Article: Track and Trace for Medical and Adult Use Marijuana Programs

Track and Trace for Medical and Adult Use
Marijuana Programs
A preliminary draft rule related to the tracking and tracing of products in the Maine Medical Use of Marijuana Program is currently available for review on the Office of Marijuana Policy’s website: Parties interested in providing feedback in response to the preliminary draft rules may do so through the following page: Written comments on the preliminary draft must be submitted by this Friday, September 27th. A formal notice and comment period on a subsequent draft will follow.
On Monday, September 16th Drummond Woodsum attended the state’s track and trace kickoff event hosted by the Office of Marijuana Policy (“OMP”) in Augusta. The Chief Operating Officer of BioTrackTHC, Moe Afaneh, gave a high-level overview of the company’s seed-to-sale software for state-level data collection. The use of the state’s web-based platform will be mandatory for all registered caregivers, dispensaries, and adult use licensees. The room was packed, and OMP staff members were available to answer questions from the audience and respond to feedback about the rollout of this program.
The initial trainings for medical marijuana program participants that were held in various locations across the state last week filled up within 36 hours. If you were not able to register for one of those trainings, you are not alone. There will be ample opportunities to receive training either online or in-person before the system goes live. Once the final track and trace rules are adopted, medical marijuana program participants will have up to 60 days to enroll in the State’s tracking system. Within 30 days of enrolling and receiving all appropriate training and credentials on the BioTrackTHC platform, registrants and their assistants must track all marijuana, marijuana concentrate, and marijuana products in compliance with the rule.
While the State’s track and trace site will be free to use, it will be mandatory for labels to be purchased from within the platform and each label will cost $0.25. The labels will come with a Maine program watermark and the registrant/licensee’s ID number on them. The registrant/licensee must have a thermal printer for printing the specific tracking number on each individual label that will be affixed to a particular batch or lot. Under the proposed rule, certain registered caregivers who do not operate a caregiver retail store may be eligible for “plant-only tracking” to help reduce costs for small-scale operations. Individual products available for sale to consumers or patients must meet the state’s packaging and labeling requirements. 
Any individual who will be inputting data into the track and trace system under either the medical or adult use program must be registered with OMP and will need to receive training. Trainings specifically for prospective adult use licensees will be held in October; dates and locations TBD. Online trainings and recorded webinars will also be available at a later date.
At the training, BioTrackTHC provided the following contact information to reach employees that are responsible for covering the company’s contract with Maine.
If you have questions about the state’s seed-to-sale tracking requirements, including questions about transportation manifests/chain of custody documentation and/or packaging/labeling requirements, please contact a member of Drummond Woodsum’s Regulated Substances Group.



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