This article originally appeared in the September 2017 print edition of Cannabis Business Times. To subscribe, click here.
In our industry, How can we define security?
A patient with an eligible condition wants medication that will predictably and consistently address her needs. Let’s call that medical security. Our patient also deserves medication that is free from contamination of any kind. Recreational customers also want predictability in their products, and products that are free from contamination. Let’s call that quality security. Regulations demand security from theft, loss and diversion of product away from fully licensed dispensaries. Let’s call that physical security. As part of an industry in development, we live with some differences in the concerns of our patients and our recreational customers, and the concerns of our regulators. Nevertheless, we need not consider patient and recreational concerns, and regulatory concerns to be mutually exclusive.
Let’s consider a local pharmacist handling Schedule II drugs in the normal course of business; she has similar concerns to those of a pharmacist or other dispensing professional in the medical marijuana industry. The pharmacist will be responsible—working with other medical professionals—for dispensing appropriate medication for a patient’s condition. She will also be responsible for reporting her pharmacy’s routine retail demand for Schedule IIs and its ordering patterns, as well as for secure storage.
She will spend most of her time, however, on precise, Schedule II inventory counts. If the counts are ever out of tolerance, she will have a reportable Schedule II event. Nevertheless, she will probably never need to assure a patient that the pills will accomplish their medical purpose, or that the pills are free of microbiological or heavy metal contamination: Medical security is built into the Food and Drug Administration (FDA)’s research and approval process, just as predictability, consistency and security against contamination are built into the FDA’s current Good Manufacturing Practices (cGMP) system.
The pharmacy analogy for our recreational users would be in the pharmacist’s over-the-counter, food and cosmetic products. FDA’s influence ensures that consumers of these products know what they’re paying for and need not worry about quality.
What does our industry’s security model look like? From a patient’s point of view, seed-to-sale does not address her medical or quality concerns with the products she purchases, and she has not noticed any thieves running down the street with bushes, large or small.
To read the full article in Cannabis Business Times' September issue, click here.
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