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MEDICAL MARIJUANA GROWERS FACE NEW TRACKING LAWS

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Here is a summary from the OLCC's recent notification discussing the new law for medical marijuana growers. Oregon Senate Bill 1544 now requires medical marijuana growers to use the same tracking system that the recreational growers have been using. The Bill requires that all OMMP medical marijuana growing sites with three or more patients must use the Cannabis Tracking System ("CTS") on or before July 1, 2018. The Bill exempts medical marijuana grow sites limited to two or fewer growers and two or fewer patients. If you are one of the 2000 OMMP registered grow sites the OHA has identified as falling under this new SB 1544, the process to use the CTS begins with designating one grower at the grow site address as the grow site administrator ("GSA"). OHA will be conducting a series of outreach sessions around Oregon to help OMMP registrants understand the new tracking and reporting laws and also begin learning about CTS. The OHA and OLCC will launch a second series of meetings to provide registered medical growers, processors, and dispensaries information on the requirements for using CTS. Oregon's CTS provider, METRC, will also be providing training workshops. GSAs will be allowed to sell up to 20 pounds of marijuana into the OLCC regulated recreational marijuana system in a 12-month period. The GSAs must provide proof of legal access to water before the marijuana can be sold into the OLCC market. This sell-in option applies to a grow site as a whole, so a grow site with four growers would only be allowed to sell a total of 20 pounds into the recreational market, not 80 pounds. The OLCC will begin auditing OMMP grow sites, processors, and dispensaries subject to tracking in CTS in July 2018. Later in 2018 OLCC inspectors will begin visiting OMMP grow sites required to use CTS to verify CTS tracking information, check to make sure CTS is being used properly, and look for any other violations. However, because OHA regulates the OMMP program, OHA will determine any enforcement based on investigations conducted by OLCC.