The passage of Florida’s SB 1030 (Compassionate Medical Cannabis Act of 2014) calls for the opening of five dispensaries for medical marijuana, located throughout the state. A passage of a ballot initiative in November, calling for increased usage of medical cannabis, could increase the number of needed dispensaries nearly tenfold. One of the chief concerns, expressed by Rep. Debbie Wasserman Schultz in an article to the Tampa Bay Times is the potential for “lax oversight” from state officials leading to “abuse, fraud, and accidents.” Within her article, she cited Florida’s “pill mill” reputation as an example of how the fraud may come about.
Seed-to-Sale Monitoring for Florida’s New Medical Cannabis Industry
The concerns may appear justified at first blush, but one company in Florida has created a unique tracking system to protect against fraud, which came out of the state’s need to crack down on “pill mills,” and which now sets the industry standard for medical marijuana oversight.
BIOTRACKTHC – From Pills to Pot
A little more than five years ago, Bio-Tech Medical Software, Inc. had been working within the medical community, utilizing patented methods for tracking prescription sales to protect against consumer fraud. A chance interview with a company located in a state with legalized medical marijuana laws led to something larger.
“The company asked if we had anything for seed-to-sale tracking of marijuana,” says BioTrackTHC Chief Operating Officer Patrick Vo. “We told them we could, and designed a system to track every part of the plant from seed to sale.” The benefit of the tracking system is not only tighter oversight for the dispensaries, but also increased efficiency in processing.
Tracking and How it Works
“When you propagate a new plant, it gets a globally unique, non-repeating, sixteen-digit id number,” explains Vo. “No matter where the plant moves every part of it is recorded. At the point of harvest, and every stage thereafter, if one item needs to be separately identified from another it gets a ‘child’ identifier. For example, you have the stem and leaves for extracts, the flower, and the waste which cannot have any use. Each of those three components gets another 16 digit number that is labeled as a ‘child’ identifier. Following the processing of each part, the end result is then identified the same way. This way, every part of the plant can be tracked back to the original plant, and tracked forward wherever each component goes. Each gram is tracked, start to finish.”
Another benefit of the tracking is one which directly affects the business owner’s bottom line. The tracking allows the grower and/or distributor to analyze the data and determine profitability and also to project future yields. The advanced technology, down to the methods of weighing, as well as the redundancy systems have already maximized the profitability for many medical marijuana business owners, by guaranteeing use of each plant down to the microgram.
The company also accounts for the possibilities of human error.
“Where possible, we automate the process to reduce the potential of human error,” explains Vo. “We firmly believe that if you make compliancy simple, you are more likely to have everyone being compliant.”
Finally, the oversight serves to ease the #1 concern of all potential medical marijuana business owners: Breaking federal law. Regardless of state laws, the federal government still classifies marijuana as a Schedule 1 drug, making the sale or possession of it a felony. However, a letter from the Department of Justice was sent out stating: “In jurisdictions that have enacted laws legalizing marijuana in some form and that have also implemented strong and effective regulatory and enforcement systems to control the cultivation, distribution, sale, and possession of marijuana,…enforcement of state law by state and local law enforcement and regulatory bodies should remain the primary means of addressing marijuana-related activity.”
“Basically, for those businesses that ensure best practices are used, the federal government will leave them alone,” says Vo.
Some states however have chosen a completely different route than standard seed-to-sale tracking.
Non-Traditional Seed to Sale Tracking: Connecticut Tries a Different Way
Connecticut passed medical marijuana laws in 2012, but the six approved dispensaries are only poised to open this summer. Part of the delay was in setting up the process of distribution and in the selection of the approved dispensaries.
Unlike Florida’s laws, which call for five dispensaries where the plants may be cultivated, processed and sold, Connecticut has a central place for cultivation, manufacturing and packaging with the dispensaries only handling the prescription distribution through licensed pharmacists, much like any other prescription drug. The system for tracking and management likewise operates nearly the same way, with the same methods for tracking pills being used to track different strains of marijuana.
“The inventory of the plants is tracked through all its cycles at the cultivation, production, manufacturing and packaging,” says William Rubenstein, Commissioner of Consumer Protection for the State of Connecticut, which oversees manufacture and dispensing of all pharmaceutical drugs in the state. “The dispensaries receive inventory of pre-packaged products through a range of dosages and from there it goes into inventory control.”
“For the Connecticut model, we have a small number of production facilities with enough for competition, but also small enough to properly regulate,” Rubenstein continues. “We’d rather have the best producers producing and the most qualified dispensaries dispensing.” Another benefit to this system from the pharmacist’s standpoint is the ability to order the exact dosages and strains to best suit the patient’s needs, without being tied to any one dispensary.
Whether the Connecticut model is better regulated than the standard seed-to-sale model for the all-in-one dispensaries planned in Florida is too soon to judge, but Florida’s method of tracking does have established precedents of success from other states.
“We serve nearly 500 legal marijuana businesses across North America, including eight states, Washington D.C. and Canada,” says Vo. “In all that time, we have never had a single client in trouble with the DEA. Above and beyond that, in five years, none of our clients has failed an audit, regardless of the oversight organization.”
*image courtesy of Associated Press