We came back online about three minutes ago and Brynn is walking us through these rules. And so far you haven't said anything that's not consistent with what's written on the page. I have not. And we are just now getting into the actual regulations that are applicable to cannabis establishments after a brief review of the definition section. So this is similar language that you saw in rule one that all cannabis establishments have to abide by what's included in statute and all other applicable laws. Two to one, this is where we really get into the requirements of the operating procedures. So this requires cannabis establishments to maintain certain records, both on site and readily accessible and make them available for inspection by the board if requested. So the list is the employee list, facility security information, advertising records, inventory records, insurance records. Seed to sale tracking, visitor log, all records that are retained by the establishment for tax purpose, a waste log, surveillance log, testing records, including all certificates of analysis, sampling unit records, license application records, SOP manuals and corrective action and preventative action records if applicable. The next section is the insurance requirement. So this was referenced in rule one about what applicants are required to submit about the insurance that they're required to maintain. So this section sets forth the minimum levels of liability insurance coverage that applicants or that cannabis establishments have to maintain. Sub-B provides that if a cannabis establishment documents an inability to obtain these minimum liability coverages, they can place an escrow, no less than 250,000 or some other amounts that's approved by the board to be expended for coverage of liabilities. And then C just provides that any escrow account has to be replenished within 10 business days of the expenditure move from it. And cannabis establishments have to be prepared to demonstrate compliance with this subsection at any time with records on site and readily available. Do we know if the insurance like these amounts have been underwritten in other states? All right, miss that. Do we know if these amounts for insurance have been underwritten by organizations in other states? So the specific amounts were taken from Massachusetts. I don't know if they ever had a sliding scale or an ability to waive some of these requirements for smaller licensees, but I got these numbers from Massachusetts. So likely, yes, somewhere there's an underwriter. I think so. So the next section has to do with continuing disclosure and the background check requirements. So this language is provides that the board has a discretion to require that entities or persons that are named in the application in the rules governing the application have to be resubmitted if the board has reason to believe that any of that information that's changed since the time that the establishment was issued a license or a renewal of their license. And they can be subject to the same background checks and financial disclosures provided for in those sections. And again, just a note that that information may be shared with other state agencies remember that's BFR and some other specific state agencies. The next section is a requirement that Canvas establishments provides some procedures regarding health safety and sanitation. So they are required to develop safe and sanitary handling procedures for all products and regular training on health safety and sanitation. Ensure that employees follow those procedures that are in place. And then immediately report to the board any breaches in those procedures that may pose a risk to consumer safety. And also that they comply with all applicable health safety and sanitation rules which would include the occupational and safety and health administration rules, fire safety rules, building standards and occupancy rules and good manufacturing practices for food rule that's issued by the Department of Health. And a note here at the bottom that nothing about that subsection E assigns any responsibility for enforcement to those other agencies and the board retains full responsibility for enforcing the safety standards of Canvas establishments. Is that put in there so as not to jeopardize their federal funding? Is that the thinking there? That's exactly right. It's not to jeopardize other people's federal funding. Right. Does that put us in a bad position though? I mean, because we have to rely on those partners as well. But we're saying we're taking sole responsibility. I mean, I'm just saying if there's like negligence on this side of BOSHA or fire safety or something are we responsible for that negligence based upon that language? I wouldn't say so, but if you want to be more careful we could delete the second sentence of that short paragraph. I think that makes sense to me, but I don't know, I don't know what this rule does as far as... I don't think this rule can bind anybody else. The key thing here was to assuage some other agencies concerns that the federal government might look at these rules and say, well, hey, it says right there that people have to follow your rules. So doesn't that mean here? So just removing all concern for them, but I think it would be sufficient to do that with just the first sentence. And then the second one is more likely to come into play with your concern around us all of a sudden now being responsible in a way that we shouldn't be for somebody else's error. Yeah. Julie and Kyle, what do you feel about that? I would be comfortable removing the second sentence if that's... Yep. Okay. Yeah. Okay. All right, yeah. I think taking that second sentence out makes me a little bit more comfortable. I kind of read it on its faces. This is an opportunity for power grab from other agencies to come in and try and tell these establishments what they cannot do from an enforcement perspective and that kind of... That will live with us or our designee, but I can understand how it could be taken in red other ways. Okay. Yep. So we'll move on to employment and training. So this section provides that any employee of an establishment or a person who works at a cannabis establishment has to complete an enforcement seminar once every three years. Within 60 days of hire and then annually thereafter, employees of cannabis establishment have to complete training on a variety of topics, which are listed below. And there's a specific provision here that if the employee is an employee of a retail establishment who is selling cannabis or cannabis product, they are required to complete the first eight of these trainings prior to being able to sell any cannabis or cannabis products that a retail establishment. So one through eight are training on the establishment's operating, security, health, safety, family, teachers, health effects of cannabis, compliance, enforcement, inspection, incident reporting, and record keeping, acceptable forms of identification for staff and visitors, inventory control and the appropriate tracking system, cash handling, preventing the sale of cannabis to minors, signs of overconsumption and signs of mental health or substance abuse disorder are the first eight. So those are all required prior to any employee selling cannabis or cannabis products.  That's the complete list of required training within 60 days of hire and then annually thereafter for all employees. So the next section deals with trafficking or tracking, tracking cannabis. So this directs cannabis establishments to comply with the inventory tracking system, which is that defined term we went through earlier in a way that's determined by the board and requires them to cooperate with any third party vendors that the board uses for tracking. And that tracking system will be readily available for the public and will not change, the system will not change without at least 90 days notice. So this sub-D provides the establishments that are responsible for the cost associated with complying with that tracking system. Sub-C provides all cannabis, cannabis products have to be tracked using the system from the time the cannabis is grown by a cultivator until it's sold to a consumer. And the establishment has to reconcile all on-premises and in transit cannabis inventories every month and must complete reconciliation within 15 days of the end of every month. So sub-D provides that if cannabis is not ultimately sold it has to be disposed of as provided later in this rule and that disposal has to be entered into the system. Sub-E provides that the establishment has to conduct comprehensive annual inventory audits. We're doubling up on the annual requirement here, we'll fix that. At least once every year from the date of the previous comprehensive inventory. Sub-SF provides that people using the inventory tracking system are responsible for all the accuracy of the information that's entered and ending the statements or emissions could be considered a license violation affecting public safety. And lastly, establishments must have the ability to reconcile transported and on-hand products inventory with the system and any associated transaction history and transportation order receipt. So next is the transportation section. So every establishment has to designate a cannabis license agent, which we went through the outset and register that agent with the board. Only agents are permitted to transport cannabis between licensed cannabis establishments. These agents have to carry their ID card issued by rule at all times while transporting. And transportation must take place in a vehicle provided that the board may waive this requirement as discretion. And when cannabis is transported in a vehicle, it must not be visible from outside the vehicle. Driver must not be able to access from the driver's seat and the vehicle must be unmarked. And vehicles used for transportation have to be registered currently and updated in their registration inspection and insurance. G is a provision that agents may only transport between cannabis establishment and the transporting establishment has to enter all of the products to be transported into the tracking system. And while transporting, the agents have to use GPS tracking technology that records their route. But this is a requirement that can be waived with the board's discretion. So Sub-J provides that before leaving an establishment, the agent has to generate a transport manifest that includes the following requirements listed there. Archer date, location, time, name of the destination establishment, location of the destination establishment, name and ID card of the agent, product name and quantities to be delivered, estimated time of arrival, transport vehicle information and a signature line and a time notation that's signed by the employee of the receiving establishment. Sub-K provides the agents have to transmit these manifests before departure to the receiving establishment and the receiving establishment has to log the time of the receipt of the products and upon receipt of the transport, the receiving establishment has to ensure that all the products received are as described in the manifest and adjust its record in the system to reflect the receipt of the products. There's any discrepancy the receiving agency has to specify them. On that one, I'm just saying of Siobhan's concern about there not being a timely update. Do we want to say, you know, we have no just prescription about when they need to update their inventory tracking system they're receiving. But if we put something like in the inventory tracking system or reflect the receipt of the, it says the same day. Oh yeah, all right, I did already. Yeah, all right, sorry, yeah. Yeah, I just, I thought it was a good one. Yeah, perfect, great, thanks. Okay, this sub-N provides the agents have to log time arrival and departure from any stops whether planned or unplanned. And these logs have to be maintained temporarily, have to give reason for the stops that aren't in the establishment. Oh, provides the agents have to stay with their vehicles to the extent possible, while transporting products. And where they have the option to stay with their vehicle, they must do that. And except for when the agents are entering or exiting the vehicle, the vehicle has to remain locked. P is no crossing state borders while transporting products. Q is stored in transportation has to be under conditions that will protect the product from loss and theft, as well as against any physical, chemical and microbial contamination and against deterioration of the product. R provides that anyone who's establishing over 20 pounds of cannabis has to be transported in a secure, locked storage compartment within the vehicle. S provides that agents have to report to the board any vehicle accidents, divergent losses or any other reportable incidents that happen during transport within 24 hours. And then lastly, if a cannabis has failed and a required testing or has been contaminated or in any way presents a cross-contamination risk to other cannabis, it can only be transported if it's physically segregated and contained in a sealed package that prevents that cross-contamination. Okay, moving on to waste disposal. So this provides that with all of the applicable state, federal, local regulations the ordinances apply to waste disposal from cannabis establishment. And that includes all regulations pertinent to chemical, dangerous, hazardous waste as well as pesticides, other agricultural chemicals. Cannabis has to be rendered unusable and unrecognizable before it's disposed of. And this is a list of the acceptable methods for rendering it unusable and unrecognizable. The board is gonna enumerate a policy that with a complete list of what methods are acceptable. And that list will be available to the public. And this list includes what may be on the list that's enumerated by policy. Or any organic material that either doesn't contain any THC or has a THC content of under 0.3% doesn't have to be rendered unusable and unrecognizable. It can be composted or disposed of in a way that's consistent with applicable law. And then just a reiteration that disposal has to be tracked within the tracking system. So moving on to packaging. The packaging requirements are as follows. Must be child resistant and opaque. Include the required warning symbols and labels as provided later in this rule. Must clearly identify the contents and the ingredients and the THC content. Must be in a resealable packaging that remains child resistant for multiple uses if multiple servings are contained in the package. Must be free from false or misleading statements and it must not use any objects or child friendly depictions of food or other consumables or any other display depiction or image that's designed in a manner likely to be appealing to buyers or anyone under 21 years of age. We've talked a little bit about the deli style packaging. Do we need in the first one in A to be specific about that's when it leaves the retail establishment or do we not need to do that now? So this section is like a generalized packaging requirements section and there are further individual packaging requirements sections that change the different license types where it's relevant which I realize isn't the maybe smooth this way to do it but it does reflect the statutes which had multiple requirements depending on license type. So when we get to retailing I think it makes sense. There's another section about packaging there and we can talk about that a bit more there that works for you. Okay and so the next section is the warning labels. These warning labels are exactly as they appear in the recommendations that the board voted on two weeks ago. So all marketing advertising, branding and promotion has to include this warning label which is was developed and approved by the subcommittee on public health. So I'm just so I'm clear in my head Department of Health has reviewed this like we were supposed to and they've signed off because they were, I think they have to independently report on the warning label potentially. That's right. They do and they were our advisory committee subcommittee that worked on this kind of representative of the Department of Public Health on it and they did approve of this label. We're accepting their recommendation that subcommittee essentially yes. And the same is true for the following warning symbols developed by the public health subcommittee with the Department of Health and accepted by the board. Same with this label about keeping out of reach of children and includes multiple servings. All of this is directly taken from the recommendations from the public health subcommittee and move on to advertising. So there are restrictions on advertising contained in statute and in addition to that these following restrictions also shall apply to kind of establishments. So establishments are prohibited from using any objects as described above in any depiction or image that's likely to be appealing to minors or anyone under 21 that includes brand logo development any advertising used for the purposes of marketing. Establishments are also prohibited from advertising or promoting in a manner that's false, untrue or misleading. And they're also prohibited from including in the advertising any statement concerning a brand or product that's inconsistent with any statement on the label. Websites for establishments have to have age gating and social media accounts for establishments may only promote products using link to their age gated website. And any images or other text regarding products is otherwise prohibited. So a company can show a picture of a product on its social media page. Correct. They can link to their website with BHU to show products. Next section, audience composition presumptions for advertising. So the board has to make some presumptions when it's determining whether or not opposed to advertisements meets the statutory requirements for advertising. So the board can consider that more than 15% of the audience will be under 21 and less the prospective advertiser can show by a preponderance of the evidence that less than 15% is reasonably expected to be under 21. And that evidence must include reliable, verifiable and current audience composition data. Board can also make the presumptions of the audience for any outdoor advertisement is the general public. And that those under 21 will have the same prep once that audience that they do in the general public. Unless the prospective advertiser could demonstrate that outdoor space will not be accessed by the general public. And that those who can access it meet that audience metric that's required in statute. And except for signage, window displays, text, items, objects inside a canvas establishment that are visible to a person outside will be considered outdoor advertisement for the purposes of this rule. All right, so I'll move on to visitors. So this is sort of a general statement that visitors are only permitted to a cannabis establishment to the extent that it's provided for in the rule. And if it makes, if the rule does not is silent on visitors at a certain type of cannabis establishment then they're not permitted. Provided that contractors, the companies by cannabis establishment employee have an ID card, board designees and cannabis license agents that are making deliveries are permitted to cannabis establishment. And that provision specifically doesn't apply to retail establishment. Can we go back? I'm sorry for a second. To the audience composition and see window displays are items. Is that, do we intend that to be any item like t-shirts? Yes. Yes. That's the word item. I just wanted to be sure. Cool. So if someone does have just so- What cannabis items necessarily? Someone has large storefront windows in downtown Main Street, Montpelier. What could they have in their windows or should they just have them all kind of with blocked off? I mean they could have, they can have the basic signage that's defined in the statute in that section. And it's going to be the case that they're not able to do that much more than that. If you give me one second, I can look back at, this depends on the definitions for advertising and I can look back at that in the statute and I'll have a better answer for you in a second. But I think the short answer is there won't, isn't that much that they'll be able to put in those windows. I think that's what my question is getting at. Like could you have clothing items in your window, t-shirts or something like that and then have the rest of your displays behind that so that it can't be seen by from the street but you don't necessarily have to black out your windows. I think partly the reason for the breadth of this as I understand the policy is that the t-shirt could have products that the retailer sells. And that would effectively be getting around that advertising prohibition if you did try to carve stuff out like that. So yes, it is a broad, people will be able to tell the world that they're there with the sign and not a whole lot else. But let me look back at the advertising definition maybe get you a slightly different answer or a better answer. It may not be that different than what I just said though. A lot of that reasoning comes from the statute not necessarily from the subcommittee or from us. Yeah, that's a good point. It's a very restrictive statute in terms of permissible advertising. Okay, so we can come back to that. Let me know when you're ready. In the meantime, I'll talk about visitors. Nope, I already talked about visitors. Talk about instructions. So establishments have to submit to inspections of their physical site and an inspection of their records if the board or the board doesn't be requested. The next section about inversion and diversion from the legal market provides that no establishment can purchase or obtain cannabis or any other cannabis product from an entity that's not licensed and except for retail establishment, no cannabis establishment can sell or transfer cannabis or cannabis product to any person other than a licensed establishment statute of course. Next section is about compliance and other jurisdictions. So this just provides that to the extent that the principle of a licensee or controller of a licensee also controls or is the principle of a licensed cannabis establishment or the equivalent of a cannabis establishment of different jurisdictions. That establishment must remain in compliance with all of the laws and regulations of this jurisdiction. Reporting theft, establishments have to report such theft or loss of product to the board immediately after they discover such theft or loss and enter that loss into the tracking system. We add by the end of the day or something immediately does that, is that sufficient? Or is, I mean, I'm fine with it immediately. Immediately is, I think, I think it's fine. Sorry. Yeah, I mean, it's a little bit undefined but I think, you know, somebody waited a couple of days that would clearly not be immediate. Thank you. Can we go back up for one second to, yeah, two, two, two, one, five. You know, I know that our advisory or our exploratory committee is looking at other license types, including Farmgate or direct to consumer sales. I know we have kind of one hand tied behind our back with statute, but just considering we might make a recommendation, do we want to keep this language in our proposed rules right now? Yeah, so I think it still works even with another license type. Rule one basically is designed to say any license type needs to meet the X number of regulations and then it does specify further ones for other license types, but it doesn't mean that another license type that has been invented yet or hasn't been allowed to exist by the legislature yet couldn't still be allowed to exist. And then the first portion of rule one would apply to that new license type. It just wouldn't have specific further requirements. So you thought about this and... Yeah, yeah, so I think, you know, it may be the case that you need to reopen rule one to provide specific requirements, but even if you didn't, it's written in a way that allows for those new license types to come into play through legislation and then the first part of rule one will apply to those new license types. The first part of rule one says any license that's been permitted to exist by the legislature language along those lines. So it accounts for potential new license types. And I think that pertains to this as well. Okay, just wanted to make sure we didn't completely box ourselves in with the direct to a consumer or if there is consumption lounges that, you know, depending on the scenario might also be selling some type of product. No, we haven't. And maybe, like I said, it may be the case that you want to add stuff to rule one to address those new license types, but those new license types won't be prevented from existing by this rule. It allows for flexibility in that time period before you have a chance to promulgate a change to rule one. Okay, thank you. Sorry to backtrack. Yeah, so real quick on the advertising thing, Julie, it's really gonna depend on the definition of advertisement and whether somebody thinks that they can squeeze something in here. It's gonna be tough, but maybe not impossible with some creative thinking. And so this advertisement means any written or verbal statement, illustration, or depiction that is calculated to induce the sales of cannabis or cannabis products. And then it goes on to a list of bunch of things that that might include. So somebody might be able to put something in a window that they could argue is not calculated to induce sales of cannabis or cannabis products. So they could still put up like Christmas decorations or holiday decorations. Exactly, something like that. That doesn't really have something directly to do with cannabis or cannabis products might be the case. I mean, if they did it while also hanging, cannabis leaves from it, that might be, now we might be in different territory. So it's gonna be a case by case analysis. But yeah, it's restrictive, but doesn't make it impossible to put something in the window if you want to. Okay. Thank you. So the next section is about co-location. And the board did take a look at some proposed language for co-location on Friday. There are some differences here, which we can go over now. So this provides that cannabis establishments can operate at the same location subject to these conditions. This does not apply to retail cannabis establishment. So any other type can operate the same location as long as the co-located operation isn't in violation of any local ordinances or regulations. So the book provides that each establishment that's operating at the same location has to comply with the following provisions. First, they have to have a distinct and identifiable space area or plot. Each license be operating in its own area. Each establishment has to post notice of its license in its distinct area, space or plot. And each one has to maintain all the business operations and compliance requirements and record keeping obligations that cannabis establishment would have to maintain. If it were operating in its own location and they all have to otherwise comply with the provisions of this rule and the relevant statute. Subsea provides that co-located establishments have to limit their total canopy size to the relevant tier six plant canopy limit provided that the board has discretion to waive that limit. Can someone remind me why we didn't apply it to retail establishments? Yeah, is this saying that if you have a retail establishment you can't also have like an indoor cultivation facility in the same general building? Or are you getting at you can't have a building where there's multiple retail establishments inside the same building? The second was the intention. And now that I'm looking at this I think we could be clear about that, so I'll work on. I'd imagine there's gonna be folks wanting to build their own vertically integrated. I'll work on clarifying that. Yeah. Or we take the final vote. Thank you. Okay. Was that your question? Well, I guess I was also thinking about multiple retailers in one location. Like if you had multiple small business retailers that wanted to open and use the same four walls should we permit that? Maybe we're not. Maybe we don't need to discuss that now. Like a like a like Reading Terminal Market in Philadelphia or something like that? Yes. Haven't talked about that at this point at all. Yes. No, if I have. We don't. Strong feelings either way. To me now doesn't mean we have to discuss it either. So the part that changed about this is that last provision in subsea, which is we kept this at the either 25,000 for indoor slash 37,000 for outdoor. But we do have the ability to go above that limit at our discretion. I think, you know, we've talked quite a bit about the benefits of co-location for reducing barriers to entry for, you know, smaller cultivators that wouldn't otherwise have the capital or the lands to start their own cannabis establishment. And that this does provide an avenue for those folks. I think the, you know, the kind of one of the downsides that we talked about is, you know, by opening up that door, there's, we need to be careful not to allow certain entities. One, to kind of have kind of shadow control or indirect control over their tenants. And two, we don't want to create a situation where one entity is kind of too big to fail.  That's a big chunk of the market that would be impacted. So I think we all kind of want to encourage the first model and we kind of want to at least have some ability to retain discretion over the second model where, so I think this, at least in these early stages, because we are trying to start slow and we are trying to focus on small cultivators, this strikes that balance, which will essentially cap these facilities at 25,000 square feet indoor. And if for some reason, you know, we decide, well, this has been a real benefit to social equity applicants, the DEI applicants. Maybe we should allow this company to expand and create some more cultivation stalls or whatever we think that we could allow that on a case-by-case basis. Are you thinking we'd allow folks in their initial application that want to, depending on the types of services they might provide in their building and want to go over that at the onset from a discretion perspective, or are you thinking we might consider or hold that conversation or are you thinking we can make that determination somewhere further down the road? I mean, either. I feel like we could, in an initial application, consider exercising this discretion. But it would, to me, what I would need to see is a real commitment to social equity, essentially. I would need to see that, you know, the reason why we're going over the tier six is because we want to have 15,000 square foot or 25,000 square foot or 26 stalls. And, you know, 50% of them or 100% of them are set aside for social equity applicants and we're waiving rent in year one. You know, I think that there is ways where we might do it initially, but recognizing that, you know, we've been told to kind of start slow and, you know, it's in our ethos to really focus on social equity and small cultivators. And so, you know, I think I would have a hard time justifying co-locating, you know, 10, 25,000 square foot. Yeah, I don't want this industry to start looking like huge 100,000 square foot warehouses just circumventing our tiering structures that way. Is there somewhere in here, and I'm missing it, that what kind of ownership can the person who owns the building have in the other licenses that are there? So can they only charge rent or can they have some ownership over the business? So we have down in sub F and, David, maybe you just want to talk about that section. Yeah, so this section is trying to address the issue of co-located establishments that are effectively operating in defiance of the legislature's law, that you can't have multiple licenses under with a single ownership. And so that's what the first part of that says very directly, saying if you're operating in a manner that achieves that, the board can step in. And then more directly to what you just said around sort of ownership or something like that, the second part gets at that too, saying that nobody can exercise control over a cannabis establishment. And again, control is a defined term that talks about ownership and ownership stake. And that piece basically says, look, you can't do that either without also disclosing in rule 1.4. And that gives the board the insight to understand whether really it's a way of making sure that the first part of that sentence isn't being countered by a group of people who are trying to get around the multiple license. Even, and you know, some of this might not happen with an intentional attempt to get around, but effectively somebody is operating in that way. And that's not what the law allows and the board needs to have enough insight to be able to prevent that from happening or take disciplinary action if needs to. I see all the social equity benefits that you're talking about. Make sure we protect people from any sort of predatory. Yeah, sure, right. I think, yeah, I mean, again, not to keep bringing back Savan into this, but he did kind of bring up the point in his comments to us that, you know, if you're gonna go above a tier six or if you will, you know, you should really look at what the rental agreements are going to be and make sure that they're not tied to kind of the profitability of the underlying, they kind of sub-licensee, not sub-licensees, but the kind of the tenant's licensees because really then you could start seeing how well, I don't have an ownership in your company.  So, you know, I do think that that's why we certainly want to maintain discretion for above 25,000. And this provision I think protects also the people below 25,000 at tier six. I'm comfortable with it, with the, with the adjustment that David's gonna make on the retail being allowed at the same location as other different license types. So thank you for view. Most of the parts you didn't, are D and E. The effect of these two is essentially that the security requirements that apply to these co-located establishments have to be essentially the most strict, security requirement that would be applicable to either the entire combined plant canopy if it's co-located cultivators, or whichever individual license type would have the most strict security measures if they're co-located. Do a couple typos in that as well. Fixing them right now. So easy to see on such a large screen. Okay. And then just a note that that co-location section doesn't apply to dispensaries, which are governed in a later section of this rule and by a rule three. So regulations applicable to cultivators, section three that provides users with the regulations that apply to cultivator licenses versus cultivators. So the section requires all cultivators to abide by the guidelines set forth by the agency of agriculture on Custiside. And establishments of the cultivator license have to report to the board at the time of their harvest regarding the use and quantity of Custiside for safety. Next section governs visitors to cultivation sites, provides visitors have to be escorted at all times by employees, as an ID card. Visitors may not consume cannabis on site, may not purchase cannabis on site. Must be over the age of 21. And the establishment is responsible for ensuring that those age limits are complied with. Establishments have to issue an ID badge to all visitors, except for tier one cultivation licensees. They don't have to issue an ID badge to a visitor. But those that do have to issue a badge, badge has to have a design approved by the board, be visibly displayed while the visitor's on site and be returned upon exit. Visitors have to be logged in with the time of their entry and exit. And that log has to be made available to the board on request. And they have to be retained for calendar year. Safety protocol must be established by the, by the licensee before allowing visitors. And that protocol has to be on record with the board. And then a final note that board doesn't use or not considered visitors for the purposes of this rule. Moving on to testing requirements. So cultivators have to have their products tested in accordance with these rules and in accordance with the guidance that the board establishes to enumerate the rule. Testing for potency of a crop has to take place within three weeks of harvest, preceding harvest. And all of other testing has to occur in accordance with the relevant sections of the rule and policy. And test results have to be saved for no less than one year. Next section deals with adulterated cannabis. So subsection A is a reference to the rule four which the board hasn't reviewed yet. Sub B provides that the cannabis is adulterated due to willful or intentional misuse of pesticide. The cannabis has to be destroyed in accordance with the destruction portion of the rule and reported to the board by the cultivator of the testing lab. If the testing lab is where the adulteration is discovered. If the cannabis is adulterated due to no fault of the license holder, they can attempt to remediate if that can be done safely. And then a note that adulteration without fault can occur due to atmospheric drift or a similar natural phenomenon. And then we've got some finer detail here about remediation. It may include refinement into a manufactured product and any remediated product needs to be retested, subsequent to remediation. And if an adulteration poses a public health threat, subsequent to the remediation, it will, the product has to be destroyed in accordance with the rule. Moving on to cultivator specific packaging requirements. When a cultivator sells cannabis to any other licensee, other than a retail license, packaging has to include all the requirements that forth the statute and all the baseline packaging requirements that we just went through and the testing results, which can be conveyed with a QR code or another means that makes it available on a website. And here in sub B are the requirements for when, cultivator sells to a retailer, packaging again has to include all those statutory requirements, baseline packaging requirements, the testing results, which can be conveyed with a web address or QR code. Okay, moving on to cultivator inspections. This provides that the board can conduct annual inspections, which may or may not be noticed to ensure compliance with the rule and the statute. Inspections can include taking samples, taking photos or video, talking to employees or owners, inspecting the records for equipment or vehicles, and taking any other reasonable measure to evaluate compliance. Do we want to commit to annual inspections, just given that we don't know what our staff is going to look like? I didn't do a lot without helping. I just, that's a, it's kind of a shall. Instead of may or wait. Yeah, I mean, it's a will conduct, which essentially is a shall. So I feel like the first year of inspections is probably a learning curve forever. Probably an important learning curve, right? I don't know if you'll need annual inspections in five years, but I feel like for the first three years, probably do until work, you know, that doesn't answer your staffing question. So period's a problem, but I think, I mean, if the question is whether we can do what's contained in the entire rule without knowing our staff, I don't feel like this is the one straw that's going to break the camel's back. With that said, I think there's no reason why you shouldn't change it today, unless you want to ensure that a future board will. I mean, you could just cut out the will conduct inspection. You cut out that at least annually. We will conduct it. We shall conduct inspections. I just don't know if we're gonna be able to do it annually. I would want to, of course. So then it should be May, right? I think if you just cut out at least annually, then I think it conveys that we will be conducting inspections. It just might not be every year. I'd be okay with that, I think. I mean, my intention would be to conduct them annually. I just want to kind of at least not have to revisit this if annual inspections are just not feasible. I think that's fine. That's a decision. You could do it. We're just not committing to doing annual inspections, which I think we probably will do just to be clear. Just make sure you say that. Yeah. We hope to do so. I'm gonna move on. Next section deals with sanitation. So cultivate, this is specific to cultivators. They have to ensure that anyone working at a cultivation site with an illness or injury doesn't become a source of microbial contamination to a crop that waste is properly removed. So it doesn't become a source of microbial contamination and that cultivators have to ensure sufficient sanitation to minimize attracting pests. Cultivation and operations information is the next section. So this is information that has to be submitted to the board within 60 days of getting a license. Cultivation schedule, grow medium, any mixed light cultivation plan and schedule, irrigation plan, schedule, waste management, pest management and a plan to secure regulated products such as pesticides. Getting into sampling. So these are samples applicable to vendors and employees. So any samples that are given by a cultivator have to meet these requirements. So first cultivators may provide a sample of flower to a different license site both failure manufacturer or retailer. As long as those samples are not consumed on any like premises and are tested in accordance with the rule. Samples have to be limited to the following aggregate amount in a calendar month. Four grams per strain of flower per vendor and no more than seven strains of flower per vendor. Works out to about an ounce. So an ounce a month is the limit. Bender samples have to be labeled. Samples have to be designated and identified in the tracking system. Sub-B applies or the requirements that apply to employee samples. So the rule also allows for cultivators to give samples to employees to determine whether to make a product available to sell. Again, with the restriction that they can't be consumed on a licensed premises. Again, we have this aggregate limit in a month, four grams per strain per employee no more than seven strains of flower per employee about an ounce a month. And then employee samples have to be labeled quality control sample not for resale. And then again, samples for employees have to be designated and identified in the tracking system. They keep cruising unless somebody stops me. So section four is the regulations that are applicable to those outdoor cultivators and mixed use cultivators. So security management practices is the first subsection. So security management practices applicable to these license types include the following. Fencing, video surveillance, alarm system, photographic surveillance, motion activated flood lights which may face away from the plant canopy. Security services may or may not include physical presence of a guard, motion sensor trail cameras and control point of access. So on this one, I thought that we had decided that the motion activated trail cameras could be a subset of video surveillance system. So we didn't need that as a separate one. And then I also thought, I don't see the real difference between fencing and control point of access and may I'm just forgetting something? That may become clear when we go through the other sections that have to do with the viewing from the public road because there are provisions that, if there's restricted site view from a public road is not sufficient. So yeah, on the first one, that may be entirely right. We can delete if you feel like that is repetitive, may have dismissed that edit app with a slide presentation. And yeah, control point of access, I think we can return to it, but in carried to get speaking from the hemp sort of regulation standpoint did, I asked that exact same question, I wonder what it meant. And he was basically saying that I would boil it down to like natural geography creates barriers that are as difficult as a fence to get across. And if that's the case, and there's one or maybe two points of access outside of those and those have a gate that should be sufficient. That's the basic explanation that I doubt. That you have like a swing in the island. Sure. Or like a swinging gate fence at the long, at the end of a long dirt road where nobody else really has access to that piece of property. Okay. As long as there's some distinction there, I'm fine with it. That explicitly means, but I think it was unique enough to kind of warrant keeping it as a separate distinct best management practice from a fence. Yeah. Okay. So moving on to the standards for those outdoor security management practices. Just sorry for the like clerical, but do you need, which do you need the may or may not? Couldn't it just be may include just as a stylistic point? Are we looking under security services which may or may not include? Oh, yeah, yeah, we can definitely. And sorry, the decision point is to delete motion sensor trail cameras and assume it's under video surveillance. Right. Or the photographic surveillance, one or the other. I think it's captured in there. I just don't think it should be a standalone. I think the point, the only drawback to that is because we're using like a tiered system of management practices, the more we consolidate them, the more we're de facto getting away from giving folks different options to actually facilitate what they're doing. And I get that they're pretty similar, but if we go through this and it's like the higher up in tier you get, you need to start doing more. The lower tiers will have to start doing more because there's less distinct options. You know what I mean? Yeah. I mean, my thinking on this is just, someone puts up a single motion sensor trail camera and they think that they've satisfied this. I just feel like that's a little bit, you know. You'll be approving that, sorry to interrupt, right? Who would approve that plan? I think that you could say my video surveillance is this motion sensor trail camera. I think, and then we could approve it that way. I just, there are standards for video and electronic, video photographic surveillance coming up in the next section that may. Okay, why don't we look at those and verify some of this or may or may not. I'm getting punchy now. Then, yeah, section is the standard. So fencing has to be sufficient to prevent unauthorized entry to the cultivation areas. Electronic security has to be operating for no less than three weeks prior to a harvest, as well as while drying, curing or storing. And the video and photographic surveillance equipment has to retain footage for 30 days through date and time stamps, be capable of producing usable images and the lighting conditions where it's placed, and be placed in a way that allows for clear and certain identification of what's happening in the immediate vicinity of the cannabis product and be exportable and transferable to standard computing equipment and have a specific threshold for resolution. So here's, I think we're gonna hopefully get some clarity, the minimum outdoor security management practices. So outdoor cultivators have to abide by these management practices unless they apply to the board for a variance from the fencing requirements. And that's where the board of the authority to grant a waiver on that fencing requirement on a case-by-case basis. So tier one outdoor cultivators and mixed use cultivators have to utilize at least one of the outdoor security management practices that we just described. Tier two have to use at least two. And on tier three has to use at least three. And one of them has to be fencing. So one of them must be fencing for tier two, three, four, and five. And six, because tier six has to use all of them. Can we go back to the motion center check? So I wonder if it's better to include that in the guidance of what's acceptable? That's what I would do. I mean, it just seems if you're choosing to, I would choose video surveillance system and motion sensor trail camera and say that they're the same thing. Because I think Kyle's right that we wanna provide lots of options, but we might find that those options are not sufficient or we might find that there are other options. No, I get that. I think motion sensor trail cameras can run the gamut of how isolated they are, how effective and efficient they are. So if we're gonna get prescriptive on video surveillance requirements, we may need to, and it's just not all of those. What am I trying to say? A trail camera, if it's included in the video surveillance system, I don't know enough about trail camera the technology since I'm familiar with them when my dad was using them at our farm when I was younger. Will they meet that kind of criteria laid out in the video surveillance or are we kind of mooting them out because they might not satisfy some of those? I didn't see anything in there.  I think that's, that might be, but I would imagine most of them are high def these days anyway. You can alert your phone when there's motion. Okay, I'm not gonna.  I did do a little research on that definition resolution issue that I was writing these up. It does look like 1080p and I'm sure we'll get feedback on this and I may stand corrected, but it does look like 1080p at this point is just industry standard, even for like pretty low level commercial residential type of cameras. So, you know, well, that I think has that basis but we can also hear from people if I feel. My ring camera on my front door technically be a. I think so. Is that your trail camera? I think it would be. Or it would be a video surveillance system. Okay, you, you went, you went this way. Okay, I'm gonna move on to visibility from a public road. So, if cross is visible from a public road and that public road is defined in statute, there must be a physical barrier of concealment that's created so that the crop is not visible. So that could include fencing, hedges or building structures. And then two, four or five provides that the board has a discretion to require some additional security measures either accurate and specs a licensee and decides that there are security risks or that the crop is visible from the roadway. Or if the establishment experiences more than one incident of theft in a one year period, the board can require additional security practices. Yeah. You know, again, I think this outdoor security idea that we've created is new and not really existing in any other jurisdiction and very confident and hopeful that it'll work out as intended, but this provision I think helps in case things are not going as we hope to kind of make ensure that outdoor cultivate cultivation facilities are kind of rechecked by us if they are experiencing issues. Okay. So security for drying, curing and storage for outdoor cultivators has to meet the requirements for security for indoor and mixed use cultivators which we're gonna get to in the next section. And then the last subsection here provides that outdoor cultivators may move their plants inside for the winter months when outdoor cultivation is not possible, specifically mother plants, plant seeds and clones that are in propagation for vegetation phase development and just a requirement that these licensees may not cultivate campus indoors. They just may move these non flowering types of plants inside. Okay. Section five is getting into the regulations that apply to indoor and mixed cultivators. So first up is security requirements, locking perimeter doors and windows only individuals with ID cards granted entry. And they must have, and they may have keys or a key equivalent. The requirements that all perimeter doors and windows have operational security alarms except for tier one and next tier cultivators aren't required to have those security alarms unless the board specifically requires it which they may do on case by case basis. And lastly, that video surveillance with continuous monitoring of any space that contains cannabis, either growing or harvested or cannabis products that's required. And that surveillance has to meet the standards that they're just discussing that out previous section. And the security for drying, curing and storage has to be the same as these requirements here. Moving on to energy standards. So Vermont commercial building energy standards apply to indoor cultivation facilities in that the building envelope has to meet the standard for insulation. Non-cultivation lighting must meet the standard for new buildings and retrofits. Ventilation system must meet the standard and the HVAC system has to meet the standard for efficiency except the HVAC equipment that's used for cultivation does not need economizers and heat for capture. Greenhouses have to meet the standard for HVAC equipment efficiency except that again the equipment used for cultivation doesn't meet the economizers and heat for capture. And lastly, the fans and clean water pumps that indoor facilities have to comply with the most recent energy efficiency standards that are adopted by the federal department of energy. Energy standards for lighting. They have to have a minimum of 1.9 photosynthetic goton efficacy and lighting for greenhouses. The requirements are that the envelope has to have a minimum youth factor of 0.7. And if the greenhouse uses lighting fixtures to supplement the sun, that cultivation lighting has to have a minimum of 1.7 PPC. But if a greenhouse has total connected lighting load of less than 40 kilowatts, it's exempt from those lighting requirements. And again, a lot of this was designed to ensure that organizations like efficiency Vermont can help folks with meeting this depending on what they want to do and going above and beyond what we're requiring. Okay, so moving on to dehumidification standards. Any one of these dehumidification systems must be used for end-to-art cultivators, either standalone dehumidifier that meets these energy factors, enumerated in subsection one or two. Integrated HVAC system with on-site heat recovery. Designed to fulfill at least 75% of the annual energy for dehumidification for heat. Chilled water system. Again, with that on-site heat recovery. Solid or liquid, desiccant dehumidification system. Four system designs that require a dew point of 50 degrees Fahrenheit or less. Okay, I'm gonna move on to the reporting requirements and reduction efforts. So this section requires license holders to report their efficiency and water performance benchmarks to the board annually as a part of their license renewal. Licensees have to annually update and submit to the board all of its SOPs regarding equipment maintenance, calibration, and operation for all of its major energy equipment. Also, license holders have to annually assess and report to the board on opportunities to reduce their energy and water usage, which should include identification of potential energy use reduction opportunities, plan for implementing those opportunities, consideration of opportunities for renewable energy generation, strategies to reduce the electric demand, and engagement with energy efficiency programs that are offered around the state. Okay, I'm gonna move on to the out of cultivators and into manufacturers. So safety requirements for manufacturers, they have to the building and safety code, fire and building safety code regulations as adopted by the Department of Public Safety apply to all manufacturing operations. Manufacturers have to meet all the security requirements that we just went through in 2.51, which is the indoor security requirements and mixed use. Manufacturers have to have their products tested in accordance with rules, and the test results have to be saved for no less than a year. And then the packaging requirements that apply to manufacturers, all of those statutory packaging requirements, and the packaging requirements contained in 2.28 of this rule. The packaging for consumable cannabis has to include the number of servings in the package and serving size, provided that those servings have to be easy for a consumer to measure, either by clear and visible indentation on the product or physical separation of each serving. And they also have to include a warning that the impairment effect of the cannabis product may be delayed by two hours or more. Packaging requirements for non-consumable cannabis have to include the ingredients that were used in production, common irritants warning, and then a notice that the product is not proof onto additives. So these are prohibited additives for cannabis product, any chemicals other than those allowed in the processing of product, any psychoactive compounds other than those that are naturally occurring in the campus, any artificial sweeteners or flavor, but provided that this only applies to oil cannabis products and cannabis flower addibles. So moving on to records that manufacturers have to maintain. So they have to maintain on-site readily accessible all records of purchases from any manufacturer or supplier. And again, they have to be provided to the board on request. They have to maintain records of the name and business address of the manufacturer, of any cartridge or battery, atomizer, coil, hardware, device, any other component that's used in vaporized products. And they also have to maintain a copy of the COA for each thickening agent, or terpene to use in production. And those certificates have to be provided to the board upon request or to a retailer. I'm gonna move on to vendor samples for manufacturers. So this section provides that manufacturers can give cannabis product samples to a wholesaler or retailer. Again, with the prohibition on-site consumption, samples have to be tested in accordance with rule. And then the samples are limited to the following aggregate amounts in a calendar month, five grams of concentrate or extract, or 100 servings of edibles per vendor, as long as that THC content of each individual edible sample does not exceed five milligrams per serving, as falls within any applicable statutory and regulatory efficiency levels. Requirement of vendor samples be labeled and be designated and identified in the tracking system. So employee samples, manufacturers may provide samples to employees to determine whether to make a product available to sell. Limited in the same aggregate amounts, five grams of concentrate or 100 servings of five milligram THC edibles per employee have to be labeled and designated and identified in the tracking system. Keep going. There's a penalty in rule one for employees that are turning around and selling these, diverting them. Right. Well, there's your ability to get an employee card. Yeah. So section seven, now we're moving into the regulation that applies to the wholesalers. So wholesaler security requirements are all of those requirements that we went through for the indoor cultivators and then any manufactured product, but not flower has to be kept in a locked space. It's bolted to the ground. The next section provides some clarity about the word process as it applies to wholesalers. So if you remember the statute allows wholesalers to process cannabis. So we've added some clarification here that the act of packaging or wrapping cannabis flower in any manner that it can be transported or consumed is what process means with respect to wholesalers. Doesn't mean transforming cannabis flower into another substance through manufacturing. The packaging requirements are the same packaging requirements for product manufacturers. And they would have to follow the same transportation security rules. Yeah, that's in the section that's applicable to all cannabis establishment. Are they allowed to, are they allowed to brand a wholesaler? And I think both the statute and our rules are silent on that. I mean, they obviously have to follow the rules around advertising and labeling that are everybody. But yeah, I don't think we've said anything. I don't think the statute is saying anything about that. Changing of like white labeling and stuff like that. Is that what you're... Yeah, just for wholesaler, just wanted to purchase a bunch of cannabis, put it from the operator, put their own brand on it and then sell it to a product retailer. So I misspoke just now the packaging requirements that apply to wholesalers are the same packaging requirements for retailers. Okay, with that, I'm gonna move on to the retail regulation. So the first is the buffer zone requirement. So we have modified this language based on the meeting, the last board meeting on Friday. So retail cannabis establishments shall not be located as a place where the sale of a regulated drug will constitute a violation of Vermont statute. David, I'm gonna ask you to jump in here for my name about the statute. So this is the drug free school zone statute. And it basically says that the sale of a regulated drug is unlawful within a certain proximity of schools, school properties, it's got a couple elements, like the property has to be adjacent to a school and it also has to be within 500 feet of the school property line. So this is basically saying if you're in a place where the sale of a regulated drug would be a violation, it's not saying let's be clear that the sale of this is the same as the sale of a regulated drug. It's just saying that if you're in a place where the sale of a regulated drug would be a violation of those distance requirements that are in the drug free schools on act, then you're in violation of our rules. You can't be in a place that would constitute a violation of that. Do you recall if it defines school? It does have defined terms in that statute. And I'm just relying on the rest of that statute for its further definition.  But obviously the drug free school zone was not contemplating retail sales of cannabis. So is it where you're actually, is it actually the cash register where the sale is actually happening that needs to be 500 feet away? Or is it the kind of property line, like the parking lot around the retail establishment? I mean, I would say that. Sorry, I know that's a dumb question. I mean. There's something about a budding. I think that I would say like the inside of the retail. Okay. Would be like the place of sale, because people are looking at stuff, deciding what they're gonna buy and then buying. And those are all processes that are part of the sale. I think as long as the, I would say that, you know, from the edge of the building. The sort of inside of the retail store is what counts as the place of sale for figuring out the distance. Okay. We can just be clear about that in our guidance. Sorry, David. Good question. While we're talking about stuff related to this, you know, drug free school zone still contemplates cannabis as an illicit drug. And now it's legal from a state perspective and it's not within our bounds to amend that statute. But for purposes of it right now, this is what we've got. Yeah. It was included as a part of 164. Yeah. Okay. I think was the amendment that was made to 18VSA, not 4237, but some other piece of that. And this is designed so that if somebody, if down the road that were to change the regular drug definition or the change, this would still buy. So, yeah. And it's just schools. It doesn't say libraries, churches, community centers. That's right. Are we ready to move on to retail security? Yes. I think so. So this is requirements for the retailers. They have to meet all those requirements that apply to the indoor cultivators along with these additional requirements. So alarm systems that must be installed by an alarm installation company with expertise and industry standard, commercial grade alarms. Video surveillance has to include the point of sale area, entrances, exits, and any area where a product is stored or handled. Strict access controls to areas where a product is stored or handled have to be maintained. Video footage has to be kept for at least 90 days. Employees have to wear ID badges that clearly identify them as employees while they're working. And then upon request, retailers have to make available to the board all information that's related to their security system, monitoring, alarm activity, maps, camera locations, any surveillance equipment, including the maintenance fraud, authorized user list, operation instructions, anything else that's relevant. The number of customers that retailers have to maintain the number of customers in a retail area at any given time. They can't be more than who are easily monitored by the employees that are present in the retail area. And then lastly, the security requirements that apply in statute to the extent they're not already covered by the rules. So next is age verification procedures for retailers. So a person who's been issued an employee ID card has to inspect a visitor's group of identification and determine the visitor's age. As soon as a visitor enters a retail shop. So that age check has to take place in the immediate vicinity of the entrance to the retail premises. And for the purposes of this rule, acceptable form of identification means the photo ID, this issued by the government and it has to be a current valid ID. Subsea provides that no one should be admitted unless the retailer has verified that the visitor has an acceptable form of ID that matches the actual visitor that the visitor is 21 or older. Then there's another check that's required card completing a transaction for products. An employee, essentially an individual who's been issued an ID card as an employee has to inspect the visitor's proof of ID and determine the visitor's age before they could check that personnel. Retailer may not acquire or record any personal information of visitors other than that, which is typically required by any other retail transaction, which can include information that determines the visitor's age. Retailer can't record or retain any additional personal information without the visitor's permission. And lastly, retailers must refuse to sell to any visitors who vet visitor who's unable to produce valid proof of their age using an acceptable form of identification as defined for the rule. Okay, moving on to packaging. So retailers have to abide by these packaging requirements. They have to meet all the requirements that statute all the requirements that are contained and I think this is the wholesaler portion of the rule. That's the general package. Okay, general portion of the packaging requirements. And manufactured cannabis products have to meet the requirements contained in section 262. That is the wholesaler's portion. I think that's a new factor of portion because, yeah, manufactured. And then packaging has to have information regarding the chain of custody of the product, but it can provide that information through a QR code or some similar method. And then finally, packaging that's gonna exit the store with the customer has to be sealed or stapled closed. So moving on to the standard operating procedures for retailers, these are the things that they have to maintain on site and readily accessible to the board upon request. All security measures, employee security policies, description of the hours of operation and after hours contact information, plan for storage of inventory, procedures to ensure that record keeping is accurate, quality control plan, emergency procedures in case of emergency, how confidential information is maintained and a policy for immediate dismissal of an employee who is a diverted cannabis or engaged in an unsafe practice. Retailers can accept vendor samples as provided in earlier portions of this rule, but they are prohibited from offering such samples for sale. And accepting those samples has to be logged in the inventory track. And then here is where the board landed on the deli style conversation. The retailers may provide samples of cannabis in an exposed container for viewing or smelling by visitors that those samples can't be touched or sold to the visitors and their use in disposal has to be tracked. Yeah, you know, I know that we were hoping for a little bit more of that traditional deli style, but I think some of the repackaging language in the statute kind of prevented us from going as far as we had hoped for, or at least I had hoped for, but. But the samples may not be touched by visitors means that they could be held in tongs, right? Or they could, I think, or does it? Well, in closed containers.  It's just, you can't open a big jar and say I want that butt. Because yeah, we just couldn't figure out a good way to not be in violation of the statute that says retailers can't repackage. So this allows, from my perspective, retailers to open something and use that as a sample and use that same harvest lot or whatever, or process lot for other products to still sell, that's in essence same product to somebody that's sampling it. Am I right there, Brynne? Does this also allow for someone to open and reseal a package? So I was just thinking about that in enclosed containers. I don't think the word enclosed would prohibit the container from being opened, but we may want to get more specific there that the container could be open for smelling or serving. I mean, I think, yeah, enclosed container, the intention there was also to allow for a container that has like holes in it that you could smell something through. Just the key thing is that visitors, or I should really say, I guess really consumers, shouldn't be able to touch the actual cannabis itself, but otherwise, I think touching the container and so on and so forth is fine, although we may want to clarify that it also can't be given to consumers. So I may add in a little bit of language around there, but yeah, I think the basic idea you're envisioning is intended to be captured by this. And again, this might be an area for some guidance to be clear on what we need. So next is the safety information flyer. So retailers are required to display this flyer that's required by statute at the point of purchase. And the board is going to make the flyer readily available to the public and to retail establishments for their use. The board can update the flyer at any time. We'll provide notice when it makes an update. So moving on to regulations that apply to testing labs, cultivators and manufacturers. So these requirements apply to establishments of the testing lab license as well as cultivators and manufacturers who have their product tested at those testing labs and of course making a rule. So this portion of the rule incorporates everything that the board looked at last week with respect to the testing requirements. So the chart that describes those requirements that labs have to be prepared to administer and the standard operating procedures for sampling that establishments must follow. So top row describes the test, the last column describes the substance to be tested and the boxes in the chart describe the relevant sampling standards. Then we've got notes below. Rule two. So note one is the harvest lot testing is sufficient to show up in plan. Note two is the trim flower or concentrate testing is sufficient. And note three is residual solvents are tested whenever the product use solvent-based extraction. Four is the certified labs COA demonstrates that the product meets the acceptable level of co-complete for the processors formulation demonstrates compliance with the acceptance of the level of the sufficient level of co-complete. And then note five is testing for heavy metals is required whenever the crop land was used for orchard crops or any land use other than farming defined in the prior to agricultural practice school. Unless a recent soil test demonstrates that heavy metals are within authorized action limits. Note six is no testing for pesticides is required if the crop is certified by a third party to be pesticide free. And note seven is that testing for other contaminants is necessary when agency of natural resources has approved biosolid applications to crop land. So an explanation, a little explanation of these notes within the chart. So potency parameters, so Delta nine THC and other cannabinoids must be within 10% of the label value. And labs have to use the following formulation assessing potency. THCA is the precursor of Delta nine THC. The lab determination of potency will be determined by the total theoretical THC, which is the maximum amount of possible THC in a cannabis crop. If total conversion from THCA to THC were to occur. Calculated amount of total theoretical THC is determined by the sum of the concentration of Delta nine THC added to the amount of THCA after it's multiplied by 28.7 on a driveway basis supported to choose the different figures. And here's an mathematical equation to express that calculation. Brian, can we go back up to this table really quick? I have an edit for us to make something that was an overlook from the hemp program that we did not update in our table, but it's reflected in our six buckets down below. So on microbiological, mycotoxins, total aerobic, microbial, total combined yeast and mold.  It should be just human pathogens and that'll cover our bacteria and fungus. So just total combined yeast and mold needs to be taken out. And that was in its place with human pathogens. Yes. I was just confirming that with Carrie right now. The reaction limits for moisture parameters are less than or equal to 13 cents for moisture content. Water activity is 0.65. Microbiological parameters. We've set out the human pathogens that are measured and the guidance that is issued by the board on these limits won't be altered without at least 90 days of production, both licensees and metal parameters. So these are the list of metals that will be measured. And the limits, action limits on these metals will be issued in guidance. And again, board won't amend that guidance without providing 90 days to test the size. So as indicated earlier in the rule, cultivators are gonna be required to abide by the test standard set by the agency of agriculture. The visual solvents are going to be measured and limits set in accordance with guidelines that are issued by the board. When a laboratory wants to gain a certification for a new test, it has to submit to the board the method validation summaries for that test. Laboratories have to provide to the board full access to all testing records when requested by the board. And the board retains the discretion to change or add any testing parameters, required pathogens or any other substances to the required testing school. So I'm gonna move on to regulations that apply to the integrated licenses. So again, there are all of the regulations that are required to the other license types that apply to integrated license pool groups. And then a note that to the dispensaries and the medical cannabis registry aren't regulated by the rule, they're rather they'll be regulated by rule three and by the relevant chapters of title seven. We'll move to co-located operation. This provides the integrated licenses can co-mingle their cannabis cultivation for adult use sales with cultivation for dispensaries. And sub-D provides that after that cultivation is complete and the crop is harvested, the licensee has to separate the products. It's gonna be sold through a retailer and the cannabis that will be sold through a dispensary to register patients. And that separation extends to all cannabis products that are derived from the cannabis and documented in the tracking system. So integrated licensees may co-locate operations from different license types in the same location, but they have to maintain all the relevant security requirements for each license type and maintaining all of the tracking requirements. Sub-D provides that dispensaries can be co-located with retail establishments, as long as the integrated license, licensees have a system to ensure that staff give priority of service, which will include priority of interest sales to dispensary patients before adult use. And that shall include curbside sale if requested for dispensary patients. And also strict protocols have to be placed to make sure that medical products for patients are not sold to adult use. Related to that is the next section, but integrated licenses have to ensure that they're a dispensary, maintain a continuity of services to registered patients. And if an integrated licensee does co-neval their cultivation pursuant to that previous section, continuity of services will include designating sufficient biomass at a cultivation facility to meet demand for the product by patients, as indicated by the sales data for the preceding two months. And those records have to be provided to the board or visiting the request. So the next section provides the dispensary operations and transfer cannabis and cannabis products to integrated licensees. Subjects of section eight of Act 162, but subject to the conditions that are included in this section. It should be Act 164. Yep. I like that. Good catch, Kyle. So starting on the date that a retail establishment that are not part of an integrated license can begin sales, the tiered plant canopy limits that are set out in rule one that apply to all cultivator licenses will apply to the cultivation portion of an integrated license, except for cultivations that's dedicated to medical cannabis sold to registrations through expensory. And other than cultivation for a dispensary that cultivator portions of integrated licenses will be deemed to be the largest cultivation tier that the board has opened for application for selling to rule one. And will be subject to the plant canopy limit for that tier. Can I ask a clarifying question about, so a medical license and an integrated license will be two separate licenses, right? Is there anywhere else that we would allow a transfer between licenses without purchase like this? So I guess I'm thinking of like a co-op. I mean, yes, I think so. If you're a vertically integrated, non-integrated license holder, you would be transferring between your license types. But what if you create a co-op of multiple businesses and part of that is transferring product? I think that would be a transfer as well, yeah. So in this language, just so I'm clear and I know we've belabored this point at many different meetings, what's the total? This is saying that the total amount that you can transfer from your medical side to your adult use side is the highest tier that we have open at one time without our express approval to transfer more than that. That's the intention and that's the intention of this. I think that I think this achieves it. Yeah, I mean, basically, well, we're gonna actually want to just keep it into the end of this and that might help answer questions. Yeah. And we'll discuss the whole vector. Sure. So C provides that if they're not gonna co-mingle their dispensary and adult use cultivation, then the dispensary grow is governed by rule three, which will be the medical rule and the adult use grow will be subject to this rule too. And if they do choose to co-mingle, cultivation will be subject to the requirements here and rule two, except for that total biomass that is required to meet the demand for those medical patients that's, you know, indicated by the sales data that's gonna be collected, won't be counted towards the total for physical square footage. So if that satisfied for medical products is ultimately not needed, then it may not be transferred to adult use. So it's dependent on what your sales data indicates. So to try to put this in plainer English, I don't know if I'm gonna succeed. The, there's sort of two phases here. The first phase is the phase that will occur before general retail establishments are open to the public. And right now in statute, that's October 1st of 2022. During that period, there's essentially, you know, dispensaries can transition whatever they want because we're, there's no other competing place to purchase for a consumer in Vermont. You're gonna have to go through the dispensaries, now integrated license type, that's the only option. After October 1st, when we have a full market, hopefully with other retailers selling and other cultivators being able to sell to those other retailers, there's gonna be a different regime, which is basically that the integrated licensees get to, or their cultivation tier of that integrated license gets to operate at the total plant canopy of the highest tier that the board has opened. But they also get to grow whatever they need to grow to meet the demands of their dispensary operation. And that amount, whatever that is, it'll be measured by the total biomass needed for the prior, whatever it was, three months that is in there. That amount does not count towards that total plant canopy.  But they also get another chunk that's necessary, whatever's necessary to meet their dispensary demands that doesn't count towards that total square footage. So it's an attempt to put them in the same, they're adult use operations in the same position that every other licensee is in without cutting in on their ability to service their medical patients. Is this obligate them to share with us details about their sales? I mean, how would we know, right? What three months of their sales is, if they're not obligated, we didn't have to share that with us. Yeah, I mean, we can make that more clear. I think that the general, my thought had been that the general sort of records, availability provisions that are elsewhere covers that. But before you guys sign off on this, I can just check that to make sure that's right. And then I think my other question is one of our goals is the continuity of the medical program. So we feel like the three months limitation that they have, that you have to have three months supply protects the medical program in that way. That's what we've heard from our subcommittee on medical. There was some concern around the length of time that it takes to make it concentrate. If someone needs it on a specific day that they're committing a three months of biomass, not three months of every single product that every patient needs. So there is going to have to be some, you know, patient education, not that a lot of those concentrates can be sold in the adult rep side. So, but it's going to, we're going to have to just keep a close eye to make sure that the products that people rely on are consistently available. And I do think we have a process for patients to notify us if their products aren't available. If they have complaints about the dispensary.  So David, I'm just trying to still wrap my head around the transfer. Make sure I understand it completely. So, so they'll have the ability to make a one-time transfer. Any, is that unlimited? So until October 1st, the concept is pre-transfer. They just do what they need to to supply their stores because they're the only game of town. So if a Vermont consumer wants to get cannabis legally, it's the only place that they can go to integrate the licensee. Once that's no longer the case, the intention is to put them on the same pudding as every other commercial actor. And at that point, they are their plant, they have the same plant canopy cap as any other cultivator, except that they also get another chunk that doesn't count against that cap that services the medical side. So they could transfer. So I think once- If they grew too much on the medical side, they could transfer to the- They can't be that. That's explicitly provided for in this. So if they grow too much, they're kind of out of luck on the dispensary side. They don't get to sneak it into the building and decide to convert the cap. So there's really no transfer effectively after October 1st. I mean, I think the term transfer is in the statute, but it's not a great term. I don't think it really describes what is going on here. It's just assigning different amounts to different operations. And we're saying the amount you get for adult use is the same deal that everybody else gets. The amount you get for medical is whatever you need for medical. And you get to be both. You have to supply 25% from small cost payers. And I'll put in, assuming we do the same little process we did last time where we go through and put in some edits that you guys then review. There aren't that many. I'll put in something about records. I think it would be covered elsewhere, but just to be sure that we can have visibility on that offer. We're nearly done here. The next section reiterates that duty purchase from small cost payers references the relevant section of Act 62 regarding that requirement. Section 11, this is going to look familiar. So this is that ongoing duty to disclose to the board requirements. Anything that's submitted, any information submitted with their application or their renewal form for the ongoing obligations to disclose. And then the next section is that there's a specific obligation for campus establishments to disclose that there's going to be changing control. That will trigger the renewal process just as described in section one. Section 12, providing the board will keep all of this information confidential to the extent required by statute. And then 13, this is the provision that Vermont in importance with the statute, the board can waive any regulatory requirement. That any requirements contained in this rule to the extent that such a waiver doesn't conflict with any other state law and is necessary to achieve the purpose of Vermont law and doesn't create a danger to the public health safety and welfare. Is that it? That's it. Wow. Mm-hmm. Thank you both. We're going to start with Caroline. Very helpful. So any conversation that we haven't already covered, I do have one question for David, but it's more general, not specific to any one piece. So David, we're going to vote for on these rules and then we're going to pre-file them, go through the ICAR process and file them out with the secretary of state. How and when do they get amended if we notice things that need amendment? I mean, I want to give people watching the industry at real large some certainty about what to expect, but I'm sure certain things are going to need to be amended, changed, updated. We're going to notice things. The public is going to notice things. Can you talk about just how these might get amended in the coming months? Yeah, so the official notice and comment period will open sometime in mid-December. Of course, as the board has always said, and we always have the public comment portal open. So it's not like you're prevented from telling us something before mid-December, but just officially speaking, the notice and comment period opens in mid-December. There will be at least some number of hearings that people can attend, but again, you can always submit comment and the upon these rules or anything and that will be clear on our website. And then you, the board will make decisions about what changes you're going to make, what amendments you're going to accept, what edits you think need to be done in response to those public comments. Likely around the third week of January, again, some of this depends on how the next few sort of deadlines unfold. So I can't give you exact dates at this moment, although we will be able to give exact dates by mid-December and we can post those on the website also. But yeah, so that'll be the time when you take into account everything that everybody's telling you. And it'll probably be around the third week of January. We'll have another long or maybe even a couple of long board meetings to go through all those comments and decide what you're going to do in response to them. And so we will have, as drafts get updated of these rules, they will be available on our website or do we refile them every time we make amendments? We'll update them when you make amendments and then the way the process works is we submit another official filing and we'll post the entirety of all the official filings that we put in on the website. So our first, well, it's really called a pre-filing, but it's in statute. So I'm going to call it an official filing for this conversation. The first official filing is tomorrow and it's got the rules in that a bunch of other stuff that we need to submit. And then so that'll all be posted and then the next official filing is called the filing and that will be in the second or third week of December and we'll post that whole thing, which will look very similar if not identical to the pre-filing, those two are very similar. And then where things might change is after you get the notice and comment, the filing that happens after that may have, the rules may look a good bit different depending on how many amendments you make in response to public comment. So that will be a more significant new filing. And then the filing after that is the one that comes in response to the legislative input through the legislative committee on administrative rules. And again, depending on how much they have to say about it and how much you choose to accept, that could look a bit different from the notice and comment file. Yep, okay. So we're very much at the starting line here. Brett, the starting line. There's a lot of amending that is at least available to be done if you choose to do that. Yep. Is there some sort of like widespread notice that we intend to do saying that these are available for viewing? There's a statutory, yeah. Yeah, so the Secretary of State's office is actually responsible for doing publications broadly. And I actually don't have right off the top of my head where they do that, but it's like they pay for advertising, basically. And that's part of their process.   Additionally, just noticing that there is going to be an official public notice that the Secretary of State's office is responsible for putting out. Okay, I just want to make sure that that was the same. Can I believe our integrated transfer thing? Just a little bit more, making sure I understand. Because what I thought we were talking about, and correct me if I'm wrong is there's been so many conversations lately. You know, plan counts go away in February and then the folks that can seek an integrated license, the medical dispensaries can grow once those plan counts disappear in anticipation of licensure in May, to get a license May 1st and then conduct a transfer. And I know you don't like that language. I thought we were allowing that transfer to happen when they receive their license at our discretion, not necessarily all the way till October, whenever they choose to. And at that point, cutting off that ability to do so. Am I making sense? So are you saying that what you thought was that when they got their integrated license, they could make one transfer then? Is that what you're saying? Yes. And not again until? Until we say that they can. I mean, it's certainly one way to go.  You know, what is it February 1st? Is there plan counts are lifted? And then May 1st, their doors open. So I think that we would be looking at pretty much continuously approving transfers if we wanted to go that way, which we could do. We might have some other things going on that we wanna do instead. But I think, you know, in this early market, I think the things that we're requiring of them are paying $50,000 and we're requiring them to source 25% of their sales from small cultivators. I think those are the two things that we're the legislation does in order to kind of launch that first starter advantage that they're getting. You know, we don't wanna see lines around the block to the extent we can avoid it. We do want kind of, we do want the products hitting the shelves. I'm with you. I guess I was just a little anxious about processing the optics. I see the benefit of what you're saying in terms of having some awareness of what the availability of product is and making sure that there's no, like the mark is not flooded, like that there's no huge price fluctuation, that there's not too much that's grown or produced. By the integrated license fees. Yeah, I mean, there's only so much we can do on that respect. I know that we can have a very like heavy hand during that initial phase to really try and control price. I just don't know how good the three of us are gonna be at actually managing that. I think essentially there's going to be a shortage during that six month period, no matter what we do. And we would be accelerating that shortage by requiring pre-approval every time they wanna transfer. I think the intention of the legislation, of course, pretty clearly was to let them do this transfer pretty freely in that period to supply the market to make sure that there aren't drastic shortages. And then after a certain amount of time, they have to after that window closes October 1st when there's other retailers and there's more cultivation that they have to play by the same rule. They're on a level playing field with everyone else. The way you drafted it, let's say, and I'm not saying that I'm against, I'm just making sure I understand completely. It doesn't make a whole lot of business sense to grow an unlimited canopy if we're gonna use that language because you're gonna have this abundance of supply that you might not sell. And once October 1st hits, you won't be able to sell that into the adult use market. Essentially, yeah. I mean, again, you do get that carve out for what you can show was sold through the dispensaries, but anything, and then, you know, you can keep selling that through the dispensaries. But yeah, if you have a bunch more beyond that, you're capped. And I think when I was trying to write this and think through it based on the discussions and directives, I think there was two interests that we're trying to meet with this. One is to supply, you know, to the extent possible, and it may not be possible, but to the extent possible, have enough supply for reminders to buy who want to, to buy cannabis lawfully through a retail store before the broad retail market is open. That's interest one. And interest two is once the broad retail market is open, put everybody on an equal playing field, so it's a fair market for every participant. To the extent that the same rules apply to every participant. And so that's what this tries to do, is say, all right, up until October 1, there's only one way for Vermonters to get cannabis through lawfully, through purchase it lawfully through stores, and that's to be integrated to licensees, so just do what you can to supply it. Once October 1st hits, now we're gonna set an equal playing field for all market participants. And by that, I don't mean consumers, I mean the people trying to make money in the market. And that's what this tries to do, balance those two things. But yeah, I think you're right in the short answer. If somebody's wildly overbuilt their canopy capacity, they will effectively be prevented from using all that after October 1st. Okay, as long as that's the case. And there's not a lot of, after October 1st, there's not a lot of stuff that we don't know about that's being transferred in. And it's your feeling that demand will exceed or likely exceed supply from May to October versus supply exceeding demand so that there's so much supply that it makes it possible for other people to open. In October? Yeah. Sorry, I didn't follow that, and sorry, it's just my brain is slow right now. Okay, I think what I'm concerned about is so much supply from the integrated licenses that start in May, that it doesn't make business sense for anyone else to open because they're- No, I just, if we're looking at demand being on, you know, on average 450,000 square feet of canopy, the largest integrated licensee, and I know that, you know, slang there's all of this kind of act 250 stories going around, you know, if they maximize, I think they're the entire footprint of their facility that they're trying to build this 43,000 square feet, if they used all of that, you know, built canopy out to the edges of the building knowing that at soon that they would be limited in the future, so I don't think that they would even do that. They wouldn't even come close to meeting the demand of the state. That was my question. Yeah. And I don't know about the other three or the other integrated licensees if they have plans to expand or not. I just know about the one that's reported on. I just, but I don't think it's a good business decision to build out, you know, a grow that's larger than what you would be eventually regulated to. And if the three companies that have this kind of provision built in, this advantage built in, are all operating at what they expect our largest license here to be, then they're gonna fall well short of the demand. Okay. I'm okay. Just wanted to make sure I understood what was drafted and the reasoning for it. Maybe I misunderstood at various points along the way, the touchy, touch and go, you know, issue that we've been grappling with. Yeah. Okay. Should we vote on this? We wanna see the corrections based on, it's not gonna take long, just like we did last time. Is it worth doing a public comment period while you do that? Of course. That I leave to you. Yeah. Okay. Well, why don't, David, you get to work on that. And if you need longer, then we have public comment then we can take a break. I think we'll be ready in time. Okay. So why don't we open for public comment. If you joined via the link and would like to make a public comment, please raise your virtual hands. We'll start with the... Old growth organics up first. Old growth organics. Feel free to unmute yourself and join us by video if you'd like. Hi, thank you. Yeah, I shot my hand right up because usually I'm wired shot at this point. So if you see me again, I might be handed shot, but I'm dirt. I've had my break right now. So the timing was impeccable. You guys are amazing. That was a long day. I feel closer to all of you because I didn't see it in the whole time. But the biggest thing I wanted to comment on was the question of meeting criteria for equity and environmental impact and whether it was burdensome for small cultivators to meet this. And I think actually it wouldn't even just be small cultivators, but probably the mixed here also would apply to that question. And I think the best way forward would be to change or even create a definition of employee. You guys had touched on that when you were kind of going through the discussion. And I think you guys landed that you don't have a definition yet. But regardless, I would push to have seasonal workers excluded from that definition because that would I think fix the problem as far as meeting criteria for equity environmental impact because most small cultivators wouldn't have more than one employee if you guys bump it up to two or none. But assuming that small cultivators or mixed here wouldn't have an employee, two or even three isn't realistic. We have a small growing main right now. And it's just the two of us, but during harvest and everything, I mean, we have up to five people or they might be shifting in and out. So not only would it apply to that criteria, but also if we had to give those employees, workers' comp or all the other things that are required if you have an employee, that would also be really burdensome because you might have a trimmer that can come in for a day. So anyway, it's all of these things around seasonal employees and it would also fix the equity and environmental impact question. So, does that make sense? It does. It does, thank you. Okay. The other thing I wanted to mention was you guys had mentioned leaving or the social media that we wouldn't be able to post pictures on social media. I don't know how deep that goes, but I would suggest the possibility of leaving social media advertising policies up to those platforms rather than you guys putting that on there, if you can, just because social media is a lifeline for small businesses. So I know in other states, for example, you could get shut down easily if you're posting a lot of specifics like cannabis for sale or marijuana, this or that, but small businesses have a way of getting around that so that the algorithms don't pick that up and then you can still reach people. So maybe if you're worried about people that are 21 or under, what you could do is just make a requirement to set your page to private or write something that only 21 plus can enter, yada, yada, yada, because that's a real big lifeline for small businesses. And then the last thing, and you guys, again, I know you guys put a lot of thought into all of this. You take it all with a grain of salt, but it seemed like your, the transportation rules seemed a little excessive because it's not always so straightforward, exactly aware in how you're going to send out like samples, for example, it's just not always straightforward, who you're going to reach. So the GPS, for example, is like what really felt excessive. And I just wondered, thinking about it, like is GPS a requirement for transporting any other products in Vermont? You know, is it just marijuana that we're doing this with? Just food for thought, if we're trying to get around or break away from the stigma of what marijuana is, it just feels, it just has that kind of like sketchy feel that marijuana is a drug and you have to GPS it and track all of this stuff. It just all felt excessive, and I just wondered, do we do that with any other products? So, okay, that's it. Time for me to put my bands back on and I hope you guys get a snack break soon. Thanks for your time. Thank you. Next, we have Ben Mervis. Hi everyone. Seconding, Old Earth Organics, you are just incredible. This has been such a great long meeting, but so much included. I also second her concerns about the advertising limitations specific to social media. I've seen limitations set on not being able to advertise prices on social media and the social media platforms themselves usually say that you cannot market the sale of anything, but I do fear that not being able to show products will really limit everyone's ability to provide education and math to the public. I also would just ask that you consider when looking at the requirement for co-located licensees, the requirement of the distinct and identifiable spaces that it won't be overly burdensome that it also won't be interpreted to apply to things like loading days, safes, certain major physical aspects of the shared space that might be the reason that you need to be co-located or that you might offer space within your facility to another licensee. Now I have a couple of notes just specific to actual line items. I do have one that I'm not even sure what section this was. It was 2.3.5 and I just wrote down a note that specifically would be great if here product was not just limited to cultivators but to any license type. Also in section 2.3.9 I think it was with cultivator samples that that sample policy should be extended to every license type that might touch flour leading up to the point of retail. So wholesalers, product manufacturers who might be taking raw product and turning it into a finished product and might need to provide samples to vendors. With 2.8.3 and acquiring or recording visitor personal information, I would just ask if there's any option to include an opt in there for customers to be able to provide information that might be essential to the retail operation and product matching, keeping track of why, even if it's just something as simple as the reason that the customer is looking to purchase and consume cannabis. That might be a piece of personal information worth holding on to for retailers. And that's it. Thank you so much. Thanks Ben. Thank you. Thank you Ben. Anyone else would like to make a public comment? If you join by phone, you can hit star six to unmute yourself. Otherwise raise your kind of virtual hands there if you joined through the link. Well, David, how are you feeling? Ready to go. Okay, well, why don't we end public comment period then? I know it's been a long day for everyone. Thanks for sticking it out. And we'll just, David, have you review some of the edits or Bryn and we can vote. Do you want to go to 2.2. Do you want to eat? So the first one we're looking at here are some of your suggestions on co-location on suggestions, decisions on co-location. We'll get there in a moment. Here we go. So now near the bottom F and G, subsections F and G are where I tried to address. So I'll actually do G first. This is to the point regarding multiple retail cannabis establishments. We wanted to clarify that we're just talking about retail cannabis establishments before, which I think this says plainly, before there'd been ambiguity in how it was worded at the top, which I changed also. And it no longer reads as though retail cannabis establishment couldn't be located with some other license type. That was that fix. If you look at F, I added a sentence at the end of F, which captured what I thought was in your discussion. Just to be absolutely sure we have what we need. At its discretion, the board may require additional information of cannabis establishments to ensure compliance with this section. And that was to get at the point regarding this control and more than a license type issue, especially the issue with perhaps needing insight into rental agreements and things like that. There's a reason to believe that people are working around that. And then if we go to 2.3.2, this is a really clerical one. This is just making sure that I didn't act. You guys didn't discuss this, but this is just bringing this visitor section into consistency with the other visitor section, which basically says these three types of people arriving at cannabis establishments don't count as visitors. They're there for other reasons, like contractors who are doing work or designees or cannabis license agencies, agents making deliveries. So that's just putting the same language there that was in the other visitors section. And then go down to 2.8.7. This is another pretty small one, but this was, I think, just the making even more clear regarding consumer samples. These are, once these samples are out there, they're not to be used for either selling or some of us in some other way transferring to people who may be at the retail establishments. And then 2.9.3 was a sort of late-breaking addition from the, oh wait, no, I have that no, you're wrong. Sorry, go for it. That's been pretty, there's another one, proficiency. Wait, is that misnumbered? It is, we have to fix that. There's a numbering issue. So I'll do that, right? I think we can do that before we got there. There's Scriveners there, right? Yeah, so you can see the numbers, the point, the third decimal number is misnumbered after a few in this one section. Everything else is correct, don't worry. But anyway, so 2.9.3, which is not actually 2.9.3, it's more like, I don't know what it is, go up for a second. So it's like <IP_ADDRESS>, yeah. Okay, 9. So anyway, we'll fix that. I think you can both understanding that we'll fix that. But this was an addition from Kerry at Department of Agriculture, just noting that this should be a requirement for laboratories, the proficiency issue. He had put that in rule one, but this, it fits better putting it here. Oh yeah, thanks for that. And then this is the table fixing that. So it's just human pathogens instead of the specific citations that were there before. And then we just have one more. This is the other ones. Or is it just human pathogens? I confirm Kerry. Gee, so this is the issue or the information issue that we discussed. The board at its discretion may require integrated licensees to provide the board with any records that might demonstrate compliance or non-compliance of this section, including the knowledge of sales and manufacturing. All right. Is that it? That's it. Well, just from my knowledge, could we return to the social media? Just because we got a couple of comments on it, again. Is it that you can't advertise sales or you can't advertise, or are we drawing a distinction there? Like stuff that you grow or you produce, you can still say. I think we have, I do like the idea of having a private account. We have to do something to ensure that we're compliant with the 21 and younger crowd, not being able to see it. So we have to do something around social media. It's sort of to say that they couldn't post pictures. They couldn't post pictures of product. Yeah, specific to products. But we should look at it specifically. There it is right there. Oh, section B. But it's specific to products. I mean, I think what we don't want is exactly what the comments are said is we don't want like a buy now or a shop now button, right? If this does, I would read this still to allow for some social media presence. Certainly it is specific products, but of course they still have to abide by the other provisions of the advertising restriction. Yeah. Would we run afoul of everything else in the work of the committee if we change the sentence to something like any images or other effects regarding sales pricing is otherwise prohibited. That way somebody could show the quality of a product with which they offer without actually advertising it for sale. Is this in the legislation? I don't know. I'm just trying to kind of figure out a... I almost feel like it doesn't make sense for us to change it on the fly right now. I think that we will, again, because of the process that David laid out for us, this will, we can spend a lot more time if this deserves, I think, if we don't try and change it right now. Take more formal comments on it. Okay. And then just thinking through some of the other comments that we got, I think in the retail, and Ben noticed something that I presented, which in a retail establishment cannot by themselves laterally keep folks information, but I would be in favor of somebody allowing somebody to keep their email address or something like that to send them. What do we say? You can't keep anything outside of what a normal retail, a non-cannabis retailer would. I think that's enough to allow. There's a provision unless the person gives permission. Okay, unless the person gives permission. Yeah, as long as there's that type of opt-in, and we talked about it in the context of delivery, if that does move forward, it would have to provide some other information besides just your photo ID at the time of purchase and cash or debit card. Yeah, and I hear what people are saying about GPS. I remember we debated this too, whether we need a GPS, whether it's the GPS that is like a low jack for your car. If you get, someone steals your car, you know, and you're transporting, you know where it ends up, or whether this is the actual kind of like Garmin GPS or it's your cell phone GPS. I think, again, just like this piece, we should think about it. We should revisit it. We've heard two public comments on it already. I'm sure we'll get more, and we can have a much kind of more in-depth conversation about whether that's necessary. Recognizing that, we specifically said that we could waive that provision. Yeah, using enforcement discretion. Yeah, certain stuff that we can. There are lots of organizations that use GPS to keep track of their assets. Yeah, yeah, it might be a good thing for larger shipments, and might not need it for smaller shipments. I think we can have a longer conversation about that. So I think I feel comfortable voting on this rule at this point. Is there any further discussion? Feel it. Okay, do you feel David and Brink, okay, with us voting at this point? Yes. Okay. All right, well, then I take a motion to approve proposed rule two. So moved. Seconded. All in favor? Aye. Aye. Great job. This is, you know, it's amazing that we are here today. I really did not expect that to happen. I didn't expect a six hour meeting, but yeah. Yeah. And all the people who stuck with us. I know. Yeah, happy Thanksgiving. Happy early Hanukkah, and we will be filing these rules and making them available on our website by the end of the day today. Is that the plan? We can make the PDFs available as soon as we can up to Nellie here. And then the filings will be happening tomorrow officially. Okay. Nellie, do you think you can get them up before the end of the day? Yeah. Yeah, I can do that. Okay, so we'll put them up on our website, and then we will file them tomorrow. So thank you all again, and really terrific work all around. I will adjourn the meeting.