Michigan Office of Administrative Hearings and Rules  
611 W. Ottawa Street  
Lansing, MI 48909  
Phone: 517-335-8658 Fax: 517-335-9512  
AGENCY REPORT TO THE  
JOINT COMMITEE ON ADMNINISTRATIVE RULES (JCAR)  
1. Agency Information  
Agency name:  
Licensing and Regulatory Affairs  
Division/Bureau/Office:  
Marihuana Regulatory Agency  
Name of person completing this form:  
Jessica Fox  
Phone number of person completing this form:  
517-284-9294  
E-mail of person completing this form:  
FOXJ12@michigan.gov  
Name of Department Regulatory Affairs Officer reviewing this form:  
Elizabeth Arasim  
2. Rule Set Information  
MOAHR assigned rule set number:  
2019-75 LR  
Title of proposed rule set:  
Marihuana Disciplinary Proceedings  
3. Purpose for the proposed rules and background:  
To provide one, cohesive set of rules for regulating marihuana licenses for both adult use and medical  
marihuana in the State of Michigan.  
4. Summary of proposed rules:  
The proposed topic-based rule sets are intended to provide clarity/consistency to those working in  
both the medical and adult use markets. The rule sets provide for the implementation of a program to  
license medical/adult use marihuana businesses. The rule sets implement, administer, and enforce  
appropriate standards for marihuana businesses and associated equipment and establish regulations  
ensuring the safety, security, and integrity of the operation of marihuana businesses.  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
The Flint Journal (Pub: 1/28/20), The Grand Rapids Press (Pub: 1/28/20), The Mining Journal (Pub:  
1/16/20)  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 2  
6. Date of publication of rules and notice of public hearing in Michigan Register:  
2/1/2020  
7. Date, time, and location of public hearing:  
2/12/2020 09:30 AM at Auditorium , 525 West Ottawa Street, Lansing, Michigan  
8. Provide the link the agency used to post the regulatory impact statement and cost-benefit  
analysis on its website:  
https://dtmb.state.mi.us/ARS_Public/Transaction/RFRTransaction?TransactionID=19  
9. List of the name and title of agency representative(s) attending public hearing:  
Executive Director Andrew Brisbo, Legal Analyst Kelly Kronner, Legal Analyst Jessica Fox, Legal  
Analyst Joshua Galicki  
10. Persons submitting comments of support:  
Cannabis Legal Group  
Pollicella Tompkins  
Steve Linder, Michigan Cannabis Manufacturers Assocation  
11. Persons submitting comments of opposition:  
Jason Palomba  
12. Identify any changes made to the proposed rules based on comments received during the  
public comment period:  
Name &  
Comments made at Written  
Agency Rationale Rule number  
Organization public hearing  
Comments  
for change  
& citation  
changed  
1
2
Cannabis Legal  
Group  
The rules are too The agency agrees 420.808  
vague and do not that the rules are  
include the  
vague.  
definition of the  
violation or  
burden of proof.  
There is no  
Pollicella  
Tompkins  
The agency agrees 420.808  
that there is no  
distinction  
between the  
issuance of a  
warning or a  
citation. There is  
no clarity  
clarity.  
between the  
violations.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 3  
3
4
5
Steve Linder,  
Michigan  
Cannabis  
Manufacturers  
Association  
We don't believe The agency agrees 420.801(d)  
that it's the role of with this  
the Department to comment.  
use licensure as a  
hammer to force  
independent  
businesses into  
forming  
relationships with  
labor unions  
which will  
unalterably  
change and  
distort their  
workplaces.  
Steve Linder,  
Michigan  
Cannabis  
Manufacturers  
Association  
We don't believe The agency agrees 420.801(e)  
that it's the role of with this  
the Department to comment.  
use licensure as a  
hammer to force  
independent  
businesses into  
forming  
relationships with  
labor unions  
which will  
unalterably  
change and  
distort their  
workplaces.  
Steve Linder,  
Michigan  
Cannabis  
Manufacturers  
Association  
We don't believe The agency agrees 420.801(2)(3)  
that it's the role of with this  
the Department to comment.  
use licensure as a  
hammer to force  
independent  
(h)  
businesses into  
forming  
relationships with  
labor unions  
which will  
unalterably  
change and  
distort their  
workplaces.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 4  
6
Jason Palomba  
In support of  
labor peace  
agreements.  
The agency agrees 420.801  
with the comments  
in opposition to  
Gives the option this one.  
for workers to  
join a union if  
they choose so.  
13.Date report completed:  
3/24/2020  
MCL 24.242 and 24.245  
;