Public Comments by ASA

Over the years ASA has weighed in on state and local legislation and regulations. Look in this section to see if ASA has already responded to legislative proposals in your area.

Public Comment

Federal

• Comments on the Draft Cannabis Administration and Opportunity Act (2021)
• Docket No. FR 2021-14365-Application of Equity in U.S. National Drug Control Policy (2021)
• Docket No. FDA-2020-D-1079-0001 Cannabis and Cannabis-Derived Compounds: Quality Considerations for Clinical Research (2020)
• Docket #AMS-SC-19-0042-4666 Establishment of a Domestic Hemp Program (2020)
• Docket No. RIN 1117-AB54/Docket No. DEA-506 Controls to Enhance the Cultivation of Marijuana for Research in the United States (2020)
• Docket No. FDA-2019-N-1482 Scientific Data and Information about Products Containing Cannabis or Cannabis-Derived Compounds (2019)
• Doc. No. AMS-SC-19-0042-0983.pdf USDA considering requiring all laboratories testing hemp to have ISO 17025 accreditation (2019)
• Comments of Americans for Safe Access on Food and Drug Administration’s Request for Comments on International Drug Scheduling: Medical Usefulness of Cannabis Plant and Resin, extracts and tinctures of cannabis, delta-9-tetrahydrocannabinol (THC); stereoisomers of THC; and cannabidiol (CBD). Docket No. FDA-2018-N-1072 83 Fed. Reg. 15155 (Apr. 9, 2018)
• Letter to GOP House Reps for Veterans Equal Access Amendment (2016)
• ASA Written Statement for July 13, 2016 Senate Judiciary Crime and Terrorism Subcommittee Hearing on Medical Cannabis (2016)

Alaska

• Alaska Marijuana Control Board - Comments to Proposed Changes (2019)

California

• Sept 2016 Marin Health Board Resolution Letter of Support (2016)

Connecticut

• Connecticut Department of Consumer Safety Proposed Regulations (2013)

Colorado

• Colorado's Proposed Amendments to 5 CCR 1006-2, Regulation 6 Rules and Regulations Pertaining to the Medical Use of Marijuana
• City of Denver Proposed Ordinance on Marijuana Odor

Delaware

• Delaware Proposed Medical Marijuana Regulations, October 2013

District of Columbia

• Washington DC’s Municipal Regulations to Amend Title 22 by Adding Subtitle C “Medical Marijuana” (2010)
• Washington, DC Emergency and Third Proposed Rulemaking to Implement the Legalization of Marijuana for Medical Treatment Initiative of 1999 (2011)
• DC Department of Health Proposed Regulations April 2013
• Written Testimony to the DC Council Committee on Health Re October 21, 2013 Oversight Hearing
• 2014 Committee on Health oversight hearing testimony
• Letter to DC Council on Medical Marijuana Cultivation Center Exception Temporary Amendment Act of 2015
• Testimony to the Council of the District of Columbia Committee on Health and Human Services Bill 21-192, the “Medical Marijuana Laboratory Testing Amendment Act of 2015" Bill 21-210, the “Medical Marijuana Reciprocity Amendment Act of 2015”
• Testimony on B21-023, the “Marijuana Legalization and Regulation Act of 2015” and B21-025, the “Prohibition of Pre-Employment Marijuana Testing Act of 2015”
• Testimony to the DC Council, DOH Oversight Hearing (February 2016)

Georgia

• Presentation to Georgia Medical Cannabis Commission (June 2015)
• GA Academic And State Agency Cultivation Memo (2016)

Illinois

• Illinois proposed regulations for Title 77, Chapter 1, Subchapter u, Part 946: Compassionate Use of Medical Cannabis Patient Registry (Feb. 2014)

Kansas

• Public Comment on HB2184 (2021)

Maryland

• Maryland's Proposed Medical Marijuana Legislation
• Public Comments on Sept 2014 draft regulations
• Public Comments on Feb 2015 draft regulations
• Comments to Anne Arundel County Council on Zoning Bills (Oct. 2015)
• Dept. of Agriculture Regulation Comments (2016)
• Maryland HB 1479 (2016)

Massachusetts

• Department of Public Health Proposed Regulations, April 2013
• Letter to State Senate on Proposed Legislation on Edibles, May 2013
• Department of Public Health Proposed Regulations on Patient Fees, June 2013
• Letter to Conference Committee on MIP Packaging, June 2013
• Letter to Joint Committee on Public Health in Support of H. 2065 (2015)

Montana

• Montana HB 161: An Act Repealing the Medical Marijuana Law (2011)

Nevada

• Nevada Proposed Medical Marijuana Bill: The Compassionate Access in Nevada Act of 2011
• Nevada Proposed Dispensary Regulations Implementing SB 374 (2013), Dec. 2013

New York

• New York AB 9016 (2010)
• New York Proposed Regulation Comments (2014)

Oregon

• Comments on HB 3460 (dispensaries), May 2013 

South Carolina

• Testimony on S. 672 (Sept. 2015)

Utah

• Support Letter for SB 73 (2016)

Washington

• Comments on Washington Liquor Control Board Proposal on I-502 and Medical Cannabis, November 2013

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Analysis

Federal

• Veterans Equal Access Amendment (2016)
• Compassionate Access, Research Expansion, Respect States (CARERS) Act of 2015 (Fall 2016 update)

Arizona

• Arizona’s Proposed Medical Marijuana Program (2011)

Colorado

• Colorado Proposed Rules 1 CCR 212-1 (2015)

District of Columbia

• DC Second Proposed Rulemaking (2010)
• DC Third Proposed Rulemaking (2011)

Hawaii

• Hawaii Proposed Medical Marijuana Bill HB 923 (2011)

Maryland

• HB 302 Fact Sheet (2013)
• HB 1101 Fact Sheet (2013)
• HB 302 1101 Comparison (2013)
• HB 881 and 1321 Analysis (2014)
• HB 433, 490, 601, and SB 456 (2015)

Massachusetts

• S905, Dispensary Zoning (2013)

Michigan

• HB 4271, Dispensary Bill (2013)

Minnesota 

• HF 508, Affirmative Defense (2013)

Montana

• Montana Proposed Medical Marijuana Bill (2011)

Nevada

• Nevada Proposed Medical Marijuana Bill: The Compassionate Access in Nevada Act of 2011

New Hampshire

• HB 573 Fact Sheet (2013)

New York

• AB 6357 Fact Sheet (2013)

Ohio

• OH HB 523 Analysis (2016)

Pennsylvania

• SB 3 Analysis (2015)

Rhode Island

• Rhode Island Proposed Medical Marijuana Bill HB 5401 (2011)

Virginia

• HB 1445 and 1605 Analysis (2015)
• Safe Access VA Analysis of HB 684 (2014)

Utah

• SB 73 and SB 87 Side By Side Comparison (2016)