An open letter about Cannabis education

When Washington state lawmakers decided without a public vote to collapse the current voter approved Medical Marijuana program (I-692) into the existing voter approved recreational system (I-502) it created a unique need. Currently, recreational outlets are not allowed to even mention the word "medicine". They are legally barred from discussing medical benefits or even hinting that certain products are better for some conditions compared to others. Beginning July 1, 2016, they will be the only legal outlet for MMJ patients to purchase their medicine.

To serve the special needs of these customers, recreational outlets must receive a "Medical endorsement" from the WA LCB, but they also need to have a certified staff member to work directly with MMJ patients. These special employees will need to be trained before they are certified. Seniors MMJ Network offers a Cannabis education program and was eager to become involved. After three months of working together with the WA DOH, our involvement has hit a roadblock with the newly released proposals. Below is an excerpt of a letter we have been circulating as well as being sent directly to the lawmakers in Olympia.

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I pose this letter to you in an effort to grow the conversation and to bring attention to various problems with the proposed training program for Medical Marijuana Consultants in the WA I-502 system. My apprehension of the proposed program is two-fold. First, there is the proposed curriculum and its main focus. Second, would be the proposed limitations on who would be eligible to perform the role of instructor.

As the head of Seniors MMJ Network, I have taken an active roll in promoting Cannabis education for many years. Immediately when the stakeholder process for the WA Medical Marijuana Consultant program began, I became involved. Patient education, safety and legal rights are amongst our top concerns.

Representing Seniors MMJ Network, I have testified at public meetings, submitted written feedback and provided detailed proposals at the special request of the WA Dept. of Health. As I understand it, the Medical Marijuana Consultant Certificate program will be designed to train employees in the I-502 system to assist and educate qualifying customers. The goal is to provide education and promote safety.

On Dec. 23rd, WA LCB released a public notice for the proposed program, including required curriculum. Upon reviewing the proposal, there is an obvious disconnect between law makers and experienced Cannabis educators concerning what information would best serve the end-user. Absent from the required 20 hours of curriculum are the specific topics of plant science, whole plant medicine, product labels (understanding cannabinoid / terpene profiles) and customer service.

A curriculum focused on Cannabis education and the safety of consumers would not dedicate 25% of the required program to legal aspects. Prospective certificate holders MUST undergo a minimum of five hours of training focused on Washington state laws relating to Marijuana *WAC 246-72-110 (1.A.i). Certificate holders will use this knowledge to inform qualifying I-502 customers of the legal do's and don'ts. This training also assures that Certificate holders are performing their duties within the legal guidelines. Having created similar training, the amount of time dedicated to this topic is extremely excessive and can better be allocated to other subjects.

Another area of disconnect is the required two hours of curriculum for the safe handling of MMJ products and reducing access to minors. While an excellent topic and an essential component of any good program, two hours is excessive. Redistributing a portion of the allotted time can provide a more comprehensive learning experience.

I have attached my full list of concerns in PDF form, which I have also sent to WA LCB for the open comment period on the Medical Marijuana Consultant Program. The only public hearing will be January 26th in Tukwila.

The second area of concern is the proposed limitations on who would be eligible to perform the role of instructor. Along with demonstrated knowledge and experience related to Cannabis, instructors also must hold at least one of the following :

• An active license to practice as a health care professional as defined by RCW 69.51A.010 (2);

• An active license to practice law in Washington state;

• Bachelors degree or higher in agriculture, botany or horticulture.

Lawyers and botanists are not doctors, what makes them able to provide Cannabis curriculum that any other non-doctor couldn't? Similarly, doctors and lawyers are not botanists, what makes them able to provide Cannabis curriculum that any other non-botanist couldn't? As defined in WAC 246-72-030 (4 a-b) Medical Marijuana consultants are not to undertake the task of diagnosis or modify any medication regimen other than MMJ. The language is clear, Medical Marijuana consultants are not to act as doctors, which makes the additional requirements for instructors a bit absurd.

By imposing this additional qualification for instructors, WA LCB is preventing many talented and experienced Cannabis educators from participating in the process. Specifically the people who have had patient welfare and education as a top priority for many years under the I-692 WA MMJ program. Why disqualify educators with years of first-hand experience and research into the world of Cannabis?

Washington has made many mistakes on the road to legalization and now the safety and health of medical patients is further at risk. Do not let qualified instructors with years of first-hand experience be usurped by lawmakers pushing curriculum focused on covering their legal rear-ends. Patients first! To best serve the consumers that this program is being designed for, WA must include educators from the Cannabis community, not just the people who simply, are qualified and see a business opportunity.

The curriculum needs to be redefined and the requirements for qualified instructors needs to be adjusted.

My goal would be to continue this conversation and to bring these topics into a more public light. I don't think the citizens of this state would really be happy with another subpar attempt by the WA LCB to get it right. Change can happen! Thank you for your time in reading this.

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If you would like to know more about making a change, drop us an email at seniorsMMJnetwork@gmail.com

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