Centralized Inventory Tracking - Recommendation
Centralized Inventory Tracking v. 2 - Recommendation May 12, 2017
1. Working group name:
Operations - Production/ Manufacturing
2. Individual sponsor(s):
Anna Thornley – Department of Taxation
Bryan Hyun – Owner/Operator – The Grove
Jake Ward – Pure Tonic Concentrates
3. Describe the recommendation:
All marijuana facilities will have internal inventory control systems and movement of all
controlled substances between facilities will be closely monitored per regulation. It has been
proposed that a centralized seed-to-sale system also be put into effect by the Department which
would centrally monitor all inventory in the State. This data would potentially be used to not only
track inventory but also for tracking business transactions so that fair market values may be
established per NRS 453D.
Since inventory control systems are a very important part of how the industry interfaces with
regulators, it is recommended that the Department work closely with industry to decide whether
a centralized seed-to-sale inventory tracking system is necessary. If the system is deemed
necessary, then the Department should work closely with industry to develop system
requirements and implement the system.
4. Which guiding principle(s) does this recommendation support?
Guiding Principle 2 - Be responsive to the needs and issues of consumers, non-
consumers, local governments and the industry
Guiding Principle 4 - Propose efficient and effective regulation that is clear and reasonable and
not unduly burdensome
5. What provision(s) of Question 2 does this recommendation apply to?
- NRS 453D.200 (c) Requirements for the security of marijuana establishments;
- NRS 453D.200 (d) Requirements to prevent the sale or diversion of marijuana and marijuana
products to persons under 21 years of age
- NRS 453D.200 (g) Requirements for record keeping by marijuana establishments
- NRS 453D.200 (l) Procedures to establish the fair market value at wholesale of marijuana
6. What issue(s) does the recommendation resolve?
Centralized Inventory Tracking - Recommendation
Centralized Inventory Tracking v. 2 - Recommendation May 12, 2017
This recommendation resolves the issue of implementing an inventory control system which is
robust enough to allow for the gathering of pertinent data, but not redundant or unduly
burdensome on the industry.
7. Was there dissent in the group regarding this recommendation? If yes, please provide a
summary of the dissenting opinion regarding the recommendation.
No dissent.
8. What action(s) will be necessary to adopt the recommendation? Will statute, policy,
regulations, etc. need to be addressed?
The Department will have to reach out to industry to gain some knowledge as to how inventory
and transactions are currently tracked and industry will have to learn more about the needs of
the Department as final regulations are drafted. Inventory control systems are a very important
part of how the industry interfaces with regulators.
9. Additional information (cost of implementation, priority according to the recommendations,
etc.).
None
Local Government Regulation - Recommendation
Local Government Regulation – Recommendation May 12, 2017
1. Working group name:
Operations - Production/ Manufacturing
2. Individual sponsor(s):
Tommy Robinson, Deputy Police Chief, Reno Police Department
Alex Woodley, Director of Code Enforcement, City of Reno
Jacob Ward, Pure Tonic Concentrates
Jennifer Lazovich, Kaempfer Crowell
3. Describe the recommendation:
The intent of this recommendation is to ensure that there is consistency in regulation throughout
the State for certain matters involving recreational marijuana.
4. Which guiding principle(s) does this recommendation support?
Guiding Principle 1 – Promote the health, safety, and well-being of Nevada’s
communities
Guiding Principle 2 – Be responsive to the needs and issues of consumers, non-
consumers, local governments and the industry
Guiding Principle 4 – Propose efficient and effective regulation that is clear and reasonable and
not unduly burdensome
Guiding Principle 5 - Begin a discussion between the State and local governments regarding the
costs of carrying out Question 2
Guiding Principle 6 – Establish regulations that are clear and practical, so that interactions
between law enforcement (at the local, State and federal levels), consumers, and licensees are
predictable and understandable
5. What provision(s) of Question 2 does this recommendation apply to?
1) NRS 453D.020 (3) (c) Cultivating, manufacturing, testing, transporting and selling marijuana
will be strictly controlled through State licensing and regulation
2) NRS 453D.200 Duties of Department relating to regulation and licensing of marijuana
establishments; information about consumers.
6. What issue(s) does the recommendation resolve?
Local Government Regulation - Recommendation
Local Government Regulation – Recommendation May 12, 2017
This recommendation would provide guidance to local governments as to issues that should be
deferred to State regulation. Certain matters involving edibles, packaging, concentrates, product
types, dosing, potency and serving size limitations should be consistent throughout the State to
ensure consumer safety. Some other resolutions offered by this recommendation are:
Ensures uniformity for the industry & predictability with set regulations
Provides opportunity for State regulators to become subject matter experts
Reduces costs of regulation to local jurisdictions
Minimizes ongoing training of the local jurisdictions by the State
Minimizes possibility of contradictory regulations between the State and local governments
Provides for local and State interactions similar to that related to existing gaming
regulations
7. Was there dissent in the group regarding this recommendation? If yes, please provide a
summary of the dissenting opinion regarding the recommendation.
No dissent
8. What action(s) will be necessary to adopt the recommendation? Will statute, policy,
regulations, etc. need to be addressed?
A regulation should be adopted that makes it clear that local governments may regulate
recreational marijuana establishments on zoning, general business license matters, fire and
building code compliance. However, local governments must defer to State regulation on
matters involving edibles, packaging, concentrates, dosing, potency, serving size limitations, and
products types.
Essentially, the State should carry out the provisions outlined in 453D.200 and the local
governments should not add to or take away from the subject matter in those same provisions at
the local level. 453D.200 (1) (h) will be exempt from this regulation.
9. Additional information (cost of implementation, priority according to the recommendations,
etc.).
None
Product Types and Their Equivalencies - Recommendation
Product Types and Their Equivalencies v. 3 - Recommendation May 12, 2017
1. Working group name:
Operations - Production/ Manufacturing
2. Individual sponsor(s):
Bill Erlach – City of Reno Fire Department
Bryan Hyun – Owner/ Operator – The Grove
Meg Collins - Good Chemistry
Jake Ward – Pure Tonic Concentrates
3. Describe the recommendation:
Due to the possession and purchase limits put in place by Question 2 for marijuana and
concentrated marijuana, there is some confusion regarding the difference between marijuana
flower, marijuana edibles, and marijuana concentrates. This recommendation is intended to add
clarity to the regulation of concentrated marijuana as it relates to other marijuana product
types.
4. Which guiding principle(s) does this recommendation support?
Guiding Principle 2 - Be responsive to the needs and issues of consumers, non-consumers, local
governments and the industry
Guiding Principle 4 - Propose efficient and effective regulation that is clear and reasonable and
not unduly burdensome
Guiding Principle 6 - Establish regulations that are clear and practical, so that interactions
between law enforcement (at the local, state and federal levels), consumers, and licensees are
predictable and understandable
5. What provision(s) of Question 2 does this recommendation apply to?
NRS 453D.030 (2) - “Concentrated marijuana” means the separated resin, whether crude or
purified, obtained from marijuana.
NRS 453D.110 (1) - Possess, use, consume, purchase, obtain, process, or transport marijuana
paraphernalia, one ounce or less of marijuana other than concentrated marijuana, or one-eighth
of an ounce or less of concentrated marijuana;
6. What issue(s) does the recommendation resolve?
Product Types and Their Equivalencies - Recommendation
Product Types and Their Equivalencies v. 3 - Recommendation May 12, 2017
The need to clearly define what concentrated marijuana is and how it relates to other marijuana
types for the regulation of retails sales and personal possession limits.
7. Was there dissent in the group regarding this recommendation? If yes, please provide a
summary of the dissenting opinion regarding the recommendation.
No dissent.
8. What action(s) will be necessary to adopt the recommendation? Will statute, policy,
regulations, etc. need to be addressed?
1. A regulation should be put into place that takes topical and edible marijuana out of the
possession and purchase restrictions outlined in 453D.110 (1).
a. Edible marijuana infused products will be regulated by stringent THC limits related to serving
size and packaging limitations as outlined in other Production / Manufacturing Work Group
recommendations.
b. Topicals should not be included in the possession and purchase limits outlined by Question 2.
The THC in topical preparations are not used or consumed in a manner that would activate the
psychoactive effects of the amounts of THC that may be in topical products.
2. Question 2 allows a consumer to “possess, use, consume, purchase, obtain, process or
transport…one ounce or less of marijuana, or one-eighth of an ounce or less of concentrated
marijuana. Since there will be cases where an individual may purchase and possess a mixture of
marijuana products (concentrated marijuana, marijuana infused edible products, and marijuana
flower) then equivalency factors should be developed and put into place so that decisions can be
made upon retail sale and in the field by law enforcement. (The Medical Marijuana regulations
found in Section 453A.704 contains guidelines for equivalent purchase limits for medical
marijuana patients.)
3. It is important that a comprehensive training program be developed and be administered to
law enforcement so that a clear distinction between product types can be made in the field.
4. Retail dispensaries should develop and administer training to management and their sales
staff that ensures that they understand the sales limitations of marijuana products and
concentrate, and the likely combinations thereof, to ensure that all sales are compliant with
respect to purchase and possession limits.
9. Additional information (cost of implementation, priority according to the recommendations,
etc.).
The proposed Nevada equivalency chart is attached below.
Product Types and Their Equivalencies - Recommendation
Product Types and Their Equivalencies v. 3 - Recommendation May 12, 2017