Supporting a Thoughtful Path Forward: Clarifying Our Role in the Ongoing DOH Rulemaking Process

For more than two years, The Cannabis Alliance has been deeply engaged in the Department of Health’s process to update Washington’s medical cannabis standards. The rulemaking is still in the CR 101 exploratory phase, which allows DOH to revise language, test ideas, and gather extensive stakeholder input before any formal proposal is filed. This flexibility is one of the strengths of the CR 101 stage, and DOH has used it well, making thoughtful adjustments, asking good questions, and showing a genuine commitment to listening widely.

Throughout this period, we have worked closely with patients, medical advocates, laboratories, and cannabis businesses to gather and share feedback that reflects both scientific considerations and real operational experience. DOH has consistently been responsive to that feedback, refining concepts and making appropriate revisions as questions arise. Their openness to collaboration has been central to the progress made so far.

Because of this long and open exchange, we noted with interest when a recent internal working draft included several new concepts that had not appeared in any earlier conversations. Ideas such as treating every package size as a separate product for testing or introducing a bile-tolerant gram-negative bacteria requirement were not part of the discussions we have participated in, nor did they come from the recommendations we have offered over the past two years.

These additions did not come from The Cannabis Alliance, and they are not ideas we have put forward during this process, and we remain curious why they were added.

In the comments we shared with DOH, we focused on how these new concepts could affect the feasibility of the program, particularly because participation in Washington’s medical cannabis system is voluntary for producers and processors. Any substantial new testing or administrative requirements must be carefully evaluated to ensure they do not unintentionally reduce participation and limit patient access to safe and affordable products that meet their needs and maintain high standards.. You can view our most recent feedback to DOH HERE.

Our role throughout this rulemaking has been to offer constructive, science-supported, and experience-based feedback. That includes recognizing improvements, suggesting alternatives when appropriate, and raising questions when a proposal might have downstream effects for patients, laboratories, or businesses. The balance between patient protection and practical implementation has guided every comment we have submitted.

As DOH continues refining the draft, which is an expected and healthy part of the CR 101 process, we remain confident in the collaborative spirit that has shaped this work. We appreciate DOH’s willingness to explore ideas, revisit concerns, and continue shaping a rule that reflects the needs and realities of Washington’s medical cannabis community.

The Alliance will continue to participate with the same approach we have brought for more than two years: steady engagement, transparent communication, and a shared commitment to a medical cannabis program that is protective, sustainable, and supportive of patient access.