ellison

?One key thing to note in the regs is that the

said. ?The first is education for employees on what

security manager is responsible for making sure

to do when something does happen. We want the

the security is implemented and maintained, but

employees to know what to do and what to expect.

that same person doesn?t have to perform the

Second, we train on the various aspects of the

work,? Ellison said. ?We have customers that are big

system and the protections that are in place. Third,

enough to hire a full time dedicated security

we train the employees on being vigilant outside of

manager, and we have other customers where an

?Patients should use the same personal security

work and to not discuss anything that might be of

owner serves as the security manager and CST

measures implemented when picking up

interest to criminals such as the system, cash and

performs all of the actual work while providing

prescriptions from the pharmacy, or money from

product storage, and other potentially

constant communication to the security manager.?

the bank: Pay attention to your surroundings,

compromising details.?

The biggest threat to any facility? Internal theft.

Johnson stressed that successful security

Staff are not only the first step in having a secure

implementation is something that a facility?s whole

store, they can also be responsible for a store?s

staff must understand and take seriously. Security

failure.

isn?t a rule to check off, but a check off to a well-run business.

?Just like the 'invisible hand' theory in market

16 M OGREENWAY.COM

this and search for the most vulnerable point within the supply chain.? There is plenty to know for facility applicants and staff, but what about the patients? These systems are incredible orchestrations of technology, but not systems most patients will be unfamiliar with on the consumer side, Johnson said.

busier operating hours aren't always a bad thing, and don't hesitate to ask site security to keep an eye on you on your way to your car.?

Key Consider at ions When Choosing a Compliant POS for Your Dispensar y As hundreds of dispensary license applications are

operations and performance, you?ll

being written and submitted to Missouri Medical

want flexible and intuitive dashboards

Marijuana regulators, people are wondering, ?What

and reporting. Look for a system with

will make my application a winner?? The simple

real-time access to store data from any

answer: include clear and complete information

device, anywhere, with customized

that shows regulators you will run a responsible business and stay compliant.

views of the information important to you. Reports should be downloadable to perform further analytics. Also, be ready

For dispensary owners, accurately tracking sales

and able to produce data extracts in

and inventory, and reporting this data to the

case of a compliance issue and

government is key to running a compliant business.

friend and alibi!

minimum? requires a cannabis compliant point of Missouri statewide traceability system. However,

Verify your software provider is certified by data industry organizations (e.g., PCI, ISO) and has logging capability for monitoring all systems access and system changes. They should be SSAE18 and PCI-DSS level one complaint, which means they undergo third-party audits on internal process, change management, physical security, personnel backgrounds, and data infrastructure security.

Reliabilit y an d u pt im e. Look for company with a proven record and high

running a successful dispensary requires more than that. Here are the key compliance functionalities your POS should include: 1.

Cova Sof t war e

investigation ? this is when data is your

This is a complex endeavor that? at sale (POS) system that is integrated with the

By Ted VanDebur g

Bu ilt -in ID scan n in g an d age ver if icat ion with the ability to attach medical ID information to a customer

Can n abis pr icin g m an agem en t .

Service Level Agreement (SLA). If your

Specific market pricing may be based

system is down and unable to submit

overall on supply and demand, but how

required compliance data, you will not

a business chooses to promote,

be able to process sales, not be

discount and differentiate will vary. Your

compliant, and will create a very

POS should have flexible options to provide discounts to particular groups,

negative customer experience.

encourage loyalty for repeat visits, and

Su ppor t & t r ain in g. The cannabis

profile. Manually reviewing ID is

run promotions for new products,

industry is complex and constantly

error-prone. It also fails to establish a

brands, and categories. Analytics play a

changing. You need a POS company that

customer record, used to create an

critical role in helping you test, measure,

won?t just sell to you and disappear.

order and verify their Open-to-Buy

and refine your strategy to maximize

You?ll want training, ongoing support,

purchase amount, required for the

profits and deliver value that resonates

and confidence that your software

Missouri patient registry system.

with your customers.

provider has the resources to address your needs in a prompt and

Pu r ch ase lim it t ools, which verify each

Em ployee m on it or in g capabilit y.

customer in the Missouri patient

Monitoring employees is one of

registry system to ensure they have not

Missouri's diversion prevention measures. A plan to properly implement

exceeded their purchase limits. It calculates gram-equivalency of

User exper ien ce & f low. Software that simplifies sales and inventory management helps reduce errors and

products, prohibits over-buying, and

application, so look for a POS that can

increase efficiency, allowing

submits updated purchase amounts to

be integrated with security camera

dispensaries to simplify compliance,

METRC. Make sure your seed-to-sale

systems, enabling fast review of

streamline operation, and enhance

POS has this capability. Just because a

employees and transactions. It?s wise to

customer experience.

POS company has integrated with

run reports that identify transaction

METRC for California or Colorado does

anomalies? especially discounts and

Choosing the right compliant POS is critical for your

not mean their software has the

refunds.

dispensary success. There?s no shortage of

certification required for Missouri. Abilit y t o r eceive elect r on ic in ven t or y m an if est s, perform inventory audits with automatic adjustments, and report

this can score you higher on your

seed-to-sale software, loaded with features you

functionality, integration, and

professional manner.

Dat a pr ivacy & secu r it y. The cannabis

don?t need, but lacking the support you do. Don?t

industry has attracted many startup

settle for anything less than a proven, professional

tech companies looking to profit from the ?green rush?. Solutions should be

technology partner, dedicated to reliability,

customized for the needs of the

investment.

security, and protecting your license and

sales to METRC. Closely managing your

cannabis industry but should not skip

retail inventory and accurately reporting

data security and management best

changes to METRC are critical

practices. Cova Software uses the

Ted VanDeburg is VP of Sales for Cova Software. He

components to maintaining compliance

advanced infrastructure of an enterprise

has spent 20 years developing retail operations and

and preventing diversion.

retail software leader. We have the most

technology solutions, collaborating with merchants to

sophisticated data protection in the

grow their business and improve productivity through

Dash boar ds, r epor t in g an d an alyt ics.

cannabis market, built on a platform

sales, merchandising and loss prevention data

To keep the pulse of your dispensary

that handles more than $16 billion (200

analytics.

million transactions) every year.

17 M OGREENWAY.COM

14 Days between August 3 and August 17 for application submission for cultivation, testing, manufacturing, and dispensary facilities.

BY THE NUMBERS

20 + Number of bills introduced to the Missouri legislature in 2019 that would have amended or changed parts of the program created by Article XIV. 0 passed.

60 Day supply a patient or caregiver may possess for patients who do not cultivate their own marijuana.

30 0 /50 0 /10 0 0 Word count limits for many facility application answers.

543

Days recorded surveillance storage requirement for all facilities.

Number of prefiled application fees paid as of June 11th

68 Number of evaluation questions applicable to all applicants, an

$3,886,0 0 0

additional 8 questions are asked of dispensary applicants, 10 of manufacturers, 11 of cultivators, and 22 of testing applicants.

How much the State has collected from pre-filed application fees as of June 11.

90 Day supply a patient or caregiver may possess when cultivating at home.

192 Minimum number of dispensaries the State seeks to license 24 in each congressional district. Missouri has 8.

18 M OGREENWAY.COM

W ith th e p a s sa g e o f A m e n d m e n t 2 in N o v e m b e r 2 0 1 8 , M is so u ri to o k a s te p fo rw a rd in th e c o m p a s s io n a te c a re o f its c itiz e n s. W ith a ll n e w in d u s trie s ru le a n d re g u la tio n is re q u ire d .T h e M is so u ri D e p a rtm e n t o f H e a lth a n d S e n io r S e rv ice s s e le c te d Ly n d a ll F ra k e r to le a d th e s ta te th ro u g h th e s e u n c h a rte d w a te rs. D ire cto r F ra k e r a n d th e te a m a ss e m b le d a t D H S S w e re a b le to p ro d u c e ru le s, re ce iv e a n d a d a p t to p u b lic fe e d b a c k , re fo rm s a id ru le s, a n d m e e t a ll d e a d lin e s re q u ire d b y la w, a t a b re a kn e c k p a c e . F o r G re e n w a y re a d e rs ' c o n ve n ie n ce , fin d in th e n e x t p a g e s a ll e m e rg e n cy ru le s re le a se d b y th e D e p a rtm e n t to g o v e rn th e b e g in n in g o f th e m e d ic a l m a riju a n a m a rk e t in M is so u ri.

R UL ES PURPOSE: The Department of Health and Senior Services has the authority to promulgate rules for the enforcement of Article XIV. This rule explains what general provisions are necessary for the enforcement of the Article. EMERGENCY STATEMENT: This emergency rule informs the public of what general provisions are necessary for the enforcement of Article XIV. This rule is necessary to comply with Article XIV, Section 1 of the Missouri Constitution, which became effective on December 6, 2018. Article XIV requires that the department make available to the public application forms and instructions for qualifying patient, primary caregiver, and patient cultivation identification cards, as well as for medical marijuana cultivation, testing, dispensary, and infused products manufacturing facilities. In order to make available the forms and instructions for all of these types of applications, it is necessary to promulgate rules for the processes and regulatory functions related to these applications. Without such

rules, the department will be unable to efficiently regulate and control the cultivation, manufacturing, and sale of marijuana for medical use or provide a mechanism and regulatory structure through which qualified patients and their caregivers may access medical marijuana. As a result, the department finds a compelling governmental interest in promoting the health and safety of Missouri residents who wish to use marijuana for medical purposes, requiring this emergency action. A proposed rule, which covers the same material, is published in this issue of the Missouri Register. The scope of this emergency rule is limited to the circumstances creating the emergency and complies with the protections extended in the Missouriand United States Constitutions. The Department believes this emergency rule is fair to all interested persons and parties under the circumstances. This emergency rule was filed May 24, 2019, becomes effective June 3, 2019, and expires February 27, 2020.

AUTHORITY: Sections 1.3.(1)(b), 1.3.(2), 1.3.(3), and 1.3.(4) of Article XIV, Mo. Const. Original rule filed May 24, 2019. Emergency rule filed May 24, 2019, effective June 3, 2019, expires February 27, 2020. NOTICE TO SUBMIT COMMENTS: Anyone may file a statement in support of or in opposition to this proposed rule with Lyndall Fraker, PO Box 570, Jefferson City, MO 65102 or via email at MMPublicComment@health.mo.gov. To be considered, comments must be received within thirty (30) days after publication of this notice in the Missouri Register. No public hearing is scheduled.

19 M OGREENWAY.COM

RULES (CONTINUED)

Tit le 19 ? DEPARTM ENT OF HEALTH AND SENIOR SERVICES Division 30 ? Division of Regu lat ion an d Licen su r e Ch apt er 95 ? M edical M ar iju an a EM ERGENCY RULES 19 CSR 30-95.010 Def in it ion s (1) ?Administer ? means the direct application of marijuana to a qualifying patient by way of any of the following methods: (A) Ingestion of capsules, teas, oils, and other marijuana-infused products; (B) Vaporization or smoking of dried flowers, buds, plant material, extracts, or oils; (C) Application of ointments or balms; (D) Transdermal patches and suppositories; (E) Consuming marijuana-infused food products; or (F) Any other method recommended by a qualifying patient?s physician. (2) ?Affiliate? means any entity effectively controlling or controlled by another entity or associated with other entities under common ownership or control, including a parent or subsidiary. (3) ?Batch? means a specifically identified quantity of medical marijuana, from immature plant stage to harvest, that is uniform in strain and cultivated utilizing the same growing practices. (4) ?Canopy space? means a space measured from the outermost point of a mature flowering plant in a designated growing area and continuing around the outside of all mature flowering plants in that designated growing area but not including space allocated for walkways or ancillary equipment. This space may be spread over a single level or multiple levels. (5) ?Church? means a permanent building primarily and regularly used as a place of religious worship. (6) ?Daycare? means a child-care facility, as defined by Section 210.201, RSMo., that is licensed by the state of Missouri. (7) ?Department? means the Department of Health and Senior Services, or its successor agency. (8) ?Disqualifying felony offense? means a violation of, and conviction of or guilty plea to, state or federal law that is, or would have been, a felony under Missouri law, regardless of the sentence imposed, unless the department determines that: (A) The person?s conviction was for the medical use of marijuana or assisting in the medicaluse of marijuana; (B) The person?s conviction was for a non-violent crime for which he or she was not incarcerated and that is more than (5) five years old; or (C) More than (5) five years have passed since the person was released from parole or probation, and he or she has not been convicted of any subsequent criminal offenses. (9) ?Dried, unprocessed marijuana or its equivalent? means the marijuana flower after it has been cured and trimmed or its equivalent amount of marijuana concentrate or THC. For purposes of purchase and possession limitations, one

(1) ounce of dried, unprocessed marijuana is equivalent to eight (8) grams of medical marijuana concentrate or eight hundred (800) milligrams of THC in infused products.

authorizes a qualifying patient, primary caregiver, or employee or contractor of a licensed facility to access medical marijuana as provided by law.

(10) ?Economic interest? means rights to either the capital or profit interests therein, or a combination thereof; or, in the case of a corporation, rights to some portion of all classes of outstanding stock of the corporation.

(17) ?Liquid Capital? means any asset in the form of cash or that can be converted into cash quickly with little or no loss in value, including stocks and marketable securities, government bonds, mutual funds, money-market funds, and certificates of deposit

(11) ?Elementary or secondary school? means any public school as defined in section 160.011, RSMo., or any private school giving instruction in a grade or grades not higher than the twelfth (12th) grade, including any property owned by the public or private school that is regularly used for extracurricular activities, but does not include any private school in which education is primarily conducted in private homes. (12) ?Enclosed, locked facility? means: (A) An indoor stationary closet, room, garage, greenhouse, or other comparable fully enclosed space equipped with locks or other functioning security devices that permit access to only the qualifying patient(s) or primary caregiver(s) who have informed the department that this is the space where they will cultivate marijuana; or (B) An outdoor stationary structure: 1. That is enclosed on all sides, except at the base, by chain-link fencing, wooden slats, or a similar material that is anchored, attached, or affixed to the ground and that cannot be accessed from the top; 2. In which the plants are not visible to the unaided eye from an adjacent property when viewed by an individual at ground level or from a permanent structure at any level; and 3. That is equipped with locks or other security devices that restrict access to only the qualifying patient(s) or primary caregiver(s) who have informed the department that this is the space where they will cultivate marijuana. (13) ?Entity? means a natural person, corporation, professional corporation, nonprofitcorporation, cooperative corporation, unincorporated association, business trust, limited liability company, general or limited partnership, limited liability partnership, joint venture, or any other legal entity. (14) ?Flowering plant? means a marijuana plant from the time it exhibits the first signs of sexual maturity through harvest. (15) ?Harvest lot? means a specifically identified quantity of marijuana that is uniform in strain,cultivated utilizing the same growing practices, harvested within a seventy-two (72) hour period at the same location, and cured under uniform conditions. (16) ?Identification card? means a document, whether in paper or electronic format, issued by thedepartment that

(18) ?Majority owned? means more than fifty (50) percent of the economic interests and more than fifty (50) percent of the voting interests of an entity, including any parent and subsidiary entities. (19) ?Marijuana? or ?Marihuana? means Cannabis indica, Cannabis sativa, and Cannabis ruderalis, hybrids of such species, and any other strains commonly understood within the scientific community to constitute marijuana, as well as resin extracted from the plant and marijuana-infused products. ?Marijuana? or ?Marihuana? does not include industrial hemp containing a crop-wide average tetrahydrocannabinol concentration that does not exceed three- tenths of one (0.3) percent on a dry weight basis, or commodities or products manufactured from industrial hemp. (20) ?Marijuana-Infused Products? means products that are infused with marijuana or an extractthereof and are intended for use or consumption other than by smoking, including, but not limited to, edible products, ointments, tinctures and concentrates. (21) ?Medical Marijuana Cultivation Facility? means a facility licensed by the department, to acquire, cultivate, process, store, transport, and sell marijuana to a medical marijuana dispensary facility, medical marijuana testing facility, or to a medical marijuana-infused products manufacturing facility. (22) ?Medical Marijuana Dispensary Facility? means a facility licensed by the department, to acquire, store, sell, transport, and deliver marijuana, marijuana-infused products, and drug paraphernalia used to administer marijuana as provided for in this section to a qualifying patient, a primary caregiver, another medical marijuana dispensary facility, a medical marijuana testing facility, or a medical marijuana-infused products manufacturing facility. (23) ?Medical Marijuana-Infused Products Manufacturing Facility? means a facility licensed bythe department, to acquire, store, manufacture, transport, and sell marijuana-infused products to a medical marijuana dispensary facility, a medical marijuana testing facility, or to another medical marijuana-infused products manufacturing facility. (24) ?Medical Marijuana Testing Facility? means a facility certified by the department to acquire, test, certify, and transport marijuana. (25) ?Medical Marijuana Transportation

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Facility? means a facility certified by the department to transport marijuana to a qualifying patient, a primary caregiver, a medical marijuana cultivation facility, a medical marijuana-infused products manufacturing facility, a medical marijuana dispensary facility, a medical marijuana testing facility, or another medical marijuana- transportation facility. (26) ?Medical use? means the production, possession, delivery, distribution, transportation, oradministration of marijuana or a marijuana-infused product, or drug paraphernalia used to administer marijuana or a marijuana-infused product, for the benefit of a qualifying patient tomitigate the symptoms or effects of the patient?s qualifying medical condition. (27) ?Non-emancipated qualifying patient? means a qualifying patient under the age of eighteen (18) who has not been emancipated under Missouri law. (28) ?Physician? means an individual who is licensed and in good standing to practice medicineor osteopathy under Missouri law. (A) A license is in good standing if it is registered with the Missouri Board of Healing Arts as current, active, and not restricted in any way, such as by designation as temporary or limited. (B) Practice of medicine or osteopathy means practice by persons who hold a physician and surgeon license pursuant to Chapter 334 RSMo, including those who are admitted to practice in Missouri by reciprocity pursuant to 334.043, RSMo. (29) ?Physician certification? means a document, whether handwritten, electronic or in another commonly used format, signed by a physician and stating that, in the physician?s professional opinion, the patient suffers from a qualifying medical condition. (30) ?Primary caregiver ? means an individual twenty-one (21) years of age or older who has significant responsibility for managing the well-being of a qualifying patient and who is designated as such on the primary caregiver ?s application for an identification card under this section or in other written notification to the department. (31) ?Principal officers or managers? means persons who, regardless of title, have responsibility for supervising the management, administration, or operation of an entity, including, but not limited to: presidents, vice presidents, or general counsels; chief executive, financial, or operating officers; general partners, managing partners, or controlling partners; managing- members; or trustees. (32) ?Process lot? means, once production is complete, any amount of medical marijuana concentrate or extract of the same type and processed using the same extraction methods, standard operating procedures, and harvest lots; or any amount of medical marijuana infused product of the same type and processed

medical condition, including, but not RULESother (CONTINUED)

using the same ingredients, standard operating procedures, and harvest lots.

the condition of, symptoms related to, or side-effects from the treatment of:

(33) ?Public place? means any public or private property, or portion of public or private property, that is open to the general public, including but not limited to, sidewalks, streets, bridges, parks, schools, and businesses. However, for purposes of designating a non-public place within a public place, the owner or entity with control of any such property may, but is not required to, provide one or more enclosed, private spaces where one qualifying patient and, if

(A) Cancer; (B) Epilepsy; (C) Glaucoma; (D) Intractable migraines unresponsive to other treatment; (E) A chronic medical condition that causes severe, persistent pain or persistent muscle spasms,

required by the owner or entity with control of any such property, a representative of such owner or entity, may congregate for the qualifying patient to consume medical marijuana. The qualifying patient may be accompanied by the family of the qualifying patient, the qualifyingpatient?s primary caregiver, and/or the qualifying patient?s physician. The owner or entity with control of any such property may provide such a space by individual request or designate such a space for ongoing use and may limit use of medical marijuana in that space to uses that do not produce smoke. Any such permission shall be given in writing and provided to the qualifyingpatient or publicly posted prior to a qualifying patient?s use of medical marijuana in that space. (34) ?Qualifying medical condition? means

19 CSR 30-95.025

including but not limited to those associated with multiple sclerosis, seizures, Parkinson?s disease, and Tourette?s syndrome;

(A) Upon request and for purposes of verifying whether a particular individual is lawfully in possession of a qualifying patient, primary caregiver, or patient cultivation identification card or lawfully in possession of a particular amount of marijuana, state and local law enforcement personnel shall have access to patient and caregiver information such as names, addresses, dates of birth, and purchase limitations. (B) For the purposes of verifying whether a particular qualifying patient or primary caregiver may purchase an amount of medical marijuana or medical marijuana seeds or plants, dispensary facilities shall have access to patient and primary caregiver names and purchase limitations. (2) Variances. (A) The department may waive, for good cause, provisions of this chapter on its own initiative or by request. (B) Requests for variance from the requirements of any provision of this chapter shall be made in writing and will be granted or denied by the director of the department?s medical marijuanaprogram. Requests shall include? 1. A list of each requirement for which a variance is requested, with citation to the

(35) ?Qualifying Patient? means a Missouri resident diagnosed with at least one (1) qualifying medical condition.

patient or primary caregiver identification card, and that any given qualifying patient or primary caregiver is only purchasing the amount of medical marijuana he or she is approved to purchase at any given time. (39) ?Substantially common control, ownership, or management? means: (A) The possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, by any means, including ownership, contract, financing, or otherwise;

(F) Debilitating psychiatric disorders, including, but not limited to, post-traumatic stress disorder, if diagnosed by a state licensed psychiatrist;

(36) ?Seed-to-sale tracking system? means a software system, including the statewide track andtrace system, designed to perform functions necessary to fulfill a licensed or certified facility?sresponsibilities in tracking medical marijuana from either the seed or immature plant stage until the medical marijuana is sold to a qualifying patient or primary caregiver.

(G) Human immunodeficiency virus or acquired immune deficiency syndrome;

(37) ?Signature? means a handwritten or electronic signature.

(H) A chronic medical condition that is normally treated with a prescription medication that could lead to physical or psychological dependence, when a physician determines that medical use of marijuana could be effective in treating that condition and would serve as a safer alternative to the prescription medication;

(38) ?Statewide track and trace system? means the system the department uses to track medicalmarijuana from either the seed or immature plant stage until the medical marijuana is sold to a qualifying patient or primary caregiver to ensure that all medical marijuana sold in Missouri was cultivated or manufactured in Missouri, that all medical marijuana cultivated or manufactured in Missouri is sold only by dispensaries and only to individuals in possession of a valid qualifying

(C) The ownership, directly or indirectly through the ownership of an affiliate entity, of a majority of the capital assets, real property assets, or leasehold interests; or

(I) Any terminal illness; or (J) In the professional judgment of a physician, any other chronic, debilitating or

specific rule in which the requirement can be found; and

Gen er ally Applicable Pr ovision s (1) Patient Registry Access. Qualifying patient and primary caregiver information collected by the department shall not be released to anyone outside the department except for purposes authorized by federal law or Article XIV of the Missouri Constitution, including:

limited to, hepatitis C, amyotrophic lateral sclerosis, inflammatorybowel disease, Crohn?s disease, Huntington?s disease, autism, neuropathies, sickle cell anemia, agitation of Alzheimer ?s disease, cachexia, and wasting syndrome.

2. An explanation for why the requirement cannot be met or why meeting the requirement would impose an undue burden on the applicant. (C) Denial of variance requests shall be issued by the department in writing and shall include the specific reasons for the denial. (3) Complaints. All complaints against licensed or certificated medical marijuana facilities mustbe submitted through the department?s website at http://medicalmarijuana.mo.gov. Complaintsshall include the name and address of the facility against which the complaint is made and a clear description of what violation the complainant believes the facility has committed. (A) Upon complaint against a facility, the department will determine whether an inspection is warranted to investigate the allegations in the complaint. (B) If the department conducts an inspection, the facility will receive a copy of the complaint. (C) Employees of a facility who report potential violations by a facility to the department may not be subjected to retaliation of any kind, including termination, because of their report. (4) Facility Evaluation Criteria. All applicants for cultivation, dispensary, manufacturing, testing, or transportation licenses or certifications will be evaluated for whether they meet minimum standards as described in subsection (A) of this section. During application time periods where more qualified applicants apply for cultivation, dispensary, manufacturing, or testing licenses or certifications than there

are licenses or certificates available in that category, the department will use a system of numerically scoring ten additional evaluation criteria to rank the applications in each such license or certification category against each other. (A) The minimum standards for licenses and certifications can be met by providing all material required by 19 CSR 30-95.040(2) in order to show, as applicable: 1. Authorization to operate as a business in Missouri; 2. That the entity is majority owned by natural persons who have been residents of Missouri for at least one (1) year; 3. That the entity is not under substantially common control as another entity or a combination of other entities in violation of 19 CSR 20-95.040(3)(C-D); 4. That the entity is not within one thousand (1000) feet of an existing elementary or secondary school, daycare, or church, or, if a local government allows for closer proximity toschools, daycares, and churches, that the entity complies with the local government?srequirements; 5. Eligibility to operate in a local jurisdiction; and 6. That the entity will not be owned, in whole or in part, or have as an officer, director, board member, or manager, any individual with a disqualifying felony offense. (B) The additional evaluation criteria, which will be numerically scored, are: 1. The character, veracity, background, qualifications, and relevant experience of principal officers or managers; 2. The business plan proposed by the applicant, which in the case of cultivation

(B) The legal or beneficial ownership, directly or indirectly through ownership of an affiliate entity, of ten (10) percent or more of an entity?s outstanding voting stock or other ownership interest;

(D) The ability to make policy decisions, operating decisions, or decisions regarding the allocation of income and expenses for the entity, whether directly or by a management agreement.

facilities and dispensaries shall include the ability to maintain an adequate supply of medical marijuana, plans to ensure safety and security of qualifying patients and the community, procedures to be used to prevent diversion, and any plan for making medical marijuana available to low-income qualifying patients; 3. Site security; 4. Experience in a legal cannabis market; 5. In the case of testing facilities, the experience of the facility?s personnel with the health care industry and with testing marijuana, food, or drugs for toxins and/or potency; 6. The potential for the facility to have a positive economic impact in the site community; 7. In the case of cultivation facilities, capacity or experience with agriculture, horticulture, and health care; 8. In the case of dispensary facilities, capacity or experience with health care, the suitability of the proposed location, and its accessibility for patients; 9. In the case of infused products manufacturing facilities, capacity or experience with food and beverage manufacturing; and 10. Maintaining competitiveness in the medical marijuana marketplace. (C) When applicable, numerical scoring of evaluation criteria will be conducted as follows: 1. Applications will be separated from their identifying information, including facility business names, and names, addresses, and Social Security numbers of individuals, and assigned a numerical identifier for use during scoring.

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RULES (CONTINUED) 2. Applications will be scored based on responses to evaluation criteria questions. Responses may take the form of written answers or written answers with attachments.

average initial score of all applicants of the same facility type within the evaluation criteria topic regarding potential for positive economic impact in the site community.

A. Each type of facility or certification application will be scored and ranked against the other applications of the same type. For dispensaries, applications will be scored and ranked against other dispensary applications in the same congressional district.

C. For the purposes of this paragraph, zip code employment data was obtained from the?U.S. Census Bureau, American Community Survey 2013-2017, Employment Status, Population16 years and over,? published by the Missouri Census Data Center. The applicable zip codes are listed in the table included herein.

B. Applications will be scored without reference to the identities of the facilities or of individuals named in an application. Written responses to evaluation criteria questions must not refer to facility business names, either legal or fictitious, and must refer to individuals by titleand initials only, e.g. ?Owner A.E.M.? or ?Principal Officer R.W.M.? Any attachments toevaluation criteria question responses shall be redacted so as to obscure the facility business names and the names, addresses, and Social Security numbers of any individuals mentioned in the application. Unredacted versions of those same documents will be submitted separately in a section of the application designated for this purpose. C. Responses to evaluation criteria questions in which a business or individual is identified by name will not be scored. 3. Evaluation criteria questions and initial scoring shall be as delineated in the Evaluation Criteria Questions and Points table, the Evaluation Criteria Scoring table, and the Evaluation Criteria Topics and Values Table, which are incorporated by reference in this rule as publishedby the department and available on the department?s website at http://medicalmarijuana.mo.gov. This rule does not incorporate any subsequent amendments or additions. 4. The same evaluation criteria question in each application will be scored by the same individual, if possible, and scores that vary significantly from other scores for the same questions may be rescored. If rescored, the first score will be discarded, and the second score will stand. 5. Once all applications have been assigned an initial rank and score, the department will reconnect the applications with their identifying information. 6. After evaluation criteria questions have been initially scored, and in order to award points to applicants that seek to locate in economically distressed areas, thereby supporting a potential for positive economic impact in the site community, the rankings of such facilities will be further adjusted by awarding additional points as follows: A. Any facility seeking a license to locate within a zip code area that has an employment rate of eighty-five (85.0) percent to eighty-nine and nine tenths (89.9) percent will receive a scoring increase of thirty (30) percent of the average initial score of all applicants of the same facility type within the evaluation criteria topic regarding potential for positive economic impact in the site community; and B. Any facility seeking a license to locate within a zip code area that has an employment rate of zero (0) to eighty-four and nine tenths (84.9) percent will receive a scoring increase of forty (40) percent of the

7. For cultivation, manufacturing, and testing facilities, the score following any adjustments under paragraph 6 of this subsection is the final score. 8. For dispensary facilities, after evaluation criteria questions have been initially scored and adjusted as applicable under paragraph 7 of this subsection, and in order to facilitate patient access to medical marijuana, the rankings of dispensary facilities will be further adjusted by awarding additional points due to geographic location as follows: A. First, the highest scoring dispensary facility in each of the one hundred sixty-three (163) Missouri House of Representatives districts as drawn and in effect on December 6, 2018, will receive an increase to its score pursuant to subparagraph C. of this paragraph, and all dispensaryfacility applicants?rankings will then be reordered. A map of the state of Missouri showing theapplicable boundary lines of Missouri?s house districts is available on the department?s website;and B. Finally, any dispensary facility applicant with a location more than twenty-five (25) miles, measured in a straight line, from any other dispensary facility applicant or existing dispensary facility will receive an additional increase to its score pursuant to subparagraph C. of thisparagraph, and all dispensary facility applicants?rankings will again be reordered. The resultingrank and score will be each dispensary facility?s final rank and score. C. Scoring increases due to geographic location will be equal to five (5) percent of the average initial score of the top twenty-four (24) ranked facilities in each congressional district that has at least twenty-four (24) dispensary facility applicants. D. In cases where a house district is segmented by the boundary lines of two or more congressional districts, for purposes of the adjustments in this paragraph, only the segment of that house district with the highest population, as of the 2010 United States Population Census, will be utilized. 9. In the case of a tie for the last available license or certification in any category, the license or certification will go to: A. The facility with the highest score in the topic specifically relating to that facility type; B. If a tie remains, then the facility with the highest score in the business plan topic; C. If a tie remains, then the facility with the highest score in the character topic; D. If a tie remains, then the facility with the highest score in the site security topic; E. If a tie remains, then the facility with the highest score in the economic impact topic; F. If a tie remains, then the facility with the highest score in the legal cannabis market

experience; G. If a tie remains, then the facility will be chosen by lottery. (D) Licenses and certifications will be issued as follows: 1. When the numerical scoring system is used, the highest ranked facilities for each type of facility and, for dispensaries, in each congressional district, will receive licenses or certifications, except in cases where an entity under substantially common control, ownership, or management has applied for more than three (3) cultivation, three (3) manufacturing, or five (5) dispensary licenses. In those cases, the department will only issue licenses to the highest ranked facilities associated with that entity, up to the maximum number allowable in each category of license. 2. When the numerical scoring system is not used, all facilities that meet the minimum standards for licenses or certifications will be issued licenses or certifications, except in cases where an entity under substantially common control, ownership, or management has applied for more than five (5) dispensary licenses and some of those dispensaries are located in congressional districts that were numerically scored. In those cases, the department will first issue licenses to the dispensaries associated with that entity in congressional districts that were not numerically scored. Any remaining dispensaries associated with that entity will be issuedl icenses according to that dispensary?s rank and score. (5) The department will impose penalties as follows: (A) For possessing marijuana in amounts between the possessor ?s legal limit and twice the legal limit, in addition to revocation of identification card(s) pursuant to 19 CSR 30-95.030(3)(B)1.D, the possessor will incur a penalty of two hundred (200) dollars. (B) For failure to package medical marijuana consistent with 19 CSR 30-95.040(4)(K), a facility will incur a penalty of five thousand (5,000) dollars for each category of improperly packaged product, and the improperly packaged medical marijuana will be recalled forrepackaging or disposal, at the department?s discretion. (C) Any person or facility that extracts resins from marijuana using combustible gases or other dangerous materials without a manufacturing facility license, shall incur a penalty. 1. In addition to revocation of identification cards pursuant to 19 CSR 30-95.030(3)(B)1.I, any patients or primary caregivers who extract resins in this manner will incur a penalty of two hundred (200) dollars. 2. In addition to suspension of license pursuant to 19 CSR 30-95.040(1)(E)7, facilities that extract resins in this manner will incur a penalty of ten thousand (10,000) dollars. (6) Appeals. (A) The following department decisions shall be appealable to the administrative hearing commission: 1. Denial, revocation, or suspension of licenses or certifications; and 2. Denial or revocation of patient, primary caregiver, patient cultivation, or facility agent

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identification cards. (B) Any person or entity entitled to appeal to the administrative hearing commission under this rule must file a petition with the administrative hearing commission within thirty (30) days after the date the department decision is sent to the person or entity. An untimely appeal will not be considered. (C) Notwithstanding the limits on licenses and certifications set forth in 19 CSR 3095.050(1)(A), 19 CSR 30-95.060(1)(A), 19 CSR 30-95.070(1), and 19 CSR 30-95.080(1)(A)(B), the department may grant additional facility licenses or certifications as a remedy to timely appeals when: 1. Ordered to do so by the administrative hearing commission or a court of competent jurisdiction; or 2. The department determines doing so in settlement of such an appeal best serves implementation of Article XIV of the Missouri Constitution. (7) Statewide Track and Trace System. (A) No entity holding a contract with the state of Missouri for a statewide track and trace system or any affiliates of that entity may sell seed-to-sale services or services related to compliance with seed-to-sale tracking regulations to a licensed or certified facility. (B) Unless otherwise addressed or prohibited by contract or law, an entity holding a contract with the state of Missouri for a statewide track and trace system and any affiliates of that entity may charge a price to a licensed or certified facility for plant/product tracking labels, but no such price shall exceed the cost of producing the label in an amount that would create more than thirty (30) percent net profit on each label. (8) Unless otherwise stated, any reference to days in Chapter 95 will mean calendar days.

RULES (CONTINUED)

US Census Bur eau 20 13-20 17 Amer ican Communit y Sur vey 5-Year Est imat es

Missour i Employment Dat a by Zip Code Tabulat ion

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RULES (CONTINUED) 19 CSR 30-95.030 Qu alif yin g Pat ien t / Pr im ar y Car egiver (1) Physician Certification. A qualifying patient must obtain a new physician certification at least annually. In every application for which a physician certification is required, the physician certification must be less than thirty (30) days old at the time the application is submitted. (2) Identification Card Applications. Qualifying patients and primary caregivers shall obtain identification cards from the department, which will include unique, identifying numbers for each patient and each caregiver-patient relationship. A qualifying patient or his or her primary caregivers may also obtain an identification card to cultivate up to six (6) flowering marijuana plants for the exclusive use of that qualifying patient. The department will receive applications for qualifying patients, primary caregivers, and patient cultivation electronically through a department-provided, web-based application system. In the event of application system unavailability, the department will arrange to accept applications in an alternative, departmentprovided format and will notify the public of those arrangements through its website at http://medicalmarijuana.mo.gov. (A) All applications for qualifying patient identification cards and renewal of such identification cards shall include at least the following information: 1. The qualifying patient?s name, date of birth, and Social Security number; 2. The qualifying patient?s residence address and mailing address or, if the qualifying patient has no residence or mailing address, an address where the qualifying patient can receive mail; 3. A statement that the qualifying patient resides in Missouri and does not claim resident privileges in another state or country, as well as proof of current Missouri residency, which shall be shown by? A. A copy of a valid Missouri driver ?s license, a Missouri Identification Card, a current Missouri motor vehicle registration, or a recent Missouri utility bill; or B. If none of these proofs are available, some other evidence of residence in Missouri, which shall be approved or denied by the director of the medical marijuana program as sufficient proof of residency. 4. The qualifying patient?s e-mail address; 5. A statement confirming that? A. One (1) physician certification, which is less than thirty (30) days old, has been submitted on behalf of the qualifying patient; or B. Two (2) physician certifications, which are less than thirty (30) days old, have been submitted on behalf of the qualifying patient in order to authorize possession limits other than those established by section five (5) of this rule; 6. A legible copy of the qualifying patient?s photo identification issued by a state or federal government entity 7. If the qualifying patient is a

non-emancipated qualifying patient, the name, Social Security number, and a Parental/Legal Guardian Consent Form, included herein, completed by a parent or legal guardian who will serve as primary caregiver for the qualifying patient;

the

may be

qualifying patient?s parent; or B. A copy of documentation establishing legal guardianship of the primary caregiver over the

denied or revoked. A. If an applicant provides false or misleading information in an application, the

8. A clear, color photo of the applicant?s face taken within the prior three (3) months;

qualifying patient; 7. A clear, color photo of the applicant?s face taken within the prior three (3) months; 8. If the primary caregiver is seeking authority to cultivate medical marijuana on behalf of the

identification card for which the applicant is applying will be denied; B. If an applicant fails to provide a complete application within ten (10) days of being notified that an application is incomplete, the identification card for which the applicant is

patient: A. The address of the facility in which the primary caregiver will cultivate marijuana; B. A description of the security arrangements and processes that will be used to restrict

applying will be denied; (I) An applicant will be considered notified on the date the department sends a written

9. At the option of the applicant, a statement indicating whether the applicant is currently receiving assistance from any Missouri programs for low-income individuals, and if so, which programs; 10. If the patient is seeking authority to cultivate medical marijuana: A. The address of the facility in which the qualifying patient will cultivate marijuana; B. A description of the security arrangements and processes that will be used to restrict access to only qualifying patients and their primary caregivers; C. The name and Patient License Number or Caregiver License Number, if applicable, of one other qualifying patient or primary caregiver with whom the cultivating facility will be shared; D. A statement affirming the applicant?s agreement to immediately make available access to the patient cultivation facility upon request from the department. Such access will be only for purposes of confirming compliance with this rule and will be limited to the enclosed locked facility and any areas necessary to reach and enter the facility on a path of the patient?s or primary caregiver ?s choosing; 11. An attestation that the information provided in the application is true and correct; 12. The signature of the qualifying patient and date the qualifying patient signed, or, in the case of a non-emancipated qualifying patient, the signature of the parent or legal guardian who will serve as primary caregiver for the qualifying patient and the date the parent or legal guardian signed; and 13. All applicable fees. (B) All applications for primary caregiver identification cards and renewal of such identification cards shall include at least the following information: 1. The primary caregiver ?s name, date of birth, and Social Security number; 2. The primary caregiver ?s residence address and mailing address; 3. The primary caregiver ?s e-mail address; 4. The name and Patient License Number of the qualifying patient for whom the applicant seeks to serve as primary caregiver; 5. A legible copy of the primary caregiver ?s photo identification issued by a state or federal government entity; 6. If the qualifying patient is a non-emancipated qualifying patient, a statement that the primary caregiver is the qualifying patient?s parent or legal guardian and: A. A copy of a birth certificate or adoption record showing the primary caregiver as

access to only qualifying patients and their primary caregivers; C. The name and Patient License Number or Caregiver License Number, if applicable, of one other qualifying patient or primary caregiver with whom the cultivating facility will be shared; andD. A statement affirming the applicant?s agreement to immediately make available access to the patient cultivation facility upon request from the department. Such access will be only for purposes of confirming compliance with this rule and will be limited to the enclosed locked facility and any areas necessary to reach and enter the facility on a path of the patient?s or primary caregiver ?s choosing; 9. An attestation that the information provided in the application is true and correct; 10. The signature of the primary caregiver and date the primary caregiver signed; 11. Except in the case of a non-emancipated qualifying patient, a Patient Authorization Form, included herein, completed by the qualifying patient who the primary caregiver will serve; and 12. All applicable fees. (3) Application Processes. (A) Upon receiving an application for a qualifying patient identification card, primary caregiver identification card, or patient cultivation identification card, the department shall, within thirty (30) days, either approve the application or provide a written explanation for its denial. 1. In the case of qualifying patient and patient cultivation identification cards, if the department fails to deny or fails to approve an application within thirty (30) days, a card will be issued that will be valid for one (1) year and will serve all the same functions as would a card issued after application approval. 2. An application for a qualifying patient or patient cultivation identification card will be considered received when an application is submitted to the department that includes all information required by section (2) of this rule. The department will notify an applicant once if an application is incomplete and will specify in that notification what information is missing. (B) Denial and revocation. 1. Qualifying patient, primary caregiver, and patient cultivation identification cards

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explanation of how the application is incomplete to a mailing or e-mail address provided by the applicant. (II) If an applicant fails to provide either a mailing or e-mail address, the department will not issue notice but will hold the application for thirty (30) days before denying it. C. If a card holder violates any provision of this rule, any medical marijuana identification cards currently held by that individual may be revoked; D. If a card holder is found to be in possession of an amount of marijuana greater than the medical marijuana legal limit applicable to that individual, any medical marijuana identification cards currently held by that individual will be revoked. In such a case, the identification card may be revoked for up to one (1) year; E. If a card holder is convicted of, pleads guilty to, or receives a suspended imposition of sentence for a violation of section 579.020, 579.065, or 579.068, RSMo or for a violation of a similar law of another state, any medical marijuana identification cards currently held by that individual will be revoked. In such a case, the revocation shall be permanent, absent a gubernatorial pardon or expungement. F. If an applicant has applied for a qualifying patient, primary caregiver, or qualifying patient cultivation identification card and received two (2) denials within a twelve- (12-) month period, has any of these types of identification cards revoked twice within a twenty-four (24) month period, or applied for any of these types of identification cards and been denied once and also had any of these types of identification cards revoked once within a twenty-four- (24-) month period, the identification card for which the applicant is applying will be denied. G. If a patient cultivation identification card holder fails to immediately make available access to his or her patient cultivation facility upon request from the department, the patient cultivation identification card will be revoked; H. If medical marijuana is stolen or lost, is identifiable as medical marijuana purchased by a particular qualifying patient or primary caregiver, is discovered in the possession of an individual who is not the qualifying patient or primary caregiver authorized to possess that medical marijuana, and was not timely reported as stolen or lost by the qualifying patient or primary caregiver authorized to possess that medical marijuana, the

RULES (CONTINUED) qualifying patient?s or primary caregiver ?s identification card may be revoked; I. If a qualifying patient or primary caregiver uses combustible gases or other dangerous materials to extract resins from marijuana, the qualifying patient?s or primary caregiver ?s identification card may be revoked for up to one (1) year; J. If the department determines there is good cause to do so, an application for a patient cultivation identification card may be denied. 2. Any denial or revocation shall be issued by the department in writing to the qualifying patient or, in the case of a primary caregiver, to the qualifying patient and the primary caregiver, and shall include the specific reasons for the denial or revocation and the process for requesting review of the department?s decision. (C) Renewal. Qualifying patient, primary caregiver, and patient cultivation identification cards are valid for twelve (12) months from their date of issuance and shall be renewable by submitting, prior to expiration by at least thirty (30) days but no sooner than sixty (60) days, a new or updated application, which shall include any information required by section (2) that has changed since the date of the previous application, including a new physician certification. (D) The department shall charge a fee for medical marijuana identification card applications. 1. There will be a separate fee for each application to be a qualifying patient, each application to be a primary caregiver on behalf of a specific qualifying patient, and each application to cultivate medical marijuana on behalf of a specific qualifying patient. 2. Requests for authority to cultivate medical marijuana on behalf of a qualifying patient may be made within a qualifying patient or primary caregiver application or may be made separately at a later time. However, the authorization to cultivate will be added to the qualifying patient or primary caregiver identification card and will only remain valid as long as the qualifying patient or primary caregiver ?s identification card is still valid. 3. Current fees, including any adjustments, will be posted on the department?s website at http://medicalmarijuana.mo.gov. (E) If the name or address of a qualifying patient or primary caregiver changes after an identification card is issued, the qualifying patient or primary caregiver shall notify the department within ten (10) days of the change. (4) Qualifying Patient Cultivation. (A) All qualifying patient cultivation shall take place in an enclosed, locked facility, as defined in 19 CSR 30-95.010. (B) One (1) qualifying patient may cultivate up to six (6) flowering marijuana plants, six (6) nonflowering marijuana plants (over fourteen (14) inches tall), and six (6) clones (plants under fourteen (14) inches tall) at any given time in a single, enclosed locked facility. Two (2) qualifying patients, who

both hold valid qualifying patient cultivation identification cards, may share one (1) enclosed, locked facility. No more than twelve (12) flowering marijuana plants, twelve (12) nonflowering plants, and twelve (12) clones may be cultivated in a single, enclosed locked facility, except when one (1) of the qualifying patients, as a primary caregiver, also holds a patient cultivation identification card for a third qualifying patient, in which case that primary caregiver may cultivate six (6) additional flowering marijuana plants, six (6) additional nonflowering marijuana plants, and six (6) additional clones for a total of eighteen (18) flowering marijuana plants, eighteen (18) nonflowering marijuana plants, and eighteen (18) clones in a single, enclosed locked facility. (C) Under no circumstance will a qualifying patient be entitled to cultivate, or have cultivated on his or her behalf, more than six (6) flowering marijuana plants. (D) Nothing in this section shall convey or establish a right to cultivate medical marijuana in a facility where state law or a private contract would otherwise prohibit doing so. (E) All cultivated flowering marijuana plants in the possession of a qualifying patient or primary caregiver shall be clearly labeled with the qualifying patient?s name. (F) The department shall provide each qualifying patient or primary caregiver who receives a qualifying patient cultivation identification card with a cultivation authorization, which shall be clearly displayed within the enclosed cultivation area and in close proximity to the marijuana plants. The authorization shall list the name of the qualifying patient or primary caregiver and the address of the facility in which that qualifying patient or primary caregiver is authorized to cultivate marijuana. (5) Purchase and Possession Limitations. (A) Qualifying patients may only purchase, or have purchased on their behalf by their primary caregivers, four (4) ounces of dried, unprocessed marijuana per qualifying patient, or its equivalent, in a thirty- (30-) day period. (B) Qualifying patients may only possess, or instruct a primary caregiver to possess on their behalf? 1. In the case of qualifying patients who do not cultivate or have medical marijuana cultivated on their behalf, up to a sixty(60-) day supply of dried, unprocessed marijuana per qualifying patient, or its equivalent; or 2. In the case of qualifying patients who are cultivating marijuana for medical use or whose primary caregivers are cultivating marijuana on their behalf, up to a ninety(90-) day supply of dried, unprocessed marijuana or its equivalent, so long as the supply of medical marijuana cultivated by the qualifying patients or primary caregivers remains on property under their control. (C) All medical marijuana purchased from a dispensary must be stored in or with its original packaging.

(D) Primary caregivers may possess a separate legal limit for each qualifying patient under their care and a separate legal limit for themselves if they are a qualifying patient, each of which shall be stored separately for each qualifying patient and labeled with the qualifying patient?s name. (E) Purchase and possession limits established in this section shall not apply to a qualifying patient with written certification from two (2) independent physicians that there are compelling reasons why the qualifying patient needs a greater amount than the limits established in this section. 1. In such a case, both independent physicians must state in their certifications what amount the qualifying patient requires, which shall then be that patient?s limit. 2. If the two (2) independent physicians disagree on what amount should be the patient?s limit, the lower of the two (2) amounts shall be that patient?s limit. 3. If the patient?s limit is increased after receiving a qualifying patient identification card, the qualifying patient or primary caregiver shall notify the department within ten (10) days of the change. (6) Non-Emancipated Qualifying Patient. (A) A physician shall not issue a certification for the medical use of marijuana for a nonemancipated qualifying patient under the age of eighteen (18) without the written consent of a parent or legal guardian of the qualifying patient. (B) The department shall not issue a qualifying patient identification card on behalf of a non- emancipated qualifying patient under the age of eighteen (18) without the written consent of a parent or legal guardian of the qualifying patient. Such card shall be issued to the parent or guardian and not directly to the patient.

ten (10) days of that change. The department will confirm in writing that the qualifying patient has voluntarily surrendered the identification card and that the identification card is no longer valid. (D) If a qualifying patient?s medical marijuana is stolen or lost, the qualifying patient must notify the department within two (2) days. (8) Primary Caregiver Responsibilities. (A) No individual shall serve as the primary caregiver for more than three (3) qualifying patients. (B) No individual shall serve as a primary caregiver for a qualifying patient who is already served by two (2) primary caregivers. (C) If a primary caregiver is no longer entitled to serve as a primary caregiver or no longer wishes to hold a primary caregiver identification card, he or she must notify the department within ten (10) days of that change. The department will confirm in writing that the primary caregiver has voluntarily surrendered the identification card and that the identification card is no longer valid. (D) If medical marijuana in possession of a primary caregiver is stolen or lost, the primary caregiver must notify the department in a department-approved format within two (2) days. (9) Disposal of Qualifying Patient Medical Marijuana. (A) In any case where a qualifying patient is no longer entitled to medical marijuana under any provision of state law or is deceased, any excess medical marijuana or marijuana plants in the possession of the qualifying patient or the patient?s primary caregiver or discovered by a third

(C) Only a parent or guardian may serve as a primary caregiver for a non-emancipated qualifying patient under the age of eighteen (18).

party shall be turned over to a licensed dispensary for disposal within thirty (30) days of the event that makes the qualifying patient ineligible.

(D) Only the qualifying patient?s parent or guardian who holds a primary caregiver identification card shall purchase or possess medical marijuana for a non-emancipated qualifying patient under the age of eighteen (18).

1. Before delivering the excess medical marijuana to a dispensary, the individual in possession of the excess medical marijuana must contact the department, and the department will coordinate delivery arrangements between the individual and a dispensary; and

(E) A parent or guardian who holds a primary caregiver identification card shall supervise the administration of medical marijuana to a non-emancipated qualifying patient under the age of eighteen (18). (7) Qualifying Patient Responsibilities. (A) No qualifying patient shall consume marijuana for medical use in a public place, unless provided by law. (B) No qualifying patient who is under the care of a primary caregiver may serve as the primary caregiver for another qualifying patient. (C) If a qualifying patient is no longer entitled to medical marijuana or no longer wishes to hold

2. The individual in possession of excess medical marijuana shall receive from the department written, temporary authorization to transport medical marijuana, which shall include details regarding the delivery arrangements approved by the department. (B) The possession and transportation of medical marijuana under this section shall not subject the possessor to arrest, criminal or civil liability, or sanctions under Missouri law, provided that the possessor produces on demand to the appropriate authority a copy of the temporary authorization for transport or evidence of communication with the department regarding delivery arrangements.

a medical marijuana identification card, he or she must notify the department within

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RULES (CONTINUED) 19 CSR 30-95.040 M edical M ar iju an a Facilit ies Gen er ally (1) Application Processes. The department will begin accepting applications for licensing and certification of cultivation, infused products manufacturing, dispensary, testing, and transportation facilities on August 3, 2019. (A) The department will receive applications for facility licenses or certifications electronically through a department-provided, web-based application system. In the event of application system unavailability, the department will arrange to accept applications in an alternative, departmentprovided format and will notify the public of those arrangements through its website. (B) For cultivation, manufacturing, dispensary, and testing facilities, the department will publish on its website time periods during which it will accept applications for review. All complete applications received by the department that are submitted during the application time periods will be approved or denied within one hundred fifty (150) days of that application?s submission. 1. Any application fees submitted before or during the first application time period and during any subsequent application period are nonrefundable. 2. After the first application time period, any application fees submitted outside of an application time period will not be accepted. 3. If licenses or certifications are available after a time period for accepting applications has passed, the department will determine when to publish on its website a new time period during which it will accept applications and will publish that new time period on its website at least six (6) months prior to the beginning of that time period. 4. Applications will be considered complete if they include all information required for applications by this rule and by 19 CSR 30-95.025(4). The department will notify an applicant if an application is incomplete and will specify in that notification what information is missing. Applicants will be given seven (7) days to provide missing information. (C) For t r an spor t at ion f acilit ies, all com plet e applicat ion s r eceived by t h e depar t m en t t h at ar e su bm it t ed on or af t er Au gu st 3, 2019, w ill be appr oved or den ied w it h in on e h u n dr ed f if t y (150) days of t h at applicat ion?s su bm ission . Applicat ion s w ill be con sider ed com plet e if t h ey in clu de all in f or m at ion r equ ir ed f or applicat ion s by t h is r u le. Th e depar t m en t w ill n ot if y an applican t if an applicat ion is in com plet e an d w ill specif y in t h at n ot if icat ion w h at in f or m at ion is m issin g. Applican t s w ill be given seven (7) days t o pr ovide m issin g in f or m at ion . (D) Th e issu an ce of a f acilit y licen se or cer t if icat ion does n ot au t h or ize t h e f acilit y t o begin cu lt ivat in g, m an u f act u r in g, dispen sin g, t est in g, or t r an spor t in g m edical m ar iju an a. A f acilit y w ill be gr an t ed f in al appr oval t o oper at e u pon passin g a com m en cem en t in spect ion . (E) The department will not license or certify a cultivation, dispensary, manufacturing, transportation, or testing

facility that is owned by or affiliated with an entity that currently holds a contract with the state of Missouri for any product or service related to the department?s medical marijuana program. (F) Licenses and certification for facilities may be suspended, denied, or revoked. 1. If a facility provides false or misleading information in an application, its application may be denied or, if the information is later discovered to have been false or misleading, its license or certification may be revoked. Plans, assurances, and projections offered in answers to 19 CSR 30-95.025(4) evaluation criteria questions may be considered false or misleading if, upon application for license renewal, the department determines the facility has not made a reasonable effort to implement or follow-through on those plans, assurances, or projections. 2. If a facility violates any provision in this chapter or fails to comply with a corrective action plan, its license or certification may be suspended or revoked. 3. If an applicant fails to provide a complete application within seven (7) days of being notified that an application is incomplete, the license or certification for which the applicant is applying will be denied. 4. If a facility is granted a license or certification but has not passed a commencement inspection within one (1) year of the department issuing the license or certification, the license or certification may be revoked. 5. If a facility fails to comply with a department order to immediately suspend all or a part of its operations, the license or certification shall be revoked. 6. If an application does not meet the minimum standards for licenses and certifications pursuant to 19 CSR 30-95.025(4), the license or certification for which the applicant is applying will be denied. 7. If a facility uses combustible gases or other dangerous materials to extract resins from marijuana without a manufacturing facility license, the facility?s license may be suspended for up to one (1) year. 8. If a facility packages medical marijuana in a false or misleading manner, or in any manner designed to cause confusion between a marijuana product and any product not containing marijuana, the facility?s license may be suspended or revoked. 9. If a facility or a facility employee fails to comply with seed-to-sale tracking requirements or intentionally misuses or falsifies seed-to-sale tracking data, the facility?s license may be revoked. (G) Cultivation, infused product manufacturing, and dispensary licenses and testing and transportation certifications are valid for three (3) years from the date the license or certification is issued and shall, except for good cause, be renewable by submitting, prior to expiration by at least one hundred fifty (150) days but no sooner than two hundred fifty (250) days, an updated application, which shall include any information required by Section (2) of this rule or Section (4) of 19 CSR 30-95.025 that has changed since the date of the previous application; (H) The department shall charge an

application or renewal fee for a facility license or certification and also an annual fee once a license or certification is granted. The first annual fee will be due thirty (30) days after a license or certification is issued and shall be due annually on that same date as long as the facility?s license or certification remains valid. The department shall publish the current fees, including any adjustments, on its website. The amount of fees due for each facility will be the amount that is effective as of that facility?s due date. (2) Application Requirements. Facilities must obtain a license or certification to cultivate, manufacture, dispense, test, and transport medical marijuana in Missouri. All applications for facility licenses or certifications and for renewals of licenses or certifications shall include at least the following information: (A) Name and address of the primary contact for the applicant facility; (B) Legal name of the facility, including fictitious business names, and a certificate of good standing from the Missouri Secretary of State; (C) A completed Ownership Structure Form, included herein, which must show the applicant entity is majority owned by Missouri residents, and a written description or visual representation of the facility?s ownership structure including all entities listed on the Ownership Structure Form; (D) For each owner claiming Missouri residency for purposes of subsection (C) of this section, a statement that the owner has resided in Missouri for at least one (1) year and does not claim resident privileges in another state or country, as well as proof of current Missouri residency, which shall be shown by? 1. A copy of a valid Missouri driver ?s license, a Missouri Identification Card, a current Missouri motor vehicle registration, or a recent Missouri utility bill; or 2. If none of these proofs are available, some other evidence of residence in Missouri, which shall be approved or denied at the discretion of the director of the medical marijuana program as sufficient proof of residency;

of the facility complies with the facility location requirements of Section (4)(B) of this rule or 19 CSR 30-95.100(2)(C); (G) Descriptions, schematics, or blueprints for the facility; (H) If the city, town, or county in which the facility will be located has enacted zoning restrictions applicable to the facility, the text of the restrictions and a description of how the facility plans to comply with those restrictions; (I) An attestation that no individual who owns the facility, in whole or in part, has a disqualifying felony offense; (J) A statement confirming that all owners who hold any portion of the economic or voting interest of the facility who will also have access to medical marijuana or the medical marijuana facility, and all officers, directors, board members, managers, and employees identified in the application, have submitted fingerprints within the previous six months for a state and federal fingerprint-based criminal background check to be conducted by the Missouri State Highway Patrol; (K) All facility evaluation information required by 19 CSR 30-95025(4); and (L) All applicable fees or proof that all applicable fees have already been paid. (3) Facility Ownership and Employment. (A) Cultivation, infused products manufacturing, dispensary, testing, and transportation facilities shall not be owned by, in whole or in part, or have as an officer, director, board member, manager, or employee, any individual with a disqualifying felony offense. (B) Cultivation, infused products manufacturing, dispensary, testing, and transportation facilities shall be held by entities that are majority owned by natural persons who have been citizens of the state of Missouri for at least one (1) year prior to applying for a facility license or certification. For the purposes of this requirement, citizen means resident.

(F) Proposed address of the facility and? 1. A map of the surrounding area that shows compliance with the facility location

(C) No more than three (3) cultivation, no more than three (3) manufacturing, and no more than five (5) dispensary licenses shall be issued to any entity under substantially common control, ownership, or management. Any entity under substantially common control, ownership, or management that has applied for more than three (3) cultivation, three (3) manufacturing, or five (5) dispensary licenses shall contact the department at the time of application submission to identify for the department the applications associated with that entity. The department will use this information, once application scoring is complete pursuant to 19 CSR 30-95.025(4), solely for determining how many licenses the department may issue any particular entity.

requirements of Section (4)(B) of this rule or 19 CSR 30-95.100(2)(C); or 2. Documentation showing a local government requirement different than the requirement in

(D) No testing facility shall be owned by an entity under substantially common control, ownership, or management as a cultivation, manufacturing, or dispensary facility.

Section (4)(B) of this rule or 19 CSR 30-95.100(2)(C) and a map of the surrounding area that shows compliance with the facility location requirements of the local government; and

(E) Facility Agent Identification Cards. Each owner, officer, manager, contractor, employee, and other support staff of a licensed or certified cultivation, dispensary, manufacturing, testing, or transportation facility shall obtain an agent identification card, which shall be assigned and display a

(E) A list of all facilities licensed or certified or applying for licensure or certification in Missouri to cultivate, manufacture, dispense, or test medical marijuana that are or will be under substantially common control, ownership, or management as the applicant. For each facility listed, a written explanation of how the facility is under substantially common control, ownership, or management as the applicant, with supporting documentation;

3. An attestation that the proposed address

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RULES (CONTINUED) unique, identifying number. For all such individuals associated with an entity at the time it is licensed or certified, any work they are performing for that entity may continue, but application for an agent identification card must be made within thirty (30) days of a license or certification being granted. For all other such individuals, applications for agent identification cards will be accepted only after an individual receives an offer of employment from a licensed or certified facility, and for those individuals, agent identification cards must be granted before they may begin employment with a licensed or certified entity. 1. All applications for agent identification cards and renewals of agent identification cards shall include at least the following information in a department-approved format: A. Name, address, and Social Security number of the applicant; B. A statement confirming that the applicant has submitted fingerprints within the previous six (6) months for a state and federal fingerprint-based criminal background check to be conducted by the Missouri State Highway Patrol; C. A copy of a written offer of employment from a licensed or certified facility; and D. All applicable fees. 2. Agent identification cards shall be valid for three (3) years. 3. If arrested for a disqualifying felony offense, agent identification card holders must notify the department within thirty (30) days of the arrest. 4. For purposes of this section, a contractor is a person or company that undertakes a contract

or church. 1. In the case of a freestanding facility, the distance between the facility and the school, daycare, or church shall be measured from the external wall of the facility structure closest in proximity to the school, daycare, or church to the closest point of the property line of the school, daycare, or church. If the school, daycare, or church is part of a larger structure, such as an office building or strip mall, the distance shall be measured to the entrance or exit of the school, daycare, or church closest in proximity to the facility. 2. In the case of a facility that is part of a larger structure, such as an office building or strip mall, the distance between the facility and the school, daycare, or church shall be measured from the property line of the school, daycare, or church to the facility?s entrance or exit closest in proximity to the school, daycare, or church. If the school, daycare, or church is part of a larger structure, such as an office building or strip mall, the distance shall be measured to the entrance or exit of the school, daycare, or church closest in proximity to the facility. 3. Measurements shall be made along the shortest path between the demarcation points that can be lawfully traveled by foot. (C) All licensed or certified cultivation, dispensary, manufacturing, testing, and transportation facilities must seek and obtain the department?s approval before they may? 1. Assign, sell, give, lease, sublicense, or otherwise transfer its license to any other entity. A. If the entity to which the license or certification will be transferred is owned by the same

with a licensed or certified facility to perform work that would include access to medical marijuana or related equipment or supplies for a time period greater than fourteen (14) days.

entities as was the entity to which the department originally issued the license or certification, the request may be submitted after the facility at issue has been granted a license and must include at least the following:

5. For purposes of this section, an owner is a person who holds any portion of the economic or voting interests of a facility and who will have access to medical marijuana or a medical marijuana facility.

(I) Legal name of the facility, including fictitious business names, and a certificate of good standing from the Missouri Secretary of State;

6. Agent identification card holders must have their cards accessible to them at all times while performing work in or on behalf of a facility.

(II) A completed Ownership Structure Form, included herein, which must show the applicant entity is owned by the same entities as was the entity to which the department originally issued the license or certification;

7. The department shall charge a fee for identification cards, which shall be seventy-five (75) dollars, due at the time of application or renewal. (4) Facility Operation, Policies, and Procedures. (A) Each cultivation, infused product manufacturing, or dispensary facility in operation must obtain a separate license, but multiple licenses may be utilized in a single facility. All licenses shall be displayed at all times within twenty (20) feet of the main entrance to a facility. (B) Unless expressly allowed by the local government, no new cultivation, infused products manufacturing, dispensary, or testing facility shall be sited, at the time of application for license or for local zoning approval, whichever is earlier, within one thousand (1,000) feet of any then- existing elementary or secondary school, daycare,

B. If the entity to which the license or certification will be transferred is not owned by the same entities as was the entity to which the department originally issued the license or certification, the request may be submitted beginning January 1, 2021, and shall include at least the same information required for an initial application for license or certification; 2. Make any changes to ten (10) percent or more of the ownership interests of the facility. Such requests may be submitted after the facilities at issue have been granted a license and must include at least the following: A. Name of each new owner, if any; B. An updated Ownership Structure Form, included herein, which must show the applicant entity is majority owned by Missouri residents, and a written

description or visual representation of the facility?s ownership structure including all entities listed on the Ownership Structure Form; C. For each owner claiming Missouri residency for purposes of subparagraph B of this paragraph, a statement that the owner has resided in Missouri for at least one (1) year and does not claim resident privileges in another state or country, as well as proof of current Missouri residency, which shall be shown by? (I) A copy of a valid Missouri driver ?s license, a Missouri Identification Card, a current Missouri motor vehicle registration, or a recent Missouri utility bill; or (II) If none of these proofs are available, some other evidence of residence in Missouri, which shall be approved or denied at the discretion of the director of the medical marijuana program as sufficient proof of residency; D. A list of all facilities licensed or certified or applying for licensure or certification in Missouri to cultivate, manufacture, dispense, or test medical marijuana that are or will be under substantially common control, ownership, or management as the applicant. For each facility listed, an explanation of how the facility is under substantially common control, ownership, or management as the applicant, with supporting documentation; E. An attestation that no individual who owns the facility, in whole or in part, has a disqualifying felony offense; and F. A statement confirming that all owners who hold any portion of the economic or voting interest of a facility who will also have access to medical marijuana or a medical marijuana facility, and all officers, directors, board members, managers, and employees identified in the application have submitted fingerprints within the previous six months for a state and federal fingerprint-based criminal background check to be conducted by the Missouri State Highway Patrol; 3. Materially deviate from the proposed physical design or make material changes to the current physical design of the facility, including its location. Such requests may be submitted after the facilities at issue have been granted a license and shall include at least the following: A. New or updated descriptions, schematics, or blueprints for the facility; B. An attestation that the proposed changes to the facility comply with the facility location requirements of Section (4)(B) of this rule or 19 CSR 30-95.100(2)(C) and any facility location requirements of the local government; C. If the city, town, or county in which the facility will be located has enacted zoning restrictions applicable to the facility, the text of the restrictions and a description of how the changes to the facility comply with those restrictions; and D. For location change requests, an explanation for why the facility?s original location is no longer possible and proof that claims made in the facility?s initial licensure application regarding benefits of its original location also apply to the facility?s newly proposed location. 4. Combine licensed facilities at a single location. Such requests may be submitted

after the facilities at issue have been granted a license and shall include at least the following: A. Descriptions, schematics, or blueprints for the combined facilities; B. An attestation that the proposed combination of facilities complies with the facility location requirements of Section (4)(B) of this rule or 19 CSR 30-95.100(2)(C) and any location requirements of the local government; C. If the city, town, or county in which the combined facilities will be located has enacted zoning restrictions applicable to the combined facilities, the text of the restrictions and a description of how the combined facilities will comply with those restrictions; and D. If the combination of facilities is between two or more entities with different ownership, documents showing the agreements between the entities concerning their respective roles and their relationship in regard to management, operation, and maintenance of the combined facility. Such agreements shall include an acknowledgment that all entities sharing management, operations, or maintenance of the combined facility shall be jointly responsible for compliance with the applicable department regulations for the shared spaces of the combined facility; or 5. Begin construction on a warehouse sited at a location other than the approved location of the facility. Such requests may be submitted after the facility at issue has been granted a license and shall include at least the following: A. Descriptions, schematics, or blueprints for the warehouse; B. An attestation that the proposed location for the warehouse complies with the facility location requirements of Section (4)(B) of this rule or 19 CSR 30-95.100(2)(C) and any location requirements of the local government that would apply to the facility for which the warehouse is being constructed; C. If the city, town, or county in which the warehouse will be located has enacted zoning restrictions applicable to the facility for which the warehouse is being constructed, the text of the restrictions and a description of how the warehouse will comply with those restrictions; and D. An attestation that the warehouse will comply with all other rules applicable to the facility for which the warehouse is being constructed. (D) All marijuana for medical use, including plants, flowers, and infused products, sold in Missouri shall be cultivated in a licensed cultivation facility located in Missouri. After December 31, 2020, marijuana for medical use shall be grown from seeds or plants obtained from a Missouri licensed cultivation or dispensary facility. (E) Any excess or unusable medical marijuana or medical marijuana byproduct of a cultivation, manufacturing, dispensary, testing, or transportation facility shall be disposed of in the following manner, as applicable: 1. Solid and liquid wastes generated during medical marijuana production and processing must be stored, managed, and disposed of in accordance with applicable

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RULES (CONTINUED) state, tribal, local, and municipal laws and regulations. Facilities must keep records of the final disposal destinations of all such wastes for at least five (5) years. 2. Wastewater generated during medical marijuana production and processing must be disposed of in compliance with applicable state, tribal, local, and municipal laws and regulations. 3. Wastes from the production and processing of medical marijuana plants must be evaluated against state hazardous waste regulations to determine if those wastes qualify as hazardous waste. It is the responsibility of each waste generator to properly evaluate their waste to determine if it is a hazardous waste per 40 CFR 262.11. If a generator 's waste does qualify as a hazardous waste, then that waste is subject to the applicable hazardous waste management standards. A. All solid waste, as defined by 40 CFR 261.2, must be evaluated under the hazardous waste regulations, including:

6. Medical marijuana waste that has been rendered unusable may be delivered to a permitted solid waste facility for final disposition. Examples of acceptable permitted solid waste facilities include: A. For compostable mixed waste: Compost, anaerobic digester, or other facility with approval of the local health department. B. For noncompostable mixed waste: Landfill, incinerator, or other facility with approval of the local health department. 7. All facility waste of any type must be stored securely before final disposition, which can be done within the facility in areas designated for disposal activities or, if necessary, outside the facility in a locked, tamper-resistant receptacle. (F) All cultivation, manufacturing, dispensary, testing, and transportation facilities must establish and follow procedures to ensure medical marijuana remains free from contaminants. The procedures must address, at a minimum:

(I) Waste from medical marijuana flowers, trim, and solid plant material used to create an extract;

1. The flow through a facility of any equipment or supplies that will come in contact with medical marijuana including receipt and storage;

(II) Waste solvents, pesticides, and other similar materials used in the cultivation, manufacturing, or testing process;

2. Employee health and sanitation; 3. Environmental factors, such as:

(III) Discarded plant waste, spent solvents, and laboratory wastes from any medical marijuana processing or quality assurance testing; and (IV) Medical marijuana extract that fails to meet quality testing. B. Medical marijuana flowers, trim, and solid plant material are not in themselves considered hazardous waste unless they have been treated or contaminated with a hazardous waste constituent. 4. Medical marijuana waste that does not qualify as hazardous waste per 40 CFR 262.11 must be rendered unusable prior to leaving a facility, including plant waste, such as roots, stalks, leaves, and stems. 5. Medical marijuana plant waste that does not qualify as hazardous may be rendered unusable by grinding and incorporating the medical marijuana plant waste with other nonhazardous ground materials so the resulting mixture is at least fifty percent nonmarijuana waste by volume. Material used to grind with the medical marijuana may be either compostable waste or noncompostable waste. Other methods to render medical marijuana waste unusable must be approved by the department before implementation. A. Compostable mixed waste: Medical marijuana waste to be disposed as compost feedstock or in another organic waste method (for example, anaerobic digester) may be mixed with the following types of waste materials: (I) Food waste; (II) Yard waste; or (III) Vegetable based grease or oils. B. Noncompostable mixed waste: Medical marijuana waste to be disposed in a landfill or another disposal method (for example, incinerator) may be mixed with the following types of waste materials: (I) Paper waste; (II) Cardboard waste; (III) Plastic waste; or (IV) Soil.

A. Floors, walls, and ceilings made of smooth, hard surfaces that are easily cleaned; B. Temperature and humidity controls; C. A system for monitoring environmental conditions; D. A system for cleaning and sanitizing rooms and equipment; E. A system for maintaining any equipment used to control sanitary conditions; and F. For cultivation and manufacturing facilities, an air supply filtered through high-efficiency particulate air filters under positive pressure. (G) All cultivation, infused products manufacturing, dispensary, testing, and transportation facilities shall implement inventory control systems and procedures as follows: 1. Each facility shall designate in writing a facility agent who is generally responsible for the inventory control systems and procedures for that facility. 2. All weighing and measuring of medical marijuana required by this rule must be conducted with a National Type Evaluation Program approved scale, which shall be capable of weighing and measuring accurately at all times and recalibrated at least yearly. 3. Each facility shall use a department-certified seed-to-sale tracking system to track medical marijuana from seed or immature plant stage until the medical marijuana is purchased by a qualifying patient or primary caregiver or destroyed. Records entered into the seed-to-sale tracking system must include each day?s beginning inventory, harvests, acquisitions, sales, disbursements, remediations, disposals, transfers, ending inventory, and any other data necessary for inventory control records in the statewide track and trace system. 4. Each infused product manufacturing facility shall: A. Establish and maintain a perpetual inventory system that documents the flow

of materials through the manufacturing process; B. Establish procedures to reconcile the raw material used to the finished product on the basis of each process lot. Significant variances must be documented, investigated by management personnel, and reported to the department and to the facility that ordered the infused product within twenty-four (24) hours of discovering the variances; and C. Provide for quarterly physical inventory counts to be performed by facility employees who do not participate in the manufacturing process, which shall be reconciled to the perpetual inventory records. Significant variances must be documented, investigated by management personnel, and reported to the department within twenty-four (24) hours of discovering the variances. 5. Each dispensary facility shall be responsible for ensuring that every amount of medical marijuana sold or disbursed to a qualifying patient or primary caregiver is recorded in the seed- to-sale tracking system as a purchase by or on behalf of the applicable qualifying patient. Amounts of medical marijuana shall be recorded? A. For dried, unprocessed marijuana, in ounces or grams; B. For concentrates, in grams; C. For infused products, by milligrams of THC. 6. If a facility identifies a reduction in the amount of medical marijuana in the inventory of the facility, the facility must document where in the facility?s processes the loss has occurred, if possible, and take and document corrective action. If the reduction in the amount of medical marijuana in the inventory of the facility is due to suspected criminal activity by a facility agent, the facility shall report the facility agent to the department and to the appropriate law enforcement agencies within twenty-four (24) hours of discovering the suspected criminal activity. 7. A medical marijuana facility shall maintain all records required by this subsection for at least five (5) years. 8. In case of seed-to-sale system failure or loss of connection to the statewide track and trace system, the facility may continue performing for up to five (5) hours all actions that are required to be tracked, except sales of medical marijuana or transfers of medical marijuana from the facility, as long as the facility records all necessary tracking information and enters that information into its seed-to-sale tracking system upon restoration of the system or into the statewide track and trace system upon restoration of the connection. (H) All cultivation, infused products manufacturing, and dispensary facilities shall ensure the security of medical marijuana and facility employees by taking at least the following measures. 1. Facilities shall install and maintain security equipment designed to prevent unauthorized entrance into limited access areas and to prevent diversion and inversion of medical marijuana including: A. Devices or a series of devices to detect unauthorized intrusion, which may include a signal system interconnected with a radio

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frequency method, such as cellular or private radio signals, or other mechanical or electronic devices; B. Except in the case of outdoor cultivation, exterior lighting to facilitate surveillance, which shall cover the exterior and perimeter of the facility; C. Electronic video monitoring, including? (I) At least one (1) call-up monitor that is nineteen (19) inches or more; (II) A printer capable of immediately producing a clear still photo from any video camera image; (III) Video cameras with a recording resolution of at least 1920 x 1080, or the equivalent, at a rate of at least fifteen (15) frames per second, that operate in such a way as to allow identification of people and activities in the monitored space, in all lighting levels, that are capable of being accessed remotely by the department or a law enforcement agency in real time upon request, and that provide coverage of? (a) All entrances and exits of the facility, including windows, and all entrances and exits from limited access areas; (b) The perimeter and exterior areas of the facility, including at least twenty (20) feet of space around the perimeter of an outdoor grow area; (c) Each point-of-sale location; (d) All vaults or safes; and (e) All medical marijuana, from at least two (2) angles, where it is cultivated, cured, trimmed, processed, rendered unusable, and disposed; (IV) A method for storing recordings from the video cameras for at sixty (60) days in a secure on-site or off-site location or through a service or network that provides on-demand access to the recordings and that allows for providing copies of the recordings to the department upon request and at the expense of the facility; (V) A failure notification system that provides an audible and visual notification of any failure in the electronic monitoring system; and (VI) Sufficient battery backup for video cameras and recording equipment to support at least sixty (60) minutes of recording in the event of a power outage; D. Controlled entry to limited access areas, which shall be controlled by electronic card access systems, biometric identification systems, or other equivalent means, except that, in addition to these means, all external access doors shall be equipped with a locking mechanism that may be used in case of power failure. Access information shall be recorded, and all records of entry shall be maintained for at least one (1) year; E. A method of immediate, automatic notification to alert local law enforcement agencies of an unauthorized breach of security at the facility; and F. Manual, silent alarms at each point-of-sale, reception area, vault, and electronic monitoring station with capability of alerting local law enforcement agencies immediately of an unauthorized breach of security at the facility. 2. Facilities shall establish policies and procedures:

RULES (CONTINUED) A. For restricting access to the areas of the facility that contain medical marijuana to only persons authorized to be in those areas, which shall include, when necessary for business purposes, contractors hired for no more than fourteen (14) days and other visitors, all of which may enter the restricted area if they sign in and sign out of a visitor log and are escorted at all times by facility agents in a ratio of no less than one (1) facility agent per five (5) visitors; B. For identifying persons authorized to be in the areas of the facility that contain medical marijuana; C. For identifying facility agents responsible for inventory control activities; D. For limiting the amount of money available in any retail areas of the facility and for notifying the public that there is a minimal amount of money available, including by posting of a sign;

supervisory or security personnel, to provide for the security of the facility. If the facility uses other security measures, the facility must immediately notify the department, and the department will determine whether the other security measures are adequate and for what amount of time those other security measures will be acceptable. B. Each facility shall maintain a log that documents each malfunction and repair of the security equipment of the facility. The log must state the date, time, and nature of each malfunction; the efforts taken to repair the malfunction and the date of each effort; the reason for any delay in repairing the malfunction; the date the malfunction is repaired and; if applicable, any alternative security measures that were taken. The log must also list, by date and time, all communications with the department concerning each malfunction and corrective action. The facility shall maintain the log for at least one (1) year after the date of last entry in the log;

E. For electronic monitoring; F. For the use of the automatic or electronic notification and manual, silent alarms to alert local law enforcement agencies of an unauthorized breach of security at the facility, including designation of on-call facility personnel to respond to, and to be available to law enforcement personnel who respond to, any alarms; and G. For keeping local law enforcement updated on whether the facility employs armed security personnel and how law enforcement can identify such personnel on sight. 3. Facilities with outdoor cultivation shall construct an exterior barrier around the perimeter of the marijuana cultivation area that consists of a fence that is: A. Constructed of six (6) gauge metal or stronger chain link; B. Topped with razor wire or similar security wire; C. At least eight (8) feet in height; and D. Screened such that the cultivation area is not easily viewed from outside the fence; 4. Facilities with windows in a limited access area must ensure either that the window cannot be opened and is designed to prevent intrusion or that the window is otherwise inaccessible from the outside. 5. Facilities shall ensure that each video camera used pursuant to this section: A. Includes a date and time generator which possesses the capability to accurately display the date and time of recorded events on the recording in a manner that does not significantly obstruct the recorded view; and B. Is installed in a manner that will prevent the video camera from being readily obstructed, tampered with, or disabled; 6. A facility shall make a reasonable effort to repair any malfunction of security equipment within seventy-two (72) hours after the malfunction is discovered. A facility shall notify the department within twenty-four (24) hours after a malfunction is discovered and provide a plan of correction. A. If a video camera used pursuant this section malfunctions, the facility shall immediately provide alternative video camera coverage or use other security measures until video camera coverage can be restored, such as assigning additional

7. Each facility shall employ a security manager who shall be responsible for: A. Conducting a semiannual audit of security measures to ensure compliance with this subsection and to identify potential security issues; B. Training employees on security measures, emergency response, and theft prevention and response within one (1) week of hiring and on an annual basis;

by any facility in possession of that medical marijuana or, at the election of the facility from which the failed test or recalled item originated, and with approval of the department, may be remediated, if possible. 1. Remediated medical marijuana must pass all testing required by 19 CSR 30-95.070; 2. Facilities may only elect to remediate any particular medical marijuana once. (K) All cultivation, infused products manufacturing, and dispensary facilities shall ensure that all medical marijuana is packaged and labeled in a manner consistent with the following 1. Facilities shall not manufacture, package, or label marijuana-A. In a false or misleading manner; B. In any manner designed to cause confusion between a marijuana product and any product not containing marijuana; or C. In any manner designed to appeal to a minor. 2. Marijuana and marijuana-infused products shall be sold in containers clearly and conspicuously labeled, in a font size at least as large as the largest other font size used on the package, with: A. ?Marijuana? or a ?Marijuana-infused Product;? and

C. Evaluating the credentials of any contractors who intend to provide services to the facility before the contractor is hired by or enters into a contract with the facility; and

B. ?Warning: Cognitive and physical impairment may result from the use of Marijuana.? 3. Any marijuana or marijuana-infused products packaged for retail sale before delivery to a

D. Evaluating the credentials of any third party who intends to provide security to the facility before the third party is hired by or enters into a contract with the facility;

dispensary must be packaged in opaque, re-sealable packaging designed or constructed to be significantly difficult for children under five (5) years of age to open but not normally difficult for adults to use properly. Any marijuana or marijuana-infused products not packaged for retail sale before delivery to a dispensary must be packaged by the dispensary upon sale to a qualifying patient or primary caregiver in opaque, re-sealable packaging designed or constructed to be

8. Each facility shall ensure that the security manager of the facility, any facility agents who provide security for the facility, and the employees of any third party who provides security to the facility have completed the following training: A. Training in theft prevention or a related subject; B. Training in emergency response or a related subject; C. Training in the appropriate use of force or a related subject that covers when the use of force is and is not necessary; D. Training in the protection of a crime scene or a related subject; E. Training in the control of access to protected areas of a facility or a related subject; F. Not less than eight (8) hours of training at the facility in providing security services; and G. Not less than eight (8) hours of classroom training in providing security services. (I) The department may issue public notice of a medical marijuana recall if, in its judgment, any particular medical marijuana presents a threat to the health and safety of qualifying patients. All facilities are responsible for complying with recall notices. Recalled items must be immediately pulled from production or inventory and held until such time as the department determines the item is safe, may be remediated, or must be destroyed. (J) Medical marijuana that fails testing or is subject to a recall must either be destroyed

significantly difficult for children under five (5) years of age to open but not normally difficult for adults to use properly. All edible marijuana-infused products must be packaged for retail by the infused-products manufacturer before transfer to a dispensary. 4. Marijuana and marijuana-infused products shall bear a label displaying the following information, in the following order: A. The total weight of the marijuana included in the package; (I) For dried, unprocessed marijuana, weight shall be listed in ounces or grams; (II) For concentrates, weight shall be listed in grams; (III) For infused products, weight shall be listed by milligrams of THC;

shall not include groupings of ingredients that obscure the actual ingredients, such as ?proprietary blend? or ?spices?; E. In the case of dried, unprocessed marijuana, the name, as recorded with the Missouri Secretary of State, of the cultivating facility from which the marijuana in the package originated and, in the case of infused products, the name of the infused-product manufacturer, as recorded with the Missouri Secretary of State; and F. A ?best if used by? date. 5. No branding, artwork, or other information or design elements included on marijuana or marijuana-infused products shall be placed in such a way as to obscure any of the information required by this section. 6. Marijuana and marijuana-infused product packaging shall not include claims of health benefits but may include health warnings. 7. Marijuana and marijuana-infused products must, at all times, be tagged with traceability information generated by the statewide track and trace system. (L) Cultivation, manufacturing, dispensary, and testing facilities that transport medical marijuana must also comply with 19 CSR 30-95.100(D) in doing so. (M) Signage and advertising on facility premises must comply with the following: 1. A facility may not display marijuana, marijuana paraphernalia, or advertisements for these items in a way that is visible to the general public from a public right-of-way. 2. Outdoor signage and, if visible to the public, interior signage, must comply with any local ordinances for signs or advertising and: A. May not display any text other than the facility?s business name or trade name, address, phone number, and website; and B. May not utilize images or visual representations of marijuana plants, products, or paraphernalia, including representations that indicate the presence of these items, such as smoke. (5) Facility Inspections. (A) Submission of an application for a facility license or certification constitutes consent to inspection by the department. A department inspector conducting an inspection pursuant to this section need not give prior notice of the inspection and, during the inspection, must be given access to all areas and property of the facility, including vehicles, wherever located, without delay. 1. The department will enter and inspect at least annually, with or without notice, to ensure compliance with this chapter. 2. The department may also, at any time it determines an inspection is needed, conduct an inspection, including an inspection of any part of the premises, qualifications of personnel, methods of operation, records, and policies and procedures of a licensed or certified facility.

C. The THC, tetrahydrocannabinol acid, cannabidiol, cannabidiol acid, and cannabinol concentration per dosage;

(B) Once a licensed or certified facility believes it will, within a month, be ready to begin operations and meet all state and local requirements for its facility, it shall request that the department conduct a commencement inspection to confirm the facility is in compliance with all requirements of this chapter.

D. All active and inactive ingredients, which

B. Dosage amounts, instructions for use, and estimated length of time the dosage will have an effect;

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RULES (CONTINUED) Inspections, and Suspension. 1. If the department determines, during an inspection or otherwise, that a facility is not in compliance with the department?s regulations, the department will issue an Initial Notice of Violation to the facility that explains how the facility has violated the department?s regulations and what remedial actions the department expects the facility to take to correct the violations. 2. Once a facility has been notified of violations, the facility shall correct the violations within fifteen (15) days, and the department will conduct a follow-up inspection within fifteen (15) to thirty (30) days to confirm the facility has corrected the violations. The facility shall notify the department if it believes it needs additional time to correct the violations, which the department may grant for good cause. 3. If the department?s follow-up inspection reveals the violations have not been corrected, the department will issue a Final Notice of Violation to the facility explaining how the facility continues to violate the department?s regulations, what remedial actions the department expects the facility to take, and notifying the facility that its license or certifications will be suspended if the specified remedial action is not taken and the violations corrected within thirty (30) days. 4. If the violations have not been corrected thirty (30) days after a Final Notice of Violation and no extension of this deadline has been granted by the department, the facility?s license or certification will be suspended, the facility will be required to cease operations, and the facility must sign a corrective action plan designed to bring the facility into compliance. (D) Upon receipt of complaint against a facility, the department will determine whether an inspection is warranted to investigate the allegations in the complaint, and, if so, the department will, at the time of inspection, provide the facility with a copy of the complaint and an opportunity to respond to the complaint. Employees of a facility who report potential violations by a facility to the department may not be subjected to retaliation of any kind, including termination, because of their report. (E) If, at any time, the department determines a facility presents an immediate and serious threat to the health and safety of the public or of the facility?s employees, the department may order the facility to immediately suspend all or a part of its operations until the threat has been eliminated.

19 CSR 30-95.050 Cu lt ivat ion Facilit y (1) Cultivation Facility Licenses. (A) The number of cultivation facility licenses will be limited to sixty (60) unless the department determines the limit must be increased in order to meet the demand for medical marijuana by qualifying patients. (B) A facility license will be issued for a single facility in a single location. Combinations of licenses at the same location must be approved pursuant to 19

CSR 30-95.040(4)(C). (2) Cultivation Facility Requirements. In addition to the requirements for cultivation facilities in 19 CSR 30-95.040, cultivation facilities shall also comply with the following. (A) Cultivation facilities may cultivate medical marijuana in indoor, outdoor, or greenhouse facilities. 1. Each indoor facility utilizing artificial lighting will be limited to no more than thirty thousand (30,000) square feet of flowering plant canopy space. 2. Each outdoor facility utilizing natural lighting will be limited to no more than two thousand eight hundred (2,800) flowering plants. 3. Each greenhouse facility using a combination of natural and artificial lighting will be limited to, at the election of the licensee, either no more than two thousand eight hundred (2,800) flowering plants or no more than thirty thousand (30,000) square feet of flowering plant canopy space. 4. If a cultivation facility is operating with multiple cultivation licenses in the same location, the size limitations of the cultivation facility will be multiplied by the number of licenses. (B) Facilities must keep records, by month and by batch, of all pesticides, herbicides, fertilizers, and other agricultural chemicals applied to marijuana plants and growing medium during production and processing at its facility for at least five (5) years. (C) Facilities, except those in rural, unincorporated agricultural areas, must develop, implement, and maintain an odor control plan, which shall address odor mitigation practices including, but not limited to, engineering controls, such as system design and operational processes, which shall be reviewed and certified by a professional engineer or a certified industrial hygienist as sufficient to effectively mitigate odors for all odor sources. (D) Cultivation facilities must ensure all facility employees are trained in at least the following. 1. The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of marijuana; 2. Proper use of the statewide track and trace system; 3. Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions; 4. Standards for maintaining the confidentiality of information related to the medical use of marijuana, including but not limited to compliance with the Health Insurance Portability and Accountability Act of 1996; 5. The methods of cultivation used by the facility; and 6. The facility?s safety and sanitation procedures. (E) Cultivation facilities shall not transfer medical marijuana from the facility, except to a

testing facility, until the medical marijuana has been tested by a testing facility, according to the provisions of 19 CSR 30-95.070, and the cultivation facility has received verification from the testing facility that the medical marijuana passed all required testing. (F) Cultivation facilities may only transport medical marijuana: 1. That the facility cultivated; 2. To a dispensary, testing, or manufacturing facility; 3. If the facility complies with the requirements of 19 CSR 30-95.100(2). (G) Cultivation facilities shall store all medical marijuana? 1. At the approved location of the facility; or 2. In offsite warehouses that comply with the security requirements of 19 CSR 3095.040(4)(H), the location requirements of 19 CSR 30-95.040(4)(B), and that have been approved pursuant to 19 CSR 30-95.040(3)(C).

19 CSR 30-95.060 In f u sed Pr odu ct s M an u f act u r in g Facilit y (1) Infused Products Manufacturing Facility Licenses. (A) The number of manufacturing facility licenses will be limited to eighty-six (86) unless the department determines the limit must be increased in order to meet the demand for medical marijuana by qualifying patients. (B) A facility license will be issued for a single facility in a single location. Combinations of licenses at the same location must be approved pursuant to 19 CSR 30-95.040(4)(C). (2) Manufacturing Facility Requirements. In addition to the requirements for manufacturing facilities in 19 CSR 30-95.040, manufacturing facilities shall also comply with the following. (A) Facilities must ensure all facility employees are trained in at least the following. 1. The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of marijuana; 2. Proper use of the statewide track and trace system; 3. Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions; 4. The differences between the types of infused products manufactured at that facility and their methods of production; and 5. The facility?s safety and sanitation procedures. (B) Facilities must develop, implement, and maintain an odor control plan, which shall address odor mitigation practices including, but not limited to, engineering controls, such as system design and operational processes, which shall be reviewed and certified by a professional engineer or a certified industrial hygienist as sufficient to effectively mitigate odors for all odor sources.

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(C) Manufacturing facilities shall not transfer medical marijuana from the facility, except to a testing facility, until the medical marijuana has been tested by a testing facility, according to the provisions of 19 CSR 30-95.070, and the manufacturing facility has received verification from the testing facility that the medical marijuana passed all required testing. (D) Manufacturing facilities may only transport medical marijuana: 1. That the facility manufactured; 2. To a dispensary, testing, or other manufacturing facility; 3. If the facility complies with the requirements of 19 CSR 30-95.100(2). (E) Manufacturing facilities that produce ingestible medical marijuana-infused products shall comply with the applicable food safety standards set forth in 19 CSR 20-1.025, 1.040, and 1.050, as applicable. Such facilities are prohibited from producing frozen desserts, as defined by 19 CSR 20-1.030, or acidified foods, as defined by 19 CSR 20-1.042. (F) Manufacturing facilities shall store all medical marijuana? 1. At the approved location of the facility; or 2. In offsite warehouses that comply with the security requirements of 19 CSR 3095.040(4)(H), the location requirements of 19 CSR 30-95.040(4)(B), and that have been approved pursuant to 19 CSR 30-95.040(3)(C). (G) Manufacturing facilities that use volatile solvents shall install air-handling systems and other controls designed to minimize the risks of explosions and fires. These controls should include systems to prevent ignition; plans for safe storage, use, and disposal of solvents; and policies for continuous staff monitoring of all processes involving volatile solvents.

RULES (CONTINUED) 19 CSR 30-95.070 Test in g Facilit y

inversion of medical marijuana including:

(1) Access to Testing Facility Certifications. The number of testing facility certifications will be limited to ten (10) unless the department determines the limit must be increased in order to meet the demand for medical marijuana by qualifying patients.

1. Devices or a series of devices to detect unauthorized intrusion, which may include a signal system interconnected with a radio frequency method, such as cellular or private radio signals, or other mechanical or electronic devices;

(2) Testing Facility Requirements. In addition to the requirements of 19 CSR 30-95.040, testing facilities shall also comply with the following:

2. Electronic monitoring, including? A. At least one (1) call-up monitor that is nineteen (19) inches or more; B. A printer capable of immediately producing a clear still photo from any video camera

(A) Testing facilities must ensure all facility employees are trained in at least the following: 1. The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of marijuana; 2. Proper use of the statewide track and trace system; and 3. Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions; (B) Testing facilities shall comply with International Organization for Standardization (ISO) 17025 standards for personnel at all times. (C) During any periods of time when a facility no longer complies with ISO 17025 standards for personnel, the facility shall not conduct testing of medical marijuana. Upon return to compliance, the facility shall not resume testing until the department conducts an inspection of the facility. (D) Testing facilities shall become fully accredited to the standard set forth by ISO 17025 by an International Laboratory Accreditation Cooperation recognized accreditation body. Testing facilities shall achieve such accreditation within one (1) year of the date the facility receives department approval to operate and shall maintain its accreditation as long the facility holds a certification. 1. The scope of the accreditation shall include all medical marijuana testing performed at the facility. 2. Loss of accreditation shall be reported to the department by the testing facility within twenty-four (24) hours of the testing facility receiving notice of the loss. 3. Inspection and audit reports from the accrediting body shall be submitted to the department by the testing facility within ten (10) days of receipt. (E) Testing facilities shall participate in a proficiency testing program provided by an organization that operates in conformance with the requirements of ISO/IEC 17043 at least twice in a calendar year. 1. The facility shall notify the department of the proficiency testing provider the facility chooses, and the department will work with the proficiency testing provider to determine the schedule the provider will follow when sending proficiency testing samples to facilities for analysis. 2. The facility shall analyze proficiency test samples using the same procedures and equipment as used for testing medical marijuana. 3. Upon receipt of proficiency test results, the facility shall submit copies of those results to the department. (F) Testing facilities shall install and maintain security equipment designed to prevent unauthorized entrance into limited access areas, which shall include any area where medical marijuana is tested, stored, or disposed, and to prevent diversion and

aflatoxins and ochratoxin A, of greater than 20 micrograms per kilogram; B. Pathogenic E. coli or salmonella concentrations detectable in 1 gram; and C. Pathogenic Aspergillus species A. fumigatus, A. flavus, A. niger, or A. terreus detectable in 1 gram.

3. In the case of all other infused products, the amount of material required for sampling is:

2. Chemical residue screening. A test will fail if it shows:

image; C. Video cameras with a recording resolution of at least 1920 x 1080, or the equivalent, at a rate of at least fifteen (15) frames per second, that operate in such a way as to allow identification of people and activities in the monitored space, and that provide coverage of? (I) All entrances and exits from limited access areas, including windows; and (II) All areas in which medical marijuana is tested, stored, or disposed, from at least two (2) angles; D. A method for storing recordings from the video cameras for at least sixty (60) days in a secure on-site or off-site location or through a service or network that provides on-demand access to the recordings and that allows for providing copies of the recordings to the department upon request and at the expense of the facility; E. A failure notification system that provides an audible and visual notification of any failure in the electronic monitoring system; and F. Sufficient battery backup for video cameras and recording equipment to support at least sixty (60) minutes of recording in the event of a power outage; 3. Controlled entry to limited access areas, which shall be controlled by electronic card access systems, biometric identification systems, or other equivalent means. Access information shall be recorded, and all records of entry to limited access areas shall be maintained for at least one (1) year. (G) Testing facilities shall maintain all sampling and testing records for five (5) years. (H) Testing facilities may only transport medical marijuana: 1. That the facility intends to test; 2. From cultivation, dispensary, manufacturing, and other testing facilities; 3. If the facility complies with the requirements of 19 CSR 30-95.100(2). (3) Sampling requirements. (A) Sampling and testing of medical marijuana shall be done at the lot level. (B) Sampling and testing of each harvest lot or process lot shall be conducted with

(4) Testing requirements. (A) Testing facilities shall test all lots of medical marijuana produced by cultivation or infused products manufacturing facilities. Testing shall only be performed on the final medical marijuana product equivalent to what will be dispensed to the patient. (B) Mandatory testing requirements may only be met through testing of samples collected by the testing facility according to section (3) of this rule. (C) Upon request from a licensed cultivation, manufacturing, or dispensary facility, testing facilities may also test material received directly from the facility, including? 1. Medical marijuana plants at any stage of growth; 2. Infused products at any stage of production; and 3. Components used for the production of final medical marijuana product, such as water or growing materials. (D) Within five (5) business days of collecting a sample, the testing facility shall file a report in the statewide track and trace system detailing all test results and stating whether the lot passed or failed each required test. Filing of this report must coincide with or precede any notice of test results to the originating facility. (E) Testing of the cannabinoid profile of the final medical marijuana product shall include those analytes listed below, and the acceptable limits for each analyte will be a percentage deviation from the mean in concentration throughout the lot of fifteen (15) percent or less.

representative samples such that there is assurance that all lots are adequately assessed for contaminants and that the cannabinoid profile is consistent throughout.

1. Delta-9 tetrahydrocannabinol (THC), CAS number 1972-08-3; 2. Tetrahydrocannabinol acid (THCA), CAS number 23978-85-0; 3. Cannabidiol (CBD), CAS number 13956-29-1; 4. Cannabidiolic acid (CBDA), CAS number 1244-58-2; and

1. In the case of dry, unprocessed marijuana, the maximum amount of marijuana from which a sample may be selected is fifteen (15) pounds, and a minimum of zero point five (0.5) percent of a harvest lot will be sampled for testing.

5. Cannabinol (CBN), CAS number 521-35-7. (F) Testing for contaminants in the final medical marijuana product shall include, but shall not

2. In the case of concentrates and extracts, the amount of material required for sampling is:

be limited to: 1. Microbial screening. A test will fail if it shows:

* Permethrins cumulative residue of cisand trans-permethrin isomers + Pyrethrins cumulative residues of pyrethrin 1, cinerin 1 and jasmolin 1 3. Heavy metal screening. A test will fail if it shows:

4. Residual solvents. A test will fail if it shows:

A. A mycotoxin concentration, including

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RULES (CONTINUED) ninety-two (192) unless the department determines the limit must be increased in order to meet the demand for medical marijuana by qualifying patients. (B) Dispensary facility licenses will be limited to twenty-four (24) in each of the eight (8) United States congressional districts in the state of Missouri as drawn and in effect on December 6, 2018. A map of the state of Missouri showing the applicable boundary lines of Missouri?scongressional districts will be available on the department?s website at http://medicalmarijuana.mo.gov. (C) A facility license will be issued for a single facility in a single location. Combinations of licenses at the same location must be approved pursuant to 19 CSR 30-95.040(4)(C). (2) Dispensary Facility Requirements. In addition to the requirements of 19 CSR 30-95.040, dispensary facilities shall also comply with the following: 5. Water activity and moisture content screening. A test will fail if it shows, for dry, unprocessed marijuana, water activity that exceeds 0.65 Aw and moisture content that is not between 5.0% and 13.0%. 6. Foreign matter screening. A test will fail if it shows: A. More than 5.0% of stems 3 mm or more in diameter; B. More than 2.0% of other foreign matter (mites, hair, dirt, etc.). (5) Medical marijuana that fails mandatory testing shall not be retested and will be immediately placed on hold by the testing facility through the statewide track and trace system pending disposal or remediation. (6) Testing facilities may acquire from cultivation, manufacturing, and dispensary facilities raw material, such as plant material, concentrates, extracts, and infused products, for testing method development. (7) Testing facilities shall retain any portion of a sample that was not used in the testing process for, at a minimum, forty-five (45) business days after testing is complete. (A) Excess sample material shall be securely stored in a manner that prohibits sample degradation, contamination, and tampering and available to the department upon request. (B) When no longer subject to retention, sample material shall be disposed pursuant to 19 CSR 30-90.070(4)(E).

19 CSR 30-95.080 Dispen sar y Facilit y (1) Access to Dispensary Facility Licenses. (A) The number of dispensary facility licenses will be limited to one hundred

(A) Dispensary facilities must ensure all facility employees are trained in at least the following: 1. The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of marijuana; 2. Proper use of the statewide track and trace system; 3. Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions; 4. Standards for maintaining the confidentiality of information related to the medical use of

3. Information about the purported effectiveness of various methods, forms, and routes of administering medical marijuana; 4. Information about potential risks and possible side effects of medical marijuana use, including risk of poisoning and the phone number for the closest poison control center; and 5. The prohibition on consuming marijuana for medical use in a public place, including the definition of what constitutes a public place pursuant to this rule. (C) Dispensary facilities must, for every transaction? 1. Receive the transaction order at the dispensary directly from the qualifying patient or primary caregiver in person, by phone, or via the internet, and not from a third party; 2. At the time of sale, verify through the statewide track and trace system that the qualifying patient or primary caregiver is currently authorized to purchase the amount of medical marijuana requested and, in the case of a seed purchase, that the patient or primary caregiver is currently authorized to cultivate medical marijuana; 3. In the case of a delivery order, receive payment before the medical marijuana leaves the dispensary, subject to refund if the delivery cannot be completed; and 4. At the time of sale or delivery, require production of a qualifying patient or primary caregiver identification card, a government-issued photo ID, and in the case of medical marijuana seed purchases, a patient cultivation identification card.

marijuana, including but not limited to compliance with the Health Insurance Portability and Accountability Act;

(D) Dispensary facilities must report any incident of theft or attempted theft of medical marijuana to the department within twenty-four (24) hours of the incident.

5. Procedures for verifying the identity and purchase limitations of qualifying patients and primary caregivers;

(E) Dispensary facilities must design their facility and staffing in such a way as to accomplish the following:

6. The differences in the purported effects and effectiveness of the strains of medical marijuana available for purchase at that dispensary and the methods of their use; and

1. The general public, qualifying patients, and primary caregivers may only enter the facility through one access point into an area where facility agents shall screen individuals for qualifying patient or primary caregiver status. No medical marijuana may be accessible in this area;

7. Recognizing signs of medical marijuana abuse in patients. (B) Dispensary facilities must make available to all customers patient education materials that include at least the following: 1. Local resources for concerns about addiction, as well as the phone number for the

2. Only qualifying patients, primary caregivers, and, if requested by a qualifying patient, up to two (2) additional persons to support the qualifying patient, may enter any areas beyond thefacility?s access point area; and

Substance Abuse and Mental Health Services Administration?s National Helpline; 2. Information about the different strains of medical marijuana available at that dispensary and

3. In any limited access area where medical marijuana is accessible, the facility shall only allow access at any given time for a number of qualifying patients and/or primary caregivers equal to the number of staff available to serve those individuals at that time.

the purported effects of the different strains;

(F) Dispensary facilities shall not sell medical marijuana until the medical

32 M OGREENWAY.COM

marijuana has been tested by a testing facility, according to the provisions of 19 CSR 30-95.070, and been verified as passing all required testing. (G) Dispensary facilities may only transport medical marijuana: 1. To qualifying patients, primary caregivers, testing, manufacturing, and other dispensary facilities; 2. If the facility complies with the requirements of 19 CSR 30-95.100(2). (H) Dispensary facilities that sell ingestible medical marijuana-infused products shall comply with the applicable food safety standards set forth in 19 CSR 20-1.025. (I) Dispensary facilities shall store all medical marijuana? 1. At the approved location of the facility; or 2. In offsite warehouses that comply with the security requirements of 19 CSR 3095.040(4)(H), the location requirements of 19 CSR 30-95.040(4)(B), and that have been approved pursuant to 19 CSR 30-95.040(3)(C). (J) Dispensary facilities shall only sell medical marijuana seeds acquired from cultivation facilities. (K) Dispensary facilities shall not sell medical marijuana to a qualifying patient or primary caregiver in amounts greater than what that individual is currently authorized to purchase per the statewide track and trace system. (L) Dispensary facilities shall not sell medical marijuana seeds to a qualifying patient or primary caregiver who is not currently authorized to cultivate medical marijuana. (M) Dispensary facilities may accept returns and issue refunds or credits as needed except that medical marijuana that has been removed from the packaging in which it arrived at the dispensary, whether removed before sale by the dispensary or after sale by a patient or caregiver, may not be accepted as a return. (N) Dispensary facilities shall not disburse medical marijuana as part of a promotional event. If a facility disburses medical marijuana free of charge for any other reason, the facility shall record that disbursement of product in its seed-to-sale system with all relevant entries, including the qualifying patient or primary caregiver information and the amount of medical marijuana disbursed to that qualifying patient or primary caregiver. (O) Dispensary facilities shall not allow consumption of medical marijuana on their licensed premises. (P) Dispensary facilities shall not allow physicians to meet with individuals on the dispensary?spremises for the purpose of certifying them as qualifying patients.

RULES (CONTINUED) 19 CSR 30-95.090 Seed t o Sale Tr ack in g

adjustments at the facility.

(1) Access to Seed-to-Sale Tracking System Certifications. (A) The department will not limit the number of certifications available for seed-to-sale

(4) Seed-to-Sale Tracking System Prohibitions. (A) Before beginning operations, all certified seed-to-sale tracking system entities shall sign

tracking system entities. (B) The department will begin accepting applications for review on August 3, 2019. All

the department?s Medical Marijuana Application Programming Interface User Agreement. (B) No seed-to-sale tracking system entity may sell seed-to-sale tracking services or services

complete applications received by the department that are submitted on or after that date will be approved or denied within one hundred fifty (150) days of that application?s submission. An application will be considered complete if it includes all information required for applications by this rule. The department will notify an applicant if an application is incomplete and will specify in that notification what information is missing. Applicants will be given seven (7) days to provide missing information. Failure to provide missing information may result in denial of the application. (C) The department shall charge an application fee for a seed-to-sale certification and also an annual fee once a certification is granted. The first annual fee will be due thirty (30) days after a certification is issued and shall be due annually on that same date as long as the certification remains valid. The department shall publish the current fees, including any adjustments, on its website at http://medicalmarijuana.mo.gov. The amount of fees due will be the amount that is effective as of the due date for the fee. (2) Application requirements. All applications for seed-to-sale tracking system certifications shall include at least the following information: (A) Name and address of the applicant; (B) Legal name of the entity, including any fictitious business names, and a certificate of good standing from the Missouri Secretary of State; (C) An attestation by an owner or principle of the entity that the seed-to-sale tracking system can and will comply with this rule; and (D) All applicable fees or proof that all applicable fees have already been paid. (3) Seed-to-Sale Tracking System Requirements. All seed-to-sale tracking systems used by cultivation, manufacturing, dispensary, testing, and transportation facilities shall be capable of: (A) Interfacing with the statewide track and trace system such that a licensed or certificated facility may enter and access information in the statewide track and trace system as required for inventory control and tracking by 19 CSR 30-95.040(4)(G) and for purchase limitations by 19 CSR 30-95.080(2)(D); (B) Providing the department with access to all information stored in the system?s database; (C) Maintaining the confidentiality of all patient data and records accessed or stored by the system such that all persons or entities other than the department may only access the information in the system that they are authorized by law to access; and (D) Producing analytical reports to the department regarding: 1. Total quantity of daily, monthly, and yearly sales at the facility per product type; 2. Average prices of daily, monthly, and yearly sales at the facility per product type; and 3. Total inventory or sales record

one thousand (1,000) feet of any then-existing elementary or secondary school, daycare, or church.

related to compliance with seed-to-sale tracking regulations to a licensed or certified facility if it is owned by or affiliated with an entity that currently holds a contract with the state of Missouri for any product or service related to the department?s medical marijuana program. (5) Failure to comply with this rule and failure to abide by the department?s Medical Marijuana Application Programming Interface User Agreement may result in revocation of certification.

19 CSR 30-95.100 Tr an spor t at ion Facilit y (1) Access to Transportation Facility Certifications. (A) The department will certify all transportation facilities that can demonstrate they meet minimum standards as described in 10 CSR 30-95.025(4)(A). (B) A facility license will be issued for a single facility with a single, primary place of business. Combinations of licenses at the same location must be approved pursuant to 19 CSR 30- 95.040(4)(C). (2) Transportation Facility Requirements. In addition to the requirements for transportation facilities in 19 CSR 30-95.040, transportation facilities shall also comply with the provisions of this section. (A) Transportation facilities must ensure all facility employees are trained in at least the following: 1. The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of medical marijuana; 2. Proper use of the statewide track and trace system; 3. Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions; and 4. Standards for maintaining the confidentiality of information related to the medical use of marijuana, including but not limited to compliance with the Health Insurance Portability and Accountability Act of 1996. (B) Transportation facilities shall transport all medical marijuana from an originating facility to a destination facility within twenty-four (24) hours. When extenuating circumstances necessitate holding medical marijuana longer than twenty-four (24) hours, the transportation facility shall notify the department of the circumstances and the location of the medical marijuana. (C) Unless allowed by the local government, a transportation facility?s primary place of business shall not be sited, at the time of application for certification or for local zoning approval, whichever is earlier, within

1. In the case of a freestanding facility, the distance between the facility and the school, daycare, or church shall be measured from the property line of the facility to the closest point of the property line of the school, daycare, or church. 2. In the case of a facility that is part of a larger structure, such as an office building or strip mall, the distance between the facility and the school, daycare, or church shall be measured fromthe property line of the school, daycare, or church to the facility?s entrance or exit closest in proximity to the school, daycare, or church. 3. Measurements shall be made along the shortest path between the demarcation points that can be traveled by foot. (D) A transportation facility?s primary place of business shall meet the security requirements of19 CSR 30-95.040(4)(H). In addition to those requirements, transportation facilities shall also comply with the following: 1. All vehicles used to transport medical marijuana shall not be marked in any way that indicates medical marijuana is being transported by that vehicle and shall be equipped with at least: A. A secure lockbox or locking cargo area made of smooth, hard surfaces that are easily cleaned for storing medical marijuana during transit; B. A secure lockbox for storing payments and video monitoring recording equipment during transit; C. Video monitoring of the driver and passenger compartment in the vehicle and of any space where medical marijuana is stored during transit; and D. GPS tracking; 2. Facility agents transporting medical marijuana shall: A. Prior to transporting medical marijuana, print an inventory manifest for the trip generated from the statewide track and trace system and create a trip plan, which shall be provided to the facility from which the medical marijuana is transported, and which shall include: (I) The name of the facility agent(s) transporting the medical marijuana; (II) The date and start time of transportation; (III) The anticipated delivery time; and (IV) The anticipated route of transportation. B. During transport: (I) Have facility agent identification card(s) accessible at all times; (II) Keep a copy of the applicable inventory manifest and trip plan in the transportation vehicle, which shall be placed under the driver ?s seat or in a compartment beside the driver ?s seat for the duration of the trip; (III) Have a means of communication accessible at all times; (IV) Immediately report to law enforcement any vehicle accidents in which the transportation vehicle is involved; and (V) Immediately report any loss or theft of medical marijuana to a person designated by the transportation facility for this purpose. C. After transport, revise the trip plan to reflect the actual route taken and the end time of transportation and deliver the revised trip plan to a person designated by the transportation facility for this purpose.

M OGREENWAY.COM

3. Any incident of theft or attempted theft of medical marijuana shall be reported to the department within twenty-four (24) hours of the incident. 4. All trip plans and revised trip plans shall be maintained by the transportation facility for at least five (5) years.

19 CSR 30-95.110 Ph ysician s (1) Physician Certification. Physicians will submit certifications electronically through a department-provided, web-based system. In the event of system unavailability, the department will arrange to accept physician certifications in an alternative, department-provided format and will notify the public of those arrangements through its website at http://medicalmarijuana.mo.gov. (A) Physician certifications must be issued no earlier than thirty (30) days before the date the patient will apply for a patient identification card or renewal of a patient identification card. (B) Physician certifications must include at least the following information: 1. The physician?s name, as it appears in the records of the Missouri Division of Professional Registration; 2. The physician?s licensee number; 3. Whether the physician is licensed to practice medicine or osteopathy; 4. The physician?s business address, telephone number, and email address; 5. The qualifying patient?s name, date of birth, and Social Security number; 6. The qualifying patient?s qualifying condition; 7. The physician?s recommendation for the amount of medical marijuana the qualifying patient should be allowed to purchase in a thirty- (30-) day period if the recommended amount is more than four (4) ounces of dried, unprocessed marijuana or its equivalent; 8. Statements confirming the following: A. In the case of a non-emancipated qualifying patient under the age of eighteen (18), before certifying the qualifying patient for use of medical marijuana, the physician received the written consent of a parent or legal guardian who asserts he or she will serve as a primary caregiver for the qualifying patient; B. The physician met with and examined the qualifying patient, reviewed the qualifying patient?s medical records or medical history, reviewed the qualifying patient?s current medications and allergies to medications, discussed the qualifying patient?s current symptoms, and created a medical record for the qualifying patient regarding the meeting; C. In the opinion of the physician, the qualifying patient suffers from the qualifying condition; and D. The physician discussed with the qualifying patient risks associated with medical marijuana, including known contraindications applicable to the patient, risks of medical marijuana use to fetuses, and risks of medical marijuana use to breastfeeding infants; and 9. The signature of the physician and date on which the physician signed.

PHOTO/CHRIS SMITH

Fr aker leads depar t ment t hr ough r ulemak ing Being the director of a medical marijuana

family for over 50 years. He has grandkids - two -

government division tasked with creating the

just down the street.

program from scratch on a tight deadline may not

By Rachael Dunn Gr eenway

the reception. ?Every generation sees that kind of shift,? Fraker

Marshfield itself is idyllic - it hosts the oldest Fourth

said, citing the changes in this country?s culture

of July parade west of the Mississippi. President

before and after the death of President John F.

George H.W. Bush joined the parade in 1991. A

Kennedy, Civil Rights, Vietnam, and also the 1990s

Not long ago, Dr. Randall Williams, director of the

picture of Bush?s visit hangs in Fraker ?s office.

with the insurgence of the internet age. ?We went

Department of Health and Senior Services, asked

?That?s how big of a deal our little parade is,? he

from this phone,? Fraker knocked on his office

Lyndall Fraker, a recently termed-out Missouri State

says, pointing to the picture of the President in a

phone. ?- and a set of encyclopedias. What we have

Representative from Southwest Missouri, to

small World War II plane.

here -? Fraker picks up his iPhone. ?- instantly with

be a dream job, but it?s one a former state representative has risen to task.

consider taking the gig.

So far, this all-Missouri man has done quite the job

?I talked to my wife and family, thought about it,

leading a team to implement an all-Missouri

prayed about it, checked with my mentors and

medical marijuana program.

decided it was the thing for me to do,? Fraker told Greenway. ?I was humbled and honored.? Fraker is idyllically All-American. He and his family live in the town he grew up in: Marshfield, Missouri - a half hour drive from Springfield and a two hour drive from Jefferson City, where his new position is located. He still attends and is active in the same church he and his wife were married in. The same church he was baptized in. The farm where he and his wife live has been in the

Missourians came to the polls in droves, voting for Amendment 2 more than any official or other ballot measure. ?It?s been eye-opening to the fact that it has been really well received,? Fraker said. ?Missouri, surprisingly, whether the folks I talk to are civic

social media and how people express their opinions. Prior to that, they may write a letter to the editor.? Maybe they re-write that letter to the editor. Maybe that letter gets mailed. From the thought to print, there may be weeks. That cultural shift, now being the rise of cannabis in Missouri, Fraker cites as something Missourians recognize.

clubs or law enforcement, are interested,

?Everyone is anticipating the program and how it?s

concerned, on how it?s going to play out in our

laid out,? Fraker told Greenway in May. ?People

state.?

have been sympathetic.?

Fraker cited a ?cultural shift? as the root cause of

There?s a lot to be sympathetic towards. While

34 M OGREENWAY.COM

driving more than he ever did during a political

companies or small companies,? Fraker said. ?If you

campaign visiting all corners of the state, Fraker has

do the math, we?re going to issue about 340

overseen a team drafting hundreds of rules,

licenses - let?s say an average of 50 employees per

hosting over a dozen public hearings, and meeting

license. That?s a lot of employees, a lot of

non-stop tight deadlines for program

individuals that this industry will support in the

implementation.

state of Missouri. That?s a very big positive.

?All the agencies have been very helpful,? he said,

?There?s a lot of interest - this is an industry of the

noting support from the Highway Patrol and law

future,? Fraker said.

enforcement. ?We?re all in this together. It?s our constitution. We have to make it work.?

Fraker has been at the forefront of dozens of department announcements regarding the

?We have more people who have pre-applied than

implementation of the program, whether it was the

we have licenses,? he said. ?We want to make sure

announcement of blind scorers, the organization of

we get it right - no hanky panky.?

application question advisory committees, or an

Fraker ?s tenure has not been completely smooth.

increase in testing facilities.

The St. Louis Post-Dispatch has maintained

?We want this whole industry to be treated fairly,?

regularly critical coverage of the program,

Fraker said. ?We?re trying to bring in some general

accompanied with a lawsuit to acquire a list of

public folks to help - we feel like it?s the most fair

those who have pre-applied for licenses. However,

way. The amendment was very clear that they

Fraker maintains the division will maintain privacy

wanted everyone to be able to be part of this

with that list.

business.?

?The amendment was fairly clear that personal

The division has received incredible public input,

information was not to be divulged and presented,?

whether in public comment or as part of the

Fraker said. ?We?re just following the Constitution.?

advisory committees, to build the rules and

Fraker has taken the oath of office four times in the

regulations that were released on May 26.

legislature, where he vowed to maintain and

?We have a job to do,? he said. ?We have to make

uphold the Missouri and U.S. Constitutions. Valuing

sure the health and welfare of the citizens is

the weight of the Constitution is not the only

protected. We have to do it within the confines of

benefit Fraker has acquired from his former four

the Constitution, which is very unusual - most

terms in the legislature.

states it is statutorial. The attitude in general is

?It has been tremendously helpful to understand how things work,? Fraker said. ?Statutes and laws are things that affect us in everyday life.? Procedures and networking have also been valuable assets to Fraker. ?A lot of people I've talked with in my 8 years here are going to be involved in the industry.? Fraker ?s time in the legislature showed him as a valuable ally to business - he also took a vote in support of medical marijuana, even though the legislature ultimately never pushed a statutorial medical marijuana program through to the finish line. Fraker ?s legislative experience is not the only experience that has been valued. His former day job was in business development and corporate management.

important. It?s here, it?s part of the Constitution, regardless of how you feel about the product. Keep the illegal side illegal and the legal side legal.? Beyond Missouri, Fraker has been lent support from other states - even visiting Arizona, which has a similar population and economic make up to Missouri. ?Our biggest help has been the knowledge from other states,? Fraker said. ?That?s who we had to turn to, what states have done it well and which states have done it less well. We are trying to utilize the best practices from those who have done it well.? Fraker ?s crusade to be accessible and present continues this summer, as he will be present at the upcoming conferences put on by MoCannTrade and MCIA. His job is nowhere near over - on June 28, patients can submit their applications for care

?In my experience, even my past experience in

cards, those applications must be processed by the

management for Wal-Mart, has been helpful. We?re

department. From August 3-17 the department will

building an organization here. We?re going to have

accept facility applications, then oversee a

about 50 employees. My time is spent working on

contractor who will blind score the applications,

that piece more so than the technical content.

and return licenses to over 300 facilities before

Extremely helpful.?

beginning inspections of facilities.

Private and public experience have led Fraker to

?We know what we?re doing and we?re listening to

value the impact of small business - something the

the people of Missouri.?

vast majority of medical marijuana facilities will ultimately be. ?It helps the local economies by providing jobs, whether the businesses are owned by big

35 M OGREENWAY.COM

About theMan Chris Sm it h w akes up at 4 in t he m orn in g, he w orks an d p rovides f or his f am ily, t hen drives across t he st at e cap t urin g t he f aces, p laces, an d m om en t s t hat have def in ed t he can n ab is m ovem en t an d w ill shap e t he in dust ry f or years t o com e. What st art ed out as a hob b y has b ecom e a self - m ot ivat ed ob ligat ion t o cap t ure as m an y p ieces of hist ory t hrough a len s as t im e, an d light , w ill allow .

Cannabis through the lens of Chris Smith By Brandon Dunn

An agon ist is a sub st an ce or agen t t hat in it iat es a resp on se w hen in t roduced t o a recep t or. There m ay b e n o b et t er def in it ion f or Chris Sm it h an d Agon ist Can n ab is Com p an y, he seem s t o b e t he acciden t al b in din g f orce of t he can n ab is in dust ry in Missouri. Sm it h aim s t o sp read his p assion f or can n ab is b eyon d in dust ry p hot ograp hy, he is hop ef ul t hat Agon ist Can n ab is Com p an y w ill b e, ?a source f or f act - b ased, scien ce- b acked educat ion regardin g all t hin gs can n ab is.? Sm it h says ACC is m ore t han a disp en sary an d b ran d, ?We are p at ien t advocat es an d act ivist s an d w e p lan on con t in uin g t hat w ell in t o t he f ut ure.? SM ITH | CONTINUED ON 38

36 M OGREENWAY.COM

PHOTOS/ CHRI S SM I TH www.n at u resagon i st .com

" Cannabis will change the world as we know it, and f or the better. ?

37 M OGREENWAY.COM

SM ITH | CONTINUED FROM 36

So how does a b oy raised in a st rict Morm on hom e w it h 1 b rot her an d 2 sist ers in 1980 s Ut ah am id t he ?Just say n o? gen erat ion b ecom e t he m an b ehin d t he cam era at t he t ip of Missouri?s legal can n ab is m arket ? ?Our f am ily t raveled a lot ? Travelin g m y en t ire lif e t hrough m oun t ain s, desert s, rain f orest s, f arm lan ds, t rop ics, et c., I f ell in love w it h m ot her n at ure. I w an t ed t o rem em b er all t hose view s an d cap t ure all t he det ails of her aw esom en ess. I st art ed t akin g p ict ures t o t ry an d hold on t o t hose m em ories. I w ish sm ells could b e cap t ured t oo, b ut at least I had p ict ures.? Sm it h describ es his journ ey as a t een w it h his f irst job , b ecom in g an en t rep ren eur in his t w en t ies, an d grow in g in t o a f am ily m an w it h 2 b oys an d a w if e t hat he says m akes it all p ossib le. ?I m et t he love of m y lif e, Christ in a From m er, in 20 0 3,? he says. Sm it h describ es Christ in a as a social just ice w arrior, w orkin g f or a n on - p rof it t hat help s t he less f ort un at e w it h legal issues. ?We have 2 am azin g b oys t oget her, Hun t er 14, an d Can yon 9. Hun t er is our com p ut er/ codin g gen ius w ho loves t o creat e t hin gs. SM ITH | CONTINUED ON 41

38 M OGREENWAY.COM

M CI A CannaCon

39 M OGREENWAY.COM

M oCannBizConn & M oCannTrade M eet Ups

40 M OGREENWAY.COM

SM ITH | CONTINUED FROM 38

He t akes af t er b ot h of us in his n eed f or kn ow ledge ab out everyt hin g t hat in t erest s him . Can yon is our art ist , at hlet e, an d socialit e w ho m akes f rien ds w it h everyon e an yw here he goes. He loves b ein g act ive t hrough sp ort s an d he?s sup er creat ive w it h everyt hin g he does.? ?Christ in a holds dow n t he f ort w hile I ?m aw ay an d she sacrif ices so m uch t o help m ake t his a realit y. I couldn ?t do an y of t his w it hout her! ? Sm it h says t he m ost excit in g t hin g ab out t he b egin n in g of legalized m edicin al can n ab is is t he en d. ?The suf f erin g is f in ally goin g t o com e t o an en d regardin g can n ab is, on t he healt h side, on t he social just ice side, an d on t he ecological side. The w orld w ill b en ef it m ore an d m ore as t he in dust ry p rogresses an d p eop le b ecom e m ore educat ed. Our air w ill b e clean er. Our healt h w ill b ecom e m ore st ab le. Our t ext iles an d in dust ries w ill b e m ore ecologically sust ain ab le an d eart h- f rien dly. Can n ab is w ill chan ge t he w orld as w e kn ow it , an d f or t he b et t er.?

41 M OGREENWAY.COM

PHOTO/CHRIS SMITH

I gnite M issouri setting the bar f or supporting businesses By K aycee Barry Ignite Missouri, hosted by Green Rush Consulting, was held May 19th in the Duck Room, at Blueberry Hill in St. Louis. It was an event hoping to start the discussion of cannabusiness in Missouri, and it did not disappoint. The room was dimly lit, and the stage spotlighted green, the DJwas spinning house music. The room was surrounded by sponsors and CBD vendors. The food was

delicious and the drinks were plentiful, the energy of the room was electric. After meeting and greeting one another, attendees found their seats for the highlight of the night, the cannabis entrepreneur pitch competition, which was moderated by founder and CEO of Green Rush Consulting, Zeta Ceti. Participants in the Cannabis Business Licensing Bootcamp, a program to help people of color, women, veterans, and small

42 M OGREENWAY.COM

business owners win Missouri cannabis business licenses, were invited to compete for prizes provided by community sponsors including: cannabis business seminars in Oakland, Ca. donated by Oaksterdam University, memberships to Missouri?s cannabis business trade association were donated by MoCannTrade, and MJBizCon, a series of marijuana professional events, donated registration for its New Orleans conference. Nine teams presented in front of the

I gnite

crowd and then received critical feedback from a panel of judges. Competition judges included Charles Wu, cannabis investor and educator who serves as chief revenue officer of Agrinamics and Minorities for Medical Marijuana; Dr. Lance McCarthy, economist and investment advisor who founded Ferguson 1000, an initiative to create jobs in Ferguson, Mo.; Leah Heise, D.C.-based cannabis regulatory compliance attorney; and Derek Mays, corporate lawyer and

founder of REAL Cannabis Co. Event winners included: MajestiKs LLC led by Marne Madison, Live Roots led by Tiffany Brewer, and Pure Leaf Collective led by Taronda Ransom. After announcing winners of both the raffle and pitch competition, the night ended with live music and dancing. It was a night for the books that brought together cannabis-connoisseurs and canna-curious alike, and set the bar high for forthcoming Missouri cannabis events.

The greatest thing about the event was the diversity of participants and attendees that filled the room. People of every gender, race, and age came together for one shared love of cannabis, and one goal of community. Ignite Missouri was powered by A Red Circle, and Cannabis Doing Good. The event benefited Minorities for Medical Marijuana 501(c)(3) & The Last Prisoner Project.

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How amazing arethewomen in the cannabis industry? Maybethereal question: how amazing are women in Missouri?

WOMEN

MAKING WAVES

Greenway is thrilled to announcethe Women to Watch series, highlighting women who areembracing Amendment 2 and leading this developing industry with their talents and passion. Sincethelaunch of this publication on April 20, we?vemet hundreds of amazing peoplewho areso inspired by what cannabis can do for thestate. From health careprofessionals turned businesswomen to accountants and attorneys to strategy wizards, wehavetalked to dozens of women and weareexcited to featuresomeof them in our first series. Continueto keep an eyeout to meet some familiar, and maybenot- so- familar, faces who areat theforefront of this developing economy. Wehopeyou enjoy learning about someof thetalented professionals devoting their careers to cannabis. This series will continueonlineat mogreenway.com. This is just thefirst of many series to comeprofiling themovers and shakers of thecannabis industry in Missouri and I could not, personally, beprouder to feature women first. Best,

Rachael Dunn Publisher | Greenway Magazine

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WOMEN MAKING WAVES Wendy Callicoat is a mom, a businesswoman, an entrepreneur, and now, the principal at Sarcoxie Nursery. Callicoat, who grew up learning to ?just say no,? has gone from medical marijuana advocacy to leadership of a company with historic roots all while reenergizing a Southwest Missouri community.

Gr een w ay: Wh at w as you r car eer bef or e f ocu sin g on can n abis? Callicoat: First and foremost, I was fortunate to be able to have a career as Mom. After many years working in customer service and sales for various companies, I transitioned to working as a stay-at-home mom raising my two children until they reached middle school. At that point I returned to the workforce and spent more than 15 years working side-by-side with my husband, Paul, managing his cardiology practice. We had a staff of 15 caring for more than 5,000 patients. Our motto, ?You aren?t just a number to us; we treat you like family,? shaped what type of business we ran. I thoroughly enjoyed seeing patients in the clinic daily and many of them are still dear friends. My area of expertise was medical coding, billing and compliance for both government-based and private health insurance. In 2002, Paul entered into a joint venture with a large Oklahoma-based hospital corporation to build and staff a cardiac catheterization lab in a rural healthcare facility. I was responsible for working with CMS to ensure that the lab would be able to obtain its provider status. This proved to be complicated, because under Medicare guidelines, there wasn?t a designation for this type of facility. After months of working through the rules and regulations of CMS, a designation was determined, and the lab received its provider identification under Medicare and private insurers. Grand Lake Regional Cardiology became one of the first privately owned stand-alone cardiac catheterization labs in the country. Along with my position of managing the private practice of Regional Cardiology, I was appointed as the government and private insurance contract compliance officer for the cardiac catheterization lab. I retired in 2013. Gr een w ay: Did you alw ays su ppor t m edical m ar iju an a? Callicoat: I am new to the world of medical marijuana. I can honestly say that if you had asked me two years ago what medical marijuana was, I probably wouldn?t have been able to give you an answer. Growing up in the era of ?Just Say No,? my position on marijuana was just that. However, my mind was changed after watching a documentary about a young child suffering from Dravet syndrome. I was amazed at the results she experienced from medical marijuana. This story tugged at my ?mom? heartstrings and I wanted to find out more about this type of medical treatment. I began to read all I could to educate myself and then began meeting advocates and hearing their stories of success. Shortly thereafter I began to advocate for medical marijuana as well. Gr een w ay: How did you get in volved w it h New Appr oach M issou r i? Callicoat: My son Jonathon was very involved with Amendment 2 and New Approach as an advocate and signature gatherer in Kansas City. He suggested we get involved in the campaign in our area of Southwest Missouri. We attended several meetings in Kansas City and St. Louis to educate ourselves about the Amendment 2 campaign and New Approach. Paul was asked to give a presentation on medical marijuana from a physician?s perspective at the Southwest Missouri Democrats in August 2018. We both attended the meeting and realized that there was a tremendous amount of support and excitement for Amendment 2 in our local Joplin area. The organization asked for volunteers and my hand immediately went in the air. Gr een w ay: Wh y do you su ppor t Am en dm en t 2? How did

you assist t h e cam paign ? Callicoat: Amendment 2 was incredibly well written with the focus on patients. Not only did Amendment 2 provide for patient treatment, it clearly applied the rules and regulations in a manner that an entrepreneur could develop and execute a viable business model. My background in the medical field put me in an excellent position to speak to voters about Amendment 2 from a patient treatment perspective. I have seen patients in a clinical setting who struggle with the various illnesses that would qualify them as patients for treatment under Amendment 2 and I have seen patients struggle with addiction to opioids firsthand. I knew that medical marijuana provided a better, more holistic way for patients to control pain and various chronic illnesses. I have lived in the Joplin area for over 25 years and being a part of a community that long and being involved in many philanthropic organizations in the area allowed me to present Amendment 2 in various arenas. I became the Amendment 2/New Approach Volunteer Coordinator for the western half of District 7 in Missouri in August 2018. I was able to work with various organizations and to put together a team of very talented volunteers and advocates to help educate the voters of our area. The level of dedication by the grassroots advocates not only in our area but all over the state was, I believe, instrumental in the success of Amendment 2.

PTSD, chronic pain, opioid addiction and other illnesses who want to use medical marijuana and still be seen at the VA. I?ve seen patients who have become addicted to opioids

Gr een w ay: Wh at k in d of r espon se did Sou t h w est M issou r i h ave t o Am en dm en t 2? Callicoat: When I first started as Volunteer Coordinator for our area, I was unsure how well the message would be received. I used my social media accounts to slowly spread the word about medical marijuana as a medicine. I then began to post about Amendment 2 and encouraged people in our area to become more educated voters. I was amazed by the positive response from all walks of life. Paul and I both began to speak locally and statewide on behalf of the campaign. We saw support for Amendment 2 begin to take root in our area and across the state. I credit a lot of our success to the incredible volunteers who worked the campaign alongside me. These volunteers gave of their time and talents to educate the public on the benefits of medical marijuana? how it can help patients with chronic pain, children with epilepsy, etc. If you gauge public support for Amendment 2 by the 3,000 yard signs that were distributed, I would say their efforts were hugely successful. Case in point, our district in Southwest Missouri passed Amendment 2 by a wide margin. Gr een w ay: Wh at is you r h ope? pr of ession ally, per son ally an d gen er ally? f or t h e in du st r y cr eat ed by Ar t icle XIV? Callicoat: My work with Amendment 2 has given me a new mission. My family and I plan to enter this industry through our medical marijuana business, Sarcoxie Nursery. As a principal, I will be able to utilize my expertise in government-based healthcare compliance and apply it to the emerging, highly regulated medical marijuana industry. I also believe my experience as a patient advocate will be beneficial as we develop our dispensary plans. I?m excited to work with my family, a team of Missourians, to bring jobs to the state of Missouri. For the industry itself, I hope that as we move forward, we remember how and why we are in this business. At Sarcoxie Nursery our mission is to bring patients a new, high-quality option in their healthcare treatment.

WENDY CALLICOAT because they had no other options to control their pain. These stories are why I am very excited and honored to be able to be involved in the evolution of a new industry in Missouri that will allow patients to have an option that isn?t the traditional pharmaceutical-based treatment plan. My favorite part of my job is turning skeptics into believers through education. Gr een w ay: Tell m e abou t Sar coxie Nu r ser y. Callicoat: The floral business of Sarcoxie Nursery is steeped in history. The nursery is in Sarcoxie, Missouri, which was once known as the Peony Capitol of the World. It had been in operation since 1875 when the Wilde Brothers first began growing peonies and other varieties of flowers. Some time ago the original property was split up and sold off. Paul and I were driving around one Sunday morning looking for a potential site for our cultivation facility. I happened to type in ?nursery? while I was searching online, and the listing for Sarcoxie Nursery came up. We drove to the 72-acre property and it was love at first sight. After seeing the original water tower, the historic barn from the mid-1800s and the rows and rows of beautiful maple trees we knew we had to have it. The property has been abandoned for six years, so we are currently working to restore the buildings. In addition, we are creating a vertically integrated cannabis company with cultivation and manufacturing facilities located on-site. The local support for our project has been overwhelming and we are so excited to be bringing life back to this beautiful spot.

Gr een w ay: Wh at in spir es you abou t m edical m ar iju an a? Callicoat: There are many different things that inspire me when it comes to medical marijuana. The patient stories probably have had the biggest impact on me personally. I?ve watched warrior moms advocate for their children who suffer so tragically from seizures. I?ve talked to veterans with

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WOMEN MAKING WAVES A nurse turned CBD advocate, Leigh Carr and her husband founded Hari Om Hemp in 2018. Carr has several shops in the Kansas City area and an active online presence, but ultimately hopes to help usher in change at the educational level for health care professionals.

amazing plant that has had a stigma on it for too long. The more I learn, the more I teach myself that this plant can do so much for so many. What do you think makes you and your company stand out, can you share your story?? ?

Who are you and what do you do? Hi everyone! My name is Leigh Zarda Carr and I am the CEO and Co-founder of Hari Om Hemp. I wear many hats in the cannabis industry from making our all natural and organic products, holding educational seminars on the endocannabinoid system, working at Brookside Holistic Solutions a few days a week for those needing guidance, as well as education on the difference between hemp and marijuana, as well as you can find me at a number of different fundraisers supporting the community around us and always giving back to a community that we love so much. What is your backstory? My background is in Nursing and I hold my BSN from Research College of Nursing and Rockhurst University. I am currently working towards my CNNC nursing certification as well. My whole life, I knew I was here to help others, never did I think that I would have the pleasure to get to help so many with a PLANT not a PILL. I have found my calling and am so lucky that I get to wake up every day and spread the knowledge and benefits of cannabis and cannabinoids. Having suffered my entire adult life from chronic pain, anxiety, insomnia, depression, I found relief from Hemp Oil that no other medication was ever able to do. Having found that relief in Hemp Oil after years and years of PT, steroid injections, and daily sciatica pain, I knew I had to let others know that there are alternative therapies out there that do and can work outside of modern medicine. You see, we are not taught in nursing school what you would think and that is another reason why I knew I had to get in the industry to help educate from a medical perspective.

Hari Om Hemp was founded on the belief in alternative and holistic therapies. While we strive to educate on the benefits of CBD, we are not just any other CBD company. At Hari Om Hemp our goal is to promote better overall health and wellness as a whole, mind, body, and spirit using an all natural and holistic approach. We want to help people on their journey to health and wellness as a whole. Hari Om Hemp started in the heartland of the midwest in the great city of Kansas City. Hari Om Hemp began as an idea from husband and wife, Dustin and Leigh Carr, when they both noticed the many benefits that

What is the most challenging thing in the industry? Payment Processing. We have now been shut down online 5 times and are currently in the midst of trying to find our 6th payment processor. Trying to provide access to safe medicine has become the hardest part. I can only hope and pray soon this is all a thing of the past and we do not have to worry about waking up to another email saying we can no longer accept CBD sales. What motivates you? My family and our community. Without the love and support from both none of what we do would be possible. The community has welcomed us with open arms and for that we could not be more thankful.. Our goal is to always give back to the community that has been so good to us!

LEIGH ZARDA CARR

When did you first get involved? Hari Om Hemp was founded in April of 2018 and within that last year the growth and direction we have taken is something we never thought we would get to so quickly. But with the drive and ambition that we have to truly help others. There are no days off and we keep pushing to be at the front of Education and providing the highest quality Hemp products on the market. Where do you see yourself within the industry in a few years?

What made you fall in love with cannabis? I fell in love with cannabis at a young age in college. While it was illegal, it was the only thing that I could use to function and study ? nothing that Adderall could ever do for me. I spent many years hiding this from people because of the stigma and it being illegal. Now in this day and age, with the acceptance of medical cannabis across the country, I feel it is my duty to educate on the misconception of this powerful plant and why consuming this plant can help restore our endocannabinoid system to homeostasis. The endocannabinoid system is not taught in nursing school and this is a system I have dedicated hours and hours of research over the last 18 months. Why do you want to work in Missouri?s cannabis industry? Having found relief myself from Full Spectrum Hemp oil that no other medication could ever do for me I knew with my nursing background that I had to help educate where education is needed. With my Bachelors in Science of Nursing, I understand the science behind why cannabinoids work within our endocannabinoid system and I wanted to be able to use my science background to educate others on the benefits of this

My son is my overall driving force and my reason why I work as hard as I do. My son has special needs and he takes hemp oil everyday as well and just another reason why I love this plant so much and want to help educate and break the stigma upon Cannabis consumption. I truly believe that this plant has so much to offer for so many!

Leigh saw from CBD herself. L?eigh, who holds a bachelor?s in Science of Nursing was sick and tired of being sick and tired. Bound to the drive-through pharmacy line for refill after refill for little to no relief was not the life Leigh wanted to live anymore. That is when she started to do research on alternative and holistic therapies. All her research led her to CBD. L?eigh has suffered from numerous different ailments ranging from mental health, addiction, and chronic pain ? all of which can benefit from CBD. We pride ourselves with our direct relations with the farmers in Oregon who grow the hemp we use in our Full Spectrum Hemp Oil. Having these direct relations we know exactly where our hemp is sourced from, how it is extracted, and genetics will be the same each and every time. At any given time we have direct access to the farm and the farmers. We third party test all of our products in an outside testing facility to ensure every product has in it what we say is in it. In an industry with companies popping up every day and labeling the same white label product, we are happy to say that we were built from the bottom up and are a one of a kind unique business led by the brains of a Nurse.

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At the forefront of Cannabis Nursing Education in the Midwest. I want every Nursing School to be teaching about the Endocannabinoid system and the benefits of consuming cannabinoids. It is a disservice to our patients to NOT be educating the future nurses about such a very important system that is a regulatory system! What are your and your company?s roles in the cannabis industry? To provide the highest quality hemp products in the midwest and to continue to educate those who need educating and to break the stigma on Cannabis. Hari Om. What is your favorite thing about the cannabis community? The connections that I am making with like-minded individuals. Like I said earlier, I used to hide my use of cannabis because of the legalities and stigma surrounding it and now I can express openly the love and benefits of it too so many! Plants over Pills, Health over Wealth!

WOMEN MAKING WAVES By Kaycee Barry Sarah Ceti, co-Founder and owner of Green Rush Consulting, has Missouri roots. Born and raised in the Ferguson/Florissant area of North St. Louis County, Ceti studied journalism at the University of Missouri in Columbia before traveling the country working with different publications focusing on documentaries and non-profits. Then she packed up all her belongings and moved to San Francisco, the epicenter of the cannabis movement, where she landed her first big gig at Mother Jones magazine. Before moving to San Francisco, she was a consumer of cannabis, but didn?t quite understand the movement behind it.

them to have the opportunity to have a piece of the pie,? she said. ?They deserve it.? While consulting, Ceti noticed that these marginalized communities were heavily underrepresented in business. ?We saw all different kinds of walks of life, but we noticed something very important? there was a small demographic of individuals who could really go through the whole application process and have the business experience to do so.?

excited about. She said, ?We are trying to bridge a lot of gaps, and bring together a lot of diverse communities. It is a very intentional activity we are doing, and by happenstance, we learned that this Monday is Michael Brown?s Birthday. There is a lot of attention on St. Louis right now, and we are really hoping that this will Ignite Missouri. We hope to see, acknowledge, and give honor to what has happened historically, and write a new story going forward.?

Ceti?s goal of equality is what drives her daily work. In addition, she takes pride in being a community builder.

When asked if she is bringing the life back into North County, she stated, ?I hope to be a part of it. I really believe cannabis is a movement, yeah it has an industry aspect, but it can really revolutionize how we interact with and think about: medicine, health, healing, and how we interact and connect with each other ? as well as in the way we do business.? She believes that one can do good, and make money at the same time. That is the ideal Green Rush instills in their clients. Ceti ensures that all the companies she consults with have a balanced community benefit plan that can be followed through.

SARAH CETI

Everything changed when Ceti met her husband. While living in a hostel her first year in California, Ceti met Zeta. Zeta was an artist, a musician, and an underground grower for 18 years. ?On our first date, I saw his grow room, and I instantly fell in love.. it was pretty amazing,? she laughs. As they continued their relationship, Zeta made his way from the underground market into the legal market. Zeta was working as a consultant, doing sales, assisting with growing operations, and landing his first big project that included four large-scale cultivations in the city of Oakland.

Ceti thinks that women should be involved in the cannabis industry because it is one of the first industries that actually has the opportunity to be woman lead. She states, ?Women are 51 percent of the population, and that should be reflected in the ownership of these businesses.?

He then founded Green Rush Consulting, and in 2014, Ceti hopped on board. ?It was picking up at lightning speed,? she said. ?I was like, I got to get in and help, there is a lot to do here.? The first state she focused on was Illinois. It was a large and competitive process, but she jumped right in. She wrote a press release, and within two weeks time, she had already booked 40 meetings to discuss the application process. In the midst of starting Green Rush, Ceti?s mother had been dealing with a very rare form of cancer that she struggled with for about 20 years. ?The doctors prescribed her opiates, and it was killing her,? she says. Through connections, they were able to get her mother cannabis, which then replaced all of her opiates. ?The night before she passed she was laughing,? Ceti says. ? I attribute her safe passage to cannabis. I really believe in the power of this medicine on so many levels.? Ceti had a ?lightning strike? moment in her life. Two days after her mother had used cannabis to heal her pain and be at peace, Michael Brown was shot. Being from North County, this hit home for her. ?My city was erupting,? she said. ?I saw that this huge injustice had occurred? I asked myself, how is it that this middle class white woman who was dealing with cancer illegally used cannabis for her safe passage, yet this person over here was shot, and they tried to connect the shooting with the fact that he had cannabis on him ? and with those lightning strikes, I went from advocate to activist, and being an activist via my business.? After that, Ceti?s biggest mission became making cannabusiness accessible to everyone ? marginalized communities, communities of color, those who she believes have most borne the weight of the war and drugs. ?We want

While in Oakland, she started a monthly meet up at the park for people in the cannabis community to get connected. The events are free, volunteer-run, and communicated through a Facebook. In the first month, eight people showed up for the social. Four months later, there were hundreds. She has since passed off the reins, but five years later, they still have monthly meetings. After the passage of Amendment 2, Ceti found her way back to Missouri. Ceti has already implemented canna-community building in St. Louis. The meet-ups are being held every second Saturday at Schlafly?s, which are organized by another Greenway Magazine Woman to Watch, Marne Madison. In addition to the monthly meet-ups, Green Rush Consulting is pairing with Oaksterdam University and Missouri Cannabis Business Review to host ?Ignite Missouri,? which took place Sunday, May 19, at Blueberry Hill in St. Louis. The first event of its kind, Ignite is hosting a ?Shark Tank? style pitch competition. With food, CBD vendors, and live music the event aims to bring the cannabusiness community together.

Ceti says it is a constant challenge being a woman who deals with ?traditional businesses-doers,? who are predominantly older white men. Sometimes it takes two women in the room to echo and raise one another up to be able to be heard in these spaces, she said. ?Basic capitalism says there is no room for divergent thought or emotion in the workplace,? she says. ?The kind of companies we want to support are those who understand the importance of empathy and compassion in business. They must understand that this is so much more than about money. It?s about changing how we interact with medicine, ourselves, and changing how we interact with each other.? Ceti believes she has found her life?s purpose. She states, ?It was no coincidence that I was in the epicenter of the cannabis movement all while my mom had just died from cancer after switching from opiates to marijuana. The timing of her death and the fact that I?m from North County? I don?t believe in coincidence, I see this as a sign for why I am here. This is my calling.?

The event is something Ceti and her team are extremely

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WOMEN MAKING WAVES YEN-ology aspires to bring healthcare and patient education to the forefront of medical marijuana in Missouri. Partners, Dr. Mimi Vo and attorney Sarah Glasser, are the women behind the curtain. Dr. Mimi Vo attended University of Missouri-Kansas City medical school at the age of 18, and has been practicing as an internal medicine physician in the St. Louis area for over 10 years. Sarah Glasser is a transplant from Oklahoma, having grown up in Tulsa, she went on to receive an undergraduate degree at Washington University with a B.A. in East Asian Studies. Glasser then returned to Tulsa for law school at The University of Tulsa ? College of Law. Together they represent two of the most important aspects of the cannabis business, healthcare and understanding of legal rights for patients. They share more than a business practice ? Glasser describes herself as, ?the mother of three amazing children, wife to an extremely supportive husband, an advocate for Women?s Rights, and a supporter of local arts organizations.?

to use this information to provide better avenues for our patients to live happier healthier lives. This plant is consumed by such a diverse group of people and this is a perfect opportunity to bring together people from all walks of life. There is no reason why people from different social circles, economic backgrounds and cultural backgrounds can?t connect, join together, inspire, and empower each other to do great things in this new thriving industry and within our communities.

to the United States in 1975. My sister and I were born and raised here in the Midwest and were taught to follow in the healing traditions of our family. We both became doctors and now practice in St. Louis. Knowing my familial history, cultural roots as being healers, and my grandfather ?s background in plant and herbal therapies, has helped cement my need to understand cannabis as a medicine. I had to do much probing and self-education on cannabis as there was not one place to find all the information I hoped to seek. The more I learned, the more I became enthralled

SARAH GLASSER & DR. MIMI VO

While Vo says she is, ?a BoyMom to a 7-year-old and twin 3-year-olds,? and that she is passionate about, ?healing, the arts, and my community.? Greenway recently had the opportunity to get to know these brilliant women and learn more about how they see themselves, and their business, in the cannabis community. Gr een w ay: How did you bot h w in d u p in M issou r i? Glasser: After graduating law school I moved back to St. Louis to practice Family Law. My passion has always been women?s rights, supporting women and children who are victims of domestic and sexual assault and giving back to my community. Dr. Vo: My husband and I have known each other since high school, when I went to medical school we parted ways. Ten years later we re-connected. Gr een w ay: Wh y can n abis? Dr. Vo: I became immersed in modern medicine, (my husband) came to understand medical cannabis living on the West Coast. I was initially very skeptical, as I had only learned about its intoxicating properties. Over the past few years, as I care for patients who have had an opportunity to use cannabis as medicine from other states, I am seeing first-hand the therapeutic benefits of it. I am seeing grandmothers whose arthritis pains are improved, mothers with multiple sclerosis spasms relieved, children with reduced seizures, and patients with incurable cancers in which tumor growth is suppressed by cannabis. Glasser: I was driven to this industry to help others. I believe cannabis is an unbelievably complex plant with highly medicinal qualities. I have learned in my research and by talking to other people that there are so many unanswered questions and benefits and we are just scratching at the surface. The claims about the use of cannabis in the healthcare realm are exhilarating. I am so excited to have such a rare opportunity to build a company as a woman with other intelligent women leaders and to create something unique, educational, and life changing in this developing industry. The cannabis industry is about to grow exponentially. Gr een w ay: Wh at do you h ope t o do in m edical m ar iju an a?

Dr. Vo: I am very passionate about educating others on cannabis. Education for patients, physicians, care-takers, and the community. I became one of the board members for the Missouri Cannabis Trade Association last year and am their Healthcare and Education Chair. My first order of business, while we await the start of the program, is to educate physicians on cannabis and its use as a medicine. 9 out of 10 physicians I talk to in Missouri do not understand the endocannabinoid system or cannabis. I hope that I can spread enough knowledge that patients can feel comfortable speaking to their physicians about it, and that these Missouri physicians will have a point of reference to understand their patients better. I am also on the board of directors for the Society of Cannabis Clinicians whose mission is to educate and advocate for medical cannabis research and knowledge sharing. As a member of their International Committee, my mission to educate spreads beyond the borders of Missouri to the global stage. Going forward, because of all that I have learned about cannabis and its use as a medicine, I have decided to pursue licenses for a vertically integrated cannabis company. I have found 3 other women all with talents in compliance, cultivation, and industry experience to join me. I hope to have the chance to bring cannabis to Missouri by manufacturing medical cannabis products that have influences from both Eastern and Western cultures, bringing maximum efficacy to patients needing relief from pain and other ailments.

with the research and case studies that I found. The most amazing part of this journey has been meeting all of the people who are passionate about cannabis and learning from them. Glasser: My undergraduate degree was in East Asian Studies at Washington University and I spent a semester abroad in China. During that time, I became very interested in alternative forms of medicine, which included acupuncture, acupressure, use of essential oils and herbs to aid in medical care, health and wellness. (Mimi) a close friend, and now my business partner, is an internal medicine physician. She approached me to see if I had any interest in learning more about cannabis. I had done some research on the benefits of cannabis and at the time I was also looking into learning more about cannabis law because the three initiatives were going to be on the ballot November 2018 and it seemed like Missouri was moving in the direction of finally voting for Medical Marijuana. I wanted to be in the forefront of its transition into Missouri. I am also up for learning new things and I was enthralled with the cannabis legal industry. I went out to San Jose in 2018 and attended my first National Cannabis Industry Association Business Summit. There I met some of the smartest, talented and powerful women from any industry. I was hooked from that moment. I was scared to death about entering an industry that was so new and with regulation and compliance issues changing rapidly was quite overwhelming. However, I love a challenge and competition.

Gr een w ay: Wh at in spir ed you r plan s? Glasser: To educate, inspire, empower and connect. Although many people have been using this plant for decades there is still so much unknown. Being able to work closely with a physician to not only educate, but to gather data as this industry is expanding is very exciting. We hope

Dr. Vo: My grandfather was an Eastern Medicine Herbalist physician. He sent my father, at the age of 13 to move to Saigon in Vietnam to pursue western medicine and attend a U.S. led medical school. My father was an emergency medicine physician and became a pediatrician after coming

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The most amazing part of this journey so far has been meeting so many people who are passionate about cannabis and learning from them. Read more from Glasser and Vo at mogreenway.com.

WOMEN MAKING WAVES By Rachael Dunn

wrap my head around!?

CAMP Cannabis co-founders Susan Griffith and Jennifer McGuire are best friends taking their vast knowledge of health care to Missouri?s medical marijuana industry.

And so with the passage of Amendment 2, now Article XIV, Griffith and McGuire took their passion for education and treatment and turned it into an opportunity to make a

Griffith (pictured, left) has been in healthcare for 20 years, doing sales from pharmaceuticals to Healthcare Capital Equipment. McGuire (pictured, right) left politics to get into nursing ? she will receive her Master ?s in Nursing this year. The duo leads a team building a company they plan to develop medical marijuana from cultivation to dispensing to patients. ?CAMP will be able to provide qualifying Missouri residents with safe, efficacious options for management and treatment of their qualifying medical conditions,? Griffith, CAMP president, said. ?Our mission for CAMP is to make a difference in each patient?s quality of life by cultivating, manufacturing and providing access to superior grade medical cannabis. We want patients to understand and find comfort knowing all CAMP representatives will be compassionate and well educated in all cannabis brands provided, as well as all qualifying medical conditions, and that CAMP will truly walk side-by-side with the patient throughout their medical treatment journey.?

SUSAN GRIFFITH & JENNIFER MCGUIRE

Taking from their professional experience in healthcare, the team plans to see patients through their treatment beyond the sale. ?My hope for CAMP is for us to responsibly educate and to bring compassionate relief to patients who so desperately need an alternative to synthetic, manufactured medicine,? CAMP Vice President McGuire said. ?My mom has been on a doctor-prescribed opioid regime for approximately 20 years. When the war on opiates began last year, her pain doctor cut her regularly prescribed dosages in half at one of her scheduled visits. This resulted in her experiencing a significant decrease in her quality of life. It has been heartbreaking seeing how powerless she is with her healthcare decisions as it relates to her medicine, knowing there is natural medicine available that truly can help her. I know that with this happening to her, there are thousands of other patients in Missouri who have gone through similar experiences. We hope that all patients in Missouri know that CAMP is committed to bringing them safe, effective medicine through quality flower and reliable products. We want them to know we are with them, through every step, and we welcome all qualified patients from all walks of life.? From PTSD to epilepsy, Griffith and McGuire believe in the ?healing power of cannabis.? The pair have been friends for over 27 years, witnessing patients, family members, and friends struggle with medical conditions and the resulting decline of their quality of life. ?I think over the past 10 years, however, that belief has become even stronger as we begin to see scientific results in the effectiveness of the plant,? McGuire said. ?There is absolutely nothing like reading a story about a parent who has been able to effectively treat their child for epilepsy with medical cannabis. Or to hear from a veteran with PTSD how cannabis has been able to provide them with some relief from their symptoms. The endocannabinoid system isn?t taught in medical school or nursing school, but it?s a regulation system promoting homeostasis between all of the operating systems in our body. The science behind the medicine and all of the possibilities for healing inspire me to learn as much as I can every single day!? Griffith has recognized the unlimited potential of cannabis, saying the science behind the plant has been suppressed for so long. ?Over the past several years, the data that has been released and the personal testaments that have surfaced regarding the amazing results and relief that cannabis has provided so many patients ? PTSD, epilepsy, Parkinson?s, Alzheimer ?s, chronic pain, Cholitis, etc. ? has truly fascinated me. Just knowing that this ONE plant can have such life-changing results for so many has, at times, been hard to

resulted in a willingness and open-mindedness to consider cannabis in this new, positive light.? Since making the jump into the cannabis industry, the pair has been encouraged by the people they have met and are both reassured by their own experience transferring so well. ?From meeting all of the wonderful people in the industry to learning more about the plant, to hearing the stories from patients and how their lives have been positively impacted; it has truly been an amazing ride thus far,? McGuire said. ?To be on the forefront of an industry that can individually affect lives in a positive manner has been so inspiring to me. Every day is a growing experience with more things to learn and to make CAMP the best it can possibly be for Missouri patients. There is no other place I can imagine myself.? Griffith said the best part of the jump has been, ?hands down, the people and the plant. Every single day is different and the ?to do?list becomes longer and more involved, but even with all the flux, it is absolutely exciting and invigorating! We are able to say we are a part of an industry that is truly changing the way our state and country approach healthcare. We are surrounded by truly amazing people, from our industry colleagues to our service providers, to all of the vastly talented members of our team. Each day I wake up truly energized, and I feel like I am exactly where I belong. Not to be clichĂŠ, but I feel like my life path thus far has prepared me for this role, in this industry, and my hope is that is will make a difference in peoples?lives.? As empowered as they are, they?re both accutely aware of two challenges the cannabis industry faces: regulation and banking.

difference in others?lives by providing quality, natural medicine. ?We knew that the passage of Amendment 2 would enable safe, natural medicine to be brought to patients in Missouri who could truly benefit from its vast healing qualities,? McGuire said. ?We wanted to not only bring this beautiful, healing medicine to patients, but we wanted to work with them to help educate and empower them make the best possible decisions for their well-being.? From cultivation to manufacturing and to dispensing, each member of our team brings a skill set like none other Missouri has seen, McGuire says. The CAMP team brings extensive research and development of cannabis for a number of conditions named in Article XIV. CAMP will apply research and development to design therapies for each qualifying condition. The team is dedicated to ?addressing each and every patient?s disease state while positively impacting their lives.? McGuire says she is thrilled with the reception of medical marijuana in Missouri, saying, ?the spread of information on the benefits of the plant has finally come to the mainstream enabling more patients to abandon their manufactured prescriptions in favor of natural medicine devoid of fatal side effects.? Griffith pointed to the surging opioid epidemic in the state as a reason Missourian?s are also embracing cannabis. ?Our citizens are desperate for solutions to defeat this epidemic, and at the same time, they are seeing the amazing improvement in so many patients with other chronic conditions,? Griffith said. ?All these combined have

?I believe most all cannabis businesses face similar challenges,? Griffith said. ?We are in a very highly regulated industry, which means making sure we are addressing every detail with equal vigor. We must ensure 100% accuracy in so many different areas, for application purposes, so that we are able to be successful in our license efforts. We must also work through additional challenges to ensure compliance with tax and regulatory issues, as well as challenges in the banking industry. Due diligence is paramount in navigating all these waters successfully.? Regulation compliance is a topic the pair have seen trending nationwide. ?I think regulations and compliance will be huge issues for all new canna-businesses in Missouri,? McGuire said. ?Susan and I recently attended a cannabis conference in Chicago and a majority of the focus was spent on regulation and compliance so it?s obviously a topic that is nationwide. The industry is even more regulated than alcohol and spirits so it opens it up to a number of opportunities for mistakes. We are laser-focused in following all regulatory and compliance guidelines in every aspect from the application process to the implementation of the business to day-to-day operations. ?Another challenge I see for canna-businesses is in the banking industry. With cannabis being illegal on the federal level, there are no federally backed banking entities willing to do business with these companies. This provides a number of issues as every transaction for the business has to be completed in cash, from payroll, to service providers and leases, and taxes. No other industry operates in this manner. It is my hope that Congress can come to some sort of agreement and enact the SAFE Banking Act of 2019 at some point in the near future.? Awareness of challenges and change have equipped this pair as they look towards the application process this summer. ?At CAMP, we want to facilitate connecting patients with cannabis, to provide them choices and empower them when making decisions for their health and wellness,? Griffith said.

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WOMEN MAKING WAVES representation inside of companies, when studies show we are the best decision makers, and business partners to have. I think its extremely important for women to be involved in the industry to show equality. Its pivotal for young girls coming up to know that opportunities are limitless throughout the industry. And I personally think if you want something done right, ask a woman to do it (I may be a little biased.) Wh at m ot ivat es you ?

MARNE MADISON By Rachael Dunn You?ve seen her all over cannabis events in St. Louis, but her roots in the area run deep. Growing up in the North City of the Greater Saint Louis area, Marne Madison observed hardships and struggles throughout her community. ?I knew early in life that I wanted to make a difference for my community,? Madison said. ?I get a lot of work ethic from my grandfather for sure. My grandfather moved his family here, leaving behind a small farm in Arkansas to see what Saint Louis had to offer for the man known with the best watermelon this side of the Mississippi. After landing a contract to sod and landscape the grounds of the Gateway Arch, my grandfather took on several roles to impact the new place he called home. Providing housing opportunities and tons of jobs at this landscaping company are just a few of the ways he impacted his neighbors, and is still remembered today. Being one of the youngest grandchildren, we didn?t have a lot of time together to learn the family business, but I think I inherited everything genetically. Although I attended college for finance/accounting, my green thumb has always sat patiently waiting for its turn.? Madison believes she has found her destiny in medical cannabis and is preparing her application to open a dispensary. Driven, with an education in finance and accounting, a love for herbalism, and a natural gift for plants and social media, Marne Madison is a woman to watch in Missouri?s emerging cannabusiness industry. Wh o ar e you an d w h at do you do? Hey guys! I?m Marne Madison, a community advocate for financial literacy, and health and wellness. I am the founder of Her Herbs, an online herbal shop geared towards the awareness of natural alternatives for women?s reproductive health concerns. Over the past few years, I have helped over a hundred women throughout my community and globally

subside health issues from minor migraines to fibroid or thyroid complications. Horticulture and Agriculture have been the forefront of my studies while volunteering at the Earth Dance Farm School in Ferguson, Missouri. I have dedicated years to learning, understanding, and growing hundreds of household herbs. With years of hands-on experience and knowledge, I have now found myself to be a leading influence as one of the most common medicinal plants, Cannabis, has finally made its way into Missouri. Wh at m ade you f all in love w it h can n abis? Science! As you embark on a journey to learn and understand you, and your body, you in many ways become a plethora of mini scientist. When I first came across endocannabinoid receptors, my eyes went straight to the root ?canna.?I researched everything there was to know about this system and how it helps the mind, body and soul align together. I literally became consumed in the education of cannabis. Wh y do you w an t t o w or k in M issou r i?s can n abis in du st r y? Being well-versed in herbal studies and attending horticulture school years ago has manicured me for this moment! Have you ever felt destined for something? Well, honestly, me either ? until now! On top of all the hard work my business partner and I have been doing these past months, I feel destined. I have studied and worked closely with this budding industry for years and promised to be prepared if Missouri was giving a chance. With my networking from trade shows, and industry leaders on the West Coast, I want to provide Missouri businesses several opportunities to be successful inside of the Industry! Wh y is it im por t an t f or w om en t o be in volved in t h e can n abis in du st r y? We have always lived in a predominately male-driven society. I was reminded of this every day throughout my corporate career, being one of the only women in operational management. Women have always lacked proper

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My community and my family ? I know its so clichĂŠ, but seriously. Statistically and realistically speaking, there aren?t many who look like me working in the industry. It?s my time, and the time is now! There are so many community engagement and youth development programs to come from this opportunity. I want to teach the community about health, wellness, and herbs. I want the youth to start early growing their own food and obtain the tools and resources to make this world Green! My family is my overall motivating force. To hear of all the good things my grandfather did throughout his community and to wish I was able to work beside him has always kept me going. A lot of days I feel like my grandfather is my extra strength to pull thru and complete the day. Wh at ar e you r an d you r com pan y ?s r oles in t h e can n abis in du st r y? Being the co-founder of MajestiKs LLC, a potential minority-owned dispensary in the city of Saint Louis, we plan to continue to be on a leader and influencer throughout the industry and community. Social equity, and justice are some of the main focuses of MajestiKs overall objective to give back. There needs to be proper representation for such a traumatic disconnect the cannabis prohibition has caused inside of my neighborhood. We plan to be a hub for low?income veterans and qualifying patients in relevance to the industry and the community. Our overall role is to be the representation and advocate in the Cannabis Industry for the community we have grown in. Wh at is you r f avor it e t h in g abou t t h e can n abis com m u n it y? The people! Organic people! This is such an open-minded community of beings that are all growing at their own pace but also provide nurturing resources to help you as well. Becoming the Social Coordinator of ?STL Canna Community?has allowed me the ability to meet amazing people throughout the cannabis community from CBD to Medical Marijuana, I have learned so much from people who focus on health and wellness and natural alternatives for their families!

You can follow Marne Madison on Instagram at @justa_being.

WOMEN MAKING WAVES

ASHLEY MARKUM

By Brandon Dunn Ashley Markum is a wife, mother, advocate, and cannabis missionary. Markum currently holds leadership positions as the director of Springfield NORML and president of the recently formed non-profit, Ayden?s Alliance. Ayden?s Alliance is a 501(c)3 focused on helping Special Needs and Low-Income families with their cannabis-related therapy. Married to her husband, Chris, for almost 15 years, the couple has 6 children. While the workload of managing a family alone is strenuous, Markum?s household is slightly different. ?My cannabis journey started when my son, Ayden, ran out of Anti Epileptic Pharmaceutical options,? Markum says. ?My mom had watched a documentary about children with Epilepsy that were having success reducing those seizures with cannabis oil. We right away knew this was our next step. Ayden was actually the 5th person in Missouri to receive his Hemp Card, which allowed us to purchase high CBD oil from the 2 state-licensed dispensaries.? The Markums saw such dramatic results with Ayden?s treatment, not only in seizure reduction but also with cognitive gains, that Ashley was hooked on healing. ?We got involved with NORML in 2015 when a friend invited me to a monthly meeting. Shortly after, we began volunteering with the New Approach campaign and spent the majority of our lives working to pass medical cannabis in Missouri. I can count on one hand the times I turned down an interview or speaking engagement during those 3 years. Thankfully we had a great support system of family and friends that made it possible for us to invest so much into the campaign.? ?Passing medical cannabis meant, literally, everything to us, because if it hadn?t passed in 2018, our plans were to move to a legal state so we could have access to what Ayden needed,? Markum explained that while CBD has helped greatly, Ayden still needs more options. With the passage of Amendment 2, Markum had time to refocus.

Ayden?s Alliance was founded in December 2018 by Daryl Bertrand of Missouri Cannabis Consultants. Markum says that since formation, she has dedicated the time and energy she had focused on the campaign for medicinal legalization to focusing on helping other families through Ayden?s Alliance. ?Being a special needs mom myself, I wanted to create an easy way for families like mine to apply for and receive assistance. I also didn?t want other families to go through what we did in the beginning of Ayden?s cannabis journey, not knowing what oils were best and how to pick good, clean medicine.? ?I have seen medical cannabis give people their lives back, help families spend quality time with their children, and give patients the relief nothing else can,? Markum said, explaining that Ayden?s Alliance?s objective is to provide Missouri patients with access to treatments, certifications, and even state issued ID cards. ?We also want to help get the information into the patients? hands. Our classes are free and accommodating for all patients.? Markum?s husband, Chris, is a registered nurse and educates patients and the public about the endocannabinoid system, among other things. But working toward a goal and offering education is only part of the initiative ? now, Ayden?s Alliance has to spread the word. ?Social media has been very helpful in getting our mission out there and finding supporters,? she said. ?I have personally seen social media, in general, be valuable for special needs parents ? when you have very involved children or are sick yourself, getting out of the house can be next to impossible. Online support groups can fill that gap.? What?s next for Ayden?s Alliance, Ashley Markum, and Missouri? ?I hope cannabis can become a front line treatment instead of one of last resort. I don?t want finances or lack of education to prohibit any patient from trying cannabis, and I believe with Ayden?s Alliance, we can build a huge resource for patients so that doesn?t happen.? Please visit and donate to aydensalliance.org. An event is planned in Kansas City on June 24 to benefit the organization, the Industry SuperHero MeetUp, at the Guild KC at 7:00 p.m.

?I knew I wanted to do something to help patients. I shared my dreams of a huge patient support program with Missouri Cannabis Consultants and they helped make it a reality.?

TARONDA RANSOM By Brandon Dunn

sustainability.?

Ransom was part of the Minorities 4 Medical Marijuana

Taronda Ransom is the founder of Pure Leaf Collective, an

Ransom says that cannabis has become her passion, ?It?s a

employee-centered company that she says ?knows the

lifestyle, and the way of the future. Not only does it have

value of teamwork, cohesiveness, and positive vibes.? An

endless health benefits, but it can have an economical

aspiring applicant for a medical marijuana dispensary

impact as well. It provides me a chance to be a part of

license, Ransom says that Pure Leaf Collective is focused on

history and make a difference in the industry, the

providing organic cannabis for preventative care of

community, and to become a leader among my people.? For

veterans, seniors, and low-income patients, ?We are a

Ransom, people and community drive her passion for the

wellness brand focused on the healing and preventative

industry.

bootcamp and participated in the Ignite Missouri pitch competition. ?It was an amazing learning experience. Sarah and Roz developed a solid program that not only gave us knowledge for getting started in the Missouri market, but in the cannabis industry. They brought in experienced cannabis industry leaders, local influencers, and even investors to provide insight and tips to help us get started and be successful as minorities and new cannabis business owners.? Ransom said the opportunity to participate in the

care of all patients and their conditions.? ?Being a minority woman is one of the toughest challenges I

Ignite competition was, ? an elevating experience, especially

Ransom has been actively pursuing her dream since

face. With us being underrepresented in this industry, it is

for being my first time pitching in front of a crowd. I really

discovering cannabis. ?I got into cannabis by becoming a

critical that we share knowledge and offer guidance to help

appreciate the opportunity to express my passion for the

patient and using products for injuries I obtained while

other women to get started and succeed. The industry is

plant and share my vision with my family, potential patients,

playing sports, such as back pain and knee pain.? Ransom

consistently growing, and more minority women need to be

and the community.?

says she saw the direct effects of prescription drugs and

a part of that moment. I have been blessed to meet some

wanted a healthier alternative for herself and those around

women in the industry that are helpful in every aspect of

her. ?My company is four years in the making, I fell in love

the business and want to see me win, and for that I really

with the idea of being able to provide a safe place that

appreciate them,? she said. ?Right now is the perfect time to

offers top quality products to the people who have been

be a woman in the industry, we are taking the industry by

most affected by the war on drugs. I knew I wanted to be a

storm. We are setting new standards, breaking boundaries,

part of history to help change the stigma behind cannabis

and reaching new limits, we are taking over and it?s only the

through education, community outreach, and

beginning.?

Ransom describes bringing medicinal cannabis to her hometown of St. Louis, ?The opportunity to open a dispensary in the community I went to school in, grew up in, and my family still lives in today, only comes around once. I am taking full advantage of this time to ensure the dispensary is owned by someone who is a direct reflection of that community.?

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By Rachael Dunn

Senate Committee on Veterans Affairs for Ranking Member Jon Tester.?

Tightline Public Affairs has been a quarterback in campaign circles for over a decade. They were instrumental in the passage of Amendment 2, and they continue their involvement assisting the Missouri Medical Cannabis Trade Association (MoCannTrade). One Woman to Watch is part of the Tightline team: Erin Schrimpf, principal at Tightline Public Affairs. ?You?ve most likely seen our names pop up as quoted in the media as spokespersons for Amendment 2 or MoCannTrade,? Schrimpf said. ?Having been deeply involved in the campaign, we have a sincere passion and goal to help make sure Missouri has the best medical marijuana law in the country. So we work to help MoCannTrade and others working within the industry, like doctors, patients, and veterans, shape public opinion and engage policymakers to try and accomplish that.? Schrimpf grew up in Jefferson City, where her parents were both active in state politics. She says pursuing a career in

Eventually, all roads led back to Missouri, which is where she always wanted to be, working in politics in her home state. Before serving as the Communications Director for New Approach Missouri, she came back to serve as the spokeswoman for the No on Prop A campaign that defeated right-to-work in August. It?s only fitting that Schrimpf ?s support of Amendment 2 was rooted in her policy upbringing, education, and experience. ?It is good public policy,? Schrimpf said of medical marijuna. ?Sometimes, in politics, that isn?t always the case ? you don?t always get everything you want or a policy falls short of where you want it to be. Our country has a complex, but mostly harmful and destructive history when it comes to drug policy, so it is a rewarding experience to be on the right side of trying to reform our drug laws.? Schrimpf says Amendment 2 sets Missouri up to have a

ERIN SCHRIMPF

role in helping get Amendment 2 passed,? Schrimpf said. ?Our most passionate, personable and articulate advocates were actually mothers of young patients, suffering from very serious, chronic illnesses. These moms are truly remarkable. It is difficult enough to balance the needs of your family, do everything moms take on in a conventional household, and take on caring for a special or high-needs child, and then on top of that become an advocate for medical marijuana, volunteer on the campaign, and deal with the stigma that can be associated with advocating for medical marijuana, even though it is proven, effective medical relief for your child. Moms really made a compelling case for medical marijuana, and I think their voices resonated with folks you wouldn?t have expected to support our cause.? Schrimpf said, in general, the industry is well-positioned for women to have a huge impact. ?An emerging and high-growth industry requires keen attention to detail and the ability to pivot quickly and manage change. I think those are traits that come naturally to women and will help them excel, and I think we are already seeing that.? Continuing to see policy through after a campaign may be rare at times, but Schrimpf ?s motivation lies in true passion. ?Well, I am one of the few, brazen individuals ready to admit I really do love politics. I have really enjoyed working on this issue. Something that has stuck with me for a few years now is something one of my professors said on my first day of graduate school, that public policy is essentially ?who gets what, how much and why.?Politics is at its best when people feel like the system is working for them. And that is kind of the problem we see the most today is that so often ordinary people feel that isn?t the case on so many issues, and the blame falls equally on both parties. From jobs and the economy to healthcare, regardless of political affiliation, you hear over and over again, ?the system doesn?t work for me, no one is looking out for me.? ?Then obviously the holy grail of policymaking is when we can collectively work together to make the system work for people. So it feels really good to be a part of something where I feel like we are doing good, people are looking around and saying this is making things better, this is improving their lives. That makes the work meaningful and hopefully helps me grow and learn for the future.? Beyond passion, Schrimpf has a rare skill set in communications noted by journalism industry professionals as being efficient, detail-oriented, and comprehensive.

politics felt ?a little cliche at times, but there was never anything else I really wanted to do, besides being a veterinarian, but I was 5 and my parents wouldn?t let me have a dog, so here we are.? After graduating from Mizzou, Schrimpf went on to serve as a social assistant for public affairs for the then-newly elected mayor of Kansas City, Sly James. ?I handled a number of the office?s day-to-day communications operations, but I had the opportunity to do a lot of speechwriting and spent a lot of time with the Mayor at speeches, events, and meetings,? she said. ?The Mayor really encouraged my love for both writing and politics and after three years I was onto the next challenge which was getting my Masters at Georgetown University. After graduate school, I was appointed to a Presidential Management Fellowship which opened up all kinds of interesting work experiences. I served as a speechwriter at the Department of Veterans Affairs and also worked on the

robust but well-regulated industry, that protects patients and doctors, generates economic activity, creates jobs, and puts new money into state veterans programs. ?I think the really remarkable and fascinating thing about cannabis-reform is how far it has come and how the issue has managed to break out of these very niche circles of advocacy into mainstream public policy debate,? Schrimpf said. ?These are conversations I never dreamed we could be having a decade ago, and certainly not in Missouri. It just shows how far the public can move on an issue with the right information and strategy.? Coincidentally enough, Schrimpf found out 3 weeks before Election Day, where Amendment 2 was on the ballot, that she was pregnant. Schrimpf observed how vital women, especially moms, were instrumental in the passage of Amendment 2 during the campaign. ?To me, it is important because they played such a critical

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?Social media was instrumental to our Amendment 2 campaign strategy,? Schrimpf said. ?Social has the power of spreading things in just a few clicks that other traditional media platforms just don?t have. I think it has also been a favored tool by activists for many years, so it benefited our communications goals and strategy from the beginning. One of our challenges was educating voters on the different medical marijuana questions. We knew that we needed some Missourians to be voting ?no?on Amendment 3 and Proposition C. Social media was the best way to differentiate the campaigns, answer questions and build our base support. In addition, many traditional forms of paid media that are usually good persuasion tools during a campaign were too expensive and so we relied solely on digital ads and expanding their reach through social platforms, which ultimately paid off.? The implementation of Amendment 2, now Article XIV, continues, Schrimpf and Tightline Strategies continues to be a voice for the policy and MoCannTrade. Though Schrimpf might be out of pocket for a little bit for the birth of her first child early this summer, there is no doubt that she?ll be back, leading the industry?s proactive messaging.

WOMEN MAKING WAVES

CEALLY SMITH

By Rachael Dunn

industry.?

Ceally Smith, owner and founder of The Original Hemppreneur and mother of 2, first became an advocate for CBD when her son?s life changed for the better while using it. She went from consumer and advocate to entrepreneur when she became frustrated with the lack of education surrounding the use of CBD.

Smith said after 3 months being treated with CBD, her son was unlocking previously unseen behaviors and coming out of his shell. Not only did his quality of life improve, but her entire family?s quality of life improved.

CBD is an organic compound found in cannabis flowers, often sold in hemp oil or in terpenes. CBD is one of hundreds of cannabinoids found in the cannabis plant. CBD was recommended from a friend that had symptoms similar to what her son was experiencing ranging from: behavior problems, nervousness, feeling overwhelmed, hyper activity, lack of focus, and beyond. Smith now hosts free seminars for the general public in seat and online about using CBD. At the seminars, she shares her ?son?s story and being a voice for parents that might consider using cannabis for themselves or with their children.? For her son, CBD drastically improved his mood and behavior, but also his digestion. Smith left a career in nutrition to pursue CBD. But Smith and her son?s journey to CBD was a bumpy one. ?Check labs and make sure you are really buying CBD, it?s the Wild West right now in the industry,? Smith said. ?Buyers need to beware. Unfortunately, my son and I learned the hard way when he first tried CBD he had an allergic reaction to a CBD product that was riddled with fillers and additives that are not necessary in a quality CBD product. After this event, I focused on educating on how to find quality products and clear education in the

By Kaycee Barry Cady Goble of Springfield, Missouri, is a farmer and project coordinator at the nonprofit Springfield Community Gardens, the owner of Queen City Micros, LLC, and the Director of Cultivation for The Wholesome Bud Company. Goble obtained her Masters in Plant Science from Missouri State University, and has worked in various sectors of the horticulture industry. Currently, Goble and her team at Springfield Community Gardens help disadvantaged and disenfranchised members of the community overcome barriers to growing their own food. Members include refugees, homeless veterans, and recovering addicts. With her shift to the cannabis industry, Goble is taking her passion and education of healing others through food, to healing others through cannabis. She is looking to lead The Wholesome Bud Company to become Missouri?s most trusted source for medical cannabis. Wh at is you r r ole at Th e Wh olesom e Bu d Com pan y? Goble: I am the Director of Cultivation for The Wholesome Bud Company. My role in the application process has been cultivation research, deciding upon growing methodology, and writing standard operating procedures. When we receive our licenses, I will manage cultivation operations and staff to ensure a consistent supply of high quality cannabis to patients in Springfield and the surrounding area. Wh at in spir ed you t o go in t o t h e gr ow in g f ield? Goble: My passion for horticulture and plant science began several years ago while I was working towards a degree in biology at Ozarks Technical Community College. I took a plant and soil science class, and found that horticulture really peaked my interest. From there, my passion grew and I went on to work in various sectors of the horticulture industry - from greens keeping and landscaping, to plant science research and education, and local food production. Along the way, I completed my Masters of Science in Plant Science at Missouri State University, and started my own small business, Queen City Micros LLC, where I grow

specialty microgreens for local chefs. I am also currently a farmer and project coordinator for Springfield Community Gardens. We are a local non-profit that uses grassroots efforts to create access to healthy, local food for our community. My introduction to the cannabis industry came when I ran into my friend Desmond Morris, CEO of The Wholesome Bud Company, at a bank several months ago. He told me that he was beginning to put together a team to apply for licenses to cultivate, manufacture, and dispense medical cannabis. He was looking for someone to head up cultivation, and he ended up inviting me to join the team a few weeks later. I was inspired to join the Wholesome team, because I am passionate about using my knowledge and skills in horticulture to help others in my community live happier, healthier lives. This is why I became a local food advocate and grower, in the first place. The medical cannabis industry is a new frontier in our state that is offering horticulturists, like myself, another way to continue our mission to positively impact the lives of people in our community by providing them with a safe alternative treatment for their medical conditions. It is providing me with an exciting new path for continuing to learn, and using my knowledge and skills to make a difference in peoples' lives.

Smith said bad CBD products have economic impact beyond immediate health. ?A study published in JAMA found that 30% of CBD products are mislabeled. Vape products were mislabeled most often,? Smith said. ?This mislabeling means consumers are often getting less CBD than they paid for or more THC than they bargained for- and that is a major risk. No one wants to take a product to improve their sleep only to fail a drug test that could impact work, insurance, or other commitments.?Smith stressed anyone considering CBD to Google ?the Endocannabinoid System,? saying ?our bodies are hard wired for it!? In a few weeks, Smith will go to Washington, D.C., to advocate for regulation in the CBD market. ?The industry is filled with bad guys coming into the industry just to make money, they don?t care about the quality or the standards of which the product is sourced or how it?s made,? Smith said. ?With people that look at this product as Hope, they shouldn?t have to worry about it impacting them more negatively. I?m going to D.C. to be a voice for the industry for consumers and for my son, in hopes that having clear guidelines in the industry will resolve the gaps!?

CADY GOBLE

How do you com par e w h at you ar e cu r r en t ly doin g at you r n on pr of it t o w h at you w ill be doin g in t h e can n abis in du st r y? Goble: At Springfield Community Gardens, I grow food in a responsible and sustainable manner, and I work hard to help empower others do the same. Currently, my focus in food production mostly centers around helping disadvantaged and disenfranchised members of our community (like refugees, homeless veterans, and recovering addicts) overcome barriers to growing their own food. I provide them with space, supplies, and technical support. As Director of Cultivation at The Wholesome Bud Company, I will be using a holistic approach to training my staff to grow high quality medicine for the community in a way that is environmentally responsible, just as I help train people to grow their own food now. Though medical cannabis is a unique field, the experience that I have in

production of specialty crops lends itself well to cannabis production. Just like I work tirelessly to grow healthy food for my community, I will strive to help The Wholesome Bud Company become Missouri's most trusted source for medical cannabis. Read more about Goble at mogreenway.com.

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By Rachael Dunn From volunteering at an AIDS non-profit in the 90s to helping clients at Sullivan Law, Bianca Sullivan of Fresh Green is a woman with a passion for medical cannabis that only matches her education and experience. ?I am very excited about being able to be a part of the birth of this industry in our state and be involved with a new venture that brings all of my experience and passions together on a new and exciting path. Helping others, science, business, law, all of these experiences and passions will serve me well and set me up Fresh Green for success in an industry where I can continue to truly help veterans and other people in need. ?For a number of years now I have actually been preparing to enter the industry, feeling that legalization was inevitable in Missouri and knowing that when it did happen, I wanted to be ready. I think that the background that I have in business, science and compliance is well-suited to success in the Missouri market. ?Helping people is what I like to do most and always have. I?ve had experience running commercial real estate businesses, and for the last 10 years have not only been an attorney, but the manager of a successful law firm with my husband. Along with my background in biology and love of science, I think my business experience and legal experience has set me up for success in this industry.

medicinal marijuana did for those people I knew who were suffering from this terrible disease, really convinced me of the incredible medicinal properties of cannabis. Even though I may not have directly known then, I really think it was that moment and those experiences that set me on the path to where I am now.?

dispensary to fulfill the mission of bettering the lives of those patients that will benefit from cannabis, but may not be able to afford it.,? Sullivan said.

After California, she went to business school at Loyola Marymount before returning home to Kansas City, attending the University of Missouri ? Kansas City. However, the potential of cannabis did not end for Sullivan in California.

?Of course the company will have to profit to survive, but a dedicated percentage of that profit will always be earmarked for discounts available to veterans and low income patients in need,? Sullivan said. ?Having supported the Challenged Athletes Foundation while competing in triathlons over the years, I have had an up close look at some of the challenges that our veterans are facing these days. However, I do not want Fresh Green to stop there. The company will also be dedicated to reducing, and hopefully one day removing, the stigma associated with cannabis use.?

?Later in life when I became a mother, I faced the challenge of a child with a different auto-immune disease. I also suffer from a health condition myself that I do believe medicinal cannabis may well help someday. These things really brought the whole subject matter home to me in personal way. ?That path gave me extensive experience in the restaurant and food service industry, compliance with FDA and local health and safety regulations, commercial real estate, and other business management skills that have served me well and I think provide a good base for the newest path that I have chosen in the cannabis industry. ?While helping the family business when it was in need was gratifying, it did not completely satisfy my natural desire to help others really in need. I think that is what ultimately led me to law school. Early on in my legal career I found ways to help others. I got great satisfaction from working with the Midwest Innocence Project, an organization with a mission to educate about, advocate for, and obtain and support the exoneration and release of wrongfully convicted people in the Midwest.?

BIANCA SULLIVAN

Beyond personally supporting causes, Sullivan and her husband opened a law firm and are able to regularly take on pro bono cases.

Sullivan?s story with cannabis started in Southern California, where she lived for six years. ?My original goal was to carry-on with my education in medical school, but as is often the case, life things happen and you take a different path,? Sullivan said. ?I first became interested in the cannabis industry when I was an undergrad at UCLA when California was in the early stages of medical legalization. Some of my earliest exposure to the medicinal properties of cannabis came while volunteering at an AIDS non-profit group in Los Angeles. We helped educate patients and the community on Proposition 215, the Compassionate Use Act of 1996, which was the first state to legalize medical cannabis. With a majority of the states now having legalized marijuana in one form or another I?m proud to say I was a part of its inception.? Her time in California not only put her in the middle of the beginnings of legalization, but in the middle of the AIDS crisis. ?This was right in the midst of the AIDS crisis and I had several friends and acquaintances at the time unfortunately suffering from the disease,? Sullivan said. ?Seeing what

?From there, even after opening the law firm with my husband, I continued to get the most satisfaction from helping others in need. At Sullivan Law we have done that for nearly 10 years now and we have always represented individuals that face long odds and uphill battles get well, or at least be made as whole as possible after their injuries. Along the way, I was fortunate to be involved in pro bono cases where I was able to help people and families that could not afford to help themselves and would certainly have been crushed under the power of legal authorities or government agencies without lawyers willing to fight for them without being paid.? Sullivan is taking all of her experience and education, from her undergrad in Biology to food service and legal, to her dispensary. ?Obviously, there is a lot to learn and it?s a new industry in Missouri, but I feel that I am well-positioned to learn that with the background that I?ve had in business and law. Particularly in the landscape of legalization in Missouri, a legal background, leaving aside actual experience in the cannabis industry in another legal state, is perhaps the most valuable experience that one can have as the industry begins and grows in Missouri.? ?Above all else, I want Fresh Green as a company and as a

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But Sullivan is not just paying lip service to helping those get the medicine they need.

Sullivan has been hands-on with monitoring the rule making process, attending the advisory committee hearings in person. ?I?m here to make a difference and learn everything I can to ensure the success of my new company. I just felt strongly that I should be at these hearings in person to absorb any information I could about this emerging industry in Missouri.? ?When Missouri began seriously considering legalizing cannabis for medical purposes, I was immediately interested in being involved. I saw another way to help some of my clients and others that would benefit from legalization. ?The legal industry is a constant evolving and developing industry, so that is nothing new to me. That being said, with that set up for success in Missouri?s regulatory scheme, also comes some level of complexity in the number of rules and the requirements of the rules that Missouri is imposing on businesses in this industry. As a lawyer, I have been dealing with rules, regulations and compliance with rules, and specifically precise compliance with rules my entire career. While the cannabis industry may be a new topic for me, its rules and regulations, while clearly addressing a new subject matter, are no different than rules and regulations that my husband and I have had to research, read, interpret, and comply with for our entire legal careers. As lawyers, complying with rules is basically what we do everyday.? From the first to one of the most recent states for legalization, Sullivan is encouraged by the state?s approach to rulemaking. ?I think that Missouri has chosen the smart path to legalization and learned from a lot of the mistakes that were made by many of the 32 states that came before it. The state has set up a system of regulations and an application process that will set up those who do obtain licenses for success, avoid many of the problems that other states have encountered, and avoid many of the hard lessons those states had to learn along the way.? In addition to providing access to medicine, Sullivan hopes to also reduce the stigma related to cannabis. ?Another thing I feel very passionate about is reducing, and with any luck, removing the stigma surrounding the use of cannabis in general, but more specifically the medicinal use of cannabis. So many people are afraid to speak with their family, friends, even their physicians about cannabis and whether or not it is a viable option for their ailments. My hope is Missouri becomes an example for the elimination of that symbol so that everyone that can benefit from this extraordinary plant can do so without the stigma that is so often associated with cannabis.?

By Brandon Dunn

them.?

Bethanie White is the brains behind one of the sleekest branding machines in Missouri cannabis. She is the Director of Marketing at Clovr Cannabis.

In a market where many companies hold their cards close and have resigned to wait for licensure to put their brand?s face forward, Bethanie and Clovr have chosen to be active around the state and on social media.

White is a midwest native, growing up in Independence, Kan., and obtaining her associate?s from Independence Community College, before earning her BA from the University of Kansas, and making her home in Kansas City. ?I?ve worked with this group for eight years and throughout its involvement in medical marijuana beginning in 2014. I, with a talented team, did the marketing for seven dispensaries. Once the possibility of Missouri legalizing cannabis arose we were all hands on deck here and the company gave me the opportunity to continue doing the marketing for Clovr.?

BETHANIE WHITE

Clovr aims to bring experience, brand partnerships, and options to the medical market in Missouri. ?We have seen, from building design and cultivation and extraction methods, to dispensary user-experience what works and what doesn?t and we?re excited to be able to bring that knowledge home to Missouri, under the Clovr brand,? White says. ?We?ve seen that people like to medicate differently, and in some ways we haven?t even thought of yet. Offering Missouri patients as many different dosing and delivery methods as fits their lifestyle is important to us,? White explains, ?We have signed letters of intent with some of our favorite partners including Pax, Incredibles, Wana Brands and Keef Brands to distribute exclusively on their behalf in Missouri. The product mix of these companies brings proven delivery methods with consistent dosing to patients whether they are looking for an edible, a beverage, a tincture to add to their current meal plan, a capsule, and even a suppository.? ?Clovr is a group of people who have been in the cannabis industry and have seen the difference cannabis has made in people?s lives.? White, like many others in the industry, owes some of her passion to personal experience. ?My mom had cancer and was taking morphine for the pain the last few months of her life. The pain went away but it also put her to sleep for hours. If she was awake it meant she was in pain. I wish I would have had the ability to give her cannabis for the pain. I would have gained a lot more valuable time with her those last few months if I had access to cannabis.? White says that, ?Cannabis is the American underdog that I am proud to be part of. Having the opportunity to change opposing opinions every day through marketing mediums, testimonials, and face-to-face conversation is a dream job. Helping people get access to safe and legal medication that allows them to just live a normal life to be with their family, play with their kids and go to work ? why would you want anything less for anyone??

?You must go where your customers are and they are on social media. It is one of the only mediums to get a direct and immediate response from your patients and customers. I love the raw, informal platform that social provides where you can truly show your brand personality and the team that makes it what it is. No other medium gives the customer an inside look at a company like social media does.?

When asked about her duties as Director of Marketing, White credits her team for her ability to be hands on.

White said ?it is absolutely necessary to connect with your customers and deliver valuable content. The best advice I ever received was to ?Never put all your eggs in a basket you don?t own.?Some social platforms make it difficult to be present so use them as a place to connect with your customers and disperse your content, but have your website be the main hub of your marketing plan.?

?Any place our brand is present you?ll find me in some form. I help with the design of the dispensaries, traditional media ads, the website, and packaging to posting and answering DMs on social media. If there is a Clovr logo, you?ll find me somewhere behind it. We have a super-talented team that allows me to be everywhere and I couldn?t do it without

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What is t he dif fer ence bet ween Hemp and Mar ijuana? Hemp and Marijuana, it?s the same thing, right? Well, contrary to what many people believe, what?s often portrayed in the media and even how some of our laws over the years have defined marijuana and hemp, would make many people believe they are the same thing. While both hemp and marijuana come from the species of cannabaceae, they contain different genetic makeups and have different uses and growing strategies. One simple way to explain the hemp and marijuana differentiation might be to compare it to another crop, such as tomatoes. You have an heirloom tomato, grape tomato and cherry tomato, among others. They are all the same species but they all have very different shapes, sizes, and tastes as well as even differing uses. Here are some of the key aspects we?ll take a look at to understand the high level differences between hemp and marijuana. 1. 2. 3. 4.

THC levels Industrial uses How they are grown Legality

THC Levels So, what is the most striking difference between hemp and marijuana? Well, before we get into the physical and wide variety of uses that differ between the two, let?s address what might be the most key distinction between hemp and marijuana, which is quite frankly a legal definition. Hemp by legal definition has less than 0.3% THC, while marijuana has more than 0.3% THC and may have up to approximately 30% THC. So while they may even look identical as they both come from the cannabis family, the difference that classifies them as either hemp or marijuana is the amount of THC in them. THC is the psycho-active cannabinoid found in them, the 0.3% level is measured at the dry weight of THC. While, marijuana is obviously known for its psycho-active influences, it has many medicinal possibilities and uses, but the first association most people have with marijuana is the high it gives off. Unfortunately, many people have a misconception about hemp and believe hemp has the same ?high? effect as marijuana, but hemp does not. With hemp having 0.3% or less THC it will have no psycho-active influence. In du st r ial Uses Hemp and marijuana are grown and cultivated for different reasons. Again, marijuana is grown primarily for its recreational and medicinal

benefits, which is primarily the only reason that various species of marijuana, two main ones being Sativa or Indica, are grown. Hemp, as mentioned, is grown more for its industrial uses. It has many potential uses, each of the key parts of the plant, including the roots, seeds and leaves have purposeful and helpful uses. Some of these uses include: -

Fibers for clothing Paper Foods & Supplements Industrial Uses (such as rope, or nets) Bath & Body products

It is said that there are 20,000 known uses of hemp. Some have even claimed as high as 50,000 uses have been identified. Don't know if we will ever know for sure exactly how many uses or products can come from hemp but it is a lot! How Th ey Ar e Gr ow n Which leads us into another key difference, that is how hemp and marijuana are grown. Having different uses in mind for each, means each can be grown specifically for those uses. Marijuana, tends to be grown more frequently indoors, in controlled environments, where all the variables such as temperature, sunlight, oxygen and Co2, soil nutrients and water can all be more micro managed to produce specific preferences for potency and taste. There are many factors typically associated with growing marijuana, such as isolating the male and female plants from each other so that the female may produce ?sensimilla, which are seedless flowers (provides higher quality), that can go into growing customized or specific strains of marijuana where a specific flavor or potency is trying to be achieved for recreational or medicinal purposes. Hemp on the other hand, is more often grown to be used in industrial or commercial products for its strength and durability. So it may be grown to maximize the size of the plants so to produce more materials. This is why you may see some hemp plants that are easily over 7-8 feet tall. Hemp is usually grown outdoors, where the fibers of the stalks and leaves are grown more to be used in products and therefore do not typically need the micro-managed, customized growing controls that are put on growing marijuana. Hemp is used industrially for its strength, but its also much more efficient than other plants or trees for many of the same purposes. For instance, hemp can be grown closer together than trees (meaning more can be grown on the same amount of land) and can be grown at a much quicker rate than trees. With being able to grow hemp in the same fields for multiple seasons without needing rotation, it

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By Leigh Zar da Car r Har i Om Hemp

makes for a much more efficient and cost effective alternative for paper than trees. As CBD derived from hemp became legal at the federal level with the passage of the 2018 Farm Bill, more hemp is beginning to be grown in a similarly controlled fashion as marijuana to produce specific strengths or strains of hemp that produce customized or desired characteristics of CBD and other cannabinoids. With more hemp being customized, if you see shorter hemp plants, especially grown indoors or in greenhouses in more controlled environments, these are producing higher quality CBD or other specific cannabinoids. It?s not just CBD that hemp is grown for that can be consumed. All cannabis comes from the earth and contains many nutrients that can be good for people to eat or consume through digestive system. Hemp can be used for many food products such as hemp protein or hemp seed oil and other hemp supplements, meaning nearly all parts of the hemp cannabis plant can be used for something purposeful. There?s also been a big uptick in hemp products for skin or muscle issues as well, as more people are turning to it hemp for the benefits it can provide being absorbed topically. CBD an d Legalit y As mentioned, THC is the essentially the legal difference between hemp and marijuana at the Federal level. While each state, many of which have already legalized marijuana in some for (recreational or medical), can set their own rules, on the Federal level the legal limit by dry weight for THC is 0.3%, so any hemp that is over that level would be classified as marijuana. Even at times the 0.3% THC limit can be a bit gray legally, as THCA may be below the limit in things such as hemp flower, but once heated and consumed it maybe over the 0.3% level even though it is still hemp and still at levels likely not enough to be psycho-active. Each species contains and can have CBD extracted from it, however, under the 2018 Farm Bill it must come US grown industrial hemp, so any CBD from marijuana federally would be illegal. In the first section we talked about how marijuana has much higher levels of THC, while both hemp and marijuana contain it, the opposite is somewhat true with CBD where hemp tends to have higher levels of CBD than marijuana, making more ideal for extracting CBD oil. Hopefully, this provides a high level idea of the key difference in hemp and marijuana. With CBD going mainstream, the process of educating has certainly picked up steam as more and more people are learning of its important health benefits and shedding the stigma that has been placed on it through the past few decades.

A Pat ient 's Guide t o...

Visit ing a cannabis clinic We ask Drs. Hari Khalsa and Radhika Ratnabalasuriar of Canna Therapy MD what a patient should expect when visiting a clinic specializing in cannabis medicine.

interactions with other medications, etc., to ensure that cannabis therapy is actually a medically sound treatment for each individual.

What should a potential patient know before walking in the door?

If you are approved for medical cannabis, you will leave your appointment with a physician certification letter. You will need to submit this physician letter to the state as part of your application.

Patients should understand that they must be a resident of Missouri and are required to provide identification issued by the State of Missouri. Patients should also have reviewed the State?s list of qualifying medical conditions (?Qualifying Conditions?), which may be found on the Missouri Department of Health and Senior Services website. All recommendations a physician makes for patient use of medical cannabis relate to helping the patient best utilize cannabis to treat the symptoms and side effects of their qualifying conditions. These decisions have the patient?s overall health in mind, as well as specific goals for their qualifying condition. In this and other ways, the physicianguided use of medical cannabis is different from recreational use, which remains illegal under Missouri and federal law. What should a patient bring with them for an appointment? Patients should bring a copy of their medical records. This helps our physicians establish a firm diagnosis of a qualifying medical condition that would benefit from medical cannabis. It also helps us anticipate side effects and drug interactions with current medications, and guide our recommendations for cannabis therapy. Patients should also bring their Missouri State ID. The ID must have their picture and a Missouri address. This could be a Missouri-issued driver ?s license, or non-driver ID card. What do you look for to write (or not write) a recommendation? We want to see if you have a qualifying medical condition, as determined by Missouri law. It is also important for us to know which treatments you have already tried, if those treatments are working, and how long you have been affected by your medical condition(s). Some medical conditions are counter-indicated for cannabis therapy, meaning that for specific reasons, cannabis might not actually be a good fit for that patient. We screen for these conditions, for

After an initial appointment, what are the next steps?

The state application for your medical cannabis card will likely be online. The most recent information available at press time indicates this will cost approximately $25. This does not include the fees associated with your evaluation appointment. The state then has 30 days to decide if you have been approved for a medical cannabis card. The final wording of rules promulgated by the Missouri Department of Health and Senior Services will not be finalized until after the deadline for this article. There are roughly five months between applications being accepted and the first dispensary opening. What do you advise patients do in that time? We recommend that patients continue the treatment plans that have been established by their doctors. We do not recommend initiating treatment with hemp-based CBD unless you have had proper education and guidance from a physician with experience in cannabis medicine. What do you look for in a good candidate for medical marijuana? We look for patients who suffer from a state qualifying medical condition who are not finding success in their current treatment plans, or whose current treatment plans are not ideal for the timeframe of their recovery. We also believe that patients who experience chronic pain and would like to stop using opiates could be good candidates.

Once a patient can go to a dispensary, how do you advise patients proceed? During your appointment, our cannabis medicine ?trained physicians will cover dosing, specific cannabis strains, ratios, and ingestion methods that they feel may work best for your medical condition. This information is very important to empowering patients to purchase precisely what they need from a dispensary. Take those specific recommendations to the dispensary, and their staff will help you select an available strain that meets your specific needs. They will also be able to help you select any equipment necessary for your physician-recommended means of ingesting medical cannabis. No prior knowledge about using cannabis is required for a successful first visit to the dispensary? just your state-issued medical cannabis card, state-issued ID card, and your physicians?recommendations so you can confidently tell the staff what you need. What should patients look for when they are able to go to a dispensary? They should look for a state-licensed dispensary that sends their products to a third-party lab for testing. This is standard in many other states where medical marijuana has already been legalized. Many such dispensaries make lab reports available by request. These tests show the THC concentration, CBD concentration, the results of tests for contaminants, and other useful information. While these tests aren?t always available, and the details might not mean much to you, they are nonetheless a reassuring sign of a dispensary?s commitment to providing the highest quality medical cannabis. Do you accept insurance? Why or why not? We cannot accept medical insurance at this time because medical marijuana is still federally illegal. Most medical cannabis evaluation clinics take cash, checks, or credit cards. It is best to confirm which forms of payment they accept before visiting a specific clinic.

Our patient population is diverse and we have people who are pursuing medical cannabis treatment for a variety of reasons. We do not approve medical marijuana for pregnant patients and we review patients under 18 on a case-by-case basis since these are high-risk populations.

The content herein is provided for informational purposes only. If you would like to discuss the particulars of your unique medical symptomology and condition, please consult with a trained medicinal cannabis physician.

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in number s:

r ulemak ing 1

Ounce amount of dried, unprocessed

The number each of flowering plants,

marijuana equivalent to 8 grams of

non-flowering plants, and clones under 14?

medical marijuana concentrate or 800

a patient may cultivate individually.

milligrams of THC in infused products

7 Points a response offers on a medical

The minimum number of testing facilities

marijuana facility application that indicates

to be licensed by the State. The State has

some benefits beyond the minimum

said it may license up to 10 testing

expectations; no material weaknesses

facilities.

exist; confidence in the proposed approach or ability to fulfill claims.

Maximum number of patients a caregiver may cultivate for.

Congressional districts where 24 dispensary applications will be accepted,

4 The 30-day purchase limit of dried,

each.

7/4 July 4, 2019 is the constitutional day patients can apply for a patient care card from the state. The State will begin accepting applications on June 28. Applications are submitted to the State via an online form.

12 Number of months a patient care card is valid. Cards must be renewed monthly. All patients must apply and have a card to use medical marijuana.

30 Number of days the State has to approve or deny an application for a patient care card. In the event the state does not approve or deny an application in that time, a physician?s referral serves as the card.

unprocessed marijuana per patient, in ounces.

Number of qualifying conditions specified in Article XIV for physician referral.

Years to have passed since an employee or company leader was released from parole

Number of advisory committees DHSS

or probation, and he or she has not been

originally hosted to compile and review

convicted of any subsequent criminal

application questions.

offenses, before they can work in a facility.

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$25 How much a patient care card costs.

20 20 The very earliest a dispensary could open. Patients can realistically expect dispensaries to begin to open in the late spring of 2020.

Wor k ing for Special Needs Families We help special needs families afford their children's medical cannabis expenses.

Ayden's Alliance is a patient advocacy organization that exists to help Missouri residents afford access to medical cannabis. Whether it is application, physician or treatment expenses, our mission is to provide free or low-cost solutions. As an organization that consists of special needs parents, grandparents and therapists, we know what it's like to fight for your loved ones so that they may have the best quality of life possible.

www.AydensAlliance.org

Ayden?s Alliance is a 501(c)3 charity, donations and sponsorships are tax deductible

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