Arkansans recent passage of the Arkansas Medical Marijuana Amendment of 2016 set in motion fast-paced efforts to promulgate rules for cultivation, processing and dispensing of marijuana for medicinal related consumption.
The Arkansas Medical Marijuana Commission (“AMMC”) must develop both facility structural and operational standards for marijuana cultivating, processing and dispensing activities.
Facility security, financial capability, quality control, product consistency, packaging, transportation, labeling and related issues have been to date the primary focus of the AMMC in its development of the medical marijuana program.
The AMMC and the two Arkansas agencies with jurisdictional oversight (Alcohol Beverage Control Administration and Arkansas Department of Health) will likely continue to concentrate on these areas of interest in the development and/or the eventual enforcement of the Arkansas Medical Marijuana program regulations.
Nevertheless, a number of other operational aspects of medical marijuana facilities will need to be considered by both facility owners and the regulatory agencies. For example, cultivation/processing facility owners would be well advised to take into account the significant amounts of energy such operations can consume. The potential energy issues associated with marijuana cultivation were analyzed in a recent article posted on this blog titled:
Arkansas Marijuana Legalization: Are there Energy Implications?
An equally important aspect of these operations that should be considered are the potential environmental and safety issues and regulatory requirements. This is arguably particularly true in the case of marijuana cultivation, grow and processing operations. The potential environmental effects of marijuana production are typical of similar horticultural or agricultural facilities. However, these are clearly material issues for cultivation/grow facilities that will require investment in terms of both thought and expense. Note that these issues may not be as important for dispensaries since the product is more likely to be already packaged or handled in ways that minimize the potential for releases to air or water.
In summary, while environmental and safety considerations are not necessarily a predominant consideration in the development of medical marijuana cultivation processing infrastructure, they are still worthy of attention and policy design.
The attached 9-page outline addresses in some detail:
- Environmental/safety issues potentially associated with cultivation/processing operations;
- Examples of environmental/safety regulatory requirements applied to cultivation/processing facilities by certain federal/state/local governments
- Examples of Arkansas environmental/safety authorities/regulatory requirements potentially applicable to Arkansas cultivation/processing facilities