BILL ANALYSIS                                                                                                                                                                                                    �






                             SENATE COMMITTEE ON HEALTH
                          Senator Ed Hernandez, O.D., Chair

          BILL NO:       SB 1262
          AUTHOR:        Correa
          AMENDED:       April 21, 2014
          HEARING DATE:  April 30, 2014
          CONSULTANT:    Diaz

           SUBJECT  :  Medical marijuana: regulation of physicians,  
          dispensaries, and cultivation sites.
           
          SUMMARY  :  Places certain practice restrictions and requirements  
          on a physician and surgeon who recommends medical marijuana to a  
          patient; requires medical marijuana dispensaries and cultivation  
          facilities to be licensed by the Department of Public Health;  
          provides for enforcement of the licensing provisions by county  
          health departments; prohibits anything in the medical marijuana  
          statute from preventing a city or other local governing body  
          from adopting local ordinances that regulate the location,  
          operation, or establishment of a medical marijuana cooperative  
          or collective, or from prohibiting one from operating within its  
          borders.

          Existing law:
          1.Requires the Medical Board of California (MBC) within the  
            Department of Consumer Affairs (DCA) to license, certify, and  
            regulate physician and surgeons (physician) under the Medical  
            Practice Act. Requires the MBC to take action against a  
            physician who is charged with unprofessional conduct, as  
            specified. Requires the MBC to prioritize its investigative  
            and prosecutorial resources to ensure that physicians  
            representing the greatest threat of harm are identified and  
            disciplined expeditiously, including those with repeated acts  
            of excessive prescribing, furnishing, or administering of  
            controlled substances, or repeated acts of prescribing,  
            dispensing, or furnishing of controlled substances without a  
            good faith prior examination of the patient and medical  
            reason.  

          2.Prohibits criminal prosecution, pursuant to the Compassionate  
            Use Act (CUA) of 1996, of a patient with specified illnesses  
            or a patient's primary caregiver, as defined, for the  
            possession or cultivation of medical marijuana (MM) upon the  
            written or oral recommendation or approval of a physician.  
            Encourages federal and state governments to implement a plan  
                                                         Continued---



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            to provide for the safe and affordable distribution of MM to  
            those who need it. Specifies that existing law related to MM  
            is not to be construed to supersede legislation prohibiting  
            conduct that endangers others or to condone the diversion of  
            MM for nonmedical purposes.

          3.Prohibits physicians from being punished or denied any right  
            or privilege for having recommended MM to a patient.

          4.Defines "primary caregiver" as an individual designated by a  
            patient who has consistently assumed responsibility for the  
            housing, health, or safety of that person.

          5.Requires the Department of Public Health (DPH) to establish  
            and maintain a voluntary Medical Marijuana Program (MMP) by  
            which patients can apply for MM identification cards (MMICs).  
            Requires county health departments to issue MMICs, as  
            specified, to patients and primary caregivers who voluntarily  
            register for the MMP. Specifies that MMICs are valid for one  
            year and may be renewed annually. Requires DPH to develop a  
            system by which state and local law enforcement officers can  
            immediately verify the MMIC's validity. Prohibits state or  
            local law enforcement officers from refusing to accept MMICs  
            unless there is reasonable cause to believe that the MMIC is  
            being used fraudulently or its information is false or  
            fraudulent.  

          6.Prohibits patients and primary caregivers with MMICs who  
            associate within the state in order to, among other  
            activities, possess, cultivate, process, and transport MM  
            collectively or cooperatively from, solely on that basis,  
            being subject to state criminal sanctions under state laws  
            that prohibit those activities otherwise.

          7.Makes it a misdemeanor offense to, among other things,  
            fraudulently represent a medical condition or provide any  
            material misinformation to a physician, health department  
            designee, or to law enforcement, for the purpose of falsely  
            obtaining MMICs; fraudulently use any person's MMIC in order  
            to acquire, possess, cultivate, transport, use, produce, or  
            distribute MM; counterfeit, tamper with, or fraudulently  
            produce MMICs; breach any confidentiality requirements  
            pertaining to the MMIC program.

          8.Requires a person who seeks an MMIC to pay a fee and provide  
            to the county health department a name, proof of residency,  




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            written physician's recommendation, physician's name and  
            contact information, the primary caregiver's name and duties,  
            and patient's and primary caregiver's government-issued photo  
            identification card.

          9.Prohibits anything in the MMP from preventing a city or other  
            local governing body from adopting local ordinances that  
            regulate the location, operation, or establishment of a MM  
            cooperative or collective, or prohibiting one from operating  
            within its borders; enforcing local ordinances for civil or  
            criminal purposes; or enacting other laws consistent with the  
            MMP. 

          10.Designates marijuana as a hallucinogenic substance in  
            Schedule I of the California Uniform Controlled Substances  
            Act.

          11.States legislative intent for the state to commission  
            objective scientific research by the University of California  
            (UC), and if the Regents of the UC accept the responsibility,  
            the UC is required to create the California Marijuana Research  
            Program (CMRP) to develop and conduct studies intended to  
            ascertain the general medical safety and efficacy of MM and to  
            develop guidelines for the appropriate administration and use  
            of MM; requires the CMRP to use a peer review process, as  
            specified, to guard against funding research that is biased;  
            requires the CMRP to report to the Legislature, as specified;  
            requires the President of the UC to appoint a  
            multidisciplinary Scientific Advisory Council to provide  
            policy guidance.

          This bill:
          1.Requires a physician, prior to recommending MM, to have a  
            physician-patient relationship, conduct an appropriate prior  
            exam of the patient, consult with a patient as necessary, and  
            periodically review the MM treatment's efficacy.

          2.Requires a physician that recommends MM to discuss side  
            effects with the patient, address what kind of MM to obtain,  
            as specified, explain the reason for the type of MM  
            recommendation, and maintain a system of record keeping to  
            support recommending MM. Prohibits a recommendation for butane  
            hash oil. Requires a recommendation to patients under 21 to be  
            approved by a board certified pediatrician, to be for high  
            cannabidiol MM, and to be for non-smoking delivery.




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          3.Makes it unlawful for a physician who recommends MM to accept,  
            solicit, or offer any form of remuneration from or to a  
            licensed MM facility if the physician or his or her immediate  
            family have a financial interest in that facility. Makes a  
            violation of this provision a misdemeanor.

          4.Requires the MBC to convene a task force, as specified, to  
            review and update guidelines for recommending MM to ensure  
            competent review in cases concerning the recommendation of MM.

          5.Provides for a civil fine of up to $5,000 for any violation by  
            a physician of any requirements when recommending MM.  
            Specifies that any recommendation for MM without an  
            appropriate prior examination and a medical indication  
            constitutes unprofessional conduct and may be punishable, as  
            specified.

          6.Prohibits, except as provided in the CUA and MMP, a person  
            from selling, providing, growing, or processing MM other than  
            at a licensed facility. Defines a licensed dispensing facility  
            as a dispensary, mobile dispensary, marijuana processing  
            facility, or other facility that provides MM that is licensed  
            by DPH, as specified.

          7.Requires DPH, prior to issuing a license to a MM facility, to  
            obtain specified information, including names of the owners, a  
            description of the scope of business, a certified copy of a  
            local jurisdiction's approval to operate the MM facility, and  
            payment of a fee determined by DPH that is sufficient to cover  
            the administrative costs of licensing MM facilities. Requires  
            DPH to consult outside entities and establish standards for  
            quality assurance testing of MM. Prohibits non-organic  
            pesticides from being used to cultivate MM.

          8.Prohibits a licensed MM facility from acquiring, possessing,  
            cultivating, delivering, transferring, transporting, or  
            dispensing MM for any purpose other than for those authorized  
            by the MMP. Prohibits a licensed MM facility from acquiring  
            plants or products except through the cultivation of MM by  
            that facility or another licensed cultivation site. Prohibits  
            a licensed MM facility from providing a MM product until it  
            verifies that a recommending physician is licensed to practice  
            in the state.

          9.Prohibits a person from distributing any form of advertising  




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            for physician MM recommendations in the state unless the  
            advertisement bears a notice to consumers indicating that the  
            CUA ensures access to MM when the use is deemed appropriate  
            and in accordance with accepted standards of medical  
            responsibility.

          10.Requires a licensed MM facility to implement security  
            measures to deter and prevent unauthorized entrance into areas  
            containing MM and theft of MM, including limiting access to  
            the facility, as specified; storing MM in a locked safe or  
            vault; and notifying law enforcement when there are breaches  
            in security, as specified.

          11.Requires county health departments, with DPH oversight, to  
            enforce the licensure requirements of MM facilities, including  
            conducting inspections, obtaining evidence, and reporting to  
            DPH on the number and types of MM facilities operating within  
            their jurisdiction. Specifies that an MM facility license is  
            subject to local jurisdiction restrictions and provides that  
            any violation is punishable by a civil fine of up to $35,000. 

          12.Specifies that the licensing of MM facilities by DPH does not  
            prevent a city or other local governing body from, among other  
            things, adopting and enforcing local ordinances that regulate  
            or prohibit MM facilities.

          13.Makes a legislative declaration that the police power, as  
            specified, allows each city and county to determine whether or  
            not an MM facility may operate within its borders and that,  
            when there are MM facilities, there is a need for the state to  
            license them and, among other things, prevent the potential  
            diversion of MM for recreational use.

           FISCAL EFFECT  :  This bill has not been analyzed by a fiscal  
          committee.

           COMMENTS  :  
           1.Author's statement.  According to the author, since the  
            approval of the CUA (Proposition 215) and passage of SB 420  
            (Vasconcellos), Chapter 875, Statutes of 2003, no broader,  
            feasible regulatory structure has been established, and the  
            implementation of these laws has been marked by conflicting  
            authorities, regulatory uncertainty, intermittent federal  
            enforcement action, and a series of lawsuits. Nearly all  
            recent attempts to regulate MM do not have appropriate health  




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            and safety standards and neglect the importance of local  
            control. This bill will set needed health and safety  
            standards, require licensing, protect local authority, and  
            establish security measures for the sale of MM.
            
          2.CUA.  The CUA was passed by California voters and established  
            the right of patients and their primary caregivers to obtain  
            and use MM, as recommended by a physician, in the treatment of  
            cancer, anorexia, AIDS, chronic pain, spasticity, glaucoma,  
            arthritis, migraine, or any other illness for which MM  
            provides relief. Additionally, the CUA specifically protects  
            physicians, for the purposes of any state laws, who recommend  
            the use of MM to patients and exempts qualified patients and  
            their primary caregivers from California drug laws prohibiting  
            possession and cultivation of marijuana. 

          3.MBC policy on MM. In May 2004, the MBC issued a statement on  
            the CUA and a physician's role in recommending MM, which  
            according to the MBC is still recognized policy. The MBC  
            stated that physicians who recommend MM will not be subject to  
            investigation or disciplinary action by the MBC if the  
            decision to recommend MM is made in accordance with accepted  
            standards of medical responsibility, which MBC states is not  
            specifically defined. The statement also indicates that a mere  
            complaint that a physician is recommending MM will not  
            generate an investigation absent information that a physician  
            is not adhering to accepted medical standards. According to  
            the MBC, while MM is not subject to reporting to the  
            Department of Justice's Controlled Substance Utilization  
            Review and Evaluation System, MM recommendations are treated  
            like any prescription for a controlled substance, meaning  
            there are no added training requirements for prescribing a  
            certain type of controlled substance nor are any controlled  
            substance prescriptions for people under the age of 21  
            required to be approved by a board certified pediatrician. The  
            MBC also indicates that it does not track complaints by  
            controlled substance but rather by allegations against a  
            physician, such as unprofessional conduct.   

          4.MMP.  The MMP was established by SB 420 to create a  
            state-authorized system by which patients and their primary  
            caregivers could obtain MMICs, along with a registry database  
            for verification of the MMICs.  Participation by patients and  
            primary caregivers in the MMP is voluntary. The Web-based  
            registry allows law enforcement and the public to verify the  
            validity of a qualified patient or primary caregiver's MMIC as  




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            authorization to possess, grow, transport, and/or use MM  
            within the state. Under the MMP, the local county health  
            department issues MMICs and collects fees. The MMIC is valid  
            for one year, after which it may be renewed.  A primary  
            caregiver's card expires when the patient's card expires.  
            Patients are responsible for notifying the county within seven  
            days when they change primary caregivers and must instruct the  
            previous primary caregiver to return the MMIC to the county  
            for confidential destruction.  

            In order to receive an MMIC, patients must reside in the  
            county where they apply, present the physician recommendation  
            for MM, and pay the fee required by the county. If the primary  
            caregiver lives in a different county, he or she must obtain  
            an MMIC in the county where the patient lives. A patient or  
            primary caregiver is not required to obtain an MMIC or to  
            participate in the MMP in order to use, obtain, possess, or  
            cultivate MM upon the recommendation of a physician pursuant  
            to the CUA.

            According to DPH, the total amount of MMICs issued to date is  
            72,762. DPH began tracking MMICs in Fiscal Year (FY) 2004-05  
            when 85 cards were issued. A peak 12,659 MMICs were issued in  
            FY 2009-10. The number of MMICs issued began to decline in the  
            following years with a total of 3,732 being issued in FY  
            2013-14. MMIC application fees are $66 each for patient and  
            primary caregivers, and for patients who are Medi-Cal  
            eligible, the fees are $33 for each the patient and the  
            primary caregiver.
               
          5.Center for Medicinal Cannabis Research (CMCR). The UC's CMCR  
            was created pursuant to SB 847 (Vasconcellos), Chapter 750,  
            Statutes of 1999. SB 295 (Vasconcellos), Chapter 704, Statues  
            of 2003 subsequently repealed SB 847's three-year sunset on  
            the CMRP. CMCR is tasked with developing and conducting  
            studies intended to ascertain the general medical safety and  
            efficacy of marijuana and, if found valuable, to develop  
            medical guidelines for the appropriate administration and use  
            of MM. According to their Web site, CMCR coordinates and  
            supports cannabis research throughout the state, which focuses  
            on the potential medical benefits of cannabis, the general  
            medical safety and efficacy of cannabis, and on examining  
            alternative forms of cannabis administration.

            In 2010, CMCR issued a report to the Legislature and Governor  




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            pursuant to SB 847. At that time, CMCR had approved 15  
            clinical studies, including seven clinical trials, which  
            focused on conditions identified by the Institute of Medicine  
            for which cannabis might have potential therapeutic effects,  
            based on current scientific knowledge. Three of the studies  
            utilized cannabis as an add-on treatment for patients who were  
            not receiving adequate benefit from a wide range of standard  
            pain-relieving medications. The studies demonstrated that  
            cannabis has analgesic effects on pain conditions. CMCR  
            suggests that cannabis may provide a treatment option for  
            those individuals who do not respond or respond inadequately  
            to currently available therapies. The CMCR report also stated  
            that until alternative delivery systems and new molecules are  
            available, smoked cannabis offers the most effective delivery  
            of cannabinoids for clinical trial.
            
          6.Litigation involving MM. The Legislature sought to clarify the  
            CUA in 2003 through SB 420 by establishing the MMP. SB 420 set  
            limits on the amounts of MM to be legally grown and possessed.  
            However, the California Supreme Court later ruled in People v.  
            Kelly (2010) 47 Cal.4th 1008 that the MMP section limiting  
            quantities of MM is unconstitutional because it amends a voter  
            initiative, and the CUA did not specifically include  
            legislative authority to amend it. Pursuant to the CUA,  
            patients and primary caregivers who obtain a physician's oral  
            or written recommendation are protected from state prosecution  
            for possessing or cultivating an amount of MM reasonably  
            related to their current medical needs. Although the MMP  
            provides protections from state law, patients and their  
            primary caregivers who engage in these activities remain  
            liable for federal arrest and prosecution, and those who  
            operate dispensaries face frequent federal enforcement  
            actions. The U.S. Supreme Court ruled in Gonzales v. Raich  
            (2005) 545 U.S. 1 that the federal government can enforce  
            marijuana prohibition despite state MM laws. The CUA and the  
            MMPA have no effect on federal enforceability of the federal  
            Controlled Substances Act. In 2013, the California Supreme  
            Court in City of Riverside v. Inland Empire Patient's Health &  
            Wellness Center (2013) 56 Cal.4th 729 upheld that local  
            governments have inherent zoning power. The issue in this case  
            was whether state MM statutes preempt a local ban on  
            facilities that distribute MM. The Court concluded they do not  
            and upheld the City of Riverside's implementation of a ban on  
            MM dispensaries and on any facility that is prohibited by  
            federal or state law. 
            




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          7.Double referral. This bill was heard in the Senate Committee  
            on Business, Professions, and Economic Development on April  
            21, 2014 and passed with a 9-0 vote.
               
          8.Related legislation. AB 1894 (Ammiano), would establish the  
            Medical Cannabis Regulation and Control Act and creates the  
            Division of Medical Cannabis Regulation and Enforcement within  
            the Department of Alcoholic Beverage Control (ABC) for the  
            purpose of registering people for the cultivation,  
            manufacture, testing, transportation, storage, distribution,  
            and sale of MM within the state subject to specified  
            exemptions for a city or county; provides that the ABC  
            director and its employees who administer and enforce  
            provisions of the Act are peace officers; requires the ABC to  
            work with law enforcement entities to implement and enforce  
            the rules and regulations regarding MM and to take appropriate  
            action against businesses and individuals that fail to comply  
            with the law; authorizes a board of supervisors of a county  
            and the governing body of a city to levy, increase, or extend  
            transactions and use taxes on the retail sale of or storage,  
            use, or other consumption of MM or MM-infused products. AB  
            1894 is currently in the Assembly Appropriations Committee.

            AB 604 (Ammiano) of 2013 is substantially similar to AB 1894.  
            AB 604 is currently in the Senate Committee on Public Safety.
            
          9.Prior legislation. SB 439 (Steinberg), of 2013, would have  
            exempted MM collectives and cooperatives from criminal  
            liability for possession, cultivation, possession for sale,  
            sale, transport, importation, and furnishing MM.  Clarifies  
            MBC enforcement of MM recommendations, what constitutes  
            unprofessional conduct, and the bar on the corporate practice  
            of medicine. SB 439 was last set for hearing in the Assembly  
            Committee on Health on August, 13, 2013. The hearing was  
            canceled at the author's request. On April 21, 2014, SB 439  
            was gutted and amended to a new purpose.

            AB 473 (Ammiano), of 2013, would have enacted the MM  
            Regulation and Control Act, and created a Division of MM  
            Regulation and Enforcement in the ABC to regulate the  
            cultivation, manufacture, testing, transportation,  
            distribution, and sale of MM. AB 473 failed passage on the  
            Assembly Floor.

            AB 2312 (Ammiano), of 2012, would have established a  




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            nine-member Board of MM Enforcement within DCA to regulate the  
            MM industry and to collect fees from MM businesses to be  
            deposited into a new MM Fund.  AB 2312 would have authorized  
            local taxes on MM up to 5 percent.  AB 2312 was never heard in  
            the Senate Committee on Business, Professions, and Economic  
            Development.
                                                                             
            AB 2465 (Campos), of 2012, would have made patient and primary  
            caregiver MMICs mandatory and required MM collectives to keep  
            copies of members' MMICs. AB 2465 was never heard in the  
            Assembly Committee on Public Safety.

            SB 1182 (Leno), of 2012, would have exempted a MM cooperative  
            or collective that operates within the Attorney General's (AG)  
            guidelines from being subject to prosecution for MM possession  
            or commerce, as specified; exempted such an entity and its  
            employees, officers, and members from being subject to  
            prosecution for MM commerce because the entity or its  
            employees, officers, or members received compensation for  
            actual expenses incurred in carrying out activities in  
            compliance with the guidelines. SB 1182 died on the Senate  
            Inactive File.

            SB 129 (Leno), of 2012, would have prohibited employment  
            discrimination on the basis of a person's status as an MM  
            patient or on the basis of the person's positive drug test for  
            MM, provided that the person is a qualified patient and the  
            use of MM does not occur at the place of employment or during  
            hours of employment. SB 129 died on the Senate Inactive File.

            AB 1300 (Blumenfield), Chapter 196, Statutes of 2011, permits  
            a local government to enact an ordinance regulating the  
            location, operation or establishment of an MM cooperative or  
            collective. Authorizes a local government to enforce such  
            ordinances through civil or criminal remedies and actions;  
            authorizes the local government to enact any ordinance that is  
            consistent with the MMP.

            AB 1017 (Ammiano), of 2011, would have made the cultivation of  
            marijuana, except as allowed by the MMP, punishable as a  
            misdemeanor with a penalty of imprisonment in a county jail  
            for a period of not more than one year. AB 1017 died on the  
            Assembly Inactive File.

            AB 223 (Ammiano), of 2011, would have specified that the CUA  
            does not authorize a person with an MMIC  to engage in the  




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            smoking of MM within 600 feet of the grounds of a school,  
            recreation center, or youth center, unless it occurs within a  
            residence or within a MM cooperative, collective, or  
            dispensary.  AB 223 was never heard in the Assembly Committee  
            on Public Safety.

            SB 626 (Calderon), of 2011, would have required the Board of  
            Equalization (BOE) to establish a nine-member task force to  
            conduct a study to determine ways to enhance collections of  
            sales and use taxes on retail sales of MM and ensure proper  
            regulation of the cultivation, transportation, and  
            distribution of MM and MM-based products. SB 626 was held  
            under submission in the Senate Committee on Appropriations. 

            SB 847 (Correa), of 2011, would have prohibited any entity  
            that possesses, cultivates, or distributes MM from locating  
            within 600 feet of a residential area unless a local ordinance  
            has been adopted to specifically regulate the location of  
            these entities in relation to residential use. SB 847 was  
            vetoed by Governor Brown who stated that he had signed AB  
            1300, which gave cities and counties authority to regulate MM  
            dispensaries and that SB 847 went in the opposite direction by  
            preempting local control and prescribing the precise locations  
            where dispensaries may not be located.

            AB 2650 (Buchanan), Chapter 603, Statutes of 2010, prohibits  
            an MM cooperative, collective, dispensary, operator,  
            establishment, or provider authorized by law to possess,  
            cultivate, or distribute MM that has a storefront or mobile  
            retail outlet from being located within a 600-foot radius of  
            any public or private school providing instruction in  
            kindergarten or grades 1 to 12, except as specified; provides  
            that local ordinances, adopted prior to January 1, 2011, that  
            regulate the location or establishment of MM establishments  
            are not preempted by its provisions.
            
            SB 1098 (Migden) of 2008 would have required the BOE to  
            administer a tax amnesty program, as specified, for MM  
            dispensaries, as defined. SB 1089 was never heard in the  
            Senate Committee on Revenue and Taxation. 

            SB 420 (Vasconcellos) established the MMP Act, a statewide,  
            voluntary program for the issuance of MMICs to identify  
            persons authorized to engage in the use of MM.





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            SB 295 (Vasconcellos) eliminated the CMRP's three-year  
            duration limit, which was established pursuant to SB 847.
            
            SB 847 (Vasconcellos) provided that the UC Regents, if they  
            elected to do so, could implement a 3-year program, the CMRP,  
            under which funds would be provided for studies intended to  
            ascertain the general medical safety and efficacy of MM and,  
            if found valuable, to develop medical guidelines for the  
            appropriate administration and use of MM. 

          10.Support. A sponsor of the bill, the California Police Chiefs  
            Association, writes that the policy underlying this bill is  
            the need for inclusive and substantial reform of the CUA,  
            which has had troublesome issues, including the ability of  
            virtually anyone to obtain a recommendation for MM. The other  
            sponsor, the League of California Cities, writes that the  
            state had been unable to enact a regulatory structure that  
            both ensures patient access to MM while recognizing laws that  
            authorize local regulations and address safety concerns. A  
            coalition of other supporters argues that the CUA lacked a  
            responsible, health-based regulatory scheme that upholds local  
            control and includes important health and safety requirements.  
            Supporters also argue that local governments should have a  
            prominent role in any regulatory process for MM.

          11.Opposition. California NORML writes that many Californians do  
            not have primary care physicians or belong to HMOs with  
            policies that do not allow MM recommendations. CA NORML also  
            states that the restrictions on physicians' right to recommend  
            MM conflict with the CUA's intent. Law Enforcement Against  
            Prohibition (LEAP) states that the prohibitive language of the  
            bill will discourage and limit the number of MM patients by  
            placing undue burdens on both the patient and provider. LEAP  
            also states that patients need dispensaries and a safe place  
            to access MM instead of forcing them to go to other cities to  
            find it, which benefits the criminal element and threatens  
            patient safety. Yolo County, the Imperial County Board of  
            Supervisors, and the Health Officers Association of California  
            oppose based on the requirement that county health departments  
            enforce the licensing provisions of the bill, citing issues  
            like a lack of funding, staff, expertise, equipment, and  
            training.
            
          12.Oppose Unless Amended. The California Medical Association  
            (CMA) opposes based on the bill's effort to legislate the  
            practice of medicine. CMA states that if a goal of the bill is  




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            to ensure recommendation for MM is appropriate and medically  
            indicated, then they stand ready to engage in those  
            discussions. The Drug Policy Alliance (DPA) opposes based on  
            the requirement that a physician make recommendations for a  
            certain kind of MM. DPA argues that medical schools have just  
            barely begun to teach students about the endocannabinoid  
            system. DPA further states that the ABC, rather than DPH,  
            would be better suited to oversee the licensing of MM  
            facilities since they have experience regulating an  
            age-restricted product. The Urban Counties Caucus states that  
            county public health department and county agricultural  
            commissioners would have to enforce MM with no expertise,  
            experience, or knowledge in this field. The California Health  
            Executives Association of California states that county public  
            health departments lack expertise and the infrastructure for  
            inspections or evaluations of MM.
            
          13.Policy comments.
               a.     Verification of a license to practice. This bill  
                 requires a licensed MM facility to verify a physician's  
                 license to practice medicine in the state before an MM  
                 product can be provided to a patient. The MBC and the  
                 Board of Pharmacy indicate that no other scheduled drug  
                 carries this same requirement. Committee staff suggests  
                 an amendment to delete this requirement.
                 
               b.     Physician requirements. This bill proposes a number  
                 of requirements for physicians who recommend MM. Some  
                 concerns have been raised about the requirements, such as  
                 requiring physicians to make recommendations for a  
                 certain type of MM. This is a major concern given the  
                 lack of research available, and it is unclear why the  
                 practice of medicine should be included in legislation.  
                 Committee staff suggests deleting Sections 2525 and  
                 2525.3 of this bill.

               c.     Regulation of MM facilities. This bill requires DPH  
                 to license MM facilities, but enforcement officers (a  
                 term that is not defined) of a county health department  
                 would regulate and conduct site inspections. DPH states  
                 that they currently do not license any type of facility  
                 that another entity regulates or inspects. DPH also  
                 indicates that they do not have the resources to fulfill  
                 requirements in this bill. It is unclear why a state  
                 agency that licenses a facility would rely on another  




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                 entity to perform regulation and inspection duties. The  
                 author may wish to consider whether or not DPH is the  
                 appropriate entity to administer the licensure of MM  
                 facilities and whether there is another appropriate state  
                 agency that can both license and regulate MM facilities.
               
               d.     Background checks. The author has indicated that an  
                 amendment requiring background checks for a MM facility  
                 applicant will be offered. Committee staff recommends  
                 language be included to allow denial of a license only if  
                 a past conviction is substantially related to the  
                 qualifications, functions, or duties of the business for  
                 which the license will be issued.

               e.     CMB task force. This bill requires the CMB to  
                 convene a task for of experts in the use of MM to review  
                 and update, as necessary, guidelines for recommending MM.  
                 CMCR is tasked with conducting studies to ascertain the  
                 general medical safety and efficacy of marijuana and  
                 developing medical guidelines for the appropriate  
                 administration and use of MM. It is unclear why a new  
                 entity would be created when the CMCR has been performing  
                 identical duties for more than 10 years. The author may  
                 wish to consider an amendment to recognize the existence  
                 of the CMCR within the UC system and to consider how the  
                 CMCR can replace the requirement for the CMB task force.
          
          14.Technical amendments. Committee staff suggests the following  
            technical amendments.

               a.     111657.9. Violation of   this provision  Section  
                 111657.8  shall be punishable by a civil fine of up to  
                 thirty-five thousand dollars ($35,000) for each  
                 individual violation.

               b.     111657.6. (a) A facility licensed pursuant to this  
                 article shall implement sufficient security measures to  
                 both deter and prevent unauthorized entrance into areas  
                 containing marijuana and theft of marijuana at those  
                 facilities. These security measures shall include, but  
                 not be limited to, all of the following:
                  (1)       Allow only   registered   qualifying patients   
                    registered with the facility  ,   personal  the patient's  
                    primary  caregiver   s  , and facility agents access to the  
                    facility.





                                                            SB 1262 | Page  
          15


                                                                    

               c.   111657.10. Nothing in this article shall prevent a  
                 city or other local governing body from  doing any of the  
                 following:  
                  (a) Adopting and enforcing local ordinances that regulate  
                 the location, operation, or establishment of medical  
                 marijuana cooperatives or collectives.
                 (b) The civil and criminal enforcement of local  
                 ordinances described in subdivision (a).
                 (c) Enacting other laws consistent with this article.    
                 taking any action as specified in Section 11362.83.   
                  
          
           SUPPORT AND OPPOSITION  :
          Support:  California Police Chiefs Association (sponsor)
                    League of California Cities (sponsor)
                    Americans for Safe Access
                    Association for Los Angeles Deputy Sheriffs
                    Association of Orange County Deputy Sheriffs
                    California Fraternal Order of Police
                    California Police Chiefs Association
                    Cities Association of Santa Clara County
                    City of Adelanto
                    City of Beaumont
                    City of Canyon Lake
                    City of Chowchilla
                    City of Colton
                    City of Concord
                    City of Covina
                    City of Del Mar
                    City of Encinitas
                    City of Etna
                    City of Fortuna
                    City of Gardena
                    City of Hemet
                    City of Highland
                    City of Indio
                    City of La Palma
                    City of Lathrop City Council
                    City of Lodi
                    City of Merced
                    City of Modesto
                    City of Norwalk
                    City of Patterson
                    City of Rancho Cordova
                    City of Rancho Mirage




          SB 1262 | Page 16




                    City of Rosemead
                    City of Sacramento
                    City of San Carlos
                    City of San Luis Obispo
                    City of Woodland
                    Covina Police Department
                    El Cerrito Police Department
                    El Monte/South El Monte Chamber of Commerce
                    Greater Merced Chamber of Commerce
                    International Faith Based Coalition
                    Long Beach Police Officers Association
                    Los Angeles County Professional Peace Officers  
                    Association
                    Los Angeles Police Protective League
                    Office of the San Diego County District Attorney
                    Riverside Sheriffs Association
                    Sacramento County Deputy Sheriffs Association
                    Santa Ana Police Officers Association
                    Town of Colma Police Department
                    Town of Danville
                    2 individuals

          Oppose:   California Medical Association (unless amended)
                    California Cannabis Industry Association
                    California NORML
                    County Health Executives Association of California  
                    (unless amended)
                    County of San Bernardino (unless amended)
                    Drug Policy Alliance (unless amended)
                    Health Officers Association of California
                    Imperial County Board of Supervisors (unless amended)
                    Law Enforcement Against Prohibition
                    Rural County Representatives of California (unless  
                    amended)
                    Urban Counties Caucus (unless amended)
                    Yolo County (unless amended)

                                      -- END --