Substance abuse prevention groups raised various concerns on medical marijuana dispensation, ranging from possible black market activities, dispensary regulation, to edible marijuana-infused products. In the public hearing on April 22, they shared their views on the marijuana draft regulations.

Dave Morgan, chairperson of the Weymouth Youth Coalition Substance Abuse Prevention Team, said that the maximum limit of 10 ounces for a 60-day supply is extraordinarily high, and it could lead to diversions. “Based on a study, heavy users, who met criteria for marijuana dependence, used an average of 2 ounces per month.  The 10-ounce limit will tempt many people to request a 10-ounce recommendation, use up to 4 ounces per 60 days and divert the rest,” he said.

Morgan also proposed that all marijuana dispensaries should report their sales to the health officials like any other pharmacy. “Medical marijuana treatment centers must submit sales to the state Prescription Monitoring Program, as well as using the physician look-up as pharmacies are currently required to do,” he said.

His suggestion was supported by MaryanneFrangules, executive director of Massachusetts Organization for Addiction Recovery. She said that the system will help physicians identify warning signs of addiction and prevent “doctor shopping” for excessive quantities of prescription drugs.

Another group, Massachusetts Prevention Alliance, advised the DPH to define marijuana-infused product as both a food and a drug, therefore subject to the state’s food and drug safety laws. One of its members, Jody Hensley from Westboro, Mass., argued that the draft regulation runs counter to the public health and well-being of the citizens.

“By excluding these products from being defined as a food or drug, DPH is blatantly circumventing food and drug safety regulations. This exception must be deleted from this definition in this regulation.  Why avoid safety standards?” Hensley said.

She noted that the DPH’s definition will exempt the products, like cookies, chocolate and juice, from the state’s food safety guidelines. “These products should be under supervision of the Massachusetts Food Protection Program, within Bureau of Environmental Health in the Department of Public Health,” she said.

Her view on the food products was also highlighted by Morgan, who said, “This is compounding and it needs to be regulated by FDA and Board of Pharmacy.”

The DPH’s proposed regulation allows any dispensary to have one growing house outside of its distribution store. On this matter, the Massachusetts Prevention Alliance said there should be a notification to the community where a marijuana cultivation will be located. “Communities should be notified. The risk of diversion is too high to leave local officials unaware of potential marijuana sources in the neighborhoods,”Heidi Heilman, president of the Massachusetts Prevention Alliance, said.

Commenting on the draft in general, these organizations shared the same opinion that the state’s oversight obligations are weak because inspections on dispensaries are optional rather than mandatory, and are not regularly scheduled.Heidi Heilmann referred to the recent case in Maine where marijuana growing facilities violated regulations including use of pesticides.  She said the DPH must include a requirement for inspection and testing for contaminants.  “Medical marijuana treatment center licensing fees should be high enough to pay for the staffing required to do this properly,” she said.