Pharmacy Board denies my petition again

Des Moines 20100822 066Here are the events that took place on my peti­tion for mar­i­jua­na sched­ul­ing. First the sub­com­mit­tee report from Novem­ber 19, 2014.

Here’s a link to a copy of the sub­com­mit­tee report.

After the sub­com­mit­tee report was read, the fol­low­ing con­ver­sa­tion took place:

EDWARD MAIER: So, that entire doc­u­ment is what the com­mit­tee has rec­om­mend­ed to the board. I would now open it for dis­cus­sion or any action that the board would like to take.

SUSAN FREY: Well, I would like to thank the com­mit­tee for their work. I think it, this doc­u­ment and these rec­om­men­da­tions, sum up what we have been try­ing to do for the last five years that we’ve been look­ing at this project, or this sub­ject. So, I would be in sup­port of the com­mit­tee rec­om­men­da­tion.

JAMES MILLER: I, too, would like to thank the com­mit­tee for all its work, and it’s cer­tain­ly been a wor­ri­some issue since 2009 or before. I think there’s a lot to this doc­u­ment that Ed has just read and we just received it in copy a few min­utes ago to review. I would be in favor of tabling this thing until at least until our next meet­ing so we have time to review it more thor­ough­ly. I’m espe­cial­ly con­cerned about the last para­graph, that the Iowa Board of Phar­ma­cy mak­ing a rule about sched­ule changes when this is clear­ly the purview of the fed­er­al gov­ern­ment. We just went through a sit­u­a­tion in Iowa where hydrocodone, one of the most wide­ly pre­scribed opi­ate pain reliev­ers in our state, and in the whole coun­try; and we sched­ule it as a sched­ule 3 in Iowa until the fed­er­al gov­ern­ment said, “No, it’s going to be a sched­ule 2.” We could have a peti­tion say­ing, “You know what? In Iowa I think we’re just going to leave it in sched­ule 3.” That was not our abil­i­ty to do that. The fed­er­al gov­ern­ment decides what sched­ule things are in. So, I think we should take our time as far as mak­ing any fur­ther rec­om­men­da­tions. So, I would move that we table this. Give it some more thought.

EDWARD MAIER: Do we have any dis­cus­sion?

SUSAN FREY: Jim does bring up an inter­est­ing point. And, again, we find our­selves in that quandary of we already have the estab­lished, the leg­isla­tive estab­lished cannabid­i­ol act. I would cer­tain­ly be will­ing to table it and hear more.

EDWARD MAIER: That was the quandary that the com­mit­tee placed our­selves in. We knew that num­ber one we could have a rec­om­men­da­tion straight out against because of the fed­er­al class 1. And, then we could look at Iowa law, the act this last year, the cannabid­i­ol act has placed us in a posi­tion where Iowa law, it meets all the cri­te­ria of for class 2. We’re into the catch-22, so to speak here.

JAMES MILLER: I would say that Iowa leg­is­la­tors are elect­ed rep­re­sen­ta­tives of the cit­i­zens of Iowa. We are not elect­ed rep­re­sen­ta­tives. We have dif­fer­ent scope and ser­vice to the cit­i­zens. The elect­ed body can choose to do what­ev­er they wish. But as an Iowa cit­i­zen, I’m a cit­i­zen of Iowa, and so I’m sub­ject to Iowa laws. I’m also a cit­i­zen of the Unit­ed States. So, I’m sub­ject to fed­er­al laws. I’m not attor­ney. My rec­ol­lec­tion is fed­er­al law super­sedes. So, I think even, regard­less of what the Iowa leg­is­la­ture does, as a cit­i­zen I have to kind of be thinkin’, “Hmm, I won­der which set of laws are we going to be under?”

EDWARD MAIER: And, I think it’s impor­tant that no mat­ter which way this goes, this is sim­ply a rec­om­men­da­tion to the leg­is­la­ture and the leg­is­la­ture then would have to take action and the gov­er­nor would have to sign that. It would have to be, go through the reg­u­lar chan­nels. And, it’s a dif­fi­cult, very dif­fi­cult mat­ter.

JAMES MILLER: I think it’s extreme­ly dif­fi­cult. But I also think that there’s some cred­i­bil­i­ty here as far as the board and what our role is and that we main­tain our dili­gence as far as the safe­ty of the cit­i­zens of Iowa. And, we’ll be looked at to estab­lish the safe­ty of the drug prod­ucts that we cur­rent­ly take respon­si­bil­i­ty for. Mar­i­jua­na wouldn’t fall into that cat­e­go­ry at all: the stan­dard­iza­tion of dose; as far as proven effi­ca­cy; as far as proven safe­ty. I think that clear­ly is out­side of the bounds of our exper­tise.

EDWARD MAIER: Any oth­er com­ments?

EDWARD McKEN­NA: I agree with Jim, because I think that the mar­i­jua­na oil that peo­ple use for epilep­sy, the Uni­ver­si­ty of Iowa is mon­i­tor­ing that pro­gram. Right? So, I think we need more infor­ma­tion that the oil is actu­al­ly work­ing. That pro­gram was just imple­ment­ed.

Jan­u­ary 5, 2015:

Item 3.5 on the Agen­da (around 9:30 a.m.)

JAMES MILLER: Item 3.5 is the Olsen ver­sus the Board of Phar­ma­cy peti­tion.

LLOYD JESSEN: I think Meghan might have a lit­tle com­ment for us.

MEGHAN GAVIN: Yes, I’ll give you a lit­tle update. This is one of your sev­er­al judi­cial reviews right now going through the courts at the moment and time, but the board will remem­ber this was Mr. Olsen’s request that you con­sid­ered in Jan­u­ary of last year about the reclas­si­fi­ca­tion of mar­i­jua­na resched­ul­ing, I should say of mar­i­jua­na. Judge Ovrom deter­mined after the brief­ing and oral argu­ment that this board main­tains dis­cre­tion about which par­tic­u­lar drug it choos­es to make rec­om­men­da­tions to the leg­is­la­ture for. She said that your deci­sion on whether or not to rec­om­mend can only be over­turned for abuse of dis­cre­tion. She found no abuse of dis­cre­tion in the year 2014 rec­om­men­da­tion. So, she is say­ing that. This has since been appealed by Mr. Olsen to the Iowa supreme court. The case is not done, but this is the first time that we actu­al­ly have a judi­cial deci­sion that direct­ly per­tains to what your, this board’s oblig­a­tion is under the con­trolled sub­stances act to make rec­om­men­da­tions every year. It’s a fair­ly short deci­sion, so I encour­age you all to read it. If you have any ques­tions, just let me know.

JAMES MILLER: Is there any indi­ca­tion of when the supreme court’s going to review it?

MEGHAN GAVIN: Appeals take time and what will hap­pen is once the tran­script is sent to the court, they’ll send out a brief­ing sched­ule and that usu­al­ly takes about four to six months for the brief­in­gs to be com­plet­ed and giv­en to the court, at which time Iowa has kind of a unique appel­late sys­tem, so it will be reviewed by staff attor­neys and the supreme court will make a deci­sion on whether or not to keep the case or to give it to the court of appeals. I sus­pect, because the case is based sole­ly on statu­to­ry inter­pre­ta­tion, that it will be sent to the court of appeals for adju­di­ca­tion. They then get things pret­ty quick­ly before them. So I would imag­ine next fall. I know, does that seem quick from an out­side per­spec­tive? But, actu­al­ly it is fair­ly quick. So I would imag­ine next fall they will have it sub­mit­ted to the court of appeals. Both the court of appeals and the supreme court take short recess­es in the sum­mer to work on admin­is­tra­tive things, so that’s my best guess. After the court of appeals you have an oppor­tu­ni­ty to request the supreme court review, but you don’t have a right to that. So, that could keep the case pend­ing for a lit­tle while longer.

JAMES MILLER: Any oth­er ques­tions regard­ing item 3.5?

Item 2.1 on the Agen­da (approx­i­mate­ly 10:00 a.m.)

The phar­ma­cy board delayed the dis­cus­sion of my peti­tion (Item 2.1 on the Agen­da) until 10:00 a.m. on Jan­u­ary 5, 2015.

EDWARD MAIER: We’re ready to pro­ceed and my under­stand­ing is that we are at 2.1 on our agen­da, the peti­tion to request reclas­si­fi­ca­tion of mar­i­jua­na. And, what we’ve heard on that is that we have some sug­ges­tions from the last time around from the sub­com­mit­tee. And, we vot­ed to table it. And, so I’m going to open it up here to the board for some dis­cus­sion at this point and see where we want to go from here on that top­ic.

JAMES MILLER: Well, I think we should lim­it our dis­cus­sion to the cannabid­i­ol that was act­ed on by the Iowa leg­is­la­ture. The Iowa leg­is­la­ture did not, cer­tain­ly had dis­cus­sions about reclas­si­fy­ing mar­i­jua­na, and they did not take any action on that. I think their purview demands that they would, but they did take action as far as address­ing cannabid­i­ol. And, so I think we can, we could uphold the act. But as far as the rest of the 400 com­po­nents of the mar­i­jua­na plant that are list­ed, I don’t think we have any purview there.

SUSAN FREY: I guess I would agree with that, sim­ply because as a board our pro­ce­dure has always been in the past that we name the spe­cif­ic com­pound or chem­i­cal enti­ty. For instance, we don’t just rec­om­mend that we resched­ule all pain killers, because there’s dif­fer­ent lev­els, they are used for dif­fer­ent things. And, so, I would, I think that’s prob­a­bly been our biggest stum­bling block, is just by say­ing mar­i­jua­na it’s not spe­cif­ic enough. So, I would sim­ply, we already have leg­is­la­tion that has addressed the cannabid­i­ol oil, and that we rec­om­mend reclas­si­fi­ca­tion of that prod­uct. And, as sci­en­tif­ic and med­ical infor­ma­tion comes along for oth­er deriv­a­tives, since we already have Mari­nol that is sched­uled, that’s a mar­i­jua­na deriv­a­tive or THC prod­uct, a chem­i­cal enti­ty of mar­i­jua­na, it’s already sched­uled. I think we should address each indi­vid­ual chem­i­cal as they become, or enti­ty as they become avail­able. So, that would be, I would sec­ond Jim’s rec­om­men­da­tion that we address sim­ply the cannabid­i­ol oil to bring us in com­pli­ance with the leg­is­la­tion.

MEGHAN GAVIN: Can I inter­ject one sec­ond?


MEGHAN GAVIN: The board is cer­tain­ly able to make your rec­om­men­da­tion as nar­row as you want. The actu­al peti­tion, how­ev­er, itself is for the reclas­si­fi­ca­tion of mar­i­jua­na. So, if you’re going to go down the route as has been sug­gest­ed, you would deny that rec­om­men­da­tion in total and make your more spe­cif­ic rec­om­men­da­tion. That would be the pro­ce­dure.


JAMES MILLER: I would move that we …

EDWARD MAIER: Just a sec­ond. I think that we need to have a lit­tle more dis­cus­sion from the mem­bers of the the com­mit­tee who made the rec­om­men­da­tion. I’d like to hear if they have any input on what’s just been said.

SHARON MEYER: Well, I think as a phar­ma­cist we all have that sci­en­tif­ic view­point that if a par­tic­u­lar chem­i­cal or com­pound that has some med­ical effect, it would need to be stud­ied and researched and stan­dard­ized. And, that’s what we pre­fer for dosage forms for patients. As a mem­ber of the sub­com­mit­tee I think what we wres­tled with is what is cur­rent­ly in the code that has lan­guage to the effect that if a sub­stance is cur­rent­ly in sched­ule 1 is found to have some med­ical ben­e­fit then per­haps it should be con­sid­ered sched­ule 2. I think that’s kind of where we as a sub­com­mit­tee were going is because we were fol­low­ing what’s in the Iowa Code now to make rec­om­men­da­tions.

LADONNA GRATIAS: And, also the leg­is­la­ture did pass med­ical mar­i­jua­na. It was told to us that it real­ly was a sched­ule …

EDWARD MAIER: That was cannabid­i­ol oil.

JAMES MILLER: Just one com­po­nent.


SUSAN FREY: Well, I guess …

JAMES MILLER: I would say, there’s a prod­uct being test­ed in the US and UK, it’s being test­ed in human sub­jects in a prod­uct that has both THC and cannabid­i­ol. It’s been in clin­i­cal tri­als. So there are some stan­dard­ized prod­ucts being devel­oped. But to con­sid­er the whole mar­i­jua­na plant I think is way beyond the scope of what …

SUSAN FREY: I guess I’m, in ret­ro­spect, it makes sense to me that if you can use the anal­o­gy of opi­um, opi­um is in sched­ule 1. So, it’s a raw plant. And, so it has med­i­c­i­nal val­ue. It’s in sched­ule 1. But, yet, we have mor­phine, which is in sched­ule 2, which is a direct deriv­a­tive of that plant. To me, that’s where this should fit. We should keep mar­i­jua­na in sched­ule 1, but then the chem­i­cal enti­ties that devel­oped from that should go into sched­ule 2.

EDWARD MAIER: Okay, I guess I agree with Sharon from the per­spec­tive of the group. That is what we strug­gled with. But we also strug­gled with the fact that I don’t think any of us were com­plete­ly ready to say we want to jump both feet in and say that we think there should be a med­ical mar­i­jua­na pro­gram in this state. That’s not, at least from my per­son­al per­spec­tive, and I think I recall a con­ver­sa­tion that was a part of it, because it is such a broad thing. And, there is such a vari­ance in poten­cies of the plant. It’s a very hard thing to get your hand on sci­en­tif­i­cal­ly. We’ve heard some peo­ple say there’s some uses for deriv­a­tives, but, you know, at this point and time we’re still, we need more research. But sched­ule 1 and sched­ule 2 both allow research. One point that I real­ly am, because I’m real­ly, I’m real­ly strong on, because I’ve been here for the last six year and we’ve strug­gled with this, there are con­flict­ing cita­tions in the code. One place it says its sched­ule 1 except by rules of the board and one place it says its sched­ule 2 except by the board. I strong­ly believe that we need to rec­om­mend, or that we need to do some­thing leg­isla­tive­ly to clear that mess up, whichev­er way we go.

JAMES MILLER: There’s a peti­tion to your point and I think the peti­tion itself talks about two places in the Iowa Code. You know, we have a leg­is­la­ture that is charged with writ­ing the code in par­tic­u­lar. I don’t think they need any rec­om­men­da­tion from us. We’re not attor­neys. We’re here to take care of the phar­ma­cy laws and pro­tect the health of our cit­i­zens. So, I think that kind of stuff is way beyond our area of exper­tise. I don’t think we have any busi­ness telling them what to do.

EDWARD MAIER: I agree with the part about the fact, prob­a­bly I feel more com­fort­able with mak­ing a rec­om­men­da­tion of cannabid­i­ol than I do on mar­i­jua­na. Per­son­al­ly, if somebody’s will­ing to make that rec­om­men­da­tion, then I’m will­ing to go … I don’t think we can just deny this request and move away because the legislature’s already said that there is some use for cannabid­i­ol. If we’re allowed to turn aroundthen and make a rec­om­men­da­tion for cannabid­i­ol, I’m will­ing to say we deny the mar­i­jua­na part of it and we just include the cannabid­i­ol and rec­om­mend that the change be made to delete those ref­er­ences to the rules of the board.

MEGHAN GAVIN: Well, your pro­pos­al then would be to make clear that the leg­is­la­ture would have to act before mar­i­jua­na would be resched­uled, then the board would not be com­mit­ted to estab­lish a mar­i­jua­na pro­gram.

EDWARD MAIER: That’s what I’m thinkin’. Our idea is that we don’t have the pow­er to estab­lish a mar­i­jua­na pro­gram. We can’t write those rules because they’re too broad. But, yet, there’s a sug­ges­tion there that we should, and that’s not right. That’s the legislature’s pre­rog­a­tive, not our pre­rog­a­tive. And, those things need to be out of the code.

SUSAN FREY: I agree that if we deny the peti­tion, that we should turn around and do a rec­om­men­da­tion for the cannabid­i­ol oil. But, then, per­haps we should move the oth­er part of that as a piece of leg­is­la­tion to be entered in and not part of a sug­ges­tion.

EDWARD MAIER: And I’m per­fect­ly agree­able to that. I was think­ing to make that change as a part of the whole thing. It’s going to keep com­ing back to us as rule mak­ing and those are those out­dat­ed word­ing that has been there for years. That kind of a pro­gram is way too broad for one board. It would be way too broad for the board of med­i­cine, or the board of nurs­ing, or any­body else to write those kinds of rules. So, I guess I would enter­tain … Is there any oth­er dis­cus­sion? Okay, I would enter­tain a motion from any­body.

EDWARD MCKENNA: I think we already have a motion.

EDWARD MAIER: Just a sec­ond now, we have a com­ment.

CARL OLSEN: Opi­um plants are in sched­ule 2, not sched­ule 1. And coca plants are in sched­ule 2, not sched­ule 1. We don’t have any plants in sched­ule 1 from which any med­i­cines are derived. So, that was an incor­rect state­ment. If you want to nor­mal­ize the act, you rec­om­mend mar­i­jua­na be clas­si­fied like opi­um pop­pies and coca plant because that’s where we put plants that are the source mate­r­i­al for these deriv­a­tives like cannabid­i­ol.

JAMES MILLER: Duly not­ed. I’ll make a rec­om­men­da­tion that we deny the request.

SUSAN FREY: And I will sec­ond it.

EDWARD MAIER: Any fur­ther dis­cus­sion? All those in favor, aye.


EDWARD MAIER: Opposed? Okay, the motion has been denied. Does any­one have any fur­ther rec­om­men­da­tion they would like to …

SUSAN FREY: I move that we rec­om­mend to the leg­is­la­ture to resched­ule cannabid­i­ol oil to sched­ule 2.

MAIER: Sec­ond. Any fur­ther dis­cus­sion?

EDWARD MCKENNA: The only dis­cus­sion I have on it is, how broad is that? In oth­er words, if you have mor­phine sched­uled like 15 mg, 30 mg, dif­fer­ent things like that? How do we know if there’s oth­er ingre­di­ents in that oil? What are we rec­om­mend­ing? In oth­er words there are cer­tain com­pa­nies out there that make that. Are they legit­i­mate com­pa­nies?

EDWARD MAIER: And, that’s already been said. I think at this point the leg­is­la­ture has rec­og­nized the med­ical use for it and that is our cri­te­ria.


EDWARD MAIER: But, duly not­ed that there are con­cerns, a major con­cern.

JAMES MILLER: Anoth­er major con­cern, accord­ing to DEA it’s sched­ule 1. So, every phar­ma­cy in the state has to have a DEA license and you have to abide by that license. So we would all be break­ing the law if we had a cannabid­i­ol prod­uct. Its con­sis­tent with the leg­isla­tive act, but noth­ing else.

MEGHAN GAVIN: I think, I want to say this accu­rate­ly, the clas­si­fi­ca­tion of cannabid­i­ol under fed­er­al law is a lit­tle bit of a gray area at the moment and time. Some peo­ple believe it to be part of sched­ule 1 as mar­i­jua­na and some peo­ple believe it to be unsched­uled. There’s no defin­i­tive state­ment. And, to my knowl­edge I don’t believe DEA has tak­en a posi­tion pub­licly on it.

EDWARD MAIER: Carl, do you want to …

CARL OLSEN: The DEA web­site clear­ly clas­si­fies cannabid­i­ol as sched­ule 1.

EDWARD MAIER: So, if we were to go to sched­ule 2, we would still be …

CARL OLSEN: It has a drug con­trol num­ber, 73 some­thing.

JAMES MILLER: But the deriv­a­tive prod­uct being approved, you know, in the approval process, includes the cannabid­i­ol that is in the act.

SHARON MEYER: Just for the sake of dis­cus­sion, is some­thing that is need­ed pos­si­bly some­thing the leg­is­la­ture needs to address with that? That a sub­stance, cannabid­i­ol is includ­ed in this to the leg­is­la­ture? That is is a sched­ule 1 sub­stance? Is that some­thing that real­ly the leg­is­la­ture needs to address, that there is con­flicts in the code? So, I don’t know if we’re rec­om­mend­ing that it should go to sched­ule 2 or that the leg­is­la­ture needs to address that there’s a con­flict.

EDWARD MAIER: Your motion, Jim.

SUSAN FREY: It was my motion.

SHARON MEYER: We were also try­ing to think of oth­er poten­tial deriv­a­tives that may come on the scene, that there are active uses for. And, we were going to the conun­drum of the sched­ul­ing of sched­ule 1 / sched­ule 2, the oth­er deriv­a­tives, the fed­er­al, the state. So, I feel its like as a mem­ber of the sub­com­mit­tee, that’s where we had a tough job because there is con­flict­ing code.

EDWARD MAIER: The code says cannabid­i­ol. So, if we change cannabid­i­ol, we’re fol­low­ing what the leg­is­la­ture did. The sub­com­mit­tee had already rec­om­mend­ed sched­ule 2 any­way.

JAMES MILLER: It’s total­ly cor­rect. There’s no prod­uct. There’s con­flict­ing code. I think the only thing we’re doing with this rec­om­men­da­tion is sup­port­ing the cannabid­i­ol leg­is­la­tion that this par­tic­u­lar prod­uct has some use, pos­si­ble use in cas­es of epilep­sy.

SUSAN FREY: So, are you offer­ing a friend­ly amend­ment?

EDWARD MAIER: No, I just want­ed to clar­i­fy because of the ques­tion she brought up. This is a change.

SUSAN FREY: That’s where I want to see this going. If the exist­ing pro­gram, whichev­er is being devel­oped, we don’t know what that is, the depart­ment of pub­lic health, whether that’s going to involve, what dis­tri­b­u­tion sys­tem, we don’t know. So, I guess, putting it in sched­ule 2 makes it more read­i­ly avail­able if that comes to, once those plans and design is avail­able.

EDWARD MAIER: Any oth­er dis­cus­sion? We have a motion to resched­ule cannabid­i­ol to sched­ule 2. All those in favor, aye.


EDWARD MAIER: Opposed? Okay, the motion is car­ried. And I would com­mend the sub­com­mit­tee. And I, when we get to the leg­is­la­tion, we need to talk about what we said. The oth­er thing is that’s going to get lost in this is that we real­ly felt now, twice, bod­ies of the board have said some­thing about there being a com­mit­tee of a cross sec­tion of peo­ple from mul­ti­ple dis­ci­plines that take a look at either cannabid­i­ol oil or mar­i­jua­na or what­ev­er it is. And, I hope that this doesn’t just get lost in the record that some­where a com­mit­tee forms and takes it seri­ous­ly. With that, we’re going to move on.

TERRY WITKOWSKI: Ques­tion. Do you want to go … Do you want to have a rec­om­men­da­tion that the leg­is­la­ture look at the cur­rent lan­guage that talks about the board of phar­ma­cy adopt­ing rules for med­ical? Because nei­ther of these motions real­ly address any kind of a rec­om­men­da­tion to them regard­ing that.

EDWARD MAIER: Susan was talk­ing about that. We look at that as a piece of leg­is­la­tion that goes up. Or would that have to be a rec­om­men­da­tion?

TERRY WITKOWSKI: If you want to pro­pose any leg­is­la­tion now, you’d have to get a leg­is­la­tor to do it because we’re beyond the dead­line for pre-fil­ing.


EDWARD MAIER: I’d like to see a rec­om­men­da­tion.

SUSAN FREY: And, refresh my mem­o­ry, Ter­ry. What is it that we need to review, or to remove from …?

TERRY WITKOWSKI: There is a pro­vi­sion in sched­ule 1 that makes an excep­tion or an exemp­tion for mar­i­jua­na when pur­suant to rules of the board for med­ical mar­i­jua­na pro­gram. There’s a pro­vi­sion in sched­ule 2 that, along that same line, that says that mar­i­jua­na is a sched­ule 2 sub­stance pur­suant to rules of the board. So, it makes an exemp­tion out of sched­ule 1 and an excep­tion into sched­ule 2, both of them pur­suant to rules of the board for a med­ical mar­i­jua­na pro­gram. So, your rec­om­men­da­tion could sim­ply be to elim­i­nate those two pro­vi­sions.

EDWARD MAIER: And the rea­son being that our author­i­ty is too nar­row to adopt the rules.

MEGHAN GAVIN: You could just remove “pur­suant to rules of the board.” That’s all you have to say.

EDWARD MAIER: In both places. Would you like to make a motion to make that rec­om­men­da­tion?

SUSAN FREY: Okay, here goes. I move that we send a rec­om­men­da­tion to the leg­is­la­ture to remove in sched­ule 1 con­cern­ing mar­i­jua­na the exemp­tion … No, I mean in sched­ule 1, giv­ing the exemp­tion for a med­ical mar­i­jua­na pro­gram, I sug­gest we remove the word­ing “pur­suant to rules of the board of phar­ma­cy,” or, “the board.” Okay, because the board does not have the author­i­ty to estab­lish a pro­gram. And, I fur­ther rec­om­mend that the excep­tion of a med­ical med­ical mar­i­jua­na pro­gram that we remove the wordage “pur­suant to rules of the board” for that same rea­son, that the board does not have author­i­ty to pub­li­cate those rules.

EDWARD MAIER: Do we have a sec­ond?


EDWARD MAIER: Dis­cus­sion? All those in favor, aye.


EDWARD MAIER: Opposed? Car­ried.

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