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seaanenome

MMFLA Secure Transporter Questions

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Anybody know of anyone applying for a Secure Transporter license?

Only half a dozen of them in Colorado, seems like there will be a distribution bottle neck / capacity constraint once Growers start harvesting across the state...

Any opinions on the below?

  1. How many Growers do you think most Provision centers will buy from? 
    • How many orders per month would you expect to be made between Growers and Provision Centers?
    • What do you think a reasonable average weight (lbs) per order would be?
  2. How many Processors do you think most Provision centers will buy from?
    • How many orders per month would you expect  would made between Processors to Provision Centers?
    • What do you think a reasonable average weight (lbs) per order would be?
  3. How many Growers do you think most Processors will buy from?
    • How many orders per month would you expect to be made between Processors to Provision Centers?
    • What do you think a reasonable average weight (lbs) per order would be?

How will most Provision Centers order product from Growers / Processors?

Thank you for your insight!

Seaanenome

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I am retired and not interested in participating in the commercial market, however I have had nearly 30 years of experience in the alcoholic beverage industry and I think the secure transporter category represents a unique opportunity to create a business with little risk.   Everything I have seen to-date seems to define the category as a sort of Brinks/UPS trucking/delivery  type business.   

There is a missing component to the industry as defined by MMFLA, i.e. Wholesale Sales.     I have not seen any discussions as to how sales actually happen between the growers, processors and the retail outlets?    It would seem that the successful "transporter" would not just be a UPS sort of business, but it would have a sales force that called on the retail outlets and made exclusive deals with various growers/processors.

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Related and interesting;

Pharmacy delivery vans targeted by thieves seeking painkillers

By David Armstrong @DavidArmstrongX

December 22, 2015

002_JohnLatham_STAT-1600x900.jpgPharmacy delivery van driver John Latham of Alabama was robbed at gunpoint in May of narcotics and other drugs with a retail value of $108,000.Wes Frazer for STAT
 
 

 

They’re the new Brink’s trucks.

Delivery vans that transport prescription painkillers from warehouses to pharmacies and hospitals are the targets of an escalating number of thefts across the country, STAT has learned. Amid a nationwide epidemic of opioid addiction1, the delivery vans have become an appealing and vulnerable target for thieves, addicts, and drug dealers.

Hitting the right pharmaceutical courier can yield a payoff similar to robbing an armored car. But the pharmaceutical van drivers usually receive little security training, work alone, and rarely carry weapons.

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I think we are seeing another reason why a large number of smaller distributions BY CAREGIVERS are much smarter and safer for everyone. 

Bigger isn't better, it's just more expensive and more dangerous when it comes to cannabis.

Take a great thing and make it stupid because someone wants to make a fortune. That's America! Freedom to be stupid and greedy. 

Ever wonder why the law made it so caregivers only have 5 patients? Now you know. 

 

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Thank you for your reply, semicaregiver.  MMFLA Emergency   "Rule 21. State operating licenses; licensees; operations; general 2 (d) The marihuana facility must be at a fixed location. Mobile marihuana facilities and drive through operations are prohibited. Any sales or transfers of marihuana product by internet or mail order, consignment, or at wholesale are prohibited."

https://www.gpo.gov/fdsys/pkg/CFR-2010-title29-vol3/pdf/CFR-2010-title29-vol3-sec779-327.pdf

Retail and wholesale law seems to clearly define MMFLA Growers and Processors as wholesale establishments - § 779.328 Retail and wholesale distinguished. "Wholesale establishments usually exclude the general consuming public as a matter of established business policy and confine their sales to other wholesalers, retailers, and industrial or business purchasers in quantities greater than are normally sold to the general consuming public at retail."

This makes me think that rule 21 prohibits provision centers from engaging in wholesale, understanding that patients and caregivers will have daily purchase limits (presumably 12.5 oz if a caregiver were to purchase 2.5 oz for 5 patients at once).  Growers and Processors by definition are wholesale establishments, right?

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19 minutes ago, seaanenome said:

Thank you for your reply, semicaregiver.  MMFLA Emergency   "Rule 21. State operating licenses; licensees; operations; general 2 (d) The marihuana facility must be at a fixed location. Mobile marihuana facilities and drive through operations are prohibited. Any sales or transfers of marihuana product by internet or mail order, consignment, or at wholesale are prohibited."

https://www.gpo.gov/fdsys/pkg/CFR-2010-title29-vol3/pdf/CFR-2010-title29-vol3-sec779-327.pdf

Retail and wholesale law seems to clearly define MMFLA Growers and Processors as wholesale establishments - § 779.328 Retail and wholesale distinguished. "Wholesale establishments usually exclude the general consuming public as a matter of established business policy and confine their sales to other wholesalers, retailers, and industrial or business purchasers in quantities greater than are normally sold to the general consuming public at retail."

This makes me think that rule 21 prohibits provision centers from engaging in wholesale, understanding that patients and caregivers will have daily purchase limits (presumably 12.5 oz if a caregiver were to purchase 2.5 oz for 5 patients at once).  Growers and Processors by definition are wholesale establishments, right?

Wouldn't using a third party transporter be transfers by consignment? Might need to have/be your own transporter to stay away from illegal transfers. 

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Restorium2, I agree that caregivers have a valuable place in the market and have since 2008.  Due to the high value shipments of product and cash, I also see why secure transporters will be in high demand (pun intended ;)).  As for the pharma courier transporting $100k in opioids, I can see why criminals are targeting them with their lack of sophistication, training and $$$ potential.  Although I would not anticipate most provision centers to be ordering more than a ~5 lbs at a time from each grower (w/ 250 patients consuming 1 ounce per week, provision centers would sell 33.5 lbs per month, with 6 growers ~5.5 lbs per month) and given the fact that each transaction route manifest is submit to the state police for random auditing, it seems like less than ideal target for criminals but time will tell.

Regarding consignment, I interpret this to mean that the secure transporter is not allowed to sell the product on behalf of the grower or provision center.  I cannot imagine the law requiring growers and processors to have their own transportation (if that is what you were referring to), that would defeat the purpose of a separate and distinct secure transporter license, which is not allow to have any affiliation or interest in a provision center, grower, processor or safety facility.

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52 minutes ago, seaanenome said:

Restorium2, I agree that caregivers have a valuable place in the market and have since 2008.  Due to the high value shipments of product and cash, I also see why secure transporters will be in high demand (pun intended ;)).  As for the pharma courier transporting $100k in opioids, I can see why criminals are targeting them with their lack of sophistication, training and $$$ potential.  Although I would not anticipate most provision centers to be ordering more than a ~5 lbs at a time from each grower (w/ 250 patients consuming 1 ounce per week, provision centers would sell 33.5 lbs per month, with 6 growers ~5.5 lbs per month) and given the fact that each transaction route manifest is submit to the state police for random auditing, it seems like less than ideal target for criminals but time will tell.

Regarding consignment, I interpret this to mean that the secure transporter is not allowed to sell the product on behalf of the grower or provision center.  I cannot imagine the law requiring growers and processors to have their own transportation (if that is what you were referring to), that would defeat the purpose of a separate and distinct secure transporter license, which is not allow to have any affiliation or interest in a provision center, grower, processor or safety facility.

A transfer is a transfer. 

Even if the courier only had 5 pounds a crook would assume there were 100 pounds. You obviously haven't been around cannabis enough to realize what crooks will do when it comes to stealing it. People have been shot and killed recently at a mid Michigan store parking lot for a quarter pound delivery.

Edited by Restorium2

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2 hours ago, seaanenome said:

Thank you for your reply, semicaregiver.  MMFLA Emergency   "Rule 21. State operating licenses; licensees; operations; general 2 (d) The marihuana facility must be at a fixed location. Mobile marihuana facilities and drive through operations are prohibited. Any sales or transfers of marihuana product by internet or mail order, consignment, or at wholesale are prohibited."

Seaanenome,   The transporter/sales organization would not hold or buy any product for resale and hence would meet the letter of the law as defined in Rule 21.     As an example as to how it might work.  Let say you set yourself up as a transporter in Washtenaw County.   You go around to the smaller class A and B growers in the county and make a deal to be their exclusive sales and transport company for any sales in say the three or four adjoining counties.  In addition if there are sales outside your area, you are the one that picks up their product and transfers it to a transporter that covers the territory outside of your four counties.    

The point here is the "transporter" category is not well defined by LARA/BRRM and there exists an opportunity for some business savvy individuals to create a very profitable business that would be immune to the whims of the consumer or agricultural problems that both the retailer and the grower must deal with.  

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