- Target:
- Washington State Liquor Control Board
- Region:
- United States of America
- Website:
- www.wasavp.org
WASAVP represents professionals in the field of substance abuse prevention which focuses on stopping the harm from legal marijuana before it starts. We remain concerned that without stronger restrictions and safeguards on the commercial marijuana marketplace during its infancy, that illegal diversion and “Big Marijuana” will flourish and unnecessarily harm youth and communities.
Without a “crystal ball” to predict vulnerabilities in the rules and given that the marketplace will rapidly evolve, we urge the Liquor Control Board to err initially on the side of caution. As we have learned from “Big Tobacco,” it is much easier to loosen ineffective regulations than to tighten them once precedent is set and reinforced by the marketplace.
The following modifications to the Proposed Rules will maximize and extend the protective measures in I-502 and help keep youth and communities as safe as possible in the emerging commercial marijuana marketplace.
We, the undersigned, call on the Liquor Control Board to modify the Proposed Rules on implementing I-502 and the recreational marijuana industry in Washington State by including the following four provisions:
1. MANDATORY MINIMUM COMPLIANCE CHECKS
2. FURTHER RESTRICT MARIJUANA ADVERTISING
3. ESTABLISH A MINIMUM PRICE
4. LIMIT OUTLET DENSITY
(Details below.)
1. MANDATORY MINIMUM COMPLIANCE CHECKS
Rationale: Insuring a mandatory minimum level of compliance checks for marijuana retail stores sets a precedent of effective enforcement and deters illegal activity. We recommend compliance checks at a rate of 10% of marijuana retail stores per month.
2. FURTHER RESTRICT MARIJUANA ADVERTISING
Rationale: Advertising is directly related to underage use. Although we support a full ban on advertising marijuana, certain specific limitations that align with the Tobacco Master Settlement Agreement will help minimize sales to minors. These include, banning billboards and other outdoor advertising, product placement in entertainment media, and distribution of brand name merchandise. In addition, learning from “Big Tobacco,” we recommend banning brand sponsorships of events (including on television and internet broadcasts), sponsorship by parent companies (not brands), direct mail solicitation and advertising, advertising product on the internet beyond a business website, offering discount coupons, appealing to youth via shape and form of the edible product itself, and specifically advertising in other print media with greater than 10% youth readership.
3. ESTABLISH A MINIMUM PRICE
Rationale: Lower price directly correlates with increased marijuana use by both youth and adults. Commercialization will put downward pressure on price. A minimum price will safeguard against the possibility of the acquisition price falling low enough that current price restrictions are inadequate to dissuade sales to minors.
4. LIMIT OUTLET DENSITY
Rationale: Given that one ounce of dried cannabis will supply the average recreational user for months (~60 marijuana cigarettes or “joints”), a more conservative projected consumption rate, and therefor fewer outlets, will allow adequate access while still minimizing the illicit market.
Consider: COMMUNITIES OF COLOR are currently disproportionately burdened with the public health risks associated with high density alcohol and tobacco retail. We recommend that the board only grant marijuana retail licenses to businesses further than 1,000 feet from existing licensed alcohol retail to slow the industry practice of targeting vulnerable communities.
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The Modify LCB Proposed Marijuana Rules petition to Washington State Liquor Control Board was written by WASAVP and is in the category Health at GoPetition.