(Written by Ted Smith, the founder of Victoria Cannabis Buyer’s Club)
Tomorrow is the public’s last opportunity to send comments to Health Canada regarding regulations controlling the production and sale of edible and topical cannabis products, as well as other concentrates!
This is a common tactic of Health Canada; They give interested taxpayers two months to submit answers to a handful of questions, appearing open to ideas when the most critical decisions have clearly already been made.
In typical fashion they announced these proposed regulations days before Christmas.
On one hand, it seems futile to respond to a government that will listen to fear-mongering public health officials and corporate lobbyists over long-established compassion clubs.
However, it is important for us to have our opposition to these limitations on record so everyone can understand what the problems with these infant rules might be.
Please send your response to one or all of these questions before the deadline is up tomorrow.
1- What do you think about the proposed THC limits for the new classes of cannabis products?
2-Do you think the proposed new rules addressing the types of ingredients and additives that could be used in edible cannabis, cannabis extracts, and cannabis topicals appropriately address public health and safety risks while enabling sufficient product diversity?
3-Do you think that the proposed rules for other classes of cannabis will accommodate a variety of oil-based products for various intended uses, even though cannabis oil would no longer be a distinct class of cannabis?
4-What do you think about the proposed six-month transition period for cannabis oil? Is a six-month transition period sufficient?
5-What do you think about the proposed new rules for the packaging and labelling of the new classes of cannabis products?
6-With respect to edible cannabis, what do you think about the requirement for all products to be labelled with a cannabis-specific nutrition facts table?
7-What do you think about the proposal that the standardized cannabis symbol would be required on vaping devices, vaping cartridges, and wrappers?
8-Do you think that the proposed new good production practices, such as the requirement to have a Preventive Control Plan, appropriately address the risks associated with the production of cannabis, including the risk of product contamination and cross-contamination?
9-What do you think about the requirement that the production of edible cannabis could not occur in a building where conventional food is produced?
10-What do you think about the overall regulatory proposal?
11-Are there any additional comments you would like to share on the proposed regulations for the new classes of cannabis?
12-Are there any additional comments you would like to share regarding the legalization and strict regulation of cannabis in Canada? For example, are there measures the Government could take to support individuals to be in compliance with the public possession limits for cannabis (i.e. 30 grams of dried cannabis “or equivalent”)? Do you have views on how to minimize environmental concerns associated with packaging, while maintaining key aspects, such as child resistant packaging, that help to prevent accidental consumption?