August 31, 2015
Dear Sir or Madam,
My name is Lukas
Barfield. I am the Director of the Medical Marijuana Coalition of Washington
State (MMCWS). Our mission is to bring a medical marijuana system here to
Washington State that is based in compassion and science. I am writing today to
give public comment concerning the Medical Marijuana Consultant Certification
rules. The MMCWS has 5 key points we believe should be addressed when drafting
the rules for the Medical Marijuana Consultant Certification. They are…
Disability and
Sensitivity Training
Medical marijuana patients are often people with
disabilities. Additionally, some medical marijuana patients are veterans with
PTSD. Other medical marijuana patients are living with the burden of cancer.
These populations often require special accommodations for mobility, sound and
light levels and other factors that uniquely affect the medical Marijuana
patient. Consultants must be trained to work with vonerablepopulations.
Furthermore, consultants should be knowledgeable of the various conditions
medical marijuana can be recommended for in order to be sensitive to patients
needs.
Training in the Clinical
Application of Cannabis, Cannabis constituents and various cannabis derived products
Consultants must be trained on the clinical application of
raw cannabis, as well as on the clinical application of its various constituents
including, but not limited to, terpenes, THCA, CBDa, THC, CBD and other trace
cannabanoids. Additionally, consultants must be familiar with the clinical
application of activated cannabis, and other cannabis derived products such as
tinkshiers, lotions, concentrates edibles and other cannabis derived products
on the market. (AHPA, 2015).
Training in the Laws
and Regulations that Govern Cannabis
Consultants must be trained in the laws that govern cannabis
on a Local, State and Federal Level. Consultants must also be trained on how to
interact with regulators, law enforcement and other public officials. (AHPA, 2015)
CPR
Due to the population Medical Marijuana Consultants will
work with, Medical Marijuana Consultants should be trained in CPR (AHPA, 2015).
Cost
The medical Marijuana Consultant Certification must not be
cost prohibitive. Many of the states foremost experts on medical marijuana are
medical marijuana patients themselves. As you know this population is often low
income. The cost to earn a certification should be affordable for everyone.
These are five
key areas the Medical Marijuana Coalition of Washington State believes the
Medical Marijuana Consultant rules should entail. Thank you for taking my
public submission on behalf of the MMCWS. If you have any questions, please
feel free to contact me using the information provided below.
Regards,
Lukas Barfield
MMCWS Director
253 241 7399
P.O. Box 9085
Tacoma, WA 98409
American Herbal Products Association, (2015) Cannabis Dispensing
Operations Recommendations, retrieved from http://www.ahpa.org/Portals/0/pdfs/13_0709_Cannabis_Dispensing_Recommendations.pdf
on 8/20/2015
