Dr. Berg's Letter to the Hawaii Department of Health
Dr. Berg addressed the Hawaii Department of Health with questions regarding medical cannabis growing regulations, caregiver limitations, and patient transitions.
Dr. Berg's Letter to the Department of Health On December 13, 2023, Dr. Jim Berg sent a letter to the Hawaii Department of Health, Medical Cannabis Registry Program, acknowledging their State of Hawaii Medical Cannabis Registry Program Newsletter. He expressed appreciation for the clarifications provided regarding growing regulations but posed several questions seeking further detail. Questions on Cannabis Growing Regulations Caregiver Growing Limitations The newsletter indicates that after December 31, 2024, caregivers will no longer be allowed to grow cannabis for patients, with certain exceptions. Dr. Berg inquired for clarification on what constitutes lacking legal capacity for adult patients who would qualify for this exception. Five-Patient Limitation Dr. Berg asked if the five-patient limitation per grow site applies retroactively to existing grow sites currently registered with more than five patients. He also requested clarification on the timeline for compliance if it does apply retroactively. Transition Period Guidance Regarding patients and caregivers affected by these impending changes, Dr. Berg questioned whether the Office of Medical Cannabis Control and Regulation (OMCCR) would provide guidance or resources to facilitate the transition before the December 31, 2024, deadline. Registration Process for New Grow Sites For patients who will need to establish new grow sites due to the regulatory changes, Dr. Berg asked if there would be any fee waivers or expedited processing available for registration. Island Dispensary Status The newsletter mentioned an exception for patients on islands without a licensed dispensary. Dr. Berg requested a current list of which islands qualify for this exception. Dr. Berg concluded by stating his belief that many patients and caregivers would benefit from additional clarification on these points and thanked the Department for its continued work.
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