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:  
Marijuana 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:  
Name of Department Regulatory Affairs Officer reviewing this form:  
Elizabeth Arasim  
2. Rule Set Information  
MOAHR assigned rule set number:  
2021-10 LR  
Title of proposed rule set:  
Marihuana Employees  
3. Purpose for the proposed rules and background:  
To update the existing rules to allow for hearings for employees/individuals who have received notice  
of the agency’s intent to exclude them from employment at a marihuana business and to address  
employees being allowed to work at multiple marihuana businesses.  
4. Summary of proposed rules:  
The rule changes are designed to create consistency in the hiring and employment practices of  
marihuana businesses, specifically as it relates to an employee being employed by more than one  
marihuana business.  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
The Flint Journal – September 7, 2021  
The Grand Rapids Press – September 7, 2021  
The Mining Journal – September 7, 2021  
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:  
9/1/2021  
7. Date, time, and location of public hearing:  
9/27/2021 09:30 AM at Williams Building, 1st Floor 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:  
9. List of the name and title of agency representative(s) attending public hearing:  
Andrew Brisbo – Executive Director  
Jessica S. Fox – Departmental Analyst, Scientific & Legal Section  
Kelly Kronner – Departmental Analyst, PR Section  
10. Persons submitting comments of support:  
MCMA  
Cannabis Law Section Special Committee on Rules  
Terrapin  
11. Persons submitting comments of opposition:  
Cresco Labs  
Bob Hendricks  
Carbidex  
Cannabis Law Section Special Committee on Rules  
NORML  
Terrapin  
Shryne  
MCMA  
12. Identify any changes made to the proposed rules based on comments received during the  
public comment period:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 3  
Name &  
Comments made at Written  
Agency Rationale Rule number  
Organization public hearing  
Comments  
for change  
& citation  
changed  
1
MCMA  
Responsible  
The agency agrees R 420.602(2)  
Operations Plans with this  
should only apply comment.  
to specific  
(e)  
licensees (those  
who sell/transfer  
to customers).  
Other licensees  
cover the topics  
applicable to  
them in the  
required security  
plans.  
2
3
Cannabis Law  
Section –  
Special  
Committee on  
Rules  
The definition of The agency agrees R 420.602(6)  
employee listed with this  
in 420.602(6) is comment.  
inconsistent with  
the definition in  
420.602(1).  
MCMA  
Comment was  
received on the  
Marihuana  
Definition updated R 420.601(1)  
to match definition (j)  
in other rule set  
Licenses rule set where feedback  
that the definition was incorporated  
of Marihuana  
Establishment  
should be  
under R 420.1(1)  
(s).  
modified to  
match the  
definition in  
MRTMA.  
13.Date report completed:  
12/16/2021  
MCL 24.242 and 24.245  
;