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To our esteemed patients and customers,

I recently provided testimony at the final Office of Manufactured Cannabis Safety,  California Department of Health public comment hearing in Santa Rosa, Ca regarding the proposed regulations. I have provided a transcript of that testimony for your consideration. It is so important that we work, united, in efforts to ensure practical regulation in California.

Best regards,

Christopher Coggan – CEO

Good Morning, thank you for having me. My name is Christopher Coggan and I am the founder of Therapy Tonics and Provisions. We specialize in cannabis Infused, ready to drink, specialty coffee and teas, made with organic, non-GMO ingredients. We currently operate out of La Jolla, California.

As a member of the CCIA manufacturing committee, I’d Like to thank the California Department of Health and the Office of Manufactured Cannabis Safety for being mindful of our advice as manufacturers in the drive towards regulations that are practical and effective. We share the common goal of ensuring safe access for patients and providing a fertile environment for evolution and innovation in this growing multi-billion-dollar industry.

That said, I believe there are several proposed regulations that are ill-conceived and threaten to limit access to both medical and adult use consumers, significantly increasing costs and stifling innovation in what will be the largest cannabis market in the world.

I would like to focus on Section 40300 in the proposed regulation text entitled “prohibited products”. Firstly, it is important to note that none of these regulations exist in a vacuum, but rather in the real world.

In the real world, California is a state of great diversity, but many of the defining characteristics are embodied by what California Board of Tourism captures in there marketing efforts, which is best summed up as the California lifestyle. Extrapolating on this, we are a progressive, forward-thinking state defined by active lifestyles and the healthy choices that promote and support these lifestyles.

That said, I find it hypocritical that a state known for cold-press, organic juices, fresh, farm to table choices, and the ‘got milk?’ advertising campaign, would restrict access to the very ingredients that many of our residents have come to depend on in the mainstream marketplace. The proposed elimination of fruit and vegetable extracts or juices, as well as dairy is counterintuitive to this market, a market that has been borne from alternative medicine and a holistic approach to health and wellness.

If I were to guess, over 80% of infused products currently available today would either disappear completely or have to compromise their formulas to accommodate these poorly considered prohibitions. The results for consumers would be catastrophic. Gone would be many of the products that have come to depend on. Gone would be the growing number of healthy choices and organic ingredients. Gone would be the innovative spirit that accompanies the cannabis industries drive for alternative, healthier forms of medicating.

What exactly replaces dairy or a fruit-derived substitute like coconut milk in a chocolate bar?

What replaces a fruit-derived sweetener in a beverage?

What we would be left with is a greatly reduced selection of products, filled with synthetic, processed ingredients and preservatives. In many ways, this completely compromises the values of Californians as well as the progressive choices that accompany the turn to alternative medicines and the holistic approach to health.

Add to this the prohibition of all products that are not shelf stable, and you have severely curtailed patient’s choices and destroyed the innovative spirit of our industry.

To reiterate, this is the real world. Refrigeration has been a common feature of every American household since the 1950’s and as savvy consumers turn more and more towards fresh and organic alternatives in the infused cannabis market, the dependence on temperature controlled options will increase exponentially.

I believe that any product that follows existing food safety standards through the production, distribution, and storage process should be available to cannabis consumers. For example, my company’s drinks are produced and packaged in accordance with current FDA guidelines as well as the health and safety standards as defined by the state of California.

In closing, it is important to note that this industry has self-regulated rather effectively for the last 20 years in California. Long before the state made any effort to monitor our manufacturing or regulate our processes, we stepped up to the plate and took on that responsibility ourselves.

In the real world, you are not regulating a new industry, you are regulating a maturing industry. Guided by existing food safety standards, our own principals, and commitment to safe access for patients, we provide the state a clear roadmap to regulation through example. Please embrace our knowledge and address our concerns to ensure that California leads the nation and the world in this emerging and innovative Cannabis economy.

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