I.  18VAC110-60-285. Registration of products and 18VAC110-60-290. Labeling of batch of cannabidiol oil or THC-A oil products.

Support the deletion of naming of the "products" or "batches", however there is still concern with naming by   "Brand" name if same brand also manufactures or sells cannabis for recreational use.   

II.  18VAC110-60-110 through 130. 

For safety and security of employees, the public and adjacent neighbors, the Emergency Regulations should require Permittees be be housed in free-standing buildings, not multi-tenanted buildings with shared demising walls and parking areas.  Fire safety, noxious odors, personnel safety, facility security, are all compromised with shared tenancy.

To discourage promotion of recreational use, the Emergency Regulations should require that applicants should be isolated from residential development, much like the stipulated minimum distances from schools (1000').  Average families may not care to distinguish between medical and recreational use and may not wish to be exposed to traffic generated by medical cannabis users,  security risks, etc…

III. 18VAC110-60-330. Disposal of cannabidiol oil or THC-A oil.

The Regulations are not specific enough regarding acceptable methods of disposal (incineration, mulching/composting/disposal).  Rather than run afoul of a subjective standard, Processors would appreciate further detail as to which methods of disposal are acceptable to the Board.  Further, in the event disposal where time is of the essence, e.g., contamination of plant material, please stipulate availability of Agent of the Board.

IV.  Preference to Virginia Applicants.  The Emergency Regulations should stipulate a preference for applicants owned of 51% or greater Virginia residents.  This should be an industry by Virginians for Virginians.

VI.  Avoidance of Monopoly.  Permittees should not have interest in more than one Processing Permitee, creates a monopoly and inhibits fair trade.

VII.  Regulations should stipulate that Permits should be renewable automatically upon compliance with Regulations and payment of Fees. Permits should be renewable automatically upon the payment of fees if inspections are obtained and in absence of infractions to Regulations.  Significant investment in infrastructure requires objective renewal standard (vs. discretionary renewal.)