The Pennsylvania Department of Health (PA-DOH) has been busy drafting temporary regulations for its medical marijuana program since June 25, 2016. But it appears to be making good headway towards a target of completing all regulations between now and the middle of next year, with more guidance to help permitted entities be up and running in six months.

The temporary regulations are designed to explain the program’s operation, and were originally announced that they will be in place for two years from the date they were published, which is expected to be in July, 2018.

During that time period, the department will be preparing to issue more formalized regulations, and has been publishing the temporary regulations sequentially, addressing the requirements for growers/processors so that those entities can come online and begin to produce products, then detailing requirements for dispensaries and physicians, followed closely by requirements for the registration of caregivers and patients.

In August, 2017, the Medical Marijuana Program, Office of Medical Marijuana for the Department of Health issued a checklist for dispensary operations, offering a sort of general framework for dispensaries in lieu of more permanent regulations, listing information about the permit, background checks, electronic tracking system, administrative and agency compliance, among over 40 other checklist items.

More recently, the PA-DOH released a draft of regulations for patients, caregivers and medical marijuana card holders, outlining regulations that appear standard and fair – about what caregivers can do, how medical marijuana patients get their cards and the fees that have to be paid, etc.

But there are some nit-picky questions. One example: The draft states that a medical marijuana patient cannot get more than a 30 day supply of cannabis at any one time, but that, during the last seven days of that 30 day period, can replenish their 30 day supply…essentially allowing them to have a 37 day supply of cannabis which appears to violate the rule.

Still, the program marches on.

In October, the PA-DOH approved Cresco Yeltrah, in southwest Pennsylvania, to begin growing and processing medical marijuana, making it the first facility to be deemed fully operational in Pennsylvania’s medical marijuana program, something that Governor Tom Wolf jumped on to indicate the progress that the state is making in its program.

Cresco Yeltrah went through several inspections by the PA-DOH, and is fully integrated with the MJ Freeway seed-to-sale electronic tracking system. Cresco will now be able to begin accepting seeds and clones to grow medical marijuana.

In a release about Cresco, Acting Health Secretary Dr. Rachel Levine said that, in the coming weeks, they expect the 11 other licensed grower/processors in the state to be ready to grow and process medical marijuana.

Cresco was one of the highest scoring contenders in the state’s application process. It is constructing a cultivation center and laboratory in northwest Brookville and dispensaries in Butler, Pittsburgh (Strip District), and a third location soon to be announced.

The company’s 46,000 square foot cultivation center and lab facility will be constructed and equipped in phases, but the state has already signed off on the company’s secure growing environment as being fully operational.

With their controlled cultivation environment, a full grow cycle takes approximately 120 days, which will allow for their complete line of products to be available for patients statewide in February 2018. They will grow a variety of over 30 different genetic strains in Brookville and will produce an array of pharmaceutical-grade marijuana products ranging from high CBD strains, vapor oils, transdermal patches and pills.

As Cresco and the other licensed growers/processors get to work, more updated advisories on the rules for all involved in the program will be coming through the Pennsylvania Bulletin.

The medical marijuana program has already approved more than 300 applications; issued permits to grower/processors and dispensaries; approved two laboratories to test medication before it is delivered to patients; and continues to work with permitted entities to ensure they will be operational within six months.