4141 Yonge Street, Suite 401 Toronto, Ontario M2P 2A6 SENT VIA EMAIL March 10, 2020 Ministry of The Attorney General Policy Division Legalization of Cannabis Branch 720 Bay Street, 11th Floor Toronto, ON, M7A 289 Subject: 20-MAG001 Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits The Canadian Federation of Independent Business (CFIB) is a non-profit, non-partisan business association with 110,000 members across Canada, including 42,000 here in Ontario. We welcome the opportunity to provide feedback on the potential implementation of additional cannabis business opportunities in Ontario, including allowing for cannabis consumptions establishments and special occasion permits. We would expect any broadening of the cannabis sector to include ample small business opportunity and competition, as is the case in the current retail environment. Any broadening of cannabis points of sale will likely bring new licencing, reporting and regulatory requirements. We encourage the government to streamline these processes as much as possible to reduce red-tape barriers to entering the sector. We have heard from our existing members in the space that communication from the AGCO has been lacking during the application process. Additionally, we have heard complaints from existing retailers that the product procurement process has been a pain point, and the government would do well to look into opportunities to improve, particularly on the user-experience side. It is our understanding that cannabis consumption establishments will hold exclusivity on commercial cannabis consumption, as opposed to allowing existing bars, cafes and/or restaurants to sell cannabis products edibles, beverages) in addition to their current offerings. In either case, we strongly recommend the government enhance its CanSell program to ensure staff serving cannabis products are educated and able to educate customers on the effects of what it is they are consuming. We also recommend that the government examine the federal cannabis marketing restrictions and the impacts they would have on consumption establishments? ability to operate. Depending on the interpretation of certain clauses, a customer asking for a recommendation or explanation of a given product, or store signage, could contravene federal law. The Ontario government should work with their federal counterparts to recommend changes to the federal rules where necessary to ensure consumption establishments are able to operate without the threat of another jurisdiction?s laws over their heads. At the time of writing, there are 45 Retail Store Applications in the public notice phase almost double the number of operating stores in the province. In order to guard against the supply shortages that plagued the early days of cannabis retail in the province, we recommend that the government work with the Ontario Cannabis Store (OCS) in its capacity as wholesaler to study the supply levels necessary to maintain a robust cannabis consumption outlet sector, while also ensuring retail outlets have access to the supply they need. We would not recommend proceeding with consumption outlets before those supply levels are known and product availability can be guaranteed to prospective consumption establishment operators. Furthermore, the government should consider that if it continues to act as wholesaler, if the final price point offered at a consumption site will be sustainable for the business and meet the government?s goals of eliminating the underground cannabis market. We look forward to continuing to engage with government on the next steps of this consultation. Sincerely, Ryan Mallough Director of Provincial Affairs, Ontario REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). David Clement- North American Affairs Manager Consumer Choice Center Consumer Choice Center- 2464 Post Road Oakville, Ontario, L6HOJ2 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement I Other? Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Yes, the government of Ontario should allow for cannabis consumption in commercial settings. Specifically, edibles and beverages should be available in any restaurant, bar, or clubs currently licensed to sell alcohol, as well as in stand-alone establishments dedicated solely to cannabis consumption. Ready access to legal consuming space is what can ultimately make the legal market more attractive than the alternative. The black market has always had various forms of edible cannabis available for sale but it has never offered a controlled and legal place for users to ingest or consume it. By liberalizing where it allows cannabis consumption the Ontario government can empower the legal and regulated market at the expense of illicit trade. Cannabis consumption establishments should be allowed to sell all items that are currently allowed to be sold alongside beverage alcohol. This should also include accessories that may be required for consumption. Yes, the government should allow for SOP's for cannabis consumption. Consumers should have the ability to purchase cannabis products at special events that have the appropriate special occasion permit. These products should be sold alongside alcohol to allow for parity. Edible and beverage consumption should be permitted in spaces where alcohol consumption is permitted. The smoking of cannabis should be permitted wherever tobacco consumption is permitted under the Smoke Free Ontario Act. The SOP process for cannabis should be automatically included in the SOP process for alcohol. We would advise against creating a second SOP process exclusively for cannabis. Cannabis Consumption Establishments Allowing for consumption establishments would help the legal market compete with the black market. Allowing for consumption establishments would allow for bars, restaurants, and lounges to have more product variety for their customers, and more consumer choice for consumers. SOPs: SOPs give festival, concert and special event participants more consumer choice and product variety, which is a big positive for cannabis consumers in the province. Further more, there are economic benefits for the venues and events who sell these cannabis products. We would advise against allowing for municipalities to be able to opt out of cannabis consumption establishments or SOPs. Allowing for municipalities to ban the sale/consumption of legal products does nothing but benefit the black market. -. '14? -.-.- Cat egorles Pro Licensed Est ,Organi zat' Ion Permits Potential for Cannabis Consumpti on Establishments and/or Cannabis Speci alO Ontario Legalization of Cannabis Secretariat (MAG) From Sent February 14, 2020 10 (M EDJCT) 46 AM Regi Marti Ashley (MAG) -. .Irr -.-. e- a ,3 - . .3 5.4 as?! Ontario Cannabis Policy Council Submission Re: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits 1. Taking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or Why not? Released in April 2019, the ?report entitled Supporting Ontario?s Budding Cannabis Indnsigj/ noted that, as cannabis becomes more widely used and available post?legalization, consumers will want to consume it in public places and social settings just like beverage alcohol is consumed. Accordingly, the report encouraged the province to consider where Ontarians would be allowed to consume cannabis once THC?in?ised edibles and beverages entered the legal market. OCC members believe that the introduction of edibles provides an opportunity that the province should continue to explore. With this said, the Ontario Government should ensure the rules that currently exist for cannabis retailers around safety, storage, display, and security, among others) should also apply to cannabis consumption lounges and caf?s. These measures would ensure a level playing field between cannabis retailers and consumption lounges and caf?s. Moreover, it would also ensure that Ontario does not have a two?tier system in which cannabis lounges operate under different or less stringent requirements than retailers. Evidence sugests consumer preferences are trending increasingly towards derivate products such as edibles. A May2019surveybyEYandLift8cCo found that as many as three million new consumers (who are not interested in purchasing dried cannabis products) may enter the cannabis market after legalization and the availability of new product formats. From this demographic, 1.5 million would be new consumers of edibles according to report. x/f found that Canadian cannabis consumers are most interested in three formats: edibles (59 percent); topicals or ointments (53 percent); and cannabis?in?ised beverages (37 percent). Not surprisingly then, Deloitte estimated that most of this burgeoning market would be cannabis extract?based products, including edibles, which was estimated at $1.6 billion alone. For new consumers or those who do not want to smoke cannabis, edibles are viewed as an option that has less stigma than combustible forms of consumption, as well as more discreet and potentially less harmful option. To ensure that public safety is top ofmind, it is critical to also consider the current state of familiarity and awareness of consumers about cannabis 2.0 products. An October 2019 survey by Responsible Cannabis Use (RCU) found that 39 percent of consumers are not aware of dosage recommendations, nearly one third do not know how long the effects take, and 94 percent did not know about the public possession limits. Considering the general appetite among Canadians, the importance of ensuring public safety, and the regulatory complexities retailers must navigate to sell recreational cannabis responsibly, the province should consider giving existing cannabis retailers in Ontario the chance to operate a lounge or cafe. This would result in a pool ofprospective operators that have an existing track record, requisite knowledge, and capacity to successfully open lounges or cafes. The emergence of lounges and cafes could provide adults with a safe, secure, and sanitary space to consume cannabis products publicly and in a social setting. 2019 report found that knowledge of cannabinoids in Canada is low among non?cannabis consumers and there is a lack of credible information about cannabis online. This also makes these licensed locations a unique channel for consumer education as consumers want to and should be encouraged to learn more about cannabis products, the effects, the laws, the limits, and regional policies. Effective education can help ensure public safety, promote responsible use, and address overall stigma in communities where the stores operate. Meanwhile, in the interest of public safety, law enforcement efforts to address illegal lounges and stores should continue in earnest. With these points in mind, consumption lounges and cafes could act as a front?line resource for new and inexperienced cannabis consumers, helping to promote safe and responsible consumption of relatively new products. OCC members believe that the province should implement mandatory training for operators and employees at consumption lounges and cafes, similar to how cannabis retail employees, holders of retail store authorizations, and holders of cannabis retail manager licenses are required to complete the online CannSell training program before their first day of work. This course should focus on additionally training operators on cannabis 2.0 products, their effects, regional laws, and concepts such as dose, set and setting which empower employees with actionable information required to operate safely and responsibility. In addition to further employer training, the operators must also make educational information available for consumers, providing the option for those interested to learn about cannabis safety tips, regional laws, possession limits, as well as other information that allows consumers to consume safely and responsibly. According to a December 2019 survey by RCU, 67 percent of Ontarians believe retailers should educate consumers on the local cannabis laws at the point of sale. We believe that education must be at the heart of these operations. As the report explained, edibles pose a unique set of challenges for inexperienced consumers, namely the fact that the effects of an edible product are not felt immediately. Chemicals from an edible product must enter an individual?s digestive system first, followed by the bloodstream, central nervous system, and then the brain. Depending on several factors, including the individual?s metabolism and if cannabis was ingested with food or an empty stomach, the effects can be felt after 30 minutes or after three to four hours. Moreover, the effects from an edible can last up to eight hours or longer. lndividuals unfamiliar with this latency period may accidentally consume more than intended, resulting in severe anxiety, nausea, vomiting, a episode, hypotension, and or loss of consciousness. Thus, education of consumers and employees at lounges will also raise public awareness of cannabis and edibles, as well as complement the province?s efforts to educate consumers on responsible consumption. It is also worth mentioning that industry is making significant research and development efforts for 2.0 products, such as beverages, to have more predictable onset and comedown times similar to the effects of alcohol. This would hopefully alleviate some of the challenges of managing the effects of existing edibles. 2. If cannabis consumption establishments were considered in Ontario, what other products should be permitted for sale in those establishments cannabis accessories, food beverage products that do not contain cannabis)? The cannabis lounges should be able to offer sales of other products such as cannabis accessories, and food/beverage products that do not contain cannabis. Food and drinks can help increase public safety, as they have been known to help reduce or calm down the effects of cannabis products over time. Of course, all food and beverage products must pass Health Canada?s requirements. The Province should ensure that cannabis lounges or cafes do not permit ?off? sales.? In other words, consumers should not be able to purchase large quantities of edible products to consume at home as this would blur the lines between cannabis retail establishments and cannabis lounges or cafes. The precedent already exists with restaurants, bars, and similar establishments as consumers cannot purchase bottles ofbeverage alcohol to consume at home. While it may be beyond the scope of this specific question, it is worth examining how service? oriented industries could participate and add further value to these proposed establishments. For instance, offering customers the opportunity to partake in a yoga class or buy topicals and receive a massage. 3. In Ontario, the Alcohol and Gaming Commission of Ontario (AGCO) oversees the administration of an alcohol SOP program, which allows for the sale and service of alcohol at special occasions, including large scale events that are open to the public, such as festivals. 0 Should the government consider establishing a similar SOP program for cannabis to be sold and consumed at festivals and events? Why or Why not? 0 If yes, What conditions should be included should alcohol consumption at the same event be restricted, should the event be age-restricted to 19+, What methods of cannabis consumption should be permitted)? The recommendations contained in this submission builds on the April2019report, Supporting Ontario?s Budding Cannabis Based on input from OCC members, including representatives from Chambers and boards of trade, industry, and public health, the report encouraged the province to consider the licensing ofprivate consumption lounges as edibles were to enter the legal market later that year. The OCC is pleased that the province ended the lottery system, moved towards an open allocation model, and is currently consulting the public and industry on consumption Although special occasion permits ($0st are part of the province?s current consultation and the OCC is in support of them, it is viewed as separate and distinct from cannabis consumption lounges and cafes. Currently, regulations prohibit cannabis companies from displaying cannabis products and providing adults with the opportunity to consume and purchase cannabis on?site. This presents a signi?cant issue for festival and conference organizers. For instance, L1ft&CoandtheirCannabisEXpo a four?day conference that is held in Toronto and brings together over 250 exhibitors from around the world and over 100 speakers. However, the province will need to determine and clarify the following: 0 Can event organizers obtain both an alcohol SOP and cannabis Alternatively, do conference organizers have to Choose between one of those 0 Where will event organizers be required to procure cannabis products from the Ontario Cannabis Store, Retailers and/ or 0 What products are conference organizers permitted to make available for consumers striking the right balance between providing Health Canada approved products and showcasing new products not available in the Canadian market)? 0 Would event organizers be allowed to grant retailers the permit to sell cannabis on site? 4. Are there any additional risks opportunities created by cannabis consumption establishments or SOPs when compared to authorized cannabis retail stores? In numerous public opinion polls, the issue of driving and cannabis use post?legalization has consistently emerged as a prominent concern for Canadians. For example, a national survey conducted by Leger in August 2018 (on behalf of the Insurance Bureau of Canada) found that 78 percent of Canadians were concerned about cannabis?impaired drivers. These fears are not unfounded. In fact, Statistics Canada data shows that 13 percent of cannabis users with a valid driver?s licence reported driving within two hours of using cannabis in 2019. lBC?s survey also found that 43 percent of respondents did not know how long they should wait before getting behind the wheel. The above concerns may be heightened given the previously mentioned complexities associated with edibles. These concerns ?lrther highlight the need for education at point of sale, and underscore the need for the province to invest in public awareness campaigns that provide adult consumers with basic cannabis literacy and work with relevant stakeholders, like consumption lounge and caf? operators, to develop effective campaigns. While the current business opportunities for cannabis lounges under the existing regulatory regime may be limited, there is a significant business opportunity should federal rules be amended to allow for a cannabis?in?lsed culinary or artisanal beverage experiences to be a part of cannabis lounges. To this end, the province should Clarify what its long?term vision for cannabis lounges or caf?s and whether the intent is to develop a tourism and hospitality industry surrounding cannabis lounges, with cannabis?in?lsed products available at such establishments. For regions like Niagara that are Close to the US border, consumption lounges and cafes in Ontario could help attract tourists and cannabis tourism. Moreover, these establishments would provide tourists with Clarity in terms of where they can legally consume cannabis and deter consumption in parks or other public venues. As cannabis tourism grows, this will increase traffic at the border and the potential for impaired driving. Thus, the province may need to install more officers at the border to deal with and deter impaired drivers. 5. What should be a municipality?s involvement, if any, in a potential framework for cannabis consumption establishments or OCC members believe that individual municipalities should not regulate where consumption lounges and cafes are located. The rules that dictate where restaurants and bars (that serve beverage alcohol) can be located as well as existing rules for where retailer locations can be established should inform regulations for consumption lounges. The province should consult with relevant associations that represent municipalities, like Ontario Urban Municipalities Association and Association of Municipalities of Ontario, to develop a common set of criteria (and harmonization) that prospective cannabis lounge and cafe operators must meet. Allowing each municipality in Ontario to create their own criteria would make it more difficult for prospective operators to navigate distinct criteria across Ontariogs 444 municipalities. 6. Other comments or suggestions you Wish to make about cannabis consumption establishments and or SOPS. The April 2019 report noted that many post?secondary institutions in Ontario have developed programs and invested in the development of facilities, such as the Guelph Centre for Cannabis Research, related to cannabis. Since legalization impacts a range of sectors, including public health, human resources, transportation, and law enforcement, it is likely that new cannabis courses and research centres will continue to emerge. As new product classes enter the legal market and the province permits new cannabis?related business opportunities, the demand for labour will likely evolve. Ultimately, Ontario is home to a robust talent pool and professionals with knowledge of cannabis production, cultivation, regulations, and law, to name a few areas of expertise. With access to quali?ed personnel, cannabis tourism is an additional market that the province could consider developing to support legal businesses and drive economic growth and job creation. The 2019 report, therefore, recommended that the Ministry of Tourism, Culture and Sport work with relevant stakeholders to incorporate cannabis?related tourism in its forthcoming Ontario Tourism Strategy. As it develops additional policies and education campaigns related to cannabis, and as the stigma around cannabis consumption continues to dissipate, the province should regularly review policies and regulations surrounding the sale and distribution of cannabis to mitigate risks and foster a competitive regulatory environment. RESPONSE TO 0 LTAT a ON CANNA CONSUMPTEON ESTABLESHMENTS Submission March 10, 2020 Ontario?s Cannabis Consumption Establishments Consultation Response March 10, 2020 Ministry of Attorney General Policy Division Legalization of Cannabis Branch 720 Bay Street, 11th Floor Toronto, ON M7A 259 RE: Proposal 20-MAG00 1 On behalf of the hospitality industry in Ontario, ORH MA is supportive of the government?s efforts to explore future policies that could result in a more open cannabis market for the hospitality industry and allow recommendations through a consultation to solicit input on permitted cannabis consumption in lounges, outdoor festivals and concerts across the province. The purpose of this submission is to provide comments and recommendations on behalf of the hospitality industry and members of the Ontario Restaurant Hotel Motel Association (ORH MA) regarding the introduction of cannabis consumption establishments (permanent and special occasion lounges, restaurants, cafes, culinary events, etc.) within the province of Ontario. ORH MA has collected supportive feed back from industry operators and has provided comments and recommendations which respond to specific questions that the Ontario government has asked on this matter in the government questionnaire. While it is unknown how much economic impact cannabis consumption lounges could have in Ontario, allowing people to consume cannabis legally in a public venue is likely to improve public awareness of the drug while reducing any stigma associated with it. It is important to recognize that cannabis is a legal product in Canada when grown, processed, transported, sold/served and consumed in a manner consistent with the Cannabis Act and regulations. This includes, but is not limited to, licensure of establishments, properly trained staff and management, appropriate food and consumer safety controls, consumer education, and administration of relevant regulations and laws. Within this context, it is entirely appropriate to consider how to enable consumers to enjoy cannabis products in a controlled manner at consumption establishments for this purpose. In fact, Canadian companies are already delivering culinary (and other) experiences that incorporate cannabis in less controlled ways Second, Ontario?s restaurant, hotel and motel business owners have a demonstrated record of world? class customer service, property quality and consumer safety and security. The industry has proven that it fulfills an essential part in achieving government public policy objectives. It has done this while delivering high quality, safe services and products, and furthermore they would do so for consumers who want to purchase and consume edibles in a welcoming public environment. Lastly, it is important to reflect on the impacts of cannabis prohibition for almost a century: banning does not work. A critical component of social normalization of cannabis is trust. This requires education of businesses and consumers on what ?responsible use? is and how to achieve outcomes consistent with public good and business benefit. Ontario?s Cannabis Consumption Establishments Consultation Response TABLE OF CONTENTS BACKGROUND 3 SUMMARY 5 RECOMMENDATIONS 7 2 Ontario?s Cannabis Consumption Establishments Consultation Response BACKG ROU ORH MA is comprised of business members in the hospitality, and food and beverage service sectors. It is Canada?s largest provincial hospitality association representing over 11,000 businesses. We recognize that on the question of cannabis consumption establishments, governments must balance competing interests, including: public and consumer safety, consistency in product processing and preparation, reliable supply of quality products that can help eliminate the illicit cannabis market, reliable training, and building an environment in which commercial business can innovate and succeed. In December 2019, according to figures released by Statistics Canada, Canada?s cannabis industry represented $7248 of the country?s gross domestic product (GDP). The legal cannabis market accounts for $3.08 of economic output to Canada?s GDP, an increase of 138% since recreational cannabis was legalized in October 2018. This means that illegal (?legacy?) sources of cannabis still account for a majority of sales. Overcoming this is a key public policy and business concern. The cannabis plant contains over 400 different chemical compounds and the ones of particular interest to most consumers are cannabinoids1 (compounds that are naturally occurring in cannabis, and indeed in humans and most mammals); terpenes (chemicals that create unique scents for the varieties of cannabis); and flavonoids (chemicals responsible for taste). The two most plentiful cannabinoids found in cannabis are delta?9?tetrahyd rocannabinol (THC) and cannabidiol (CBD). CBD is a non?intoxicating compound that has promise for medical uses ranging from epilepsy to pain control and addiction treatment because of its mechanism of action and its safety profile. THC is a compound that creates the ?high? or inebriating effects of cannabis. CBD is a component of cannabis; according to a 2017 report from the World Health Organization, ?In humans, CBD exhibits no effects indicative of any abuse or dependence To date, there is no evidence of public health related problems associated with the use of pure Thus far, clinical trials of the effects of combining cannabinoids with alcohol have produced curious results. It has been demonstrated that consuming alcohol with THC alters the level of human impairment and the level of impairment does vary3. Other human trials demonstrated that the 1 Alcohol and Drug Abuse Institute, University of Washington. 2 WHO Expert Committee on Drug Dependence, November 2017. 3 Ronen,A., Chassidim,H., Gershon,P., Parmet,Y., Rabinovich,A., Cassuto,Y., Shinar,D. The effect of alcohol, THC and their combination on perceived effects, willingness to drive and performance of driving and non?driving tasks, Accident Analysis Prevention. Volume 42, Issue 6, June2010; 1855?1865. 3 Ontario?s Cannabis Consumption Establishments Consultation Response combination of alcohol plus CBD resulted in significantly lower blood alcohol levels compared to alcohol alone. Thus, it seems the inactivity of CBD on motor and mental performance and effects also extends to its interaction with alcohol4. It is with all this in mind that ORHMA frames recommendations regarding the introduction of cannabis consumption establishments in Ontario. It supports government intentions to legalize such sites and differentiate the regulation and control of and THC?based consumables. 4 Consroe P, Carlini EA, Zwicker AP, Lacerda LA. Interaction of cannabidiol and alcohol in humans. (Berl). Ontario?s Cannabis Consumption Establishments Consultation Response SUMMARY It is important to start any discussion of regulatory approaches with agreement on common objectives. ORH MA has assumed the following objectives, because they are frequently raised in cannabis legalization debates as areas of common ground between those supporting and those opposing legalization: 1. minimizing access, availability, and use by youths (<19 years old) 2. minimizing impaired driving 3. minimizing consumption of cannabis products with unwanted contaminants and uncertain potency 4. minimizing dependence and addiction 5. minimizing concurrent use of cannabis and alcohol, particularly in public settings, and 6. minimizing purchase and use of illicit cannabis. ORH MA wishes to support achieving these outcomes by encouraging legal consumption at properly authorized locations and through education and familiarity. It is clear that informed consumers who use evidence?based decision making are more likely to make a correct ch0ice5. Therefore, ORH MA favours the Ontario government?s initiative to permit public cannabis consumption establishments (permanent and special events), provided that it is accompanied by appropriate education for consumers and the general public. ORH MA has shown it can reinforce public policy objectives and would highlight its demonstrated capabilities in addressing other issues, such as sexual harassment training, responsible alcohol consumption with programs such as Best Bar None (BBN), and food safety training. It is also a proponent of the elimination of human trafficking and has initiated a program for workforce development. In addition, ORH MA can be an effective partner?advocate for educating consumers about the science of cannabis, helping to remove stigma, and generating economic benefit for the people of Ontario. In Canada, consuming medical cannabis via oils and concentrates is increasingly preferred versus being smoked6 because it is less obtrusive, lasts longer, and is more easily tolerated by many people. 5 Centres for Disease Control. Bergum A, Grigg L, Givens ML, Booske Catlin B, Willems Van Dijk J. How to Be an Informed Consumer of Evidence Ratings: It?s in the Details. DOI: 6 Canadian Cannabis Survey 2019. 5 Ontario?s Cannabis Consumption Establishments Consultation Response However, smoking or inhaling the vapours of heated cannabis (vaping) is still the predominant format for cannabis enthusiasts7. Edible cannabis products are not solely used for recreational purposes. However, in Canada, a significant minority (30 percent) of medical cannabis buyers do prefer non?smokable forms of the product. A trend away from smoking cannabis continues. The experience of US states, such as California, Arizona, Washington and Colorad08, shows that once legalized, sales of edibles grow in a relatively short time to exceed fifty percent of total cannabis revenue. Medical use patterns may be a predictor of trends in recreational use of different cannabis products. The above factors can influence adult recreational users, who seek an eating or drinking experience and wish to try different products. With these over?arching aspects in mind, several of the recommendations reflect a need to better align business activities with the prime objectives of the Cannabis Act, as well as with proven public safety practices. Where clinical evidence to support regulation of THC and CBD dosages is absent or unclear, it is recommended that government rely on practical medical considerations to provide guidance for regulatory pu rposes.9 7 Canadian Cannabis Survey 2019. 8 Barrus, D. G., Capogrossi, K. L., Cates, S. C., Gourdet, C. K., Peiper, N. C., Novak, S. P., Lefever, T. W., Wiley, J. L. (2016). Tasty THC: Promises and Challenges of Cannabis Edibles. Methods report (RTI Press), November 2016, 10.3768/rtipress. op.0035.1611 9 McCallum, CA, Russo, EB. Practical considerations in medical cannabis administration and dosing. European Journal offnfernai Medicine, November 2018. 6 Ontario?s Cannabis Consumption Establishments Consultation Response RECOMMENDATIONS Yes. Cannabis and its recreational use by adults are now legal in Canada. Aside from the meaningful commercial and potential economic effects for Ontario, permitting permanent (and special event) locations for legal consumption demonstrates a high degree of political maturity and provides focal points for cannabis education and compliance with cannabis laws and regulations. This applies particularly to economic sectors of interest to ORH MA members such as hospitality, culinary tourism and entertainment. (Special occasion permits would similarly enable consumers and businesses to experience how cannabis may enhance their experience, education and responsible use at specific events.) interests are with regards to edible and drinkable cannabis products. If the Ontario government decides that it does not want to alter SFOA regulations at this time, we foresee a possible consequence may be that consumption occurs in locations where it is less likely to attract enforcement attention. Edible/d rinkable cannabis products are not used solely for recreational purposes. Currently in Canada, more than 25% of medical cannabis buyers prefer non?smokable forms of the product. The experience of US states, such as California, Arizona, Washington and Colorado?, shows that once legalized, sales of edibles (including drinks) can quickly grow to exceed fifty percent of total cannabis revenue. There are no evidentiary reasons to exclude accessories and non?cannabis items from sale in these establishments. In addition, educational materials concerning cannabis and 10 Barrus, D. G., Capogrossi, K. L., Cates, S. C., Gourdet, C. K., Peiper, N. C., Novak, S. P., Lefever, T. W., Wiley, J. L. (2016). Tasty THC: Promises and Challenges of Cannabis Edibles. Methods report (RTI Press), 2016, 7 Ontario?s Cannabis Consumption Establishments Consultation Response responsible consumption can and should be encouraged. Items that promote cannabis brands should be considered off?limits only if they are proven to encourage misuse or abuse. Cannabis is legal and ought to be treated that way; it is, however, unlike alcohol. The Ontario government should consider cannabis as a unique product and manage it differently than the regulatory framework of alcohol. Separate locations where cannabis can be legally consumed (such as licensed lounges) can lower the probability that cannabis and alcohol are used concurrently. Because of the evidence on how concurrent use of THC and alcohol alters the risk and degree of impairment?, regulating places of consumption can have important public safety implications. For example, cannabis use may be restricted to authorized establishments that do not allow alcohol to be consumed in the same space. This could apply to smokable forms as well as edibles. ORH MA suggests that SOPs be considered later in a second phase of introduction of cannabis consumption sites through an approval process. Cannabis effects are different from alcohol. Alcohol often creates negative social outcomes (loss of inhibitions leading to anti?social or aggressive behaviours), while cannabis creates the opposite effects. An example is impaired driving. 11 Ronen, A, Chassidim, H., Gershon, P., Parmet, Y., Rabinovich, A, Bar?Hamburger, R., Cassuto, Y., Shinar, D. The effect of alcohol, THC and their combination on perceived effects, willingness to drive and performance of driving and non?driving tasks; Prevention. Volume 42, Issue 6, June2010. 1855?1865. 8 Ontario?s Cannabis Consumption Establishments Consultation Response Detrimental effects of cannabis use vary and are more pronounced with highly automatic driving functions than with more complex tasks that require conscious control. Whereas, alcohol produces an opposite pattern of impairment. Because of this and an increased awareness that they are impaired, cannabis users tend to compensate while driving by utilizing a variety of behavioral strategiesiz. Cannabis and alcohol have each been shown to impair driving?related skills in a dose? related fashion. The effects of cannabis vary more between individuals than they do with alcohol because of tolerance, differences in ingestion technique, and different absorption rates. CBD may in fact diminish the intoxicating effects of alcohol?. Epidemiological studies have been inconclusive regarding whether cannabis use causes an increased risk of accidents; in contrast, unanimity exists that alcohol use increases crash risk?. In short, impairment due to cannabis is not the same as that from alcohol. Perhaps we can shift our thinking and instead of taking sides, we can all agree that both alcohol and cannabis have associated risks. The overall message being, if you are going to drive a car, you should not consume either. ORHMA concurs that when it comes to driving, ?impaired is impaired" and yet the differences to how cannabis is used products for medical purposes) call for a more informed and nuanced treatment of cannabis consumption establishments and SOPs. ORHMA does not support a broad prohibition of cannabis products that contain THC in consumption establishments. While products containing only CBD can be argued to hold no intoxication risk versus those with THC, the Canadian public has already spoken when it comes to consumption of cannabis?. They want to experience all types of cannabis products. We say again that legal consumption should be permitted in a way that encourages education about cannabis and its responsible use. 12 Sewell RA, Poling J, Sofuoglu M. The effect of cannabis compared with alcohol on driving. American Journal of Addiction, 185?193. 13 Ronen, A., Chassidim, H., Gershon, P., Parmet, Y., Rabinovich, A., Bar?Hamburger, R., Cassuto, Y., Shinar, D. The effect of alcohol, THC and their combination on perceived effects, willingness to drive and performance of driving and non?driving tasks; AccidentAnaiysis Prevention. Volume 42, Issue 6, June2010. 1855?1865. 14 Sewell RA, Poling J, Sofuoglu M. The effect of cannabis compared with alcohol on driving. American Journai of Addiction, 185?193. 15 Charlebois, 8., Sterling, B., Music, J., Somogyi, S. Edibles and Canadian consumers? willingness to consider recreational cannabis in food beverage products. Dalhousie University, Agrifood Analytics Lab, May 2019. Ontario?s Cannabis Consumption Establishments Consultation Response Cannabis Consumption Establishments: Tourism and culinary experiences are obvious market opportunities that can benefit from a robust Ontario cannabis consumption establishment network. When combined with efforts at consumer education, these establishments can become a unique feature of attraction for tourists in Ontario. One risk in cannabis consumption (in any location) is that of public impairment. Because of the obvious contention in trying to find common ground on restrictions or limitations on adult use, we do not include it as an explicit objective, although we recognize there may be public health arguments for making reduction in overall use a policy goal. We submit that existing laws regarding public impairment will provide sufficient enforcement authority and deterrence. SOPs: ORH MA suggests that SOPs be considered later in a second phase of introduction of cannabis consumption sites through an approval process. Concerts and other public entertainment events are clear opportunities for cannabis SOPs. These may or may not be associated with tourist attractions. The challenges associated with licensing these events are not unlike those at which alcohol is served, and/or where tobacco smoking is permitted. Municipalities that do not currently allow cannabis retail outlets within their boundaries have created the unintended consequence of providing ?cover? for illicit sales of cannabis?. Municipalities may feel an inclination to enact similar restrictions with special events involving cannabis. This should not be encouraged. If a municipality permits special events/occasions within its boundaries, then it should not be able to refuse a cannabis SOP. Ontario may want to permit municipalities to (not unduly) restrict times for cannabis consumption SOPs. 16 Statistics Canada, January 23, 2020. Quarterly cannabis pricing update. 10 Ontario?s Cannabis Consumption Establishments Consultation Response Access to cannabis and pricing are two major drivers of consumer behaviour regarding cannabis. As noted above, these facts have been amply demonstrated since legalization according to Statistics Canada?s own data. The illegal (?legacy?) market still accounts for the majority of cannabis sales in Ontario. Denying access and/0r charging high prices encourages illicit supply and sale.17 If the Ontario government is serious about addressing the availability of (access to) cannabis, it should consider these statistics as it sets the rules regarding cannabis licensing in general, and specifically those for consumption establishments. Lastly, while CBD is a component of cannabis, according to a report from the World Health Organization, ?In humans, CBD exhibits no effects indicative of any abuse or dependence potential . . .. To date, there is no evidence of public health related problems associated with the use of pure For this reason, ORH MA recommends that CBD?dominant cannabis products be afforded substantially less stringent control than products that are THC?dominant. That said, infused products should not be banned from consumption locations. For further information, or questions regarding this submission, please contact: Tony Elenis President CEO Ontario Restaurant Hotel Motel Association (ORH MA) 905.361.0268 17 Gettman J, Kennedy M. Let it grow?the open market solution to marijuana control. Harm Reduction Journal. Published 2014 Nov 18. 18 WHO Expert Committee on Drug Dependence, November 2017. 11 To: Ontario Legalization of Cannabis Secretariat Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Oocasion Permits Date: February 14, 2020 10:46:32 AM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government . would like your feedback on the potential implementation of . . additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Bianca Caramento 5 Hamilton Chamber of Commerce 120 King St. W, Plaza Level, S, hamilton chamber of commerce Hamilton Ontario L8P 4V2 Tel: 9055221151 Email: b.caramento@hamiltonchamber.ca Ontario?s legal cannabis market is not meeting its full potential. Currently, Ontario has 24 cannabis retail stores serving a population of 14 million people. An additional 50 stores are expected to be operational by spring 2020. The Province of Alberta, In comparison, has opened over 300 cannabis retail stores, serving a population of4 million people. Provincial government estimates suggest Ontario?s cannabis market could support up to 1,000 retail stores and create approximately 14,000 jobs in the retail sector alone. Ontario had the highest cannabis sales of all other provinces in Ethe first year of legalization, with a total of $216 million in sales.This suggests the legal cannabis market is drastically underserved, allowing the illicit market to continue flourishing. Ontario is home to about half of all Licensed Producers across Canada, employing .. approximately 6,000 Ontarians. To support this emerging industry, the Government of Onta rio needs to focus public policy and investment efforts effectively in key Eareas. Now that THC- infused edibles and beverages have entered the legal market, cannabis consumption lounges for edibles (excluding smoking or vaping cannabis) inE Ontario would create opportunities for investors, entrepreneurs, and existing businesses and, in turn, create jobs. The emergence of consumption lounges would provide adults with a safe, secure, and sanitary space to consume cannabis products. Consumption lounges also present an opportunity to act as a front-line resource for public education, thereby complementing the Province?s efforts to educate consumers on responsible consumption, especially for new products they may be unfamiliar with. Recommendation The Hamilton Chamber of Commerce urges the Government of Ontario to: Consider the licensing of private consumption lounges for Ontarians to consume .. TEHC-infused edibles and beverage products. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). James Rilett Vice President, Central Canada Restaurants Canada 1155 Queen Street West Toronto, ON M6J 1J4 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _lndustry Association? Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial The sale of cannabis for consumption in lounges and cafes has been a successful model in manyjurisdictions and should be considered in Ontario. The foodservice industry has a long history of serving controlled products responsibly (ie beverage alcohol) and would be a natural provider if the Ontario government opted to allow consumption cafes. (insert comments if necessary the box will expand as you type) If cannabis consumption establishments are allowed, they should not compete with established businesses. Foodservice businesses have very tight margins in a very competitive environment. If retail cannabis establishments are allowed to run consumption lounges as well as providing food and beverages, it creates an unbalanced competitive advantages. This would be akin to alcohol retailers being allowed to open bars in their establishments. There are a couple of areas that the government should be investigated in relation to on- premise consumption. The most obvious link is through the existing beverage alcohol system. These establishments are already licensed and inspected by the government and have staff who are already Smart Serve trained. Updated training requires additional knowledge in the signs of cannabis intoxication. While otherjurisdictions have segregated alcohol and cannabis sale and service, it should not be assumed that this is the best course of action. Staff must keep track of alcohol served to patrons but also must look for signs of cannabis intoxication. A server that is given control of both products can better track input as opposed to the current climate in which cannabis purchased elsewhere is consumed furtively. The second area of the foodservice sector that should be considered for cannabis consumption lounges and cafes are existing caf? concepts. These concepts already exist and would be negatively impacted if existing retail stores are allowed to expand into food and beverage service. As the current federal regulations only allow for pre-packaged consumables, the caf? concept would be a natural expansion for operations that already serve edible food products alongside beverages like coffee and tea. (insert comments if necessary the box will expand as you type) ?II-Cannabis Consumption Establishments. There are two cannabis products that could be sold in foodservice establishments: packaged edibles and packaged beverages. These should both be considered for sale in the licensed alcohol locations as well as locations that do not sell alcohol. SOPs: (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) In order to ensure a consistent sales system across the province, the municipal role should be minimized. (insert comments if necessary the box will expand as you type) REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit As part of Ontario?s transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1.facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2.cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an 1 open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feed back. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings cafes, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e?cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). 2 The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain excep?ons. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario?s cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 3 - cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) . cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) - cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada?s rules for edibles, extracts and topicals, please visit: topicals.html Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. 4 Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information 5 Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Tony Pontes, Executive Director Council of Ontario Directors of Education 1123 Glenashton Drive Oakville, ON L6H 5M1 About You or Your Organization (please check the appropriate box/boxes) Municipality Indigenous El Health organization organization/communit Educator Law enforcement Other 6 Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8 Provincial 7 NO directors of education do not support the expansion of permission to consume cannabis in establishments lIke lounges or cafes GIven the directors the provmce should be more conservatIve on its policy. And certainly we would recognize that under-age youth can be in cafes, we do not believe that they should be exposed to cannabis use in those areas. Further to our response above, directors of education do not believe that other products, especially cannabis accessories should be sold in those establishments. 8 9 This seems contradictory festivals and similar events are usually Intended for people of all ages cannabis in publIc places then by lIcensmg Its sale at special events such as festivals effectively eliminates families from attending those special events. The govt should be looking at these proposals from a family or youth/child perspective. Cannabis Consumption Establishments. Supervision and monitoring as well as the negative impact on youth would be the two main concerns SOPs: Supervision and monitoring as well as the negative impact on youth would be the two main concerns 10 (insert comments if necessary the box will expand as you type) Directors of education believe that there should be a consistent policy and enforcement of cannabis use in the province. The potential for inconsistencies that negatively impact children and youth is very high if the decision is inconsistent from municipality to municipality. 1?1 I hope that the input of the 72 directors of education, representing 2 million students is carefully considered. 12 13 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominiumlbuilding policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Andrea Campbell on behalf of Niagara College Niagara College Cannabis lnstitute ancambbell@ nia daracolleore. ca cell 289-924- 1663 About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial lf the government is moving towards and open market in Ontario, it will be important for them to facilitate the sale and consumption of cannabis in a safe environment. Lounges and caf?s should offer a safe space to consume responsibility and for new users to trial cannabis in a safe environment with knowledgeable staff The government should consider an age restriction in consultation with public health and medical authorities. Retail stores could assist with facilitating these consumption caf?s or lounges, as they already have an established retail outlet with educated staff to support. Well trained staff will play a crucial role in the success of a safe and responsible consumption experience e. Further enhanced Budtender and Cannsell training). The staff would be responsible to monitor and limit the amount that can be consumed. To encourage not driving while intoxicated and to mitigate the risk of impaired driving, a ride service could be readily available and promoted by the caf? or lounge. Upon entering, there could be a 5-minute video and waiver to reinforce key messages on the subject Ease of access. The establishment could be in a designated area that would force the individual to walk to transportation to reduce the likelihood of quickly getting into a vehicle and driving while intoxicated. Rules should be consistent across all municipalities to ensure proper enforcement. First responders should be available or offer a designate who would be trained appropriately. Further to cannabis consumption using vapes, this could be offered in a space that is properly vented with extractor or carbon filter to support safe consumption. Further education and research into vaping effects on cannabis will be important. Oversight: By facilitating the consumption of cannabis in licensed lounges and cafes, the government of Ontario would retain some oversight over the quality and quantity of such establishments. Going in the other direction NOTfacilitating one runs the risk of underground lounges and caf? proliferating in non-ideal or unsafe conditions. lt would be important to have other products, that do not contain cannabis, available for sale. The establishment would have to sell food, drinks, water, and accessories. They could offer a smart consumption package that would contain product to help reduce the effects. The establishment would not allow individuals to bring their own product. All product would have to be purchased on site to ensure proper control on the outcome and safety. Knowing what is being sold and consumed will help support a safer outcome. lf the government is moving towards and open market in Ontario, it will be important for them to facilitate the sale and consumption in a safe environment. A designated space at eventsand festivals would offer a safe place to consume responsibility and for new users to trial cannabis in a safe environment with knowledgeable staff. The government should consider an age restriction in consultation with public health and medical authorities Similar to the response to questions 1 regarding the consumption lounges and cafes. Well trained staff will play a crucial role in the success of a safe responsible consumption experience and would be responsible to monitored and limit the amount of that can be consumed. e. Budtender and Cannsell training.) To encourage not driving while intoxicated and to mitigate the risk of impaired driving, a ride service could be readily available and promoted by the caf? or lounge. Upon entering, there could be a 5-minute video and waiver to reinforce key messages on the subject Rules should be consistent across all municipalities to ensure the same rules are applied and enforced. First responder available or designate well trained. Further to cannabis consumption using vapes, this could be offered in a space that is properly vented with extractor or carbon filter to support safe consumption. Further education and research into vaping affects on cannabis will be important. For outside events, it will be important to limit the number of people allowed to enter the restricted area and the duration they can stay in the area. Cannabis Consumption Establishments. Additional Risks/Opportunities to be considered - lt will be important to ensure safe consumption as the primary focus for these establishments. - Law enforcement will need to be properly trained to ensure adequate method of detection related to cannabis impairment. - There is opportunity to work closely with MADD and other partners, to ensure transportation is readily available and easy to access. - There could be a risk of youth consumption at these caf?, lounges and festival events. The government should consider an age restriction in consultation with public health and medical authorities - The government should consider rules of guidelines related to medical vs recreational cannabis use at lounges, cafes, festivals, etc. - lf vaping is deemed to be included, it will be important to offer an area with ventilation and supported by public health authorities. - There is a risk of people entering the premise with their own cannabis. Opportunity to establish a baggage check upon entering the area. This will help to reduce any personal cannabis from entering the area. Oversight By facilitating the consumption of cannabis in licensed lounges and cafes, the government of Ontario would retain some oversight over the quality and quantity of such establishments. Going in the other direction NOTfacilitating one runs the risk of underground lounges and caf? proliferating in non-ideal or unsafe conditions. lt would be important for the government to follow a similar framework to alcohol. Opportunity for further guidance and research to support law enforcement related to the proper detection of cannabis levels if driving impaired. Ontario Pubiic Boards? Association Cathy Abraham ONTARIO 439 University Avenue, 18th Floor President - 'w I .3 Toronto, ON M5G 1Y8 {091: BOARDS Tel: (416) 340-2540 WR. (Rusty) Hick ION Fax: (416) 340?7571 Executive Director webmaster@opsba.org Leading Education?s advocates opsba. org March 10, 2020 Ministry of the Attorney General Policy Division Legalization of Cannabis Branch 720 Bay Street, 11th Floor Toronto ON M7A 289 cannabis@ontario.ca In early February, the government announced a consultation on the potential implementation of additional cannabis business opportunities in the future, including: facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, cannabis special occasion permits (SOPs). The legalization of recreational cannabis in Ontario is an issue that the Ontario Public School Boards' Association (OPSBA) has been involved with for several years and our past commentary can be found on our website, As an educational stakeholder, our mandate is ensuring student achievement and well-being and as such, our comments focus on the implications of the sale and consumption of cannabis among children and youth. Our primary concern remains the impact of cannabis on youth brain development and the need for evidence-based research. If the government was to facilitate the sale of cannabis for consumption in establishments like lounges and cafes, there must be regular communication and discussion among municipal partners, including school boards, about potential locations. We respectfully ask that school boards be part of any consultation and final decisions. Similar to our recommendations for retail locations, we suggest a distance ?buffer" between these establishments and local schools. We continue to support the Alcohol and Gaming Commission of Ontario providing more than 15 days for the public to comment on proposed locations and suggest there be clear communication and outreach to those communities. The communications should be delivered in multiple forms, including social media, and in multiple languages to ensure inclusivity. While we do not have an opinion on the products that would be for sale in lounges and cafes, we are calling for a public awareness campaign that would be represented through required resources in each location, to support this adjustment with clear information about what is permitted, by whom and where. The campaign should include an educational component that increases overall awareness of recreational cannabis and preventing substance abuse among our youth. We would also request any public campaign and education resources include and address the increasing use of vapor products and e-cigarettes among youth. 1 We want to stress that mental health and addictions are a serious challenge in our country and school boards see this first hand in many of our students. Public awareness campaigns need to include evidence-based research regarding neurotoxic effects on adolescent brain development and the link to regular cannabis use. Thank you for this opportunity to provide our comments, which will also be shared with the Ministry of Education. Sincerely, Cathy Abraham President Ontario Public School Boards' Association cc. The Honourable Stephen Lecce, Minister of Education Nancy Naylor, Deputy Minister (Education) The Ontario Public School Boards' Association represents English public district school boards and public school authorities across Ontario, which together serve more than 1.3 million public elementary and secondary students. The Association advocates on behalf of the best interests and needs of the public school system in Ontario. OPSBA is seen as the credible voice of public education in Ontario and is routinely called on by the provincial government for input and advice on legislation and the impact of government policy directions. 2 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Laurie Zeppa Director of Health Promotion Prevention Algoma Public Health, 294 Willow Ave, Sault Ste. Marie, ON, P6B 0A9 About You or Your Organization (please check the appropriate box/boxes) x/ Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial At this time, Algoma Public Health (APH) is recommending that the government not consider facilitating the sale of cannabis for consumption in establishments in Ontario, and that the use of cannabis continues to be restricted to private residences. APH strongly encourages the Ministry to take time to review the evidence and assess the impact of the current legislative structure. A thorough impact assessment would require collaboration and feedback from a variety of stakeholders to ensure public health and safety remains a priority. Facilitating the sale of cannabis for consumption in establishments warrants a number of public health considerations: There is a difference in risk: Ingesting cannabis is not the same as inhaling: Ingesting cannabis and inhaling cannabis have very different mechanisms of getting into the bloodstream and causing intoxication (?the high?? in an individuai. The effects of ingested cannabis last longer in the body when compared to inhaled cannabis effects can last up to 12 hours, with residual effects lasting up to 24 hoursl. Every individual has a unique endocannabinoid system, meaning the process for when someone becomes ?high" is uniquez, making it difficult to predict when someone has consumed the ?right amount? of cannabis anti/?or when they have consumed too much. As a result, the risk of overconsumption is increased, and can lead to over?intoxication, leading to panic and paranoia, anxiety, nausea and vomiting, and of The intoxicating effects of ingested cannabis do not ??kick in? for approximateiy 30 minutes to 2 hours after consumption. If an individual consumes cannabis in an establishment and then leaves, they could very likely become impaired after they leave and/or while they are driving1. Because of the extended effects of ingested cannabis, the Canadian Centre on Substance Use and Addiction (CCSA) recommended that individuals do not drive or operate heavy machinery after ingesting cannabis. CCSA also recommends that individuals who choose to ingest cannabis stay home or in a safe location when consuming and after consumptionl. In Canada, cannabis-related health harms have nearly tripled since 20133. There is an increased risk of harm when combining cannabis with alcohol and other substances3: Consumption of cannabis and alcohol cannabis?infused alcoholic beverages) significantly increases the risks of over?intoxication and impairment. 3 Cannabis should never be mixed with alcohol. Consuming cannabis and alcohol (canna bis?infused alcohol beverages) significantly increases the risks of over? intoxication and impairment. 9 Cannabis should also not be consumed in conjunction with stimulants caffeine). Retain the regulatory restrictions of the Smoke Free Ontario Act (SFOA), 20174: As a key piece of Public Health legislation, the Smoke?Free Ontario Act, 2017 not only restricts smoking and vaping in any enclosed workplaces, public places, bar and restaurant patios but also in the reserved seating area of outdoor sports arenas or entertainment venues?. These entertainment venues are frequent sites where permits are given for hosting special events. is Not only does this legislation protect the public from the negative health effects of second?hand smoke and vapour exposure, but it also goes a long way in changing social norms for society, in particular with youth, on the acceptability of these behaviours. a As clarified in this request for consultation, the government is not considering changes to the SFOA regime as part of this consultation. It is extremely important that at no time regardless of the economic impact of any future changes that result from this consultation, that legislation be changed to ever permit smoking or vaping of cannabis in indoor consumption venues or at special events hosted at venues currently covered by the SFOA. References: 1. Canadian Centre on Substance Use and Addictions. {2019). 7 things you need to know about cannabis edibles. Accessed on February 28, 2020 from bis?2019?en.pdf 2. Ontario Cannabis Store. {2020). How cannabis works: The endocannabinoid system. Accessed on February 28, 2020 from 3. Alberta Health Services. {October 2018). Regulation of cannabis edibl es and cannabis cafes. Accessed on February 21, 2020 from 4. Smoke Free Ontario Act. {2017). Accessed on February 28, 2020 from If cannabis consumption establishments were considered in Ontario, the sale of food/beverage products that do not contain cannabis should not be permitted for sale in those same establishments. Individuals that have made a conscious and informed choice not to consume cannabis products do not need to be influenced by cannabis product display promotion or tempted to make an impulse purchase. The federal Cannabis Act; subsection 24(1), does not permit an individual that sells cannabis or a cannabis accessory to provide or offer to provide any service if it is provided or offered to be provided as an inducement for the purchase of cannabis or a cannabis accessoryl. Prohibiting non?cannabis items to be sold would be consistent with the prohibitions for promotion set out at the federal level. It would also align with current Ontario cannabis retail regulations that allow licensed cannabis retailers to only sell products and accessories which are directly related to ca nna bisz. At a minimum, should the province chose to proceed with the sale of food/beverage products that do not contain cannabis in potential consumption establishments, there should be certain safe guards put in place. Requiring both cannabis and non?cannabis products be sold as pre? package items in their original packaging would ensure the consumer is receiving exactly what they have purchased as described on the products label. Any sale of alcoholic beverages, high? caffeine beverages coffee, tea or energy drinks), and products which contain nicotine should be strictly prohibited in these establishments. This will prevent harmful co?use of substances, which may lead to higher levels of impairment, addiction, and increased levels of harm?. References: 1. The Cannabis Act (SC. 2018, c. 16) 2. Cannabis Retail Regulation Guide, Gaming Commission ofOntario, Accessed on March 4,2020 from agco.ca/book/export/html/19736 3. Ontario Agency for Health Protection and Promotion {Public Health Ontario), Meyer W, Leece P. Evidence brief: riskfactors for simultaneous use of alcohol and cannabis. Toronto, ON: Queen's Printer for Ontario; 2018. 4. Alberta Health Services. {October 2018). Regulation of cannabis edibles and cannabis cafes. Accessed on February 21, 2020 from Algoma Public Health is recommending that the government not consider establishing Special Occasion Permits for cannabis to be sold and consumed at festivals. There are many public health considerations to highlight with regards to this: There is an increased risk of harm when combining cannabis with alcohol and other substances: 6 Simultaneous use of alcohol and cannabis is associated with more harmful consequences than the use of either substance alone, including adverse physical, social and behavioural outcomesl. ?9 Consumption of cannabis and alcohol cannabis?infused alcoholic beverages) significantly increases the risks of impaired cognition and impairment, impaired drivingl, over?intoxicationz. Regardless of age, cannabis should never be mixed with alcohol. Consuming cannabis and alcohol (cannabis?infused alcohol beverages) significantly increases the risks of over?intoxication and impairmentz. Co?location of alcohol and/or cannabis sales drives the public misperception that co?use is condoned or encouraged3. The sale and consumption of cannabis at special occasions has the potential to create significant public risk: The ability of occasion?s organizers to provide the necessary levels of security currently required of cannabis retail stores would be a challenge. Appropriate measures would be essential to ensure age verification, guarantee that individuals do not surpass possession limits from purchasing and consuming products from multiple vendors over a short period of time. Retain the regulatory restrictions of the Smoke Free Ontario Act (SFOA), 2017: As a key piece of Public Health legislation, the SFOA, 2017 not only restricts smoking and vaping in any enclosed workplaces, public places, bar and restaurant patios but also in the reserved seating area of outdoor sports arenas or entertainment venues?. These entertainment venues are frequent sites where permits are given for hosting special events. a Not only does this legislation protect the public from the negative health effects of second?hand smoke and vapour exposure, but it also goes a long way in changing social norms for society, in particular with youth, on the acceptability of these behaviours. As clarified in this request for consultation, the government is not considering changes 6 to the SFOA regime as part of this consultation. It is extremely important that at no time regardless of the economic impact of any future changes that result from this consultation, that legislation be changed to ever permit smoking or vaping of cannabis in indoor consumption venues or at special events hosted at venues currently covered by the SFOA. References: 1. Public Health Ontario. {August 2018). Evidence Brief: Riskfactors for simultaneous use of alcohol and cannabis. Accessed on March 2,2020 from 2. Alberta Health Services. {October 2018). Regulation of cannabis edibles and cannabis cafes. Accessed on February 21, 2020 from 3. Government of Canada. {2016). A Frameworkfor the Legalization and Regulation of Cannabis in Canada: The Final Report Windsor?Essex County Health Unit {2020). Consultation Response: Expanding Cannabis Business Opportunities DRAFT 4. Smoke Free Ontario Act. {2017). Accessed on February 28, 2020 from The literature on substance use is clear? increasing availability leads to increased use and consumption, leading to more harms?. The creation of cannabis consumption establishments and/or allowing extended substance use through SOPs will bring more risk to local communities (impaired driving, health risks) than opportunity (potential revenue and opportunities for small businesses). References: 1. Myran, DT CJ, Giesbrecht, N, Rees, VW. The association between alcohol access and alcohol?attributable emergency department visits in Ontario, Canada. Addiction. 2019; 114:1183?91 2. Sheiid, KD PC, Rehm, l. A ?buck a beer?, but at what cost to public health? Canadian Journal of Public Health. 2019; 110:512?5. Any potential framework now or in the future should ensure the ability of municipalities to establish more restrictive licensing and zoning by?laws for cannabis consumption establishments and special occasion permits. Algoma Public Health is recommending that should cannabis consumption establishments be permitted, they should be at minimum 150m away from parks, recreation centers, schools, daycares, and addictions treatment facilitiesl. As well any potential framework should allow municipalities authority to pass by?laws that allow or restrict the sale and/or consumption of cannabis on municipal property. It would also be important for special occasion permits to be required as a condition of the permit to comply with municipal bylaws regulating the use of municipal property. References: 1. Alcohol policy review: opportunities for Ontario municipalities. [Internet] Developed for Wellington?Dufferin Guelph Health Unit, Durham Region Health Department and Thunder Bay District; 2018. Available from The physical availability of a legal substance is linked to the health and wellbeing of the community: 9 Increased alcohol availability has already led to increased consumption, contributing to increased population?level harms?. 9 Smoking rates in Algoma are double that of the province3 9 Rates of vaping amongst youth have more than doubled since 20174 Because the health and social outcomes in the North are worse than the rest of the Ontario population5, APH continues to be concerned about the ongoing liberalization and normalization of the use of harmful substances without appropriate consideration of their health consequences. References: 1. Myran, DT CJ, Giesbrecht, N, Rees, VW. The association between alcohol access and alcohol?attributable emergency department visits in Ontario, Canada. Addiction. 2019; 114:1183?91 2. Sheiid, KD PC, Rehm, j. A ?buck a beer?, but at what cost to public health? Canadian Journal of Public Health. 2019; 110:512?5. 3. Algoma Public Health. Community Health Profile, 2018. Sault Ste. Marie (ON): Algoma Public Health; 2018 4. Boak, A., Elton?Marshall, T., Mann, R. E., 81 Hamilton, H. A. {2020). Drug use among Ontario students, 1977?2019: Detailed findings from the Ontario Student Drug Use and Health Survey Toronto, ON: Centre for Addiction and Mental Health. 5. Health Quality Ontario. {2018). Northern Ontario Health Equity Strategy. Access on March 2, 2020 from Martin, Ashley (MAG) From: Aldo Franco Sent: March 10, 2020 11:06 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Attachments: mits.DOCX Categories: Anti Licensed Est, Organization On behalf of the Board of Directors ofthe Association of Supervisors of Public Health Inspectors of Ontario (ASPHIO) and our members, please find attached the completed feedback template regarding the ?Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits? We appreciate that changes to the Smoke-Free Ontario Act (SFOA) 2017 are not being considered as part ofthis consultation. As an association dedicated to public health protection, we would like to express our concerns regarding the consideration for cannabis consumption establishments or cannabis special occasion permits, and their associated negative health and social impacts. We hope this feedback will be taken into consideration and we would be pleased to discuss further, as decisions or proposals may evolve. ASPHIO represents 100% of the health units in Ontario, representing public health inspection supervisors, managers and directors across Ontario. Our members are responsible for protecting and improving public health by managing and delivering a Wide range of environmental public health programs in food safety, safe water, vector-borne and infectious diseases, environmental and community health hazards, and the Smoke-Free Ontario Act. Sincerely, Aldo Aldo Franco, MBA, ASPHIO Chair (2019-2020) Manager Health Protection Investigation Region of Waterloo Public Health Emergency Services 99 Regina St. 8., 3rd floor Waterloo, ON, N2J 4V3 519 575 4400 x5337 226 751 3812 Fax: 519 883 2226 Confidentiality Notice: This email correspondence, including any attachments, may contain information which is confidential and/or exempt from disclosure under applicable law, and is intended only for the use ofthe designated recipient(s) listed above. Any unauthorized use or disclosure is strictly prohibited. If you are not the intended recipient, or have otherwise received this message by mistake, please notify the sender by replying via email, and destroy all copies of this original correspondence, including any attachments. Thank you for your cooperation. Submission to the Ministry of the Attorney General: Cannabis Consumption Establishments and Special Occasion Permits March 10, 2020 Thank you for this opportunity to comment on the possibility of cannabis consumption establishments and Special Occasion Permits (SOPs) in Ontario. In a submission from September 2018, we gave the provincial government the following advice regarding cannabis consumption establishments: The main health concerns with regards to places of use are the harm of second-hand smoke and the potential harms of exposure to second-hand vapour. It is critical that regulations in this area not undermine the gains of the Smoke-Free Ontario Act or municipal bylaws governing public use of e-cigarettes, waterpipes, etc. For these reasons, we recommend that smokeless cannabis consumption in licensed establishments be allowed. Such establishments would be subject to the same kinds of regulations and oversight placed on those licensed to serve alcohol. We are glad to know that the provincial government is not considering changes to the Smoke-Free Ontario Act at this time. Our advice in this area stands. With respect to Special Occasion Permits, the Alcohol and Gaming Commission of Ontario (AGCO) has a system in place for administering alcohol SOPs. It is well positioned to do the same for cannabis if the government chooses to go in this direction. We recommend that cannabis SOPs not be combined with (or available in conjunction with) alcohol SOPs due to the increased risk associated with co-consumption of the two substances. In closing, we wish to reiterate that the AGCO has a critical role to play in the retail system. The province?s move to an open market for retail cannabis sales comes with risk. While there is a need for a robust legal market offering regulated cannabis products to current adult users, there is a risk that increased availability will lead to more consumption and, in turn, increases in cannabis-related harm. For these reasons, the process of retail expansion and retail operators themselves must be carefully monitored. We recommend that the provincial government empower the AGCO to oversee and regulate the scope, scale and operations of the cannabis retail system. We also encourage the government to ensure that wholesale distribution continues to be conducted exclusively by the Ontario Cannabis Store. For more information, please contact: Jean-Francois Cr?pault Senior Policy Analyst, Centre for Addiction and Mental Health 416 535-8501 x32127 JeanFrancois.Crepault@camh.ca The Centre for Addiction and Mental Health (CAMH) is Canada's largest mental health and addiction teaching hospital and one of the world's leading research centres in this field. CAMH is committed to playing a leading role in transforming society?s understanding of mental illness and substance use and building a better health care system. To help achieve these goals, CAMH communicates evidence-informed policy advice to stakeholders and policymakers. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Rebecca Truscott Director, Population Health and Prevention Prevention and Cancer Control Ontario Health (Cancer Care Ontario) 505 University Avenue, 14th Floor Toronto, ON M5G 1X3 About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) Cannabis Consumption Establishments: (insert comments if necessary the box will expand as you type) SOPs: (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) Consistent with the recommendation in our Taking Action to Prevent Chronic Disease report, Ontario Health (Cancer Care Ontario) encourages the Government of Ontario to adopt a health in all policies approach when considering expanding the retail cannabis market in Ontario, including facilitating the sales of cannabis for consumption in establishments and allowing cannabis special occasion permits. Although current available evidence does not show that using cannabis increases the risk of developing cancer, more research is needed to address gaps in the current knowledge base. Moreover, using cannabis may lead to acute health-related harms, including anxiety, cognitive and impairment, and injuries or fatalities due to impairment. Using cannabis may also lead to long-term health-related harms, including respiratory and more frequent episodes of chronic bronchitis (if cannabis is smoked or vaped), schizophrenia and dependency or cannabis use disorder, and cannabinoids hyperemesis (cyclic vomiting). With the known and potential negative health impacts in mind, Ontario Health (Cancer Care Ontario), as in the past, advises against the introduction of any regulation that could result in potentially signi?cant negative health outcomes in the population. Public health organizations and experts are experienced in developing policies that promote positive improvement in health outcomes and the sustainability of our healthcare system. In the area of tobacco control, notable health outcomes decreasing smoking rates, lung cancer incidence and mortality) have been realized when a public health perspective is prioritized. 5 Consultation on Cannabis Consumption Establishments and Special Occasion Permits Introduction The Canadian Centre on Substance Use and Addiction (CCSA) welcomes the opportunity to provide the Government ofOntario with feedback on its consultation on ?Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits.? CCSA supports a precautionary approach to expanding opportunities for public cannabis consumption, and recommends that any relaxation of public consumption regulations be informed by a public health perspective. The following issues are key considerations when proposing to expand options for public cannabis consumption: I The need to limit youth exposure to cannabis and consumption spaces that can contribute to the normalization of cannabis use; I The need to limit potential exposure to second-hand smoke in public settings if consumption is permitted through special occasion permits I The increase in consumption and related harms associated with high outlet density, based on lessons learned from alcohol use; I The risk of increased polysubstance use and its related harms should alcohol and cannabis be co?located; I The need for established guidelines on cannabis impairment and safer dosage standards; I The risks associated with the product types available for consumption; and I The increase in supports required for municipal monitoring and enforcement activities that will accompany public cannabis consumption establishments. Key Considerations Maintaining a Public Health Focus The objectives of the federal Cannabis Act reflect the federal government?s commitment to public health and safety. In line with this commitment, CCSA recommends a precautionary public health approach that focuses on evidence-informed measures to ensure that cannabis use is not promoted and that risky use is reduced. Consultation on Cannabis consumeion Establishments and Special Occasion Permits Youth Access, Appeal and Increased Exposure Ontario?s Cannabis Control Act supports protecting children and youth from the potential adverse effects of cannabis through safeguards that restrict access to cannabis. Established regulations for cannabis retail outlets in Ontario ensure cannabis products are not visible from the exterior of the premises. These regulations should be extended to any public establishment where cannabis is being consumed to ensure minimal impact and exposure for youth. This requirement also includes ensuring establishments abide by security measures similar to those for retail establishments and implement training programs for staff to ensure training includes restricting access to youth. If SOPs are allowed, they will require oversight and restrictions to protect youth and restrict access to cannabis. SOPs for alcohol in Ontario allow for private and public events, as well as tailgate events. Many of these events have the potential to take place in outdoor locations or where provisions of the Smoke-Free Ontario Actdo not apply and where children and youth are also permitted, increasing the potential forthem to be exposed to cannabis consumption, including through smoking. In existing cannabis retail outlets in Ontario, all employees must be certified with CannSell training, which provides the tools to ensure the responsible sale of cannabis. The current system for SOPs does not require similar training for permit holders for alcohol sales and service (Alcohol and Gaming Commission ofOntario, 2019). Any allowance of SOPs for cannabis use should mirror those in the retail market and include training requirements for permit holders to ensure responsible and safer cannabis consumption. Outlet Density Lessons learned from alcohol highlight the relationship between outlet density and consumption patterns and related harms. Ample research has shown that higher rates of consumption and related harms reflect increases in the density of retail alcohol outlets (Campbell et al., 2009; Stockwell et al., 2011; Zhao et al., 2013). The addition of cannabis consumption establishments and 80 PS will likely have an impact on cannabis consumption rates and cannabis-related harms. A strong regulatory framework and enforcement will be required to ensure concentrations of establishments do not pose a significant burden to public health and safety. Simultaneous Polysubstance Use Simultaneous polysubstance use is prevalent, particularly with alcohol and cannabis (Public Health Ontario, 2018). The effects ofsimultaneous use of cannabis and alcohol, as well as the related harms, are well documented, including increased odds of impaired driving (Subbaraman Kerr, 2015), decreased cognitive functioning compared to the use ofeither substance alone (Kleczkowska Smaga, Filip, Bujalska-Zadrozny, 2016), and increased levels in the blood (Health Canada, 2016). The co-location of alcohol and cannabis products in cannabis consumption establishments will facilitate polysubstance use and could lead to increases in the incidence of the related harms. CCSA recommends prohibiting the co-location of alcohol and cannabis products within cannabis consumption establishments. Should these establishments be permitted, rigorous oversight and staff trainingto recognize the signs of intoxication will be necessary to protect consumers and limit service to those impaired by alcohol and othersubstances. Consultation on Cannabis Consumption Establishments and Special Occasion Permits Single Serving Standards and Impairment Overconsumption of cannabis, like alcohol, can result in impairment and adverse health impacts. Unlike alcohol, however, where there exists an established measure ofa single standard dose, there is no comparable measure for cannabis. This gap makes overconsumption difficult for serving staff to monitor and detect, as well as making impairment challenging to prove. Continued efforts towards establishing a single standard dose are needed, as are improved guidelines for assessing cannabis impairment, before legalizing cannabis consumption establishments and SOPs. Product Type Different product types require different considerations for use in public establishments. Unlike smoking or vaping cannabis, which has an almost immediate effect, the onset ofthe intoxicating effects of eating edible cannabis products are often delayed and last longer than when cannabis is inhaled. Even among experienced consumers, it is often difficult to predict when intoxication and impairment will emerge and subside. The delayed onset can lead to overconsumption and subsequent cannabis poisoning, particularly among inexperienced consumers. Some edible cannabis products are similar in appearance to those that do not contain cannabis, and this similarity can increase the risk of unintentional ingestion, especially in public establishments that serve food and beverage products. In addition, the longer lasting impairing effects of edible cannabis products present an increased risk of impaired driving when consumed away from a private residence. Efforts supporting the sale of products with low levels as well as restrictions on product types available for sale in consumption establishments, should be considered. In addition, as products continue to diversify, more research is needed around new product formats and their intoxicating effects. nnici pal Oversight Municipalities play a critical role in the implementation, enforcement and oversight of the cannabis market. As with alcohol, where direct costs associated with law enforcement in Canada was estimated to be $3.1 billion in 2002 (Rehm et al., 2006), the creation of cannabis consumption establishments will demand significant community resources dedicated to enforcement. Enhanced funding for enforcement activities will be needed should consumption establishments and SOPs be permitted. Extensive consultation with municipalities should be undertaken before any changes in regulations for public consumption. Given the burden of costs associated with enforcement, as well as potential health impacts from increased public consumption, options for municipalities to opt-out of licensing cannabis consumption establishments, similar to the options for retail outlet development in the province, should be implemented as part of the process. Conclusion The allowance of cannabis consumption establishments and SOPs in Ontario has the potential to heighten public health and safety issues around cannabis consumption. Any changes to current consumption regulations should be informed by this perspective. Significant investment should be made in public education to inform consumers ofsafer guidelines for consumption, including around impaired driving and simultaneous polysubstance use. Studying otherjurisdictions where cannabis consumption establishments have been introduced, such as Colorado and the Netherlands, can offer insights into best practices and lessons learned, and should be taken into consideration before any changes in legislation. Consultation on Cannabis consumption Establishments and Special Occasion Permits References Alcohol and Gaming Commission of Ontario. (2019). Speciai occasion permit guide. Toronto: Queen?s Printer for Ontario. Campbell, CA, Hahn, R.A., Elder, R., Brewer, R., Chattopadhyay, S., Fielding, J., Task Force on Community Preventive Services. (2009). The effectiveness of limiting alcohol outlet density as a means of reducing excessive alcohol consumption and alcohol-related harms. American Journai of Preventive Medicine, 37(6), 556?569. Health Canada. (2016). A framework for the iegaiization and reguiation of cannabis in Canada: The finai report of the task force on cannabis iegaiization and reguiation. Ottawa: Government of Canada. Kleczkowska, P., Smaga, Filip, lVi., Bujalska-Zadrozny, M. (2016). Cannabinoid ligands and alcohol addiction: A promising therapeutic tool or a humbug?? Neurotoxicity Research, 29, 173? 196. Public Health Ontario. (2018). Evidence brief: Risk factors for simuitaneous use ofaicohoiand cannabis. Toronto: Queen?s Printer for Ontario. Rehm, J., Ballunas, D., Brochu, S., Fischer, B., Gnam, W., Patra, J., Taylor, B. (2006). The costs of substance abuse in Canada 2002. Ottawa: Canadian Centre on Substance Abuse. Stockwell, T., Zhao, J., lViacdonald, S., Vallance, K., Gruenewald, P., Ponicki, W., Treno, A. (2011). Impact on alcohol-related mortality of a rapid rise in the density of private liquor outlets in British Columbia: A local area multi-level analysis. Addiction, 106(4), 768?776. Subbaraman, lVi.S., Kerr, WC. (2015). Simultaneous vs. concurrent use of alcohol and cannabis in the National Alcohol Survey. Aicohoiism, Ciinicai and Experimentai Research, 39(5), 872?879. Zhao, J., Stockwell, T., Martin, (3., Macdonald, S., Vallance, K.,Treno, A., Buxton, J. (2013). The relationship between minimum alcohol prices, outlet densities and alcohol-attributable deaths in British Columbia, 2002?09. Addiction, 108, 1059?1069. CCSA was created by Parliament to provide national leadershipto address substance use in Canada.Atrusted counse ,we provide national guidance to decision makers by harnessing the power of research, curating knowledge a nd bringing together diverse perspectives. CCSA activities and products are made possible through a financial contribution from Health Ca nada. The views of CCSA do not necessarily represent the views of Health Canada. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) Michelle Maynard Manager, Lung Health Program at Somerset West Community Health Center and Co?chair of the Champlain Lunch Health Network Telephone: 613?238?1220 ext 2379 Submitting comments on behalf of the Champlain Lung Health Network About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) LI 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial The Champlain Lung Health Network is opposed to the sale of cannabis for consumption in establishments at this time. The regular use of cannabis can lead to adverse health outcomes. Regular cannabis use can affect: . Mental health . Cognitive functioning, including attention and memory . Respiratory and cardiovascular health . The developing child when used during pregnancy and breastfeeding The Champlain Lung Health Network does not support the co-use of Cannabis With other harmful or intoxicating substances. Permitting cannabis consumption in public areas may further normalise use and may hinder the public's enjoyment ofthese areas, particularly, in family- or child-oriented areas and natural spaces such as conservation areas. The designation of public areas for the consumption of cannabis through SOPs may increase the risk of injury and harm. Cannabis consumption establishments or SOPs can promote the long term use of Cannabis which may result in poor lung health. Evidence suggests that individuals who regularly smoke cannabis commonly report coughing on most days, wheezing, shortness of breath after exercise, chest tightness at night, sounds in their chest, early morning phlegm and mucus, and bronchitis. For instance a study in Canada found that compared to smoking tobacco alone, the combined use of cannabis and tobacco was related to three times the risk of developing COPD. Other conditions associated with cannabis smoking include pulmonary fibrosis,3 byssinosis4 and lung tumours (Phan, Lau, Li, 2005) Cannabis smoke contains many of the same toxins and cancer-causing chemicals as tobacco smoke. Research suggests that smoking cannabis can be even more harmful to a person?s airways and lungs than smoking tobacco, since cannabis smoking often involves unfiltered smoke, larger puffs, deeper inhalation and longer breath-holding. This means the negative respiratory effects can occur earlier with cannabis smoking. Regular consultations With munICIpaIItIes prIor to and throughout the process. (insert comments if necessary the box will expand as you type) REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Chatham-Kent Public Health Unit PO BOX 1136 435 Grand Ave West Chatham, ON NTM 5L8 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario LI 8. Provincial We currently share a neutral stance on whether or not lounges and cafes should be permitted to sell cannabis products in Ontario. lf industry feels like they have a product they'd like to make available to Ontarians in retail settings there should be a variety of social responsibility and health promotion approaches embedded into the process. When looking at how people in Ontario consume cannabis, the overwhelming method of choice is smoking/vaping and the consumption of edible cannabis is much lower in comparison. From a health perspective, our major related concern at this point in time would be the loosening any regulations currently laid out in the SFOA as we would not be supportive of smoking/vaping being permitted indoors in public places in Ontario. When looking at the types of products offered for sale in Ontario consumption establishments, minimum requirements should include: -products be properly labelled with ingredients, nutritional information and required warning labels -only products that meet all Provincial and Federal requirements for packaging, safety, advertising and promotion -be delivered in standardized serving sizes to prevent overconsumption and to assist retail staff in monitoring and identifying patrons at risk for being ?overserved? -clarification would be required to distinguish between products to be ?consumed on site? versus ?products for takeaway sales? to ensure regulations are followed -meet all Federal authorizations required as per Health Canada requirements -alcohol based beverages should be restricted and/or limited for sale in these types of establishments to address co-substance use -ensure alignment with Federal Food and Drug regulations in terms of the adulteration of prepared foods -prevent establishments from making unsubstantiated health claims surrounding their cannabis product sales In order to establish a SOP program for cannabis some similar approaches used in alcohol policy would also be recommended here: -events to be 19+ (or designated 19+ areas) -appropriate signage regarding health promotion/safety concerns be posted -sales staff have ?Smart Serve" like training on cannabis use to prevent overselling -reduced hours of service (ie. close cannabis sales 1.5 hours before event ends) - imits on serving sizes - imits on amounts able to be purchased by an individual -clarification on inspection roles and who's jurisdiction this falls under -Safety and security needs for a high value product that may attract criminal behaviour - ncreased insurance costs - ncreased regulation and due diligence for event organizers -increased concerns of impaired driving with increased access to cannabis in public events -Special event applications will need to be updated to reflect potential changes -Municipal policies created for SOP on municipal properties -Alcohol policy amended to include cannabis -More time needed to investigate liability concerns The key manner in which cannabis is currently used by the majority of users is smoking and vaping. Even though this consultation is not considering smoking/vaping in public places there is a cause for concern that this could be changed or adapted through lobbying and political will. Allowing an option to begin the smoking of any product in a public place should not be considered at this time. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Sana lmran Policy Analyst Canadian Mental Health Association Ontario 180 Dundas Street West, Suite 2301 Toronto, Ontario, MSG 1Z8 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Currently, the Cannabis Act places restrictions on where people may consume cannabis, prohibiting the smoking and vaping of cannabis in all enclosed public spaces such as outdoor patios, playgrounds, or publicly owned sports fields. In order to support Ontarians who wish to consume cannabis, CMHA Ontario recommends that guidelines align with existing legislation that governs where alcohol and cigarettes may be used, such as the Liquor License Act and the Smoke Free Ontario Act. The only exceptions to this currently are under the Liquor License Act, which notes that ?No person shall have or consume liquor in any place other than, a residence; premises in respect of which a license or permit is issued; or a private place as de?ned in the regulations.? Similar to this, exceptions may be created for cannabis consumption, where the sale of cannabis in public spaces requires a license with conditions on how cannabis may be sold and consumed. This would allow individuals more options, while facilitating safer means of consumption through legal means. In order to facilitate this, CMHA Ontario strongly encourages the use ofa Cannabis Card Program, through the establishment ofa Cannabis Control Board. While acting much like the Alcohol and Gaming Commission of Ontario (AGCO), the Cannabis Control Board would be the regulatory agency responsible for issuing permits and regulating the production, sale, service and consumption of cannabis in Ontario to promote responsible use. Such a regulatory agency must also oversee the production of cannabis to establish and ensure quality control, in a similar fashion to Vintners Quality Alliance (VOA), which is the provincial authority on the standards for the production of wine in Ontario. The proposed Cannabis Card program could operate in a similar manner to the Ontario Smart Serve program by providing training to cannabis retail staff to inform customers ofthe potential harms and bene?ts of cannabis, including mental health and addictions information, road safety, and the current laws and regulations. This program would ensure safe sale of cannabis, ensure that all sales staffare informed and spread knowledge to cannabis users. lf cannabis consumption establishments were considered in Ontario, then it would be advisable to include retail items for purchase that support safe consumption. It would also be advisable to have food and beverages available that do not contain other substances. Most studies note an increased likelihood of simultaneous alcohol and cannabis use among individuals who tend to already use either substance and have found the combined use ofalcohol and cannabis is associated with more harmful consequences than using either substance alone. Separating their use is essential to reducing potential harms. Presently, individuals attending events may bring their own cannabis, provided it is in its original packaging and sealed, to be consumed at designated outdoor smoking areas. Having the option to purchase cannabis at festivals and events themselves would be another measure to encourage individuals toward purchasing safer options. CMHA Ontario recommends the following conditions to ensure the promotion of safe consumption of cannabis: 0 Events and festivals where cannabis purchase and consumption will be made available must be age restricted to over 19 years. 0 Advertising and marketing should match the guidelines in place for tobacco products. 0 Public education should be made available on the harms associated with different forms of cannabis consumption, how to consume wisely, and the risks of consuming cannabis with other substances. 0 Edibles should not be made available for sale, due to the risk of someone else unintentionally consuming once out of its packaging. 0 Apply limits of the allowable level of THC sold in the products that are available. 0 Apply limits to the number of products that may be sold per person, and the hours during which products may be available for sale. 0 Distribution of cannabis should include the provision of cannabis education through the implementation ofa Cannabis Card program, similarto Ontario?s Smart Serve program. 0 A designated area should be created if the event is to allow cannabis consumption, for individuals that may choose to smoke or vape. 0 Opportunities to promote the use of designated drivers at events to discourage impaired driving. Cannabis Consumption Establishments. Opportunities: 0 Creation of safe spaces for individuals to consume, who may not be able to consume safely in private residences or other areas. 0 Consuming in social settings instead of alone can increase safety ofthe individual. 0 Increasing access to purchasing from legal means. 0 Having trained staff would allow for more awareness and spread of education of safe use. 0 Spaces may be accessed by youth. 0 Risks associated with consuming multiple substances at once ifthe space also has permission to sell alcohol. 5 SOPs: Opportunities: 0 Encouraging purchase of cannabis through safe means. 0 A platform to spread education and awareness on cannabis use. 0 Consuming in social settings instead of alone can increase safety ofthe individual. Risks: Dif?cult to monitor if people are consuming multiple substances simultaneously. 0 In the case of cannabis edibles, may be taken out of packaging and consumed by someone unintentionally. Municipalities should work closely with the mental health and addictions service providers in their regions to better understand their needs and advocate for more supports. This would be in the best interest of clients, especially youth and those who are heavy users of cannabis. Canadian Mental Health Association Branches would be an excellent resource within each municipality, staff of which are dedicated to supporting those living with mental health and/or addictions issues. CMHA Ontario commends the Government of Ontario for taking steps to engage Ontarians around this issue. Cannabis legalization has impacted many areas of society, and we encourage that all legislation be designed with a public health perspective. We strongly encourage the government to consider the crucial role of mental health and addiction services during any changes. As shared in the submission made to government in 2017 regarding cannabis legalization and regulation, CMHA Ontario would also like to encourage the Government of Ontario to consult and partner with CMHAs and other community based mental health and addictions service providers to develop and immediately implement a comprehensive public awareness campaign regarding cannabis-associated health risks. Lastly, cannabis-related revenue should be allocated to mental health and addictions services. CMHA Ontario continues to recommend that all cannabis related revenue be allocated for mental health and addictions services and is supportive of the Mental Health Commission of Canada?s recommendation to increase spending on mental health and addictions to nine per cent ofthe overall provincial health care budget. This 6 increase is especially necessary during this period oftransition where Ontarians may have additional needs. CMHAs across Ontario are well positioned to support the Government of Ontario in protecting the health and well being of Ontarians as changes come into effect. We can support in the development of public awareness campaigns and community service initiatives. We can also provide mental health and addictions services and supports to Ontarians facing cannabis addiction and misuse. CM HA Ontario and representatives from our branches are pleased to provide further feedback and welcome any further consultation on this matter. CMHAs also welcome the opportunity to participate in any provincial, regional, and/or local planning tables that are convened. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) Ann-Marie Ho, Public Health Nurse Durham Region Health Department 605 Rossland Road East, Second Floor, PO Box 730 Whitby, ON L1N 062 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Durham Region Health Department does not support the government the sale of cannabis for consumption, including smoking, vaping and ingesting, in establishments like lounges and cafes in Ontario. The purpose of the Cannabis Act (also known as Bill 0-45), was to protect public health and safety through strict regulations that protect youth from accessing cannabis, enhance public awareness of the health risks of cannabis, provide a legal and regulated production system for cannabis and deter criminal activity. From a public health approach, it becomes concerning when the legalization model changes to a private cannabis retail model with profit being the key driver for expanding business opportunities. No otherjurisdiction in Canada has implemented cannabis consumption establishments, therefore evidence regarding community impact is quite limited. In U.S. locations where consumption establishments are legal, there are more restrictive regulations as regards places of use for cannabis only in personal residences). In Ontario, cannabis smoking is legal in the same places that tobacco smoking is legal, except for cars and boats. In addition, edible cannabis products can be consumed in most public places except for cars and boats. Therefore, the creation of cannabis consumption establishments is not needed from an equity perspective. Since cannabis legalization is still new within Canada and Ontario, it's fair to say that the full effects have yet to be realized. Moving too quickly to further expand access and availability of cannabis may lead to great health and social harms, as well as unintended consequences. The root cause of such consequences may be difficult to identify. The introduction of cannabis consumption establishments will increase access to cannabis. Evidence from alcohol and tobacco research showthat increased access leads to increased use. This may lead to increased harms, such as impaired driving, social normalization, public nuisance/intoxication, and other health effects. It is fair to assume that this correlation will also be true for cannabis. As cannabis becomes more readily available within the province, there is an increased risk of cannabis becoming a normalized substance. This is concerning as children and youth are at greatest risk if cannabis were to become normalized within society as increased social acceptance can lead to increased use by youth. Younger people are particularly vulnerable to cannabis use because their brains are still developing. We recognize the government has stated it is not considering changes to the Smoke-Free Ontario Act, 2017 (SFOA) regime as part of this consultation. Based on the known risks of second-hand smoke, we would strongly urge the government to commit to maintaining the SFOA without any amendments or exemptions. Given the current SFOA regulations, only edible cannabis products could be considered for consumption in a public space, such as a lounge or caf?. Consumption of cannabis edibles in a public setting enhances the risk of unpredictable intoxication due to individual levels of tolerance and the delayed onset of intoxicating or effects. Evidence shows that cannabis edibles can have an onset of 30 minutes to 2 hours and full effects can peak within 4 hours. At times, effects can last up to 12 hours (Canadian Centre for Substance Abuse and Addiction This creates challenges to prevent over-intoxication, impaired driving and responsible serving (peak effect may occur once the consumer has left the establishment). This may also create liability risk for establishments, which are difficult to mitigate. Due to this delayed onset, some individuals may feel safe to drive and later find themselves impaired while behind the wheel. There is also no way to control for the subsequent consumption of alcohol beyond the establishment. Using cannabis with alcohol can increase one's risk of over-intoxication and impair one's ability to drive safely (CCSA). 0 Durham Region Health Department does not support permitting licenced and regulated cannabis consumption establishments at this time. If Ontario chooses to move fonNard with cannabis consumption establishments the following harm reduction strategies should be considered: 0 Prohibit the sale and consumption of alcohol in the same premise as cannabis due to the increased risk of over-intoxication and harms when used together. Prohibit the sale and consumption of other substances that are banned in the edible cannabis regulations (caffeinated food/beverages, nicotine). Edible cannabis products sold and served at a potential establishment must be made by a licensed processor that is packaged and labelled as per existing federal regulations. 0 Edible cannabis products should be kept in their original packaging when being displayed or served to the consumer at an establishment as this minimizes the risk of mixing up cannabis containing products with non-cannabis food/beverages. 0 To prevent over-serving and over-intoxication, it is recommended that cannabis edibles be sold and served in single-serving packages, Le. a total of 2.5 mg of THC per package of edible cannabis product. 0 Edible cannabis should not be produced in the cannabis consumption establishment to comply with the federal edible cannabis regulations, including the risk of cross-contamination with non-cannabis food/beverages. 0 Do not allow consumers to bring in outside food/beverages into the establishments, including products containing cannabis, as this will make it very difficult to control public safety. 0 Prohibit accessories that advertise and promote cannabis to be sold at these establishments, as this normalizes the use of cannabis. 0 Ensure adherence to the existing food premises regulation under the Health Protection and Promotion Act. ?Durham Region Health Department strongly recommends that smoked or vaped cannabIs, In particular, to be sold and consumed at festivals and events not be considered. Smoking and vaping of cannabis via SOP would violate SFOA and expose the public to second hand smoke. An SOP program would create a risk to public safety and challenges with enforcement, the need for increased police presence/enforcement as well as first aid/ medical support would be required at any festivals and events serving cannabis. Edibles are unique due to their delayed onset and prolonged duration of effect. This creates challenges to prevent over-intoxication, impaired driving and responsible serving (peak effect may occur once the consumer has left the SOP event). This may also create liability risks for SOP licensee, which are difficult to mitigate. Due to this delayed onset, some individuals may feel safe to drive and later find themselves impaired while behind the wheel. Concerts are risky as participants often arrive under the influence of other substances, which would could lead to co-use and significant impairment Given the risk of overconsumption and unpredictable effects of cannabis edible, staff who work in any capacity involving selling cannabis for consumption would need to be specially trained on how to handle a situation of a consumer being over intoxicated and having a bad reaction which requires medical attention. Although Durham Region Health Department does not support cannabis SOPs, ifthey are permitted, the following is strongly recommended: 0 To comply with SFOA, only edible cannabis products should be considered for cannabis SOPs (no smoking or vaping) to protect public health from second-hand smoke. Prohibit alcohol to be sold and consumed at cannabis SOP events due to the increased risk of over-intoxication and unpredictable effects when co-using. All events should be restricted to individuals 19 years of age and older. Edible cannabis products should be sold and served in a separate area from the main event No samples or free products. No advertisement or promotion outside of the designated area for cannabis sale. Designated driving services readily available and advertised to prevent impaired driving. There should be a cut-off serving size limit for edible cannabis products at events. Health Canada recommends new users limit edible cannabis consumption to 2.5 milligrams of THC or less. Further research is needed for recommendations on daily limits to be served to consumers. The servers at events must be trained in the products, their effects and aware of the signs of intoxication, similar to smart serve for alcohol. 0 Require servers to educate consumers on safe consumption practices, risks and product information. 0 Consumers cannot take opened cannabis edible products out of the designated area for consumption, similar to alcohol. 0 Create a system for safe disposal of cannabis products. 0 Edible cannabis products must be made by a licensed processor and kept in its original packaging when being served to the consumer. The product should not be removed from the original packaging to serve or display as this minimizes the risk in mixing up cannabis containing products with non-cannabis products. 0 Edible cannabis should not be produced at the cannabis SOP event. 0 Do not permit consumers to bring in outside food/beverages, including products containing cannabis, into an SOP event as this will make it very difficult to control public safety. 0 Prohibit cannabis tailgating events as these would be very difficult to control. 0 Prohibit SOP request on large boat vessels or other motorized vehicles. 0 Municipalities should be informed of any applications in the same fashion as alcohol SOPs where at least 30- or 60-days notice must be provided by the permit holder to the local municipality, police, and fire and health departments notifying them of the event. 0 The building department must be notified as well if a tent, marquee, pavilion or tiered seating is used. Cannabis Consumption Establishments: Risk of over-intoxication, increased public intoxication and impaired driving since cannabis is used in the same establishment it is being sold. Increased risk of social normalization of recreational cannabis leading to increased use and harms. Opportunity to provide public education on responsible and safer edible consumption if employees are comprehensively trained and required to provide education to customers. SOPs: Amplified risk of over-intoxication, increased public intoxication and impaired driving since cannabis is used in the same establishment it is being sold. This is due to a less controlled environment. Increased risk of social normalization of recreational cannabis. Risk of exposure to cannabis for youth. DRHD does not support a framework for cannabis consumption establishments or SOPs. However, if the Province chooses to move forward with such a framework the following are recommended: 0 Municipalities should be granted the authority to enact by-Iaws that prohibit the sale and/or consumption of cannabis on municipal property. Applications for SOPs should be required to abide by any municipal requests to ensure compliance with city by-Iaws and conditions of use of municipal property. 0 Municipalities should be informed of any applications in the same fashion as alcohol SOPs where at least 30 or 60 days' notice must be provided by the permit holder to the local municipality, police and fire and health departments notifying them of the event. The building department must be notified as well as if a tent, marquee, pavilion or tiered seating is used. 0 Give municipalities the ability to opt-in or out of allowing cannabis consumption establishments and cannabis SOPs in theirjurisdictions. 0 Allow municipalities to further restrict the retail density, buffer zones/siting restrictions, hours of operation and the locations of potential cannabis consumption establishments when it is in the public interest to do so. 0 Increase the monetary investment toward Public Health to ensure sufficient resources to implement health promotion, public education, inspection of premises and enforcement of food safety regulations at cannabis consumption establishments We appreciate the note on the Regulatory Registry that changes to the SFOA are not being considered as part of this consultation but would appreciate assurances that there will be no loosening of any of the regulatory restrictions that protect Ontarians from second-hand smoke in public places in any circumstance. The SFOA's added protections from exposure to cannabis smoke in enclosed spaces are based on the known and significant health risks of inhaling smoke of any kind. We would view any motion towards considering exemptions for combustible or vapourized cannabis in any enclosed public place as an unacceptable step backwards. Irrespective of whether this proposal is intended to exclude combustible or vapourized cannabis, it also amplifies our concerns about the ongoing liberalization and normalization of the use of harmful substances without proper consideration of their health consequences. Retail expansion of alcohol sales, unrestricted promotion of e-cigarettes and proposals such as this one are concrete examples of the government's willingness to expand the markets for these substances without developing offsetting health promotion policies to mitigate their measurable negative health and social impacts. If the government facilitates the sale of cannabis for consumption in establishments like lounges and cafes, the Durham Region Health Department would strongly recommend the following: 0 Provide a clear goal and strong rationale for the need to move in this direction. 0 Ensure that the business is cautiously implemented, continuously evaluated and adjusted as required to mitigate harms and support the health and safety of communities and residents. 0 SFOA prohibits smoking and vapour in public places and should be maintained based on the known risks of second-hand smoke to protect the health of employees and members of the public. 0 Smoking and vaping should be prohibited within 9 metres of the entrance to any cannabis consumption establishment. Enforce strict marketing and advertising of cannabis consumption establishments to protect youth. 0 Follow the same restrictions in place for cannabis retail stores (age restrictions 19+, ID checks, frosted windows, no displays, no samples, etc.) Prohibit the sale and consumption of alcohol and other substances that are banned in the edible cannabis regulations (caffeinated food/beverages, nicotine). Edible cannabis products sold and served at a potential establishment must be made by a licensed processor that is packaged and labelled as per existing federal regulations. 0 Edible cannabis products should be kept in their original packaging when being displayed or served to the consumer at an establishment as this minimizes the risk of mixing up cannabis containing products with non-cannabis food/beverages. In order to prevent over-serving and over-intoxication, it is recommended that cannabis edibles be sold and served in single-serving packages, Le. a total of 2.5 mg of THC per package of edible cannabis product. 0 Edible cannabis should not be produced in the cannabis consumption establishment to comply with the federal edible cannabis regulations, including the risk of cross- contamination with non-cannabis food/beverages. 0 Do not allow consumers to bring in outside food/beverages, including products containing cannabis, into the establishments as this will make it very difficult to control public safety. Require establishments to have information posted regarding the delayed onset and prolonged duration of edible products (similar to signage re: alcohol during pregnancy). 0 Government must educate the general public on the risk associated with edible cannabis via provincial campaigns. 0 Designated driving services readily available and advertised to prevent impaired driving. 0 There should be a cut-off serving size limit for edible cannabis products in establishments. Health Canada recommends new users limit edible cannabis consumption to 2.5 milligrams of THC or less. Further research is needed for recommendations on daily limits to be served to consumers. The hours of sale should be restricted. Strict advertising, marketing and sponsorship restrictions should be instituted. The servers must be trained in the products, their effects and aware of the signs of intoxication, similar to Smart Serve for alcohol. 0 Require servers to educate consumers on safe consumption practices, risks and product information. 0 Consumers cannot take opened cannabis edible products out of the establishment, similar to alcohol. 0 Create a system for safe disposal of cannabis products. 0 Do not place cannabis consumption establishments in close proximity to venues that serve or sell alcohol Store, bars, restaurants), places where children and youth frequent (schools, childcare centres, parks, recreation facilities), gaming facilities, mental health and healthcare facilities, addiction centres, tobacco/vaping product retailors, etc. Consultation: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Comments from the Eastern Ontario Health Unit to the Government of Ontario to inform potential decisions about opportunities in an open cannabis market in the future. March 2020 The Eastern Ontario Health Unit strives to safeguard the health of our region?s young people. We believe that when it comes to health and wellness, an informed person will become a healthier person. 1. Taking into consideration the places of use rules for cannabis under the SFOA, 2017, should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not? The Eastern Ontario Health Unit does not support the government facilitating the sale and consumption of cannabis in Ontario through cannabis establishments such as lounges and cafes. Providing access to a space for consumption increases the risks of overconsumption, intoxication and, due to the delayed effects of edibles, can increase risks of impaired driving and liability for the establishment owners. However, if the government approves these establishments for consumption and sale, we have included recommendations to minimize risks and the impact of cannabis on public health. Sale and consumption of cannabis in establishments (lounges and cafes) Establishment Operators Only locations with an approved Cannabis Retail Store Authorization should be permitted to operate as a cannabis establishment lounge or caf?. All regulations under the current Ontario Cannabis License Act, 2018 should be applied to the operations of a cannabis establishment in terms of operation and training requirements, permitted cannabis products, purchase and possession limits, promotions and displays and safety measures. Risks (overconsumption, intoxication and impaired driving) The effect of ingesting cannabis usually lasts between 4 to 12 hours. (1) This delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. It can take up to 4 hours to feel the full effects of edible cannabis. Consuming more within this time can result in over-intoxication. The intoxicating effects can last up to 12 hours, with some residual effects lasting up to 24 hours. Intoxication is highly dependent on the type and close of drug and is influenced by an individual's level of tolerance and other factors. (4) During intoxication, cannabis can interfere with cognitive function memory and perception of time) and motor function coordination), and these effects can have detrimental consequences motor-vehicle accidents). Due to the delayed effect of cannabis, consumers may choose to drive after consuming a cannabis product at an establishment or a venue with a Special Occasion Permit (SOP) and be at an increased risk of a motor vehicle accident. There is clear evidence that cannabis, like alcohol, impairs the skills required for safe driving and slows reaction time which can lead to an increase in motor vehicles accidents after consumption. Everyone's response to cannabis is different, depending on sex, age, THC and CBD content, any pre- existing medical conditions, experience with cannabis, frequency of use and consumption of food, alcohol, other drugs or health products. Everyone's response to cannabis can also differ from one time to the next. (7) If we consider the history from tobacco control and alcohol, increasing access to cannabis can lead to public health implications such as increased consumption with risk of toxicity, unintended exposure to children, motor vehicle accidents, substance-use disorders, occupational safety risks and negative mental outcomes. Overconsumption of edibles among adults is associated with an increase in emergency department (ED) visits resulting from severe agitation, nausea, vomiting, panic attacks, and anxiety. Considering there is a delayed onset with edibles and ingestible cannabis products which may lead to overconsumption, intoxication and impaired driving, the government should not permit the sale and consumption of cannabis in lounges or cafe. If the government plans on moving forward with cannabis establishments, all changes should be monitored for unintended consequences. Smoke?Free Ontario Act 2017 The Smoke-Free Ontario Act, 2017 (SFOA) prohibits the smoking of tobacco, the use of electronic cigarettes (e-cigarettes) to vape any substance, and the smoking of cannabis (medical and recreational) in enclosed workplaces and enclosed public places, as well as other designated places in Ontario, to protect workers and the public from second-hand smoke and vapour. Strong evidence suggests that cannabis and tobacco smoke are equally carcinogenic, they both contain bronchial irritants, tumour promoters and carcinogens, and negative respiratory outcomes. Given the current SFOA, only edibles or ingestible cannabis products could be consumed in a public space such as a lounge and cafe, as smoking and vaping is prohibited according to this legislation. Any smoking or vaping of products should continue to be prohibited in establishments. Acknowledging the known effects of second-hand smoke and the current SFOA, any smoking or vaping of products should continue to be prohibited in establishments. Furthermore, we do not support changing the SFOA unless there are plans to add restrictions to further strengthen the current Act such as banning smoking and vaping within 9 metres of the patio or outdoor area of the lounge or cafe. Therefore, only edibles and ingestible products should be allowed at a cannabis establishment. Co?use of alcohol Alcohol increases the intoxicating and impairing effects of cannabis. Consuming cannabis and alcohol at the same time can significantly raise your risk of over-intoxication and impairment. Co-use is associated with additive impairment effects, higher and more frequent levels of consumption, impacts on cognitive and performance, increase in the risk of collisions and overall odds of driving impaired as well as, greater chances of experiencing comorbid substance use and mental health disorders. 12) Impaired driving is the leading criminal cause of death and injury in Canada, and drug-impaired driving is increasing. Getting behind the wheel while impaired by drugs is not only dangerous, it?s against the law. Trained police officers or Drug Recognition Experts can determine if a driver is under the influence of a drug and can charge them with impaired driving. An impaired driver can have their license suspended, face fines, criminal charges, and even jail time. (13) By using the only national-level drug-related ED admission dataset available, the national trends in the ED visits were examined for cannabis-only and cannabis-polydrug. These findings indicated a notable increase in cannabis-involved utilization of ED during the studied period. (14) Given the evidence on the effects of co-use, and drug impaired driving, no alcohol should be sold and consumed at a cannabis establishment due to the risks associated with simultaneous use of alcohol and cannabis. There is no way to control co-consumption of alcohol and cannabis beyond the establishment which can have immediate public health risks for the consumer and the public which may also impact local services such as police, paramedics and other emergency services. Cannabis products and Packaging Cannabis products must be in packaged in a child resistant container and be labelled with the standardized cannabis symbol, the mandatory health warning message, and include specific product information. These measures aim to reduce the risks of accidental consumption and overconsumption as well as reduce the appeal of cannabis products to young persons while providing consumers with the information they need to make informed decisions before using cannabis. Only the sale of edible and ingestible cannabis products from federally licensed producers should be permitted. There are still several questions and concerns about establishments selling cannabis edibles and ingestible products. Edibles baked on site if that is the direction that would be taken, the establishment would need to be inspected by Public Health and new laws would need to be created in the Food Safety regulations to ensure compliance is understood. Another option would be that only pre- packaged items would be allowed for sale. Will measures be put in place to prevent possible cross- contamination with other products (non-cannabis foods)? Will establishments be inspected if non- cannabis items are sold on the premise? What if the product is not fully consumed, can the consumer bring the excess cannabis product home even though it is no longer in its original package? It is edible forms of cannabis that pose the greatest risk to children who mistake them for regular food products such as brownies or cookies- ingestion accounts for at least 75% of child exposures. It is recommended to develop regulations to mitigate all concerns mentioned above. Cannabis products should be sold in their original package which contains the appropriate warning labels, THC and CBD contents, ingredients and instructions to prevent allergic reactions and overconsumption. Packaging should only be removed by the consumer. Therefore, preparation of these cannabis products should not be permitted to ensure that it is only cannabis from Ontario Cannabis stores is being utilized, and patrons should be prohibited from bringing in cannabis purchased, obtained or prepared elsewhere to avoid cross-contamination, unknown contents and illegal cannabis. We recommend that products have a limited THC content, are served in the original packaging and that excess products do not leave the premise due to the removal of the original packaging with warning labels. Staff Training A cannabis service training program like the alcohol training, Smart Serve, should be developed and mandatory for all operators and employees of cannabis establishments. The training should cover safety protocols and limits on the service of cannabis to patrons to protect them from overconsumption, intoxication and associated harms. All employees need to receive proper guidance on a process to determine whether patrons are fit to leave the establishment and operate a motor vehicle. The effect of ingesting cannabis usually last between 4 to 12 hours. (1) This delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. (2) With alcohol, there are clear signs to indicate intoxication while with cannabis, signs of impairment are not always as evident. Intoxication is highly dependent on the type and dose of drug and is influenced by an individual's level of tolerance and other factors. If a patron leaves the establishment intoxicated or impaired and causes a motor vehicle accident, the business owner may be held liable especially if safety protocols were not followed. Restrictions Follow the current restrictions on cannabis retail sale regulations regarding not permitting anyone under the age of 19 to enter the establishment by requesting ID upon entry. Additional measures can be taken such as having frosted windows and age restriction signage. Promotions Under the Cannabis Act, it is prohibited to promote cannabis or a cannabis accessory or any service related to cannabis, including communicating information about its price or distribution; by doing so in a manner that there are reasonable grounds to believe could be appealing to young persons; by means of a testimonial or endorsement, however displayed or communicated; by means of the depiction of a person, character or animal, whether real or fictional; or by presenting it or any of its brand elements in a manner that associates it or the brand element with, or evokes a positive or negative emotion about or image of, a way of life such as one that includes glamour, recreation, excitement, vitality, risk or daring. The CPHA recommends to develop and disseminate clear and consistent information regarding the potential risks and benefits associated with the use of cannabis, while recognizing that a preferred approach is to not consume the product or to delay onset of use to the extent possible and develop and implement policies and programs that strengthen community capacity and individual skills that promote healthy behaviours. There would need to be provisions to require that there is no public promotion of cannabis or a cannabis brand visible outside of the establishment as currently stated in the Ontario Cannabis License Act, 2018 to entice entry. We recommend that establishments be required to have public health messaging posted on certain cannabis key topics such as overconsumption, delayed effect of edibles, impaired driving and cannabis use during pregnancy to educate consumers on the potential risks of consuming cannabis. Municipal Controls Municipalities should have the authority to regulate the licensing of the sale and consumption of cannabis at establishments as they have access to local context information such as density and zoning. Municipalities are in better positions to conduct ongoing surveillance to monitor any negative impacts of cannabis establishments. Ongoing collection of data to monitor the impact of cannabis policies can ensure that changes be made if any negative impacts are observed as a result of cannabis regulations. It is therefore recommended that a municipality be given the authority to control local action by licensing and regulating cannabis consumption establishments to ensure that all establishments are compliant through inspections and enforcement. 2. If cannabis consumption establishments were considered in Ontario, what other products should be permitted for sale in those establishments cannabis accessories, food/beve rage products that do not contain cannabis)? Cannabis accessories Cannabis accessories should be allowed, however, only those relating to cannabis. These establishments may provide a unique, frontline opportunity to educate consumers about safe consumption practices and product information. Caffeine Do not allow products that contain added caffeine or more than 30 mg of naturally occurring caffeine, such as energy drinks, to be sold or consumed as per the Cannabis Act regulations. Non?cannabis foods and beverages We support allowing non-cannabis foods and beverages in cannabis establishment or at special events with a SOP as long as proper safety and food handling measures are in place to ensure there is no cross- contamination of foods by mixing cannabis and non-cannabis products and that Public Health Inspectors are mandated to inspect these establishments and events. If these establishments are restricted to only selling cannabis products, this can encourage overconsumption and it may compel non-cannabis users to try cannabis based on having no other options for food or drink available. 3. In Ontario, the Alcohol and Gaming Commission ofOntario (AGCO) oversees the administration ofan alcohol SOP program, which allows for the sale and service of alcohol at special occasions, including large scale events that are open to the public, such as festivals. Should the government consider establishing a similar SOP program for cannabis to be sold and consumed at festivals and events? Why or why not? If yes, what conditions should be included should alcohol consumption at the same event be restricted, should the event be age? restricted to 19+, what methods of cannabis consumption should be permitted)? The Eastern Ontario Health Unit does not support the sale and consumption of cannabis at special events through Special Occasion Permits (SOP). Permitting the sale of cannabis at special events through an SOP may cause risks to public health and safety from an increase of use and harms associated with increased risk of public intoxication and impaired driving, and the normalization of the use of cannabis. Should the government move forward with a SOP like alcohol, we recommend certain public safety measures. Sale and consumption of cannabis at special events Vendors Only retailers with an approved Cannabis Retail Store Authorization should be permitted to sell cannabis at a special event such as a fair or festival. Proper protocols for age verification, product storage and security must be in place to reduce access to youth. The number of cannabis vendors and the number of products purchased should be limited to prevent consumers from harms of overconsumption and intoxication. Risks (overconsumption, intoxication and impaired driving) The effect of ingesting cannabis usually last between 4 to 12 hours. (1) this delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. It can take up to 4 hours to feel the full effects of edible cannabis. Consuming more within this time can result in over-intoxication. The intoxicating effects can last up to 12 hours, with some residual effects lasting up to 24 hours. Intoxication is highly dependent on the type and dose of drug and is influenced by an individual's level of tolerance and other factors. During intoxication, cannabis can interfere with cognitive function memory and perception of time) and motor function coordination), and these effects can have detrimental consequences motor-vehicle accidents). Due to the delayed effect of cannabis, consumers may choose to drive after consuming a cannabis product at an establishment or at a venue with a SOP and be at an increased risk of a motor vehicle accident. There is clear evidence that cannabis, like alcohol, impairs the skills required for safe driving and slows reaction time which can lead to an increase in motor vehicles accidents after consumption. Everyone's response to cannabis is different, depending on sex, age, THC and CBD content, any pre- existing medical conditions, experience with cannabis, frequency of use and consumption of food, alcohol, other drugs or health products. Everyone's response to cannabis can also differ from one time to the next. (7) If we consider the history from tobacco control and alcohol, increasing access to cannabis can lead to public health implications such as increased consumption with risk of toxicity, unintended exposure to children, motor vehicle accidents, substance-use disorders, occupational safety risks and negative mental outcomes. Overconsumption of edibles among adults is associated with an increase in emergency department (ED) visits resulting from severe agitation, nausea, vomiting, panic attacks, and anxiety. Considering there is delayed onset with edibles and ingestible cannabis products which may lead to overconsumption, intoxication and impaired driving, the government should not permit the sale and consumption of cannabis at special events. If the government plans on moving forward with cannabis SOPs, all changes should be monitored for unintended consequences. Co?use of alcohol Alcohol increases the intoxicating and impairing effects of cannabis. Consuming cannabis and alcohol at the same time can significantly raise your risk of over-intoxication and impairment. Co-use is associated with added impairment effects, higher and more frequent levels of consumption, impacts on cognitive and performance, increase in the risk of collisions and overall odds of driving impaired as well as, greater chances of experiencing comorbid substance use and mental health disorders. 12) Impaired driving is the leading criminal cause of death and injury in Canada, and drug-impaired driving is increasing. Getting behind the wheel while impaired by drugs is not only dangerous, it?s against the law. Trained police officers or Drug Recognition Experts can determine if a driver is under the influence of a drug and can charge them with impaired driving. An impaired driver can have their license suspended, face fines, criminal charges, and even jail time. (13) By using the only national-level drug-related ED admission dataset available, the national trends in the ED visits were examined for cannabis-only and cannabis-polydrug. These findings indicated a notable increase in cannabis-involved utilization of ED during the studied period. (14) Selling cannabis and alcohol in the same location may be encouraging co-use. (20) Alcohol should be prohibited from sale and consumption at cannabis events as co-use has been associated with increased harms. Research demonstrates that simultaneous use of alcohol and cannabis is associated with more harmful consequences than the use of either substance alone, including negative physical, social and behavioural outcomes. Given the evidence on the effects of co-use, and drug impaired driving, no alcohol should be sold and consumed at a cannabis event due to the known risks associated with simultaneous use of alcohol and cannabis. There is no way to control co-consumption of alcohol and cannabis beyond the event which can have immediate public health risks for the consumer and the public which may also impact local services such as police, paramedics and other emergency services. Cannabis products and Packaging Cannabis products must be in packaged in a child resistant container and be labelled with the standardized cannabis symbol, the mandatory health warning message, and include specific product information. These measures aim to reduce the risks of accidental consumption and overconsumption as well as reduce the appeal of cannabis products to young persons while providing consumers with the information they need to make informed decisions before using cannabis. Only the sale of edible and ingestible cannabis products from federally licensed producers should be permitted. To mitigate all possible harms, cannabis products should be sold in their original package which contains the appropriate warning labels, THC and CBD contents, ingredients and instructions to prevent allergic reactions and overconsumption. Packaging should only be removed by the consumer. We recommend that products have a limited THC content, are served in the original packaging and that excess products do not leave the premise due to the removal of the original packaging with warning labels. With large events, multiple vendors may be present, therefore, a system should be in place to limit the amount of cannabis purchased and consumed. We discourage cannabis sampling at these events due to overconsumption. f sampling is to be allowed, the same consideration should be taken to limit the number of samples per adult. Staff Training A cannabis service training program like the alcohol training, Smart Serve, should be developed and mandatory for all operators and employees of cannabis SO P5. The training should cover safety protocols and limits on the service of cannabis to patrons to protect them from overconsumption, intoxication and associated harms. All employees need to receive proper guidance on a process to determine whether patrons are fit to leave the event and operate a motor vehicle. The effect of ingesting cannabis usually last between 4 to 12 hours, (1) this delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. With alcohol, there are clear signs to indicate intoxication while with cannabis, signs of impairment are not always as evident. Intoxication is highly dependent on the type and dose of drug and is influenced by an individual's level of tolerance and other factors. If a patron leaves an event intoxicated or impaired and causes a motor vehicle accident, the vendor may be held liable especially if safety protocols were not followed. Restrictions Follow the current restrictions on cannabis retail sale regulations regarding not permitting anyone under the age of 19 to enter the event by requesting ID upon entry. Additional measures can by taken by posting age restriction signage. All event staff and volunteers should be at least 19 years of age or older. Promotions Under the Cannabis Act, it is prohibited to promote cannabis or a cannabis accessory or any service related to cannabis, including communicating information about its price or distribution; by doing so in a manner that there are reasonable grounds to believe could be appealing to young persons; by means of a testimonial or endorsement, however displayed or communicated; by means of the depiction of a person, character or animal, whether real or fictional; or by presenting it or any of its brand elements in a manner that associates it or the brand element with, or evokes a positive or negative emotion about or image of, a way of life such as one that includes glamour, recreation, excitement, vitality, risk or daring. The CPHA recommends to develop and disseminate clear and consistent information regarding the potential risks and benefits associated with the use of cannabis, while recognizing that a preferred approach is to not consume the product or to delay onset of use to the extent possible and develop and implement policies and programs that strengthen community capacity and individual skills that promote healthy behaviours. There would need to be provisions to require that there is no public promotion of cannabis or a cannabis brand visible outside of the establishment as currently state in the Ontario Cannabis License Act, 2018 to entice entry. We recommend that establishments be required to have public health messaging posted on certain cannabis key topics such as overconsumption, delayed effect of edibles, impaired driving and cannabis use during pregnancy to educate consumers on the potential risks of consuming cannabis. Event Sponsorships The sponsorship of any event by a cannabis retailer or licensed producer should remain prohibited to align with the Federal Cannabis Act. Section 21 of the Act states that it is prohibited to display, refer to or otherwise use any of the following, directly or indirectly in a promotion that is used in the sponsorship of a person, entity, event, activity or facility: a brand element of cannabis, of a cannabis accessory or of a service related to cannabis; and the name of a person that produces, sells or distributes cannabis, sells or distributes a cannabis accessory, or provides a service related to cannabis. Smoke?Free Ontario Act 2017 The Smoke-Free Ontario Act, 2017 (SFOA) prohibits the smoking of tobacco, the use of electronic cigarettes (e-cigarettes) to vape any substance, and the smoking of cannabis (medical and recreational) in enclosed workplaces and enclosed public places, as well as other designated places in Ontario, to protect workers and the public from second-hand smoke and vapour. Strong evidence suggests that cannabis and tobacco smoke are equally carcinogenic, they both contain bronchial irritants, tumour promoters and carcinogens, and negative respiratory outcomes. Acknowledging the known effects of second-hand smoke and the current SFOA, all smoking and/or vaping at an event should be only permitted in a Designated Smoking Area that is removed from heavy traffic area to avoid second-hand smoke or aerosol exposure. 4. Are there any additional risks/opportunities created by cannabis consumption establishment or SOPs when compared to authorized cannabis retail stores? Liability As with many substances, there are concerns regarding liability of service. For alcohol sales, a server must be certified and follow set protocols to ensure the safety of consumers and avoid the many risks associated with intoxication. According to the Smart Serve program, the server may be held liable if the protocols are not followed. However, how will this be managed regarding edible cannabis when the effects are delayed? Who will be held responsible for any injuries or damages caused by cannabis impairment? The effect of ingesting cannabis usually last between 4 to 12 hours, (1) this delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. With alcohol, there are clear signs to indicate intoxication, while with cannabis, signs of impairment are not always as evident. Intoxication is highly dependent on the type and dose of drug and is influenced by an individual's level of tolerance and other factors. Therefore, certified training for establishment employees should be considered to recognize cannabis intoxication and for liability. 5. What should be a municipality/s involvement, if any, in a potential framework for cannabis consumption establishments or Municipalities can use licensing to require health impact assessments for every license application. ?20) Municipalities can evaluate these and contest those that could adversely impact a neighbourhood. Municipalities can also control the density and the location of these establishments and SO Ps by limiting proximity to schools and the impact on marginalized populations most at risk. Government-owned and controlled establishments can have the ability to control access and availability of cannabis to the public, especially high-risk groups such as youth, be enforcing policies and regulations such as discouraging underage customers, ensuring proper staff training and education, enforcing restrictions against the co- location of sales with alcohol or tobacco. ?22) Municipalities are in better positions to conduct ongoing surveillance to monitor any negative impacts of cannabis establishments and SOP events in their local context. Ongoing collection of data to monitor the impact of cannabis policies can ensure that changes be made if any negative impacts are observed as a result of cannabis regulations. ?18) It is therefore recommended that a municipality be given the authority to control local action by licensing and regulating cannabis consumption establishments and SO Ps to ensure compliance through inspections and enforcement. Should the government of Ontario approve cannabis consumption establishments or SO Ps, there would need to be provisions to require that there is no public promotion of cannabis or a cannabis brand visible outside of the SOP area where youth may be exposed. All smoking or vaping should be strictly prohibited, unless within an approved Designated Smoking Area which is removed from heavy traffic area to avoid second-hand exposure and does not contravene with the Smoke Free Ontario Act (2017). References 1. Barrus, D. G., Capogrossi, K. L., Cates, S. C., Gourdet, C. K., Peiper, N. C., Novak, S. P., Wiley, J. L. (2016). Tasty THC: Promises and challenges of cannabis edibles. Methods Rep RTI Press. Manuscript. doi: 2. Kim, H. S., Monte, A. A. (2016). Colorado cannabis legalization and its effect on emergency care. Annals of Emergency Medicine, 68(1), 71-75. doi: 3. CCSA (Canadian Centre on Substance Use and Addiction). 2019. Edible Cannabis, Cannabis Extracts and Cannabis Topicals: A Primer on the New Cannabis Products. Retrieved March 4th, 2020, from Topicals-Topic-Summary-2019-en 1.pdf. 4. WHO (World Health Organization). 2019. Acute intoxication. Retrieved March 4th, 2020, from abuse/terminology/acute intox/en/ 5. Effects of cannabis use on human behavior, including cognition, motivation, and a review. Volkow ND, Swanson JM, Evins AE, et al. 3:292?297, s.l. 2016, Vol. 73. 6. OPHA (Ontario Public Health Association). n.d. The Public Health Implications of the Legalization of Recreational Cannabis. Retrieved March 4th, 2020, from 7. Government of Canada. 2019. Cannabis in Canada Get the Facts. Retrieved March 4th, 2020, from 8. Monte, A. A., Zane, R. D., Heard, K. J. (2015). The implications of marijuana legalization in Colorado. JAMA, 313(3), 241-242. doi: 10.1001/jama.2014.17057 9. Ministry of Health. 2017. How the Act Affects: Enclosed Workplaces. Retrieved on March 6th, 2020 from 10. CCSA (Canadian Centre on Substance Use and Addiction). 2019. 7 Things You Need to Know about Edible Cannabis. Retrieved March 4th, 2020, from en.pdf 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. PHO (Public Health Ontario). 2018. Evidence brief: risk factors for simultaneous use of alcohol and cannabis. Retrieved March 4th, 2020, from 123. Co-use ofalcohol and cannabis: a review. Yurasek, Ali M, Elizabeth R. Aston, and Jane Metrik. 184-193, s.l. :Current Addiction Reports, 2017, Vol. 4.2. Government of Canada. 2019. Drug-impaired driving. Retrieved March 4th, 2020, from Zhu, H., Wu, L-T. (2016). Trends and correlates of cannabis-involved emergency department visits: 2004 to 2011.J Addict Med, 10(6), 429-436. doi: Government of Canada. 2019. Packaging and labelling guide for cannabis products: Requirements under the Cannabis Act and the Cannabis Regulations. Retrieved March 4th, 2020, from products/CURRENT PUBLISHED Packaging and labelling guide for cannabis products.PDF Government of Canada. 2019. The Cannabis Act and Cannabis Regulations Promotion Prohibitions. Retrieved March 4th, 2020, from CPHA (Canadian Public Health Association). 2017. A Public Health Approach to the Legalization, Regulation and Restriction of Access to Cannabis. Retrieved March 4th, 2020, from cannabis CCSA (Canadian Centre on Substance Abuse). 2015. Cannabis Regulation: Lessons Learned in Colorado and Washington State. Retrieved March 4th, 2020, from 2015-en.pdf Government of Alberta. 2017. Regulation and supply chain roundtable: Potential for cannabis cafes or lounges. Retrieved March 4th, 2020, from Government of Canada (2016). Toward the Legalization, Regulation and Restriction of Access to Marijuana. Retrieved March 4th, 2020, from Canadian Partnership Against Cancer. 2018. Local Government Alcohol Policy Pack. Retrieved March 4th, 2020, from OPHUCC (Ontario Public Health Unit Collaboration on Cannabis). 2016.Toward Legalization, Regulation and Restriction of Access to Marijuana: Submission to Federal Task Force. Retrieved March 4th, 2020, from REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Angelina Carriere Robyn Hurtubise Public Health Promoter Program Manager- Substance Use Eastern Ontario Health Unit Eastern Ontario Health Unit 1000 Pitt Street 1000 Pitt Street Cornwall, ON K6J 5T1 Cornwall, ON K6J 5T1 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) LI 1. Central Ontario 2. Eastern Ontario LI 3. Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial The Eastern Ontario Health Unit does not support the government facilitating the sale and consumption of cannabis in Ontario through cannabis establishments such as lounges and cafes. Providing access to a space for consumption increases the risks of overconsumption, intoxication and, due to the delayed effects of edibles, can increase risks of impaired driving and liability for the establishment owners. However, ifthe government approves these establishments for consumption and sale, we have included recommendations to minimize risks and the impact of cannabis on public hea?h. Sale and consumption of cannabis in establishments (lounges and cafes) Establishment Operators Only locations with an approved Cannabis Retail Store Authorization should be permitted to operate as a cannabis establishment lounge or caf?. All regulations under the current Ontario Cannabis License Act, 2018 should be applied to the operations of a cannabis establishment in terms of operation and training requirements, permitted cannabis products, purchase and possession limits, promotions and displays and safety measures. Risks (overconsumption, intoxication and impaired driving) The effect of ingesting cannabis usually lasts between 4 to 12 hours. (1) This delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. (2) It can take up to 4 hours to feel the full effects of edible cannabis. Consuming more within this time can result in over-intoxication. The intoxicating effects can last up to 12 hours, with some residual effects lasting up to 24 hours. (3) Intoxication is highly dependent on the type and dose of drug and is influenced by an individual's level of tolerance and other factors. (4) During intoxication, cannabis can interfere with cognitive function memory and perception of time) and motor function coordination), and these effects can have detrimental consequences motor-vehicle accidents). (5) Due to the delayed effect of cannabis, consumers may choose to drive after consuming a cannabis product at an establishment or a venue with a Special Occasion Permit (SOP) and be at an increased risk of a motor vehicle accident. There is clear evidence that cannabis, like alcohol, impairs the skills required for safe driving and slows reaction time which can lead to an increase in motor vehicles accidents after consumption. (6) Everyone's response to cannabis is different, depending on sex, age, THC and CBD content, any pre-existing medical conditions, experience with cannabis, frequency of use and consumption of food, alcohol, other drugs or health products. Everyone's response to cannabis can also differ from one time to the next. (7) If we consider the history from tobacco control and alcohol, increasing access to cannabis can lead to public health implications such as increased consumption with risk of toxicity, unintended exposure to children, motor vehicle accidents, substance-use disorders, occupational safety risks and negative mental outcomes. (6) Overconsumption of edibles among adults is associated with an increase in emergency department (ED) visits resulting from severe agitation, nausea, vomiting, panic attacks, and anxiety. (8) Considering there is a delayed onset with edibles and ingestible cannabis products which may lead to overconsumption, intoxication and impaired driving, the government should not permit the sale and consumption of cannabis in lounges or cafe. lfthe government plans on moving forward with cannabis establishments, all changes should be monitored for unintended consequences. Smoke-Free Ontario Act 2017 The Smoke-Free Ontario Act, 2017 (SFOA) prohibits the smoking of tobacco, the use of electronic cigarettes (e-cigarettes) to vape any substance, and the smoking of cannabis (medical and recreational) in enclosed workplaces and enclosed public places, as well as other designated places in Ontario, to protect workers and the public from second- 4 hand smoke and vapour. (9) Strong evidence suggests that cannabis and tobacco smoke are equally carcinogenic, they both contain bronchial irritants, tumour promoters and carcinogens, and negative respiratory outcomes. (6) Given the current SFOA, only edibles or ingestible cannabis products could be consumed in a public space such as a lounge and cafe, as smoking and vaping is prohibited according to this legislation. Any smoking or vaping of products should continue to be prohibited in establishments. Acknowledging the known effects of second-hand smoke and the current SFOA, any smoking or vaping of products should continue to be prohibited in establishments. Furthermore, we do not support changing the SFOA unless there are plans to add restrictions to further strengthen the current Act such as banning smoking and vaping within 9 metres of the patio or outdoor area ofthe lounge or cafe. Therefore, only edibles and ingestible products should be allowed at a cannabis establishment. Co-use of alcohol Alcohol increases the intoxicating and impairing effects of cannabis. Consuming cannabis and alcohol at the same time can significantly raise your risk of over- intoxication and impairment. (10) Co-use is associated with additive impairment effects, higher and more frequent levels of consumption, impacts on cognitive and performance, increase in the risk of collisions and overall odds of driving impaired as well as, greater chances of experiencing comorbid substance use and mental health disorders. (11' 12) lmpaired driving is the leading criminal cause of death and injury in Canada, and drug- impaired driving is increasing. Getting behind the wheel while impaired by drugs is not only dangerous, it?s against t?'zsL- iavv. Trained police officers or Drug Recognition Experts can determine if a driver is under the influence of a drug and can charge them with impaired driving. An impaired driver can have their license suspended, face fines, criminal charges, and even jail time. (13) By using the only national-level drug-related ED admission dataset available, the national trends in the ED visits were examined for cannabis-only and cannabis- polydrug. These findings indicated a notable increase in cannabis-involved utilization of ED during the studied period. (14) Given the evidence on the effects of co-use, and drug impaired driving, no alcohol should be sold and consumed at a cannabis establishment due to the risks associated with simultaneous use of alcohol and cannabis. There is no way to control co- consumption of alcohol and cannabis beyond the establishment which can have immediate public health risks for the consumer and the public which may also impact local services such as police, paramedics and other emergency services. Cannabis products and Packaging 5 Cannabis products must be in packaged in a child resistant container and be labelled with the standardized cannabis symbol, the mandatory health warning message, and include specific product information. (15) These measures aim to reduce the risks of accidental consumption and overconsumption as well as reduce the appeal of cannabis products to young persons while providing consumers with the information they need to make informed decisions before using cannabis. (15) Only the sale of edible and ingestible cannabis products from federally licensed producers should be permitted. There are still several questions and concerns about establishments selling cannabis edibles and ingestible products. Edibles baked on site if that is the direction that would be taken, the establishment would need to be inspected by Public Health and new laws would need to be created in the Food Safety regulations to ensure compliance is understood. Another option would be that only pre- packaged items would be allowed for sale. Will measures be put in place to prevent possible cross- contamination with other products (non-cannabis foods)? Will establishments be inspected if non-cannabis items are sold on the premise? What if the product is not fully consumed, can the consumer bring the excess cannabis product home even though it is no longer in its original package? It is edible forms of cannabis that pose the greatest risk to children who mistake them for regular food products such as brownies or cookies- ingestion accounts for at least 75% of child exposures. (6) It is recommended to develop regulations to mitigate all concerns mentioned above. Cannabis products should be sold in their original package which contains the appropriate warning labels, THC and CBD contents, ingredients and instructions to prevent allergic reactions and overconsumption. Packaging should only be removed by the consumer. Therefore, preparation of these cannabis products should not be permitted to ensure that it is only cannabis from Ontario Cannabis stores is being utilized, and patrons should be prohibited from bringing in cannabis purchased, obtained or prepared elsewhere to avoid cross-contamination, unknown contents and illegal cannabis. We recommend that products have a limited THC content, are served in the original packaging and that excess products do not leave the premise due to the removal ofthe original packaging with warning labels. Staff Training A cannabis service training program like the alcohol training, Smart Serve, should be developed and mandatory for all operators and employees of cannabis establishments. The training should cover safety protocols and limits on the service of cannabis to patrons to protect them from overconsumption, intoxication and associated harms. All employees need to receive proper guidance on a process to determine whether patrons are fit to leave the establishment and operate a motor vehicle. The effect of ingesting cannabis usually last between 4 to 12 hours. (1) This delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. (2) With alcohol, there are clear signs to indicate intoxication while with cannabis, signs of impairment are not always as evident. Intoxication is highly dependent on the type and dose of drug and is influenced by an individual's level of 6 tolerance and other factors. (4) If a patron leaves the establishment intoxicated or impaired and causes a motor vehicle accident, the business owner may be held liable especially if safety protocols were not followed. Restrictions Follow the current restrictions on cannabis retail sale regulations regarding not permitting anyone under the age of 19 to enter the establishment by requesting ID upon entry. Additional measures can be taken such as having frosted windows and age restriction signage. Promotions Under the Cannabis Act, it is prohibited to promote cannabis or a cannabis accessory or any service related to cannabis, including communicating information about its price or distribution; by doing so in a manner that there are reasonable grounds to believe could be appealing to young persons; by means of a testimonial or endorsement, however displayed or communicated; by means ofthe depiction of a person, character or animal, whether real or fictional; or by presenting it or any of its brand elements in a manner that associates it or the brand element with, or evokes a positive or negative emotion about or image of, a way of life such as one that includes glamour, recreation, excitement, vitality, risk or daring. (16) The CPHA recommends to develop and disseminate clear and consistent information regarding the potential risks and benefits associated with the use of cannabis, while recognizing that a preferred approach is to not consume the product or to delay onset of use to the extent possible and develop and implement policies and programs that strengthen community capacity and individual skills that promote healthy behaviours. (17) There would need to be provisions to require that there is no public promotion of cannabis or a cannabis brand visible outside ofthe establishment as currently stated in the Ontario Cannabis License Act, 2018 to entice entry. We recommend that establishments be required to have public health messaging posted on certain cannabis key topics such as overconsumption, delayed effect of edibles, impaired driving and cannabis use during pregnancy to educate consumers on the potential risks of consuming cannabis. Municipal Controls Municipalities should have the authority to regulate the licensing of the sale and consumption of cannabis at establishments as they have access to local context information such as density and zoning. Municipalities are in better positions to conduct ongoing surveillance to monitor any negative impacts of cannabis establishments. Ongoing collection of data to monitor the impact of cannabis policies can ensure that changes be made if any negative impacts are observed as a result of cannabis regulations. (18) 7 It is therefore recommended that a municipality be given the authority to control local action by licensing and regulating cannabis consumption establishments to ensure that all establishments are compliant through inspections and enforcement. Cannabis accessories Cannabis accessories should be allowed, however, only those relating to cannabis. These establishments may provide a unique, frontline opportunity to educate consumers about safe consumption practices and product information. (19) Caffeine Do not allow products that contain added caffeine or more than 30 mg of naturally occurring caffeine, such as energy drinks, to be sold or consumed as per the Cannabis Act regulations. Non-cannabis foods and beverages We support allowing non-cannabis foods and beverages in cannabis establishment or at special events with a SOP as long as proper safety and food handling measures are in place to ensure there is no cross-contamination of foods by mixing cannabis and non- cannabis products and that Public Health Inspectors are mandated to inspect these establishments and events. If these establishments are restricted to only selling cannabis products, this can encourage overconsumption and it may compel non- cannabis users to try cannabis based on having no other options for food or drink available. 8 The Eastern Ontario Health Unit does not support the sale and consumption of cannabis at special events through Special Occasion Permits (SOP). Permitting the sale of cannabis at special events through an SOP may cause risks to public health and safety from an increase of use and harms associated with increased risk of public intoxication and impaired driving, and the normalization of the use of cannabis. Should the government move forward with a SOP like alcohol, we recommend certain public safety measures. Sale and consumption of cannabis at special events Vendors Only retailers with an approved Cannabis Retail Store Authorization should be permitted to sell cannabis at a special event such as a fair or festival. Proper protocols for age verification, product storage and security must be in place to reduce access to youth. The number of cannabis vendors and the number of products purchased should be limited to prevent consumers from harms of overconsumption and intoxication. Risks (overconsumption, intoxication and impaired driving) The effect of ingesting cannabis usually last between 4 to 12 hours. (1) this delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. (2) It can take up to 4 hours to feel the full effects of edible cannabis. Consuming more within this time can result in over-intoxication. The intoxicating effects can last up to 12 hours, with some residual effects lasting up to 24 hours. (3) Intoxication is highly dependent on the type and dose of drug and is influenced by an individual's level of tolerance and other factors. (4) During intoxication, cannabis can interfere with cognitive function memory and perception of time) and motor function coordination), and these effects can have detrimental consequences motor-vehicle accidents). (5) Due to the delayed effect of cannabis, consumers may choose to drive after consuming a cannabis product at an establishment or at a venue with a SOP and be at an increased risk of a motor vehicle accident. There is clear evidence that cannabis, like alcohol, impairs the skills required for safe driving and slows reaction time which can lead to an increase in motor vehicles accidents after consumption. (6) Everyone's response to cannabis is different, depending on sex, age, THC and CBD content, any pre-existing medical conditions, experience with cannabis, frequency of use and consumption of food, alcohol, other drugs or health products. Everyone's response to cannabis can also differ from one time to the next. (7) If we consider the history from tobacco control and alcohol, increasing access to cannabis can lead to public health implications such as increased consumption with 9 risk of toxicity, unintended exposure to children, motor vehicle accidents, substance-use disorders, occupational safety risks and negative mental outcomes. (6) Overconsumption of edibles among adults is associated with an increase in emergency department (ED) visits resulting from severe agitation, nausea, vomiting, panic attacks, and anxiety. (8) Considering there is delayed onset with edibles and ingestible cannabis products which may lead to overconsumption, intoxication and impaired driving, the government should not permit the sale and consumption of cannabis at special events. lfthe government plans on moving forward with cannabis SOPs, all changes should be monitored for unintended consequences. Co-use of alcohol Alcohol increases the intoxicating and impairing effects of cannabis. Consuming cannabis and alcohol at the same time can significantly raise your risk of over- intoxication and impairment. (10) Co-use is associated with added impairment effects, higher and more frequent levels of consumption, impacts on cognitive and performance, increase in the risk of collisions and overall odds of driving impaired as well as, greater chances of experiencing comorbid substance use and mental health disorders. (11' 12) lmpaired driving is the leading criminal cause of death and injury in Canada, and drug- impaired driving is increasing. Getting behind the wheel while impaired by drugs is not only dangerous, it?s against the law. Trained police officers or Drug Recognition Experts can determine if a driver is under the influence of a drug and can charge them with impaired driving. An impaired driver can have their license suspended, face fines, criminal charges, and even jail time. (13) By using the only national-level drug-related ED admission dataset available, the national trends in the ED visits were examined for cannabis-only and cannabis- polydrug. These findings indicated a notable increase in cannabis-involved utilization of ED during the studied period. (14) Selling cannabis and alcohol in the same location may be encouraging co-use. (20) Alcohol should be prohibited from sale and consumption at cannabis events as co-use has been associated with increased harms. Research demonstrates that simultaneous use of alcohol and cannabis is associated with more harmful consequences than the use of either substance alone, including negative physical, social and behavioural outcomes. (11) Given the evidence on the effects of co-use, and drug impaired driving, no alcohol should be sold and consumed at a cannabis event due to the known risks associated with simultaneous use of alcohol and cannabis. There is no way to control co- consumption of alcohol and cannabis beyond the event which can have immediate 10 public health risks for the consumer and the public which may also impact local services such as police, paramedics and other emergency services. Cannabis products and Packaging Cannabis products must be in packaged in a child resistant container and be labelled with the standardized cannabis symbol, the mandatory health warning message, and include specific product information. (15) These measures aim to reduce the risks of accidental consumption and overconsumption as well as reduce the appeal of cannabis products to young persons while providing consumers with the information they need to make informed decisions before using cannabis. (15) Only the sale of edible and ingestible cannabis products from federally licensed producers should be permitted. To mitigate all possible harms, cannabis products should be sold in their original package which contains the appropriate warning labels, THC and CBD contents, ingredients and instructions to prevent allergic reactions and overconsumption. Packaging should only be removed by the consumer. We recommend that products have a limited THC content, are served in the original packaging and that excess products do not leave the premise due to the removal of the original packaging with warning labels. With large events, multiple vendors may be present, therefore, a system should be in place to limit the amount of cannabis purchased and consumed. We discourage cannabis sampling at these events due to overconsumption. lf sampling is to be allowed, the same consideration should be taken to limit the number of samples per adult. Staff Training A cannabis service training program like the alcohol training, Smart Serve, should be developed and mandatory for all operators and employees of cannabis SOPs. The training should cover safety protocols and limits on the service of cannabis to patrons to protect them from overconsumption, intoxication and associated harms. All employees need to receive proper guidance on a process to determine whether patrons are fit to leave the event and operate a motor vehicle. The effect of ingesting cannabis usually last between 4 to 12 hours, (1) this delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. (2) With alcohol, there are clear signs to indicate intoxication while with cannabis, signs of impairment are not always as evident. Intoxication is highly dependent on the type and dose of drug and is influenced by an individual's level of tolerance and other factors. (4) If a patron leaves an event intoxicated or impaired and causes a motor vehicle accident, the vendor may be held liable especially if safety protocols were not followed. Restrictions Follow the current restrictions on cannabis retail sale regulations regarding not permitting anyone under the age of 19 to enter the event by requesting ID upon entry. ?l?l Additional measures can by taken by posting age restriction signage. All event staff and volunteers should be at least 19 years of age or older. Promotions Under the Cannabis Act, it is prohibited to promote cannabis or a cannabis accessory or any service related to cannabis, including communicating information about its price or distribution; by doing so in a manner that there are reasonable grounds to believe could be appealing to young persons; by means of a testimonial or endorsement, however displayed or communicated; by means ofthe depiction of a person, character or animal, whether real or fictional; or by presenting it or any of its brand elements in a manner that associates it or the brand element with, or evokes a positive or negative emotion about or image of, a way of life such as one that includes glamour, recreation, excitement, vitality, risk or daring. (16) The CPHA recommends to develop and disseminate clear and consistent information regarding the potential risks and benefits associated with the use of cannabis, while recognizing that a preferred approach is to not consume the product or to delay onset of use to the extent possible and develop and implement policies and programs that strengthen community capacity and individual skills that promote healthy behaviours. (17) There would need to be provisions to require that there is no public promotion of cannabis or a cannabis brand visible outside ofthe establishment as currently state in the Ontario Cannabis License Act, 2018 to entice entry. We recommend that establishments be required to have public health messaging posted on certain cannabis key topics such as overconsumption, delayed effect of edibles, impaired driving and cannabis use during pregnancy to educate consumers on the potential risks of consuming cannabis. Event Sponsorships The sponsorship of any event by a cannabis retailer or licensed producer should remain prohibited to align with the Federal Cannabis Act. Section 21 of the Act states that it is prohibited to display, refer to or otherwise use any of the following, directly or indirectly in a promotion that is used in the sponsorship of a person, entity, event, activity or facility: a brand element of cannabis, of a cannabis accessory or of a service related to cannabis; and the name of a person that produces, sells or distributes cannabis, sells or distributes a cannabis accessory, or provides a service related to cannabis. Smoke-Free Ontario Act 2017 The Smoke-Free Ontario Act, 2017 (SFOA) prohibits the smoking of tobacco, the use of electronic cigarettes (e-cigarettes) to vape any substance, and the smoking of cannabis (medical and recreational) in enclosed workplaces and enclosed public places, as well as other designated places in Ontario, to protect workers and the public from second- hand smoke and vapour. (9) 12 Strong evidence suggests that cannabis and tobacco smoke are equally carcinogenic, they both contain bronchial irritants, tumour promoters and carcinogens, and negative respiratory outcomes. (6) Acknowledging the known effects of second-hand smoke and the current SFOA, all smoking and/or vaping at an event should be only permitted in a Designated Smoking Area that is removed from heavy traffic area to avoid second-hand smoke or aerosol exposure. Cannabis Consumption Establishments SOPs: Liability As with many substances, there are concerns regarding liability of service. For alcohol sales, a server must be certified and follow set protocols to ensure the safety of consumers and avoid the many risks associated with intoxication. According to the Smart Serve program, the server may be held liable if the protocols are not followed. However, how will this be managed regarding edible cannabis when the effects are delayed? Who will be held responsible for any injuries or damages caused by cannabis impairment? The effect of ingesting cannabis usually last between 4 to 12 hours, (1) this delayed effect may cause consumers to eat more edibles to achieve the desired effect, which can result in adverse health outcomes. (2) With alcohol, there are clear signs to indicate intoxication, while with cannabis, signs of impairment are not always as evident. Intoxication is highly dependent on the type and dose of drug and is influenced by an individual's level of tolerance and other factors. (3) Therefore, certified training for establishment employees should be considered to recognize cannabis intoxication and for liability. Municipalities can use licensing to require health impact assessments for every license application. (20) Municipalities can evaluate these and contest those that could adversely impact a neighbourhood. (20) Municipalities can also control the density and the location ofthese establishments and SOPs by limiting proximity to schools and the impact on marginalized populations most at risk. Government-owned and controlled establishments can have the ability to control access and availability of cannabis to the public, especially high-risk groups such as youth, be enforcing policies and regulations such as discouraging underage customers, ensuring proper staff training and education, enforcing restrictions against the co-location of sales with alcohol or tobacco. (22) 13 Municipalities are in better positions to conduct ongoing surveillance to monitor any negative impacts of cannabis establishments and SOP events in their local context. Ongoing collection of data to monitor the impact of cannabis policies can ensure that changes be made if any negative impacts are observed as a result of cannabis regulations. (18) It is therefore recommended that a municipality be given the authority to control local action by licensing and regulating cannabis consumption establishments and SOPs to ensure compliance through inspections and enforcement. Should the government of Ontario approve cannabis consumption establishments or SOPs, there would need to be provisions to require that there is no public promotion of cannabis or a cannabis brand visible outside ofthe SOP area where youth may be exposed. All smoking or vaping should be strictly prohibited, unless within an approved Designated Smoking Area which is removed from heavy traffic area to avoid second- hand exposure and does not contravene with the Smoke Free Ontario Act (2017). References 1. Barrus, D. G., Capogrossi, K. L., Cates, S. C., Gourdet, C. K., Peiper, N. C., Novak, S. P., Wiley, J. L. (2016). Tasty THC: Promises and challenges of cannabis edibles. Methods Rep RTI Press. Manuscript. doi: 14 10. 11. 12. 13. Kim, H. S., Monte, A. A. (2016). Colorado cannabis legalization and its effect on emergency care. Annals of Emergency Medicine, 68(1), 71 -75. doi: CCSA (Canadian Centre on Substance Use and Addiction). 2019. Edible Cannabis, Cannabis Extracts and Cannabis Topicals: A Primer on the New Cannabis Products. Retrieved March 4th, 2020, from Topicals-Topic-Summary-2019-en 1.pdf. WHO (World Health Organization). 2019. Acute intoxication. Retrieved March 4th, 2020, from Effects of cannabis use on human behavior, including cognition, motivation, and a review. Volkow ND, Swanson JM, EvinsAE, et al. 3:292?297, JAMA 2016, Vol. 73. OPHA (Ontario Public Health Association). n.d. The Public Health Implications of the Legalization of Recreational Cannabis. Retrieved March 4th, 2020, from Cannabis. Government of Canada. 2019. Cannabis in Canada Get the Facts. Retrieved March 4th, 2020, from effects.htm Monte, A. A., Zane, R. D., Heard, K. J. (2015). The implications of marijuana legalization in Colorado. JAMA, 313(3), 241 -242. doi: 10.1001/jama.2014.17057 Ministry of Health. 2017. How the Act Affects: Enclosed Workplaces. Retrieved on March 6th, 2020 from 2020-01-21-endlish.bdf CCSA (Canadian Centre on Substance Use and Addiction). 2019. 7 Things You Need to Know about Edible Cannabis. Retrieved March 4th, 2020, from Cannabis-2019-en.pdf PHO (Public Health Ontario). 2018. Evidence brief: risk factors for simultaneous use of alcohol and cannabis. Retrieved March 4th, 2020, from 123. Co?use of alcohol and cannabis: a review. Yurasek, Ali M., Elizabeth R. Aston, and Jane Metrik. 184-193, s.l. Current Addiction Reports, 2017, Vol. 4.2. Government of Canada. 2019. Drug-impaired driving. Retrieved March 4th, 2020, from 14. Zhu, H., Wu, L-T. (2016). Trends and correlates of cannabis-involved 15. emergency department visits: 2004 to 2011. Addict Med, 10(6), 429-436. doi: Government of Canada. 2019. Packaging and labelling guide for cannabis products: Requirements under the Cannabis Act and the Cannabis Regulations. 15 Retrieved March 4th, 2020, from labelling-quide-cannabis- products/CURRENT PUBLISHED Packaging and labelling guide for cannabi 16. Government of Canada. 2019. The Cannabis Act and Cannabis Regulations Promotion Prohibitions. Retrieved March 4th, 2020, from 17. CPHA (Canadian Public Health Association). 2017. A Public Health Approach to the Legalization, Regulation and Restriction of Access to Cannabis. Retrieved March 4th, 2020, from restriction-access-cannabis 18. CCSA (Canadian Centre on Substance Abuse). 2015. Cannabis Regulation: Lessons Learned in Colorado and Washington State. Retrieved March 4th, 2020, from 19. Government of Alberta. 2017. Regulation and supply chain roundtable: Potential for cannabis cafes or lounges. Retrieved March 4th, 2020, from Cannabis-Cafes-and-Lounges.pdf 20. Government of Canada (2016). Toward the Legalization, Regulation and Restriction of Access to Marijuana. Retrieved March 4th, 2020, from 21 . Canadian Partnership Against Cancer. 2018. Local Government Alcohol Policy Pack. Retrieved March 4th, 2020, from 22. OPHUCC (Ontario Public Health Unit Collaboration on Cannabis). 2016.Toward Legalization, Regulation and Restriction of Access to Marijuana: Submission to Federal Task Force. Retrieved March 4th, 2020, from 16 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominiumlbuilding policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). lan Reich, Harm Reduction and Population Health Manager Grey Bruce Health Unit 101 17th Street East, Owen Sound, N4K 0A5 About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other: Public Health Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial Due to the limited availability of research and evidence pertaining to the risks/benefits of the proposed changes, we are not able to provide a clear yes or no answer Should the province choose to open these types of establishments, there are many related risks that should be taken into account. Risks/Cautions Potential Mitigating Strategies Overconsumption inexperienced users (unknown response to dose), delayed onset - Following dosage guidelines per the Canada?s Lower Risk Cannabis Use Guidelines - Only serve products available through the 008 - Having other food and beverages available for consumption and allowing non-Cannabis related products available to others that are not consuming cannabis - Setting a max per client dosage of THC/day Training for all servers to be able to identify overconsumption in clients (refuse service similar to Safe- Serve) Driving under lnfluence Availability of alternative transportation, posted signs and phone numbers of services available when needed Mandatory posting of Canada?s Lower Risk Cannabis Use Guidelines Large-scale health promotion campaign to ensure risks are known to all prior to opening Trained employees to identify consumers that may not be suitable to drive Concurrent Use alcohol, caffeine Do not serve alcohol, or products with high caffeine. Do not mix with alcohol or high caffeine products (following Federal rules in relation to edible guidelines) Not including/allowing vaping and smoking of cannabis edibles only Enforce via SFOA 2017. Do not alter SFOA 2017 in any way Use with people that may be pregnant Follow the Canada Lower Risk Guidelines, mandatory posting of signage outlining risks Normalizing of Cannabis use, may lead to more problematic use, making it too widely available Post evidence based risks and ensure consumers are aware of these facts this will allow users to make an educated choice Potentially Viewable by youth Consumption only in areas that lie outside the view of the public No Access to anyone under 19 ever Assumption of Health Benefits of Cannabis by the customer Do not allow for any reference to any potential health benefits of cannabis - Products that contain cannabis should only be 008 approved products - Consider following the Healthy Menu Choices Act if applicable - Products that contain high caffeine or alcohol g. energy should NOT be sold - Enrichment or fortification of products (with vitamins, minerals, fiber or protein or other nutrients) that contain cannabis should not be permitted - Food or drinks sold should not be permitted to make health or nutrition claims - No infusing foods With cannabis on site all items must come from 008 product lists - Must ensure dosage. Onsite preparation Will not be able to accurately gauge dose. This may increase the risk of overconsumption. Do not support onsite preparation of edibles must be 008 approved products. We feel that if are made for Cannabis specifically, they should: 0 be exclusive of alcohol Within the same event i. e. either alcohol or cannabis SOP, not both 0 restrict the age to 19+ 0 sell only products from the 008 0 Allow a maximum amount of THC sold per individual Do not alter the SPCA to enhance the ability to smoke and vape outside of current legislation. Cannabls Consumptlon Risks lncreased risk of overconsumption lncreased risk of driving under the influence Normalizing behaviour among youth and the general public SFOA risks if there are decisions to modify lncreased risk of illegal markets using these establishments Opportunities Done properly, there may be chance to displace the illegal market (decrease costs) SOPs: Risks lncreased risk of overconsumption lncreased risk of driving under the influence Normalizing behaviour among youth and the general public SFOA risks if there are decisions to modify lncreased risk of illegal markets using these establishments Similar to Alcohol. Creation of municipal cannabis policies/bylaws with a method to elicit community engagement and feedback. Municipalities should be able to follow their constituents? needs and wants while balancing the potential risks at a local level Recommendations: - A mandated setback of 150m from schools, child care centre, youth centre - A buffer of 70m from sensitive land uses - A buffer from alcohol establishments While it is inevitable that these types of establishments will be sought be some members of the public - there may be unintended consequences. Due to the relatively recent history of legalization, research and literature is still under development, which makes it difficult to provide a wholesome recommendation. That said we are aware of the current risks associated with cannabis use. The risks laid out above must be reduced as best as possible. We support a Harm Reduction lens being applied in line with best practices and evidence. As a Public Health Agency we support the view of alPHa, and urge the government to follow the recommendations to provide the best opportunity for implementation of this potentially hazardous venture that minimizes related harms. The Regional Municipality of Halton Consultation Regarding Cannabis Consumption Establishments and Special Occasion Permits March 10, 2020 Introduction Halton Region welcomes the opportunity to participate in the consultation regarding cannabis consumption lounges and special occasion permits. Given the potential harms associated with cannabis use, Halton Region recognizes the importance of setting strict regulations to protect the health and safety of the public. The following responses are provided to the discussion questions listed in the consultation questionnaire: 1. Taking into consideration the places of use rules for cannabis under the SFOA, 2017, should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not? Halton Region staff support the preservation of the existing Smoke?Free Ontario Act, 2017 (SFOA, 2017) within this consultation. Permitting indoor smoking and/or vaping of cannabis in public places, such as lounges and cafes, should not be reconsidered at any time due to the many health and safety hazards. Further discussion regarding this issue is outlined in response to question 3. Halton Region staff do not recommend the sale and consumption of edible cannabis in lounges and cafes due to health and safety risks, implications for safe service, and increased accessibility, as outlined below. Health and safety risks While edible cannabis products allow consumers to avoid the lung?related harms associated with smoked cannabis, there can be significant health and safety consequences associated with their use. When cannabis is consumed orally in the form of food or drink, it can take up to 4 hours for a person to feel the full effects of impairment.1As well, the effects can last up to 12 hours, with residual effects lasting as long as 24 hours.1This delayed and sustained effect increases health and safety risks, including impaired driving. People tend to overconsume edible products because they do not wait to feel the full effects before eating or drinking more, which can lead to severe acute impairment and unintentional poisoning.1 It is well documented that cannabis use increases the risk of motor vehicle collisions, including fatal collisions.3 According to the 2019 summary results of the Canadian Cannabis Survey, among people who had used cannabis in the past 12 months, 16% reported that they had ever driven within four hours of ingesting a cannabis product, and of those who had driven after ingesting cannabis, 37% did so within the past 30 days, 39% within the past 12 months, and 24% more than 12 months ago.2The Province of Ontario is already significantly impacted by costs associated with alcohol?related harms, which are estimated to be 4.5 billion dollars annually.19 A portion of those costs are directly attributable to alcohol?impaired driving. Safe service Unlike alcohol, which has a more predictable effect on the body, cannabis consumers and servers cannot easily anticipate the length or severity of impairment based on amount consumed.4 It is also difficult for law enforcement to assess level of impairment and related risk. The level of tetrahydrocannabinol (THC) in bodily fluids cannot be used to reliably indicate the degree of impairment or motor vehicle crash risk.?This difference has implications for consumers as well as servers, and puts them at risk for liability. At present, people who sell and serve alcohol require training through the Smart Serve Program, which is overseen by the Alcoholand Gaming Commission of Ontario (AGCO). Currently, no such program exists for responsible service of cannabis except the training required by staff to sell cannabis in approved retail locations. Accessibility The increased availability and accessibility of cannabis may lead to an increase in public health and safety impacts. This correlation has been found with other substances. For example, research has shown that communities with higher densities of alcohol retail outlets are more likely to have higher rates of use and alcohol?related problems, such as violence.5 In Ontario, alcohol?attributable emergency department visits have increased by 18% since 2015 when alcohol sales were introduced in grocery stores.20There has also been a similar association observed for tobacco retail density and smoking rates. 5 2. If cannabis consumption establishments were considered in Ontario, what other products should be permitted for sale in those establishments cannabis accessories, food/beverage products that do not contain cannabis)? Halton Region staff do not recommend the sale and consumption of cannabis in establishments. If such consumption places were permitted, it is recommended that no cannabis accessories or other food or drink items, including alcohol and highly?caffeinated beverages be permitted for sale, as outlined below. Accessories Given the confirmation that no changes to the SFOA, 2017 are being considered as part of this consultation, the inclusion of accessories is unnecessary. There are no accessories associated with edible cannabis products and cannabis accessories for smoking and/or vaping such as rolling papers, vaporizers or vape cartridges should not be available. The availability of such items could contribute to the normalization of smoking and/or vaping and also lead to confusion for patrons if only edible cannabis is consumed on site. As well, visual and sensory cues associated with the use of tobacco, vaporizers or related products can influence smoking behaviour, including initiation and relapse.13 Other food and drink items Other food or drink items should not be sold in cannabis consumption establishments. There are risks associated with preparing and selling edible cannabis alongside other food and drink products that do not contain cannabis. For example, someone may inadvertently consume a cannabis product when they do not wish to, which could contribute to unintentional poisoning. Cannabis food and drink items look like normal food and drink items and people cannot differentiate between them through observation. Furthermore, the production of edible cannabis products should not occur in the same establishment where other food and drink products are prepared. The physical separation of edible cannabis preparation and other food and drink preparation is important to mitigate the risks of cross contamination and potential health consequences. This separation is stipulated in the Federal Government?s Regulations for New Cannabis Products.8 If edible cannabis were sold and served in an establishment, it should be in the original packaging, purchased through the Ontario Cannabis Store (OCS) so that customers are provided with the exact THC content and health risk information. Alcohol Alcohol should not be served at the same establishment as cannabis, as its availability could encourage co?use of the substances. As stated in the response to question 1, edible cannabis consumption poses significant risks to health and safety, including impaired driving. Simultaneous use of alcohol and cannabis significantly increases levels of THC in the blood which further increases impairment.?The risk of motor vehicle collisions is even higher when used together than when either substance is used alone.3 Highly?caffeinated beverages Highly?caffeinated beverages should not be sold at the same location as edible cannabis. There is some evidence that caffeine may increase the effects which could lead to more impairment for a consumer if they were to consume the products together.7According to the Regulations for New Cannabis Products, the Federal Government has stipulated: The use ofingredients containing naturally occurring caffeine will be permitted in edible cannabis products provided the total amount of caffeine in each immediate container does not exceed 30 mg. 8 On average, a cup of brewed coffee has 80 ?179 mg of caffeine and energy drinks have 80?97 mg.9 3. In Ontario, the Alcohol and Gaming Commission of Ontario (AGCO) oversees the administration of an alcohol SOP program, which allows for the sale and service of alcohol at special occasions, including large scale events that are open to the public, such as festivals. 3) Should the government consider establishing a similar SOP program for cannabis to be sold and consumed at festivals and events? Why or why not? Halton Region staff do not recommend establishing an SOP program for cannabis to be sold and consumed at festivals and events. While there is an alcohol SOP program overseen by the AGCO, the health and safety risks associated with cannabis are extensive and not easily mitigated with strict regulations. It is understood that smoking and/or vaping of cannabis is restricted in prescribed places under SFOA, 2017, and that municipalities can enact local by?laws to further restrict use. Similarly, employers and property owners can implement internal policies to address cannabis use. For venues that are not included in restrictions under the SFOA, 2017, or other by?laws and policies, a cannabis SOP that permits the smoking and/or vaping of cannabis could lead to significant second?hand smoke exposure and contribute to the role? modeling and normalization of smoking behaviour. Over the years, smoke?free policies have been shown to encourage quit attempts, denormalize smoking behavior, and prevent the initiation of smoking.10 Furthermore, there is no safe level of second?hand cannabis smoke exposure either indoors or outdoors.11 Many studies have shown that cannabis smoke and tobacco smoke contain similar fine particles, volatile organic chemicals, carbon monoxide, and heavy metals; all of which pose potential health risks.12*13There are at least 33 cancer?causing agents in cannabis smoke, some of which are at greater levels than in tobacco smoke.?15 Unique to cannabis, people who are exposed to unwanted second?hand cannabis smoke can have detectable levels of the ingredient, delta?9?tetrahydrocannabinol (THC), in their body.16 In terms of health and safety, workers, vulnerable persons, and non?smoking public should not be put at risk of experiencing the effects of THC involuntarily through second?hand exposure. As stated in response to question 1, there are health and safety risks associated with consumption of edible cannabis if it were sold and served at an SOP event. The delayed and sustained effects and potential overconsumption are concerning and have implications that are not easily mitigated. Impairment is not easily identified in cannabis consumers which has implications for servers who would require extensive training regarding responsible service of the substance. As well, edible cannabis candies, cookies and brownies) can be appealing to children and can contribute to unintentional poisoning. Between September and December 2018, there were 11 cases of a serious and life threatening event associated with non?medical cannabis use among Canadian children and adolescents identified through the Canadian Paediatric Surveillance Program.17 b) If yes, what conditions should be included should alcohol consumption at the same event be restricted, should the event be age-restricted t019+, what methods of cannabis consumption should be permitted)? Halton Region staff do not recommend SOPs for any form of cannabis consumption. If such permits were introduced, it is recommended that they be separate from alcohol SOPs in order to discourage co?use of the substances. The following is a list of evidence?based requirements that Halton Region staff recommends to be included if a cannabis SOP were permitted: 0 adherence to municipal or other local bylaws that may prohibit cannabis SOPs and/or impose additional restrictions to SOP holders 0 types of eligible and ineligible properties, e.g. must be a minimum distance from youth?serving facilities 0 admittance restricted to people aged 19 years and over only, ID required 0 visible and complete boundaries/fencing around permit area 0 liability insurance obtained by event host 0 detailed number of trained staff who would have extensive training regarding cannabis and the risks and harms associated with use as well as a specific ratio of staff to attendees 0 security arrangements including hired security staff or paid duty police officers 0 limits on standard product ?sizes? total mg of THC) 0 minimum prices of products available 0 limit on number of products that can be purchased at one time no samples allowed 0 appropriate signage 0 display of posters/flyers re: Canada?s Lower?Risk Cannabis Use Guidelines 0 criteria for permit holder that staff may not consume cannabis while working 0 transportation options available (ride share area, phone number to call, taxis on standby) limitations regarding advertising, as per the Cannabis Act, 2018 procedures and penalties for infractions no outside cannabis products allowed 0 only the sale and service of cannabis products from OCS in original packaging allowed 4. Are there any additional risks/opportunities created by cannabis consumption establishments or SOPs when compared to authorized cannabis retail stores? There are more risks associated with consumption establishments or SOPs compared to authorized cannabis retail stores. Most importantly, people do not consume cannabis in retail spaces. As stated earlier, there are many associated health and safety risks with cannabis consumption that have implications for patrons and servers working in those establishments or SOP events. 5. What should be a municipality?s involvement, if any, in a potential framework for cannabis consumption establishments or Under the Cannabis License Act, 2018, municipalities have had the option to opt?in or out of allowing private retail stores. If cannabis consumption establishments and/or SOPs are permitted provincially, Halton Region staff recommend that municipalities be afforded the same opportunity to opt?in or out. If municipalities decide to allow establishments and or SOPs, they should be afforded more control over the number and location of such places, which currently does not exist for cannabis retail spaces. For example, the Cannabis License Act, 2018, does not establish a cap on the number or density of cannabis retail outlets in a community and establishes a very minimal separation distance from schools and other land uses. Research has demonstrated that higher retail outlet density can contribute to increased consumption and harms of a substance, and proximity of such spaces to youth serving facilities can normalize and increase substance use among youth.18 Municipalities should also have the ability to require certain distances between cannabis consumption establishments and SOP locations, as well as certain distances from alcohol retail/consumption and tobacco retail outlets. As stated earlier, co?use of cannabis and other substances increases the risk of harms.18 Conclusion Halton Region thanks the Provincial Government for the opportunity to provide comments on proposed cannabis consumption lounges/cafes and special occasion permits. References 10. Canadian Centre on Substance Use and Addiction (2019). 7 things you need to know about edible cannabis. Available at: Cannabis?2019?en.pdf Government of Canada (2019). Canadian cannabis survey 2019?summary. Available at:" Fischer, 8., Russell, C., Sabina, P., van den Brink, W., Le Foll, 8., Hall, W., Rehm, J. Room, R. (2017). Lower?Risk Cannabis Use Guidelines (LRCUG): An evidence?based update. American Journal ofPuinc Health, 107(8). DOI: Government of Canada (2016). A framework for the legalization and regulation of cannabis in Canada, The final report of the task force on cannabis legalization and regulation. Available at:" Region of Peel (2017). Public health considerations for the cannabis retail system Smoke?Free Ontario Scientific Advisory Committee, Ontario Agency for Health Protection and Promotion (Public Health Ontario) (2016). Evidence to guide action: comprehensive tobacco control in Ontario. Toronto, ON: Queen?s Printer for Ontario;2017. Available at:u FullReport.pdf. Liv Science (2017). Stoned plus buzzed: Mixing caffeine and pot brings new risks. Availableat:u Government of Canada (2019). Final regulations for new cannabis products: Edible cannabis, cannabis extracts and cannabis topicals. Available at:u finaux.pdf Dietitians of Canada (2018). Facts on caffeine. Available at:v Smoke?Free Ontario Scientific Advisory Committee, Ontario Agency for Health Protection and Promotion (Public Health Ontario) (2016). Evidence to guide action: comprehensive tobacco control in Ontario. Toronto, ON: Queen?s Printer for Ontario. 11Department of Health and Human Services (2006). The Health Consequences of Involuntary Exposure to Tobacco Smoke: A Report of the Surgeon General. [Report online] Atlanta, GA: US. Dept. of Health and Human Services, Centers for Disease Control and Prevention, Coordinating Center for Health Promotion, National Center for Chronic Disease Prevention and Health Promotion, Office on Smoking and Health. Available at: V c nnis A, Plecas D. (2016). Clearing the Smoke on Cannabis: Respiratory Effects of Cannabis Smoking An Update. [Report online]. Ottawa Canada: Canadian Centre on Substance Abuse. Available at: en.pdf Smoke?Free Ontario Scientific Advisory Committee, Ontario Agency for Health Protection and Promotion (Public Health Ontario) (2016). Evidence to guide action: Comprehensive tobacco control in Ontario. Toronto, ON: Queen?s Printer for Ontario;2017. Available at, Sparacino, CIVI, PA Hughes TJ. (1990). Chemical and biological analysis of marijuana smoke condensate. NIDA Res IVIonogr 99 (1990): 121?40. Available at:n Tomar RS, Beaumont J, Hsieh JCY. (2009). Evidence on the carcinogenicity of marijuana smoke. Sacremento (CA): California Environmental Protection Agency. Available at:n Herrmann ES, et al. (2015). Non?smoker exposure to secondhand cannabis smoke II: Effect of room ventilation on the physiological, subjective and behavioural/cognitive effects. Drug and Alcohol Dependence. 2015 June 1:151:194?202. Canadian Pediatric Surveillance Program 2018 Results. Available at:m The Regional Municipality of Halton (2018). Cannabis retail outlet considerations for Halton municipalities. Available Public Health Ontario (2019). The burden of chronic diseases in Ontario. Available at:n 20. IVIyran, D., et al. (2019). The association between alcohol access and alcohol?attributableemergency department visits in Ontario, Canada. Available at:L REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Dr. Elizabeth Richardson, MD, Medical Officer of Health Public Health Services Healthy and Safe Communities Dept. City of Hamilton 100 Main Street West, 6th Floor Hamilton, ON L8P 1H6 t: 905.546.2424 x3502 e: Mailing Address: 110 King Street West, 2nd Floor Hamilton, ON L8P 456 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Hamilton Public Health Services (H PHS) does not support the provincial government facilitating the sale of cannabis for consumption in lounges or cafes for several reasons. 1. The SFOA, 2017 prohibits smoking and vaping in enclosed public places, on patios and within 9 metres of patios. Any changes to the SFOA, 2017 with regards to permissiveness for smoking or vaping of substances is not supported by HPHS. This would reverse the public health gains achieved over the past 13 years under the SFO Strategy in relation to known health risks from second-hand smoke and vape, especially for employees of establishments. 2. Prohibitions under the SFOA, 2017 would require cannabis consumption within establishments to be restricted to edible products. Consumption of edible cannabis products are unique in the length of time it can take users to feel effects in that these effects may not be felt until after patrons leave such establishments. 3. Licensed cannabis retailers currently exist whereby Ontarians are able to purchase cannabis products, and the number of retailers under the current model is already expected to increase. 4. Cannabis use is permitted in public spaces such as on sidewalks and other locations, as well as within private spaces. Spaces currently exist for use of cannabis products. The sale and/or supply of alcohol should be prohibited in any location where cannabis sale and/or supply are permitted, similar to what is currently in place in some American states. Consuming alcohol and cannabis together causes an increase in THC in the bloodstream (compared to cannabis only) which can increase negative effects such as nausea, dizziness and vomiting as well as increasing impairment.?ii Those who use both alcohol and cannabis often drink more alcohol, increasing intoxication and risk of alcohol In addition, HPHS opposes the sale and/or supply of smoking and vaping accessories such as vape pens, vapourizers, bongs, tobacco or vapour products within such establishments. HPHS supports the sale of food and (non-alcoholic) beverages in any location where cannabis is available for consumption, similar to requirements for alcohol sales. HPHS does not support a SOP program for cannabis sale and/or consumption at festivals and events in Ontario because the SFOA, 2017 prohibits smoking and vaping in enclosed public places and workplaces, as well as many outdoor areas. In addition, the City of Hamilton has a municipal by-law which prohibits smoking and vaping within City-owned parks, sports fields, beaches, and other recreational properties. Effectively, this means that currently most festivals and events in the city of Hamilton are smoke and vape-free. These laws restrict cannabis use in the majority of festival and event locations to smoke and vape-free consumption. There is a concern about increased policing costs due to the potential for impairment, similar to events permitting alcohol use. In addition, public safety concerns both during and after the 4 event need to be considered, given effects such as impairment, paranoia and poisoning. Other considerations such as having certified (cannabis) Smart Serv for those selling or supplying cannabis in relation to impairment and amount of product provided, control over festival/event attendees bringing their own cannabis versus purchasing at the event to ensure legal product, cannabis sellers use of legal product in edib es, compliance with the food safety standards in the Food Premises Regulation under the Health Protection and Promotion Act, youth access to products and advertising restrictions for events. If the government were to establish a SOP program for cannabis sale and/or consumption at festivals and events, the SOP program should: - Specify the times permitted for cannabis service - Prohibit the sale of alcohol - Establish (minimum) cannabis pricing requirements - Establish maximum THC content - Require that food and non-alcoholic beverages be available - Restrict events to those 19 years of age and older - Restrict visibility of cannabis consumption - Require that cannabis be obtained only from licensed Ontario Cannabis Retailers or the Ontario Cannabis Store We also suggest prohibitions on cannabis use under Tailgate Event Special Occasion Permits. ?Cannabis Consumption Establishments. Health Canada has indicated that the effects of consuming edible cannabis products are typically felt within 30 minutes to 2 hours, but can take up to 4 hours to feel the full effects with impairment lasting as long as 12 hours. Compared to alcohol, impairment takes a longer length of time when consuming edible cannabis. This delay would pose greater risk to public health and safety in the event that patrons who still feel sober were to choose to drive home also increasing liability to business owners. Public health and safety should be paramount when considering introducing such conditnions. SOPs: Cannabis use poses similar risks to public health and safety and liability due to the complexity of cannabis impairment as outlined above for cannabis consumption establishments. Current alcohol SOPs outline security requirements which should also be required for cannabis SOPs. Requirements for minimum insurance to address liability similar to alcohol are recommended. As outlined above, other concerns include potential increased policing costs, certified sellers and product, and compliance with the Ontario food safety standards. Municipalities should have the ability to opt out of consumption establishments, similar to the opening of licensed cannabis retail locations. In addition, they should be permitted to approve proposed locations to ensure appropriate zoning is in effect. The municipality should have the ability to deny consumption establishments based on proximity to elementary and secondary schools. In addition, municipalities should have the ability to review and approve cannabis consumption establishments for licensing purposes should they ultimately be permitted. Municipalities should have the ability to deny SOPs requesting events that involve cannabis consumption on municipal properties. Municipalities should also have the ability to deny cannabis consumption at events held on non-municipal properties as allowable under local by- laws or processes. Any new legislation in relation to cannabis should take into account public health and safety as well as access and availability of products to youth, such that cannabis use is not normalized among this population. iWellington-Dufferin-Guelph Public Health. (2019). Cannabis Facts: Using cannabis with alcohol and tobacco: A risky combination. Accessed: February 21, 2020. URL: Ontario Agency for Health Protection and Promotion (Public Health Ontario), MeyerW, Leece, P. Evidence brief: risk factors for simultaneous use of alcohol and cannabis. Toronto, ON: Queen's Printer for Ontario; 2018. URL: ?i Government of Canada. Cannabis and your health: Get the Facts: Accessed: October 17, 2019. URL: REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis?ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). David Patterson, Health Promoter Hastings Prince Edward Public Health 179 North Park St. Belleville, ON K8P 4P1 About You or Your Organization (please check the appropriate box/boxes) El Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial Hastings Prince Edward Public Health does not support the sale of cannabis for consumption in lounges or cafes. 0 Evidence from alcohol and tobacco control highlights that increased access can lead to increased consumption and potential harms. The onset of effects from inhalation of cannabis typically occurs in minutes, whereas the onset after ingestion can take hours. Consumers of edibles, particularly novice ones, can have trouble predicting what kind of effect will occur and when it will occur, and may consume more edibles to achieve the desired effect, which can result in adverse health outcomes. 0 The delayed onset of edibles/ingestible cannabis results in challenges to prevent intoxication and ensure responsible sale, including liability risks for the establishment operator incidents that may occur once the patron leaves the establishment: motor vehicle collisions, illnesses associated with overconsumption such as vomiting, fainting, sever anxiety or panic attack, loss of reality or paranoia) Should the government facilitate the sale of cannabis for consumption in a lounge or cafe establishment, only the sale and use of non-smoked or vaped products should be considered. In addition, the following considerations should be made: 1. Products sold and consumed: Only the sale of non-smoked or non-vaped cannabis products from federally licensed producers should be permitted, such as edible or beverage products. Such products should be sold only in their original packaging and not removed from their packaging by anyone other than the consumer. This will ensure consumers knowthe levels of THC and CBD that they are consuming, as well as other ingredients, and protect against overconsumption. In this regard, preparation of these products onsite should not be permitted, and patrons should be prohibited from bringing in and/or consuming their own cannabis which was purchased or obtained elsewhere. This will reduce the risk of over- intoxication and harms, as well as reduce the liability risk to the establishment. 2. Establishment operators: Only locations with an approved Cannabis Retail Store Authorization should be permitted to operate as a cannabis consumption lounge or caf?. All regulations under the current Ontario Cannabis Licence Act, 2018, should be applied to the operations of a cannabis consumption lounge or caf? in terms of operation and training requirements, permitted cannabis products, purchase and possession limits, display and promotion, and security measures. 3. Prohibition of alcohol: Licenses for a cannabis lounge or caf? should be prohibited within an establishment which also has a liquor license or serves any form of alcohol. 4. Staff training: An additional cannabis service training program should be developed and required for all operators and employees of consumption establishments to complete prior to the operation start date. Such a program should be similar to the ?Smart Serve? training program for alcohol service and include safety protocols, and limits on service of cannabis to patrons to protect them from overconsumption/over- intoxication and harm. Staff would also need to be educated on a process to determine whether patrons are fit to leave the establishment and operate a motor vehicle. Ultimately there may be liability for business owners should an intoxicated or impaired individual leave their establishment and cause a motor vehicle collision. 5. Age restrictions: The establishment should be age restricted to allow only those 19 years of age and older to enter the premises, to purchase or consume products, and to sell products, in line with current restrictions on cannabis retail sale regulations. 6. Promotion prohibitions: Provisions would need to be made to require that there is no public promotion visible outside of the establishment, as currently stated in the Ontario Cannabis License Act, 2018. It should also be explicitly noted in regulations related to these establishments that they are not to entice entry into the establishment by way of promoting them as an entertainment venue. The promotion of their use as an event space or entertainment venue movie or trivia nights, live music performances, gaming competitions, etc.) would entice patrons to use the establishment who may othenivise prefer not to be exposed to cannabis consumption. 7. Protection from second-hand smoke: In keeping with the SFOA, 2017, any smoking/vaping of products should be prohibited in the establishment and prohibited within 9 metres of any patios or outside area operating in conjunction with the food or beverage sale. 8. Municipal Controls: Municipalities should be empowered to enact local zoning and icencing regulations to have an influence over where these stores are located away from sensitive land uses like schools, parks, day cares, addictions treatment centres, or other cannabis retailers). lf cannabis consumption establishments were considered in Ontario, the sale of food/beverage products that do not contain cannabis should be limited to pre-packaged items. Keeping in line with our recommendation in Question cannabis products should also be pre-packaged and sold in their original packaging. In addition, the sale of alcoholic beverages, high-caffeine beverages coffee, tea or energy drinks), and products which contain nicotine should be strictly prohibited in these establishments. This will prevent harmful co-use of substances which may lead to higher levels of impairment and increased levels of harm. Under subsection 24(1) of the federal Cannabis Act, it is prohibited for a person that sells cannabis or a cannabis accessory to provide or offer to provide any service if it is provided or offered to be provided as an inducement for the purchase of cannabis or a cannabis accessory. Disallowing non-cannabis items to be sold would be in line with the prohibitions for promotion set out at the federal level. It would also align with current Ontario cannabis retail regulations which specify that licensed cannabis retailers may only sell products and accessories which are directly related to cannabis. Similar restrictions exist within the Smoke-Free Ontario Act, 2017 (SFOA 2017), whereby specialty stores Tobacconists and Specialty Vape Stores) are permitted to sell a ratio of specialty products relative to those which are reasonably associated with those products. These regulations are considered to be effective as they do not promote entry into the establishment for anyone not interested in purchasing the specialty product or associated product. Only accessories that relate to cannabis should be permitted for sale to reduce cross-marketing inducements for cannabis, which may be created by allowing the sale of non-cannabis related items. A similar ratio to that described above in the SFOA 2017 may be effective in ensuring appropriate products are available for sale in these establishments. The consumption of cannabis edibles in a public setting poses a risk of unintentional or unpredictable effects due to individual levels of tolerance, and the delayed onset of intoxicating or effects. Compared to inhaled forms of cannabis, edible cannabis products may take up to 2 hours for an individual to start feeling the effects, with a peak effect onset time of up to 4 hours. The effects of edibles may also last from 6-12 hours. The unpredictability and delay of effects poses safety risks not only for the consumer, but also liability risks for the municipality and the permit holder for any incident that occurs once the patron leaves the event motor vehicle collision, illness caused by over intoxication such as vomiting, fainting, severe anxiety or panic attack, loss of reality or paranoia). In addition, the sale and consumption at such events would pose unique risks as they are not likely to have the capacity to provide the necessary levels of security currently required of retail stores, including age verification measures, and ensuring that an individual does not exceed possession limits from buying and using products from multiple vendors over a short time penod. Hastings Prince Edward Public Health strongly recommends that SOPs for smoked or vaped cannabis not be considered. The current regulations under SFOA, 2017 have made great progress to reduce exposure to second-hand smoke, denormalize smoking behaviour, and create healthier environments for all. The SFOA, 2017 prohibits the smoking of tobacco, cannabis and e-cigarettes in playgrounds, recreation and sports centres, and within 20 metres of those properties. Many fairs and festivals have large sections of property that are considered a patio with the sale and consumption of food and beverages. Should the government consider establishing a SOP program for the sale and consumption of non-smoked/vaped cannabis, the following should be considered: 1. Products sold or consumed: Only the sale of non-smoked/non-vaped cannabis products from federally licensed producers should be permitted, such as edible or beverage products. Such products should be sold only in their original packaging and not removed from their packaging by anyone other than the consumer. This will ensure consumers knowthe levels of THC and CBD that they are consuming, as well as other ingredients, and protect against overconsumption. As multiple vendors may be present, limits should be put into place to restrict the amount of cannabis an individual can purchase while in attendance and a system would be required to ensure consumption limits are adhered to across multiple vendors. 2. Vendors: Only retailers with an approved Cannabis Retail Store Authorization should be permitted to set up as a vendor at a fair or festival. They would need to have proper protocols for age verification and reasonable levels of security for the storage of products products would not be able to be out in the open but would need to be stored securely and not accessible to the public). 3. Prohibition of alcohol: The sale and/or consumption of alcohol should be prohibited at the event or festival under the SOP to reduce co-use and increased risk of overconsumption, over-intoxication, and associated harms. 4. Staff training: An additional cannabis service training program should be developed and required for all operators and employees selling cannabis products for immediate consumption to complete prior to the event date. Such a program should be similar to the ?Smart Serve? training program for alcohol service and include safety protocols, and limits on service of cannabis to patrons to protect them from overconsumption/over- intoxication and harm. 5. Age restrictions: All grounds and spaces related to the SOP event should be age restricted to only those 19 years of age and older. This includes individuals permitted to purchase and/or consume any cannabis product or accessory, any person involved in handling or selling a cannabis product, as well as any person involved in the operations of the festival (including volunteers or event staff). 6. Promotion prohibitions: Provisions would need to be made to require that there is no public promotion visible outside of the SOP area which would be visible to youth under 19 years of age. To protect youth exposure in particular, the conditions of the SOP should specify adherence to the Federal Cannabis Act, section 17, which states that the promotion of cannabis, a cannabis accessory or a service related to cannabis are prohibited where the promotion may be audible or visible from outside a place where young persons are not permitted by law. While it would be difficult to fully obscure viewing of the activities which take place inside the grounds of a special event, efforts should be required to limit exposure for non-patrons. 7. Sponsorship prohibitions: The sponsorship of any event by a cannabis retailer or licensed producer should remain prohibited to align with the Federal Cannabis Act. Section 21 of the Act states that it is prohibited to display, refer to or otherwise use any of the following, directly or indirectly in a promotion that is used in the sponsorship of a person, entity, event, activity or facility: a brand element of cannabis, of a cannabis accessory or of a service related to cannabis; and the name of a person that produces, sells or distributes cannabis, sells or distributes a cannabis accessory, or provides a service related to cannabis. Cannabis Consumption Establishments: HPEPH feels strongly that changes to the SFOA should not be considered, now or in the future, to permit the sale of smoked/vaped forms of cannabis for consumption in establishments like lounges and cafes. Prohibiting the smoking of cannabis and e-cigarettes in enclosed workplaces and enclosed public places has been well adopted and continues to be accepted by Ontarians as an effective way to prevent exposure to the harmful effects of second-hand smoke and to de-normalize smoking behaviour in general. In any situation where cannabis edibles are being consumed in public, there is the risk of unintentional or unpredictable effects due to individual levels of tolerance, and the delayed onset of effects. Should the sale and consumption of non-smoked/vaped cannabis products be considered, consumers will need to be first educated about the potential effects of use, the risks of overconsumption, and the risks of over-intoxication from the co-use of alcohol. Given the risk of overconsumption and unpredictable effects of cannabis edibles, staff who work in any capacity involving selling cannabis for consumption would need to be specially trained on how to handle a situation of a consumer being over-intoxicated and having a bad reaction which requires medical attention (for example, panic attacks, fainting, and uncontrollable vomiting). SOPs: (insert comments if necessary the box will expand as you type) Cannabis Consumption Establishments Regarding cannabis consumption establishments, municipalities should be granted the authority to establish licensing and zoning criteria to ensure the locations are appropriate and meet the needs of the community. HPEPH also endorses buffer distances between cannabis retail stores and sensitive land uses such as parks, playgrounds, recreation centres, day cares and addictions treatment facilities and similar consideration should be made for special occasion permits and consumption lounges if permitted. SOPs: Municipalities should be granted the authority to enact by-laws that permit or prohibit the sale and/or consumption of cannabis on municipal property. Applications for SOPs should be required to abide by any municipal requests to ensure compliance with city by-laws and conditions of use of municipal property. Municipalities should be informed of any applications in the same fashion as alcohol SOPs where at least 30 or 60 days notice must be provided by the permit holder to the local municipality, police, and fire and health departments notifying them of the event. The building department must be notified as well if a tent, marquee, pavilion or tiered seating is used. (insert comments if necessary the box will expand as you type) To: Ontario Legalization of Cannabis Secretariat Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Oocasion Permits Date: March 10, 2020 5:05:39 PM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government . would like your feedback on the potential implementation of . . additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Janet Jackson Huron Perth Public Health 10 Downie St. 2nd Floor Stratford Ontario N5A 7K4 Tel: 1-888-221-2133 Email: iiackson@hDDh.ca Huron Perth Public Health is concerned about the potential sale and consumption of cannabis via cannabis consumption establishments and cannabis special occasion permits (SOPs). The Smoke- Free Ontario Act (SFOA), 2017 protects everyone from exposure to second hand smoke and aerosol from vaping. This protection must remain. Loosening the SFOA and accompanying regulations to permit smoking/vaping withinE cannabis consumption establishments will expose Ontarians to known health hazards. If a municipality has enacted a smoking/vaping by-law that is more restrictive, the more restrictive should prevail. Cannabis consumption establishments also have the potential to facilitate many potential risks beyond second-hand exposure, these include the normalization of substance use, contribution to substance dependency, and increased incidents of cannabis impaired driving. Should cannabis consumption establishments be considered, the following restrictions would further contribute to the mitigation of any potentially negative outcomes: - Restrict density through minimum distance requirements between cannabis consumption establishments and limits on overall density, - Protect youth from the role- modelling of substance use through minimum distanceE requirements from youth- serving facilities such as schools, recreation centres, and childcare centres, E- Reduce overall consumption and negative outcomes by limiting late night and early morning hours, - Discourage co-use by prohibiting the sale of alcohol or nicotine products, E- Limit youth access and substance-use role-modelling by limiting entry to those 19 years and older. Restricting access to cannabis and limiting substance use role-modelling is pivotal in preventing youth cannabis use and subsequent dependency. Consequently, SOPs should be restricted to those 19 years and older to protect youth. Co-use of substances, particularly alcohol and cannabis, magnifies the negative effects of those substances. If issued, cannabis should prohibit the sale of additional substances, especially alcohol. Cannabis should respect all stipulations under the SFOA, as well as applicable municipal by-laws. We hope that you will take these recommendations into careful consideration, and look forward to providing further input during this process. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis?ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Daphne Mayer Manager, Public Health Programs and Services Kingston, Frontenac, Lennox and Addington Public Health 221 Portsmouth Ave Kingston, Ontario K7M 1V5 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Although changes to the Smoke-Free Ontario Act, 2017 are not being considered as part of this consultation, Kingston, Frontenac and Lennox Addington Public Health would like to underscore the importance of maintaining the smoke- and vapour-free spaces legislation, as it is vital to the protection of Ontarians from the harmful effects of second-hand smoke and vapour exposure. Unequivocally, indoor public spaces and workplaces and other designated spaces must remain smoke- and vapour-free. Public Health strongly encourages the Government of Ontario to consider the potential health impacts on communities resulting from expanded cannabis access. Given that cannabis has only been permitted for sale and consumption in Canada since October 17, 2018 and edibles since October 17, 2019, the Government of Ontario should proceed cautiously when examining increased cannabis access in order to minimize the potential health and social impacts on communities. Public Health has the following concerns related to increased cannabis access through consumption establishments: 0 The looseninq of cannabis control policies in the absence of a robust health equity impact assessment. The physical accessibility of a legalized substance, such as tobacco, alcohol 3 and cannabis, is a determinant ofthe substance's use, and may impact an individual's dependence on the substance.? 2 For example, geographic access to cannabis dispensaries influence the purchase of edibles, with consumers being more likely to purchase edibles when in proximity to a greater number of dispensaries.3 While the link between cannabis consumption establishments and consumption patterns is not well understood, there is evidence related to access to licenced alcohol establishments and increased population level alcohol. 2These lessons should compel the Government of Ontario to use a precautionary approach in their decision making. Further still, the potential proximity of cannabis consumption establishments to sensitive use spaces, such as schools, parks, and libraries is concerning because of the potential for increased normalization of substance use among vulnerable populations such as youth.4 0 The delayed and prolonged intoxicatinq effects of edible cannabis. The delayed and sustained effects of edible cannabis products 5 will present challenges for the identification of impairment by cannabis consumption establishments service staff or service agent. These challenges can have direct impact on responsible cannabis service, over- consumption and liability. 0 Product safety and quality. If in-house production of edible products is being considered for cannabis consumption establishments there are associated risks for the consumer related to serving sizes, potency, product safety and quality assurance, and as such should be prohibited. Pre-packaged and single serving products may mitigate this risk. 0 Accidental consumption of cannabis products. Warning labels and product information are critical to safer edible cannabis use. Unconsumed product removed from packaging and taken off premise creates an opportunity for accidental consumption. 0 Burden of cannabis use on communities. At this time, there has not been sufficient monitoring and surveillance of the health and social impacts of cannabis legalization to support the expansion of cannabis access in Ontario. In the absence of this information, the Government of Ontario must heed the lessons learned from the loosening of regulations related to alcohol, tobacco and vaping and the burden it places on communities. 1. DeVillaer M. Cannabis law reform in Canada: pretense 8 perils. [document on the Internet] Hamilton, ON: McMaster University, The Peter Boris Centre for Addictions Research, 2017. [cited 2020 Feb 28] Available from 2. Berg. Carla, Henrikesen, Lisa, cavazos-Rehg, Patricia, Haardoefer, regina, Freisthler, Bridget. The emerging marijuana retail environment: key lessons learned from tobacco and alcohol retail research. Addictive Behaviours. Feb 2018. [cited 2020 Feb 28]; 81: 28?31 . Available from: 3. Kepple, NJ and Freisthler, B. Place over traits? Purchasing edibles from medical marijuana dispensaries in Los Angeles, CA. addictive Behaviors. April 2017. [cited 202 Feb 28]; 73:1-3. Available from 4. Alcohol policy review: opportunities for Ontario municipalities. [Internet] Developed for Wellington-Dufferin Guelph Health Unit, Durham Region Health Department and Thunder Bay District; 2018. Available from 5. Edible Cannabis, Cannabis extracts and cannabis topicals: A Primer on the New Cannabis Products. [document on internet]. Canadian Centre on Substance Use and Addiction. [cited 2020 Feb 28]. Available from Should the Government of OntarIo Increase cannabIs access through cannabIs consumption establishments, the co-sale of cannabis and alcohol or tobacco must be prohibited. The risk of simultaneous polysubstance greatly increases the negative health impacts on the consumer.1 The simultaneous use of alcohol and cannabis has an additive affect that impacts cognitive and performance and driving performance such that the odds of impaired driving and risks of collisions significantly increases. 1. Ontario Agency for Health Protection and Promotion (Public Health Ontario), Meyer W, Leece P. Evidence brief: Risk factors for simultaneous use of alcohol and cannabis. [document on the Internet]. Toronto, ON: Queen?s Printer for Ontario; 2018. [cited 2020 mar Available from Kingston, Frontenac and Lennox Addington Public Health strongly encourages the Government of Ontario to consider the potential health impacts on communities resulting from a cannabis SOP program. Public Health's concern related to the sale and service of cannabis at special occasions such as cash bars at weddings, charity fundraisers and festivals are the same concerns for cannabis consumption establishments: loosening of cannabis control policies in absence of a robust health equity impact assessment; delayed and prolonged intoxicating effects of edible cannabis; product safety and quality; accidental consumption of cannabis products; and burden of cannabis use on communities. Given that the synergistic and additive effects of substance use is highest when substances are consumed, alcohol should be prohibited at events under the cannabis special occasion permit program due to the increased risk of intoxication and harms.1 It is Public Health's position that it is premature for the Government of Ontario to expand cannabis access in the absence of sufficient evidence about the health and social impacts of the current regulatory regime. 1. Ontario Agency for Health Protection and Promotion (Public Health Ontario), Meyer W, Leece P. Evidence brief: Risk factors for simultaneous use of alcohol and cannabis. [document on the Internet]. Toronto, ON: Queen?s Printer for Ontario; 2018. [cited 2020 mar Available from Of those Canadians who used cannabis in the previous year, 16% reported driving within four hours of ingesting edible cannabis. V\?th a provision for on-site consumption at cannabis establishments or SOP locations there are increased risks associated with impaired driving, particularly due to the delayed and long-lasting effects of edible cannabis.1 1. Edible Cannabis, Cannabis extracts and cannabis topicals: A Primer on the New Cannabis Products. [document on internet]. Canadian Centre on Substance Use and Addiction. [cited 2020 Feb 28]. Available from 1.pdf The Government of Ontario is compelled to take a precautionary approach to expanding cannabis at this time due to the harms associated with cannabis use and insufficient evidence about the current cannabis regulatory regime's impact on communities. Municipalities, Public Health Units, among other stakeholders, must be involved to support the development of an evidence-informed framework that will protect the health and wellbeing of communities. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA, 2017 regime as part of this consu?a?on. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or caf?s, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis?ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Linda Stobo, Program Manager Rhonda Brittan, Program Manager Chronic Disease Prevention Tobacco Control Healthy Communities and Injury Prevention Middlesex-London Health Unit Middlesex-London Health Unit 50 King Street London, ON, N6A 5L7 50 King Street London, ON, N6A 5L7 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Due to multiple public health concerns posed by cannabis lounges and cafes, including but not limited to the high risk for intoxication, the normalization of cannabis use, and the infancy of the cannabis regulatory system, the Middlesex-London Health Unit (MLH U) does n_ot support the sale of cannabis for consumption in these establishments. Providing a space for the consumption of cannabis edibles in a public setting enhances the risk of unpredictable intoxication due to individual levels of tolerance, varying levels of and the delayed onset of intoxicating or effects. Compared to inhaled forms of cannabis, edible cannabis products may take up to 2 hours for an individual to start feeling the effects, with a peak effect onset time of up to 4 hours. The effects of edibles may also persist for 6-12 hours. The unpredictability and delayed onset of effects poses safety risks not only for the 3 consumer, but also liability risks for the establishment operator for any incident that occurs once the patron leaves the establishment motor vehicle collision or illness associated with overconsumption such as vomiting, fainting, severe anxiety or panic attack, loss of reality or paranoia). The cannabis regulatory system in Ontario has only been established since late 2018. Since that time, a significant expansion of cannabis access points, via bricks and mortar stores, is undenNay. Research shows that increased availability of and exposure to the use of substances, such as alcohol and tobacco, results in increased consumption, which can lead to significant health and social harms and costs. As such, a precautionary approach would be prudent until a more fulsome understanding of the impact that Ontario's expansion of private cannabis retail stores will have on consumption behaviours. ln Ontario, there are stringent rules and regulations in place to restrict youth access from entering provincially licensed cannabis retail stores. Within the stores, products cannot be visible or sold to youth, and must be sold from behind the counter. There are also strict rules in place regarding promotion and marketing to youth. These measures were enacted to prevent cannabis from getting into the hands of youth. The expansion of the sale and consumption of cannabis in lounges or caf?s will only increase the risk of youth access to cannabis, which is counter to the government's current approach to a legalized, regulated cannabis market. Moreover, the current regulations under the Smoke-Free Ontario Act, 2017 (SFOA, 2017), have carried fonNard the progress of SFOA, 2006, by prohibiting the smoking and vaping of cannabis in enclosed workplaces and enclosed public places, and outside in many public places, including bar and restaurant patios. This health protective legislation continues to be accepted and expected by Ontarians, given the documented health risks associated with exposure to second-hand smoke and the emerging evidence associated with exposure to the aerosol that vaping products produce. Smoking and vaping restrictions protect employees and patrons from the negative health effects of exposure to second-hand smoke and vapour. Long-term exposure to the toxins and carcinogens found in second-hand smoke can exacerbate existing health conditions and/or lead to chronic illness among those employed within the hospitality industry. Smoking and vaping prohibitions also help to prevent substance use; they promote smoke-free and vapour-free living while supporting those who have recently quit and/or are trying to overcome their addiction. The Middlesex-London Health Unit does not recommend the sale of smoked or vaped forms of cannabis in lounges and cafes because it may increase the likelihood of non-compliance with the SPCA, 2017 by patrons and employees; it would make it more difficult for the proprietor/owner of these establishments to ensure that patrons/employees are not smoking and/or vaping in the restricted areas. Prohibiting the sale and consumption of smoked/vaped cannabis in these types of establishments will also protect the interests of neighbouring businesses, reducing the likelihood of drifting second-hand smoke and vapour. If the retail framework is expanded to include these types of establishments, the following considerations could help mitigate the public health risks and harms: 0 Products sold and consumed: Only the sale of non-smoked or non-vaped cannabis products from federally licensed producers should be permitted. Such products should be sold only in their original packaging and not be removed from their packaging by anyone other than the consumer. This will help to ensure consumers know the levels of THC and CBD that they are consuming, as well as other ingredients, and help protect against overconsumption. In this regard, preparation of these products onsite should not 4 be permitted, and patrons should be prohibited from bringing in and/or consuming their own cannabis which was purchased or obtained elsewhere. Products available for sale should be restricted to those with low levels of THC. These mitigating factors will help to reduce the risk of over-intoxication and harms, as well as reduce the liability risk to the establishment. Establishment operators: Only locations with an approved Cannabis Retail Store Authorization should be permitted to operate as a cannabis consumption lounge or caf?. All regulations under the current Ontario Cannabis Licence Act, 2018, should be applied to the operations of a cannabis consumption lounge or caf? in terms of operation and training requirements, permitted cannabis products, purchase and possession limits, display and promotion, and security measures. Prohibition of alcohol: The licensed operators of cannabis lounges or caf?s should be prohibited from selling alcohol, in any form, at these establishments to reduce co-use and increased risk of overconsumption, over-intoxication, and associated harms. Staff training: An additional evidence-based cannabis service training program should be developed and required for all operators and employees of consumption establishments to complete prior to the operation start date, with an obligation to complete supplementary training on an ongoing basis. Such a program should be similar to the ?Smart Serve? training program for alcohol service and include safety protocols, and limits on service of cannabis to patrons to protect them from overconsumption/over- intoxication and harm. Staff would also need to be educated on a process to determine whether patrons are fit to leave the establishment and operate a motor vehicle. Ultimately there may be liability for business owners should an intoxicated or impaired individual leave their establishment and cause a motor vehicle collision. Age restrictions: The establishment should be age restricted to allow only those 19 years of age and older to enter the premises, to purchase or consume products, and to sell products, in line with current restrictions on cannabis retail sale regulations. It should be an expectation that all patrons are asked for government-issued identification regardless of apparent age. Promotion prohibitions: Provisions would need to be made to require that there is no public promotion visible outside of the establishment, as currently stated in the Ontario Cannabis License Act, 2018. It should also be explicitly noted in regulations related to these establishments that they are not to entice entry into the establishment by way of promoting them as an entertainment venue. The promotion of their use as an event space or entertainment venue movie or trivia nights, live music performances, etc.) would entice patrons to use the establishment who may othenivise prefer not to be exposed to cannabis consumption. In addition, promotion of their use as a space for the consumption of medical cannabis, or as a heath and wellness treatment venue should be prohibited. Sponsorship prohibitions: Sponsorship of any lounge or caf? use of celebrity endorsements or branded promotional exhibits and displays) or the sponsorship of events within the lounge or caf? should remain prohibited. A cannabis retailer or licensed producer operating a cannabis lounge or caf? should be required to follow the promotion and advertising restrictions outlined in Section 21 of the federal Cannabis Act. 0 Protection from second-hand smoke and vapour: Any smoking/vaping of products should be prohibited in the establishment and on the patio, and within 9 metres of any patio or outside area operating in conjunction with a place where food and/or drink is served, sold or offered for consumption. 0 Municipal Controls: Municipalities should be empowered to enact zoning and licencing regulations to have an influence over where these establishments are located within their own communities for controls pertaining to retail density, proximity to other social service agencies schools and youth centres) and clustering within sensitive neighbourhoods. 0 Education and Enforcement: As the retail sale and consumption of cannabis products expands, an investment in public health education and enforcement will be needed. lf cannabis consumption establishments were considered in Ontario, the sale of food/beverage products that do not contain cannabis should n_ot be permitted in order to reduce the cross- promotional inducement to purchase cannabis products. This is consistent with subsection 24(1) of the federal Cannabis Act, and Subsection 18 of Ontario Regulation 468/18 under the Cannabis Licence Act, 2018. This same approach was followed by the Ontario Government for the retail sale of vapour products. Under the SFOA, 2017, specialty vape stores are limited to only selling vapour products and products that are reasonably associated with vaping. These regulations are considered to be effective as they do not promote entry into the establishment for anyone not interested in purchasing a specialty vapour product. Should the sale of food/beverage products that do not contain cannabis be considered in potential consumption establishments, only pre-packaged items for both cannabis and non- cannabis products should be permitted, and both sold in their original packaging. The preparation of non-cannabis beverage and food items should be prohibited to reduce the risk of cross-contamination with products containing cannabis. In addition, the sale of alcoholic beverages, high-caffeine beverages coffee, tea or energy drinks), and products which contain nicotine should be strictly prohibited in these establishments. This will prevent harmful co-use of substances which may lead to higher levels of impairment, addiction, and increased levels of harm. This is in alignment with the prohibited substances named within subsection 34(1) of the federal Cannabis Act, whereby it is prohibited to sell any mixture of substances that contains cannabis and any substance that is referred to in column 1 of Schedule 5. In terms of accessories, only those that relate to non-smoked and non-vaped cannabis should be permitted for sale to reduce cross-marketing inducements for cannabis use. The Middlesex-London Health Unit is n_ot in support of a similar SOP program as alcohol for the sale and consumption of cannabis at special occasions or largescale public events such as festivals. Permitting the sale and consumption at such events may cause risks to public health and safety including increased use, increased risk of public intoxication, increased risk of over intoxication resulting in emergency visits, and the normalization of cannabis use. As a result, there could be an impact on our local emergency services police, EMS and hospital services). The sale and consumption of cannabis at such events would pose unique risks as they are not likely to have the capacity to provide the necessary levels of security currently required of cannabis retail stores, including age verification measures, and ensuring that an individual does not exceed possession limits from buying and using products from multiple vendors over a short time period. Moreover, providing a space for the consumption of cannabis edibles in a public setting enhances the risk of unpredictable intoxication due to individual levels of tolerance, varying levels of and the delayed onset of intoxicating or effects. Compared to inhaled forms of cannabis, edible cannabis products may take up to 2 hours for an individual to start feeling the effects, with a peak effect onset time of up to 4 hours. The effects of edibles may also persist for 6-12 hours. The unpredictability and delayed onset of effects poses safety risks not only for the consumer, but also liability risks for the SOP operator and the cannabis retailer for any incident that occurs once the patron leaves the event motor vehicle collision or illness associated with overconsumption such as vomiting, fainting, severe anxiety or panic attack, loss of reality or paranoia). Under the SFOA, 2017, the smoking and vaping of cannabis in enclosed workplaces and enclosed public places, and outside in many public spaces, including bar and restaurant patios (including outdoor special events and festivals) is prohibited. Smoking and vaping restrictions protect employees, volunteers, contracted agents and patrons from the negative health effects of exposure to second-hand smoke and vapour. Smoking and vaping prohibitions also help to prevent substance use; they promote smoke-free and vapour-free living while supporting those who have recently quit and/or are trying to overcome their addiction. While the federal Cannabis Act, 2018 includes measures to limit the promotion of cannabis to youth, consideration should be given to the promotion of cannabis to non-cannabis users of all ages. Every effort should be made to visually and physically separate cannabis and cannabis promotions from the intended special event to reduce enticing those attending events from consuming cannabis who would not have otherwise. Restrictions on substance use at special events encourages a focus on the event itself concerts, food festivals, etc.), and not the promotion of substances and substance use. If the retail framework is expanded to include the retail sale and consumption at special events and festivals, please refer to the public health mitigation measures outlined in question 1. Lack of Enforcement Capacity The investment that has been made to the enforcement of cannabis retail, cannabis use and cannabis promotion regulations at the provincial and federal levels has not kept pace with the expanding retail market. Enabling the sale and consumption of cannabis in caf?s, lounges and through SOPs would only further stretch enforcement capacity, increasing the potential for cannabis use and harms. Cannabis Lounges and Caf?s Municipalities should be empowered to enact zoning and licencing regulations to have an influence over where these establishments are located within their own communities for controls pertaining to retail density, proximity to other social service agencies schools and youth centres) and clustering within sensitive neighbourhoods. Special Occasion Permits Municipalities should be granted the authority to enact by-laws and policies that permit or prohibit the sale and/or consumption of cannabis on municipal property. Applications for SOPs should be required to abide by any municipal requirements to ensure compliance with city by- laws and conditions of use of municipal property. Municipalities should be informed of any applications in the same fashion as alcohol SOPs where at least 30- or 60-days notice must be provided by the permit holder to the local municipality, police, and fire and health departments notifying them of the event. The building department must be notified as well if a tent, marquee, pavilion or tiered seating is used. If the government chooses to expand the retail availability of cannabis as proposed above, operators of these establishments and SOPs should be required, by law, to post government- approved health information including warnings on the risks of cannabis consumption, low-risk cannabis use guidelines, and information specific to the products being sold to reduce the potential for health harms. In Ontario, the regulations for cannabis use more closely align with the regulations that govern tobacco and vapour product use, rather than alcohol consumption. Individuals are legally permitted to possess 30 grams of dried cannabis (or equivalent) and are legally permitted to consume cannabis in many public spaces; therefore, permitting the consumption of cannabis in caf?s, lounges and through SOPs is not required in Ontario. The infancy of the cannabis regulatory system, combined with the fact that the retail sale of cannabis is rapidly expanding across Ontario, warrants the need for further monitoring and assessment of public health and societal impact prior to enacting further legislative changes. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Chris Bowes, Program Manager Healthy Living Program North Bay Parry Sound District Health Unit 345 Oak Street West, North Bay ON, P1 2T2 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEXCEC The government should n_ot consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes. The legal regulatory system is still in its early stages, and the unintended consequences of cannabis legalization have not been fully monitored and researched. The does not recommend moving forward with cannabis consumption establishments until more information is known about the health and social implications of this decision. As evidenced with alcohol control, increasing the public?s access to substances has been shown to increase consumption and, in turn, increase health and social harms (Locally Driven Collaborative Project, 2014). The sale of cannabis for consumption in establishments has critical implications for public health and safety. Consumption of cannabis edibles enhances the risk of unpredictable intoxication and overconsumption due to the delayed and long-lasting effects (Ministry of Health and Long-Term Care, 2019). Compared to inhaled forms of cannabis, cannabis edibles may take up to 2 hours for an individual to start feeling the effects, with a peak effect onset time of up to 4 hours. The effects of cannabis edibles may last up to 12 hours or longer (Canadian Centre on Substance Use and Addiction, 2019). This results in challenges for establishments in ensuring the responsible sale of cannabis products to prevent cannabis intoxication. The unpredictability and delayed onset of effects poses safety risks not only for the consumer, but also liability risks for the establishment for any incident that occurs once the patron leaves the establishment. Cannabis use impairs the abilities necessary to operate a motor vehicle, including reaction time, concentration, divided attention and visual function. Research reveals that, after alcohol, cannabis is among the most detected substances among drivers arrested for impaired driving, and it doubles the risk of crash involvement (Canadian Centre on Substance Use and Addiction, 2019). Allowing the sale of cannabis for consumption in establishments has the potential to increase impaired driving and cannabis-related motor vehicle crashes. Cannabis consumption establishments should not be considered in Ontario. However, if Ontario does move fonNard with cannabis consumption establishments, the government must consider the risks noted above and establish mitigation strategies to prevent health and social harms. Mitigation strategies should include: a) Permitting only the sale of non-smoked or non-vaped cannabis products in their original packaging from federally licensed producers. In this regard, preparation ofthese products onsite should not be permitted, and patrons should be prohibited from bringing in and or consuming their own cannabis which was purchased or obtained elsewhere. b) Permitting only locations with an approved Cannabis Retail Store Authorization to operate a cannabis consumption establishment. All regulations under the current Ontario Cannabis License Act, 2018, should be applied in terms of operation and training requirements, permitted cannabis products, purchase and possession limits, display and promotion, and security measures (Alcohol and Gaming Commission of Ontario, 2020). c) Allowing only individuals 19 years and older to enter the establishment to prevent underage cannabis use and the normalization of cannabis use amongst minors. d) Requiring an additional cannabis service training program for all operators and employees selling cannabis for immediate consumption. This will inform staff of potential liabilities and their responsibilities with respect to patrons who are intoxicated from cannabis. e) Restricting establishments from selling large quantities of cannabis in a single transaction and setting moderate restrictions on THC content to reduce the risk of overconsumption (Alberta Health Services, 2018). To aIIgn With the federal Cannabis Act and the current OntarIo cannabIs retaII regulations, it is recommended to only sell products and accessories which are directly 4 related to cannabis. These regulations are effective as they do not promote entry into the establishment for anyone not interested in purchasing cannabis and cannabis- related products. The sale ofalcoholic beverages, high-caffeine beverages coffee, tea or energy drinks) and products which contain nicotine should be strictly prohibited in these establishments. This will prevent harmful co-use of substances which may lead to higher levels of impairment and increased levels of harm (Ontario Agency for Health Protection and Promotion, 2020; Government of Canada, 2020). The government should n_ot consIder establishing a SOP program for cannabIs to be sold and consumed at festivals and events. The sale and consumption of cannabis in spaces such as festivals and events have critical implications for public health and safety, including the increase of use and harms from cannabis, increased risk of public intoxication and impaired driving, and the normalization ofthe use of cannabis. lf Ontario moves fonNard with the cannabis SOP program, there are several mitigation strategies that should be considered. Mitigation strategies should include: a) Permitting only the sale of non-smoked or non-vaped cannabis products in their original packaging from federally licensed producers. In this regard, preparation ofthese products onsite should not be permitted, and patrons should be prohibited from bringing in and or consuming their own cannabis which was purchased or obtained elsewhere. b) Limiting the number of vendors present at the event who can sell cannabis products. Limits should also be put in place to restrict the amount of cannabis an individual can purchase while in attendance and a system should be implemented to ensure consumption limits are adhered to across multiple vendors. c) Permitting only retailers with an approved Cannabis Retail Store Authorization to set up as a vendor at an event. These retailers would need to have proper 5 protocols for age verification and reasonable levels of security for the storage of products. d) Restricting alcohol consumption and cannabis consumption at the same event. Individuals who co-use alcohol and cannabis tend to drink more alcohol, with consequences related to increased intoxication and risk of alcohol poisoning (Ontario Agency for Health Protection and Promotion, 2018). e) Requiring an additional cannabis service training program for all operators and employees selling cannabis for immediate consumption. This will inform staff of potential liabilities and their responsibilities with respect to patrons who are intoxicated from cannabis. f) Restricting all grounds and spaces related to the SOP event to those 19 years and older to prevent underage cannabis use and the normalization of cannabis use amongst minors. g) Prohibiting the promotion of cannabis, a cannabis accessory or a service related to cannabis. Furthermore, the sponsorship ofany event by a cannabis retailer or licensed producer should remain prohibited to align with the Federal Cannabis Act. 50 PS The sale and consumption of cannabis at festivals and events would pose unique risks as events are not likely to have the capacity to provide the necessary levels of security currently required ofthe cannabis retail stores, including age veri?cation measures, and ensuring that an individual does not exceed possession limits from buying and using products from multiple vendors over a short time period. There are also additional liabilities to consider for municipalities, including public disturbances and nuisances, property damage, injuries and enforcement costs. Municipalities should be involved in a potential framework for cannabis consumption establishments and SOPs. The AGCO currently has sole responsibility for regulating Ontario?s cannabis retail stores and overseeing the administration of the SOP program. In recognition current responsibilities and capacity, and the importance of municipalities overseeing decisions that affect their communities, it is recommended that municipalities have control over density and location restrictions. For cannabis consumption establishments, it is recommended that municipalities can: 0 Prohibit the sale of cannabis for consumption in establishments through an opt- out option. 6 Require an application fee during the submission ofa business license application. 0 Review business license applications and make appropriate decisions based on protecting public interests and minimizing nuisances. 0 Introduce site-speci?c zoning to control locations of establishments. 0 Create policy restrictions that establish limits for the number of establishments by neighbourhood. 0 Investigate public concerns, such as nuisances and property standard violations. This will allow municipalities to monitor impact and make appropriate decisions. For the cannabis SOP program, it is recommended that municipalities can: 0 Introduce policies that outline the safe, appropriate consumption of cannabis on municipally owned or managed properties, like a Municipal Alcohol Policy (Ontario Agency for Health Protection and Promotion, Giesbreht Wettlaufer, 2016). Prohibit public promotion of cannabis use or a brand visible outside ofthe SOP area where youth may be exposed The appreciates the note on the Regulatory Registry that changesto the SFOA 2017 are not being considered as part ofthis consultation, but do not support the loosening ofany of the regulatory restrictions that protect Ontarians from second-hand smoke and vapours in public places in any circumstance. The infancy ofthe cannabis regulatory system, combined with the fact that the retail sale of cannabis is rapidly expanding across Ontario, warrants the need for further monitoring and assessment of impact prior to enacting further legislative changes. It is recommended that the government start with a more conservative standpoint, enabling flexibility allowed for regulations to accurately reflect the evolving, fast-paced nature of the cannabis industry. lfthe government chooses to expand the retail availability of cannabis as proposed above, operators ofthese establishments and SOPs should be required, by law, to post government-approved health information including warnings on the risks of cannabis consumption, low-risk cannabis use guidelines, and information speci?c to the products being sold to reduce the potential for health harms. 7 References Alberta Health Services (2018). Regulation of Cannabis Edibles and Cannabis Cafes: Literature Review and Environmental Scan. Edmonton, AB: Author. Alcohol and Gaming Commission of Ontario (2020). Registrar?s standards for cannabis retail stores. Retrieved from cannabis-retaiI-stores Canadian Centre on Substance Use and Addiction (2019). 7 things you need to know about edible cannabis. Retrieved from about-edibIe-cannabis Canadian Centre on Substance Use and Addiction (2019). Clearing the smoke on cannabis: Cannabis use and driving an update. Retrieved from Government of Canada (2020). Cannabis Regulations. Retrieved from Locally Driven Collaborative Project (LDCP) (2014). Addressing Alcohol and Alcohol- Related Harms at the Local Level: A Resource for Public Health Professionals in Ontario. Ministry of Health and Long-Term Care. Health effects of consuming cannabis edibles. Toronto, ON: Queen?s Printer for Ontario; 2019. Ontario Agency for Health Protection and Promotion (Public Health Ontario), Meyer W, Leece P. Evidence brief: Risk factors for simultaneous use of alcohol and cannabis. Toronto, ON: Queen?s Printer for Ontario; 2018. Ontario Agency for Health Protection and Promotion (Public Health Ontario), Giesbreht N, Wettlaufer A. Municipal Alcohol Policies and Public Health: A Primer. Toronto, ON: Queen?s Printer for Ontario, 2016. 8 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). M. Mustafa Hirji, MD MPH Medical Officer of Health Commissioner (Acting) Niagara Region Public Health Emergency Services About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial Niagara Region Public Health and Emergency Services (NRPH ES) does not support that the Ontario government consider cannabis consumption establishments and strongly encourages that in the future, the government does not change the SFOA (with the intent of allowing exemptions under the SFOA for the smoking and or vaping of cannabis in any public place or work place). Allowing any cannabis consumption in the form of smoking or vaping in public places and workplaces will likely create confusion in the community and initiate complaints due to differences in legal places of use for cannabis compared to tobacco. In addition, as we will note throughout this response, increases in and normalization of substance use, especially smoking, will ultimately contribute to worsening hallway health care, which this government is working so diligently to decrease. In Ontario, outdoor public consumption of cannabis is legal as long as an individual is not smoking or vaping in a prohibited area covered under the SFOA. Individuals can smoke or vape cannabis in locations such as their private residences, certain outdoor public places, and designated smoking guest rooms in hotels. In the US, states such as California and Colorado permit consumption venues. However, in both Colorado and California, it is illegal 3 to use cannabis in public spaces regardless of whether smoked, eaten or vaped.1= 2 Consumption venues in Colorado and California provide spaces for tourists and those living in multi-unit dwellings to use cannabis legally. Since public consumption laws are not as restrictive in Ontario compared to some other jurisdictions such as Colorado and California, providing individuals an indoor location to use cannabis is not necessary. Under the SFOA, smoking or vaping any substance is prohibited in enclosed public places, on patios and within 9m of patios to protect Ontarians from the harmful effects of second- hand smoke in public places. lf consumption establishments were permitted and no changes were made underthe SFOA to allow smoking or vaping, cannabis lounges and cafes would be limited to serving only edible cannabis products. While edibles would protect users, other patrons and staff from second-hand smoke, edible cannabis products pose unique challenges due to the length of time it can take the user to feel the full effects (see question 4). It is also important to note that the regulatory system is still new and that the sale of cannabis edibles, extracts and topicals began in January 2020. The Ontario government also recently changed the regulations of storefronts, allowing more access to operating a storefront. With these continuous changes, it is important to caution and monitor for unintended consequences prior to considering the possibility of allowing consumption establishments. 1 State of Colorado. (2019). Laws about marijuana use. Accessed February 28, 2020. URL: 2 California Department of Public Health. (2017). What?s Legal for Adult Use? Accessed February 28, 2019. URL: lf cannabis consumption establishments were considered in Ontario, the sale of alcohol should be prohibited. Consuming alcohol and cannabis together causes an increase in THC in the bloodstream (compared to cannabis only) which can enhance such as nausea, dizziness and vomiting and increase impairment.1=2 Those who co-use alcohol and cannabis often drink more alcohol, increasing intoxication and risk of alcohol B??kmark Establishments should be required to sell non-cannabis containing food and beverages to provide alternatives for patrons. It is also recommended to prohibit any products that are currently banned from being added to cannabis edibles under the Cannabis regulations. This includes beverages/products that contain caffeine, alcohol, tobacco products, vitamins or minerals. 1Wellington-Dufferin-Guelph Public Health. (2019). Cannabis Facts: Using cannabis with alcohol and tobacco: A risky combination. Accessed: February 21. 2020- 1 Ontario Agency for Health Protection and Promotion (Public Health Ontario), Meyer W, Leece, P. Evidence brief: risk factors for simultaneous use of alcohol and cannabis. Toronto, ON: Queen?s Printer for Ontario; 2018. URL: 1 Government of Canada. Cannabis and your health: Get the Facts: Accessed: October 17, 2019. URL: The Ontario government should not consider establishing a special occasion permit (SOP) program for cannabis consumption at festivals and events. Smoking and vaping is prohibited under Niagara's Smoke and Vape-Free Outdoor Spaces By-law in many outdoor locations where festivals and events take place such as in parks, beaches, sports fields, arenas and recreation centre properties. Provincial legislation and local by-laws would restrict vaping or smoking cannabis in most of the locations in Niagara that festival and event organizers would be seeking. The SFOA would also restrict smoking or vaping in any possible indoor locations for events under a SOP. If the government were to establish a SOP program for cannabis to be sold and consumed at festivals and events, the SOP should - Specify the times permitted for cannabis service - Only retailers with an approved Cannabis Retail Store Authorization should be permitted to set up as vendors at a fair or festival - Prohibit the sale of alcohol at the event - Establish (minimum) cannabis pricing requirements - Establish maximum THC content - Require that food be made available (no cannabis-only events) - Restrict events to those 19 years of age and older, or at the very least require that designated cannabis service and consumption areas be physically separated by non- designated areas - Prohibit promotions in locations visible outside of the SOP area, which would be visible to youth - Limit consumption to edibles in light of the restrictions currently in place on smoking and vaping cannabis in enclosed public places and many outdoor locations - lf smoking or vaping were permitted, any smoking or vaping activity should be prohibited unless in a designated smoking area, but should be restricted to areas outside those prohibited in the SFOA or a municipal by-law Cannabis Consumption Establishments: There are significant risks associated with cannabis consumption establishments or SOPs that should be taken into consideration including safety concerns and increased normalization of cannabis use. By normalizing cannabis, it could further gain social acceptance and the potential harms could be disregarded, especially among youth who are at greatest risk. The effects of consuming edible cannabis are typically felt within 30 minutes to 2 hours, but can take up to 4 hours to feel the full effects (Health Canada) with impairment lasting as long as 12 hours. Compared to alcohol, impairment takes a longer length of time when consuming edible cannabis. Consumers of edibles, particularly novice ones, can have trouble predicting what kind of effect will occur and when it will occur, and may consume more edibles to achieve the desired effect, which can result in adverse health outcomes and impaired driving. It would also make it significantly more challenging for those serving cannabis to patrons to recognize the signs of intoxication. As a result, cannabis consumption at these establishments would pose issues of liability to business owners, similar to those faced with alcohol establishments. If approved, it is imperative to have adequate training in place, similar to Smart Serve Ontario for all individuals who sell, serve or handle cannabis at consumption establishments. It is also important to consider developing health promotion strategies to mitigate the negative health and social impacts that cannabis can have on the community. Should the government facilitate the sale of cannabis for consumption in lounge or cafe establishments, the following considerations should be made 0 Consider the risks noted above and establish mitigation, as well as consider impact on local services such as police, paramedics and other emergency services as well as expanded prevention work by public health agencies 0 Only cannabis products from federally licensed producers should be permitted such as products served in their original packaging or, at the very least, THC and CBD content and other ingredients should be listed on menus Establishments should be age restricted to allow only those 19 years of age and older to enter the premises, to purchase or consume products, and to sell products, in line with current restrictions on cannabis retail sale regulations 0 Provisions would need to be made to require that there is no public promotion visible outside of the establishments, as currently stated in the Ontario Cannabis License Act, 2018 SOPs: Similar to cannabis consumption establishments, cannabis poses similar risks to public health and safety due to the complexity of cannabis impairment as well as liability. In order to mitigate some ofthese risks, businesses would need to ensure they have adequate insurance for events based on an assessment of liability. Current alcohol SOPs outline security requirements, which would be just as necessary for events where cannabis use were to be permitted. It is important to consult with municipalities throughout the process of developing a framework to understand their perspectives and challenges they may encounter during this potential policy change. It is recommended that municipalities have the ability to opt out of consumption establishments as per a similar process with the opening of licensed cannabis retail locations and have the ability to deny SOPs requesting events with cannabis consumption on municipal properties. Municipalities should also have the ability to deny cannabis consumption at events held on non-municipal properties through local by-laws or by municipal council resolution. NRPH ES appreciates the opportunity to provide feedback on this important issue and would like to reiterate that there are significant concerns with respect to health, safety and normalization of cannabis use when considering the implementation of cannabis consumption establishments and/or SOPs. Ontario has been a leader in utilizing a comprehensive tobacco control strategy, which includes the pillars of industry, prevention, protection, cessation and enforcement. V\?th this strategy, Ontario has reduced tobacco use significantly. Tobacco use and substance use are still two of the highest contributors to emergency room visits, and illness. It is encouraged that the government consider a similar framework when determining policy implications for cannabis use in order to help end hallway health care. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis?ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Michael Perley Director Ontario Campaign for Action on Tobacco 150 Bloor St. W., Suite 900 Toronto, ON M58 3C1 About You or Your Organization (please check the appropriate box/boxes) El Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial The Ontario Campaign strongly supports the government?s stated intention not to consider any changes to the controls on smoking and vaping of cannabis under the SPCA regime ?as part of this consultation?. That said, however, we strongly recommend that the government explicitly state that it has no plans to change this commitment in the foreseeable future, for the following reasons: 0 Marijuana smoking is associated with cancer, respiratory problems and cardiovascular disease. 1 Tar from cannabis cigarette harms the lungs: smoking it increases the chances of respiratory diseases including lung cancer;2 0 There are at least 33 known carcinogens in marijuana smoke,? Widespread smoking of marijuana in public may risk renormalization of smoking in general,? 0 US researchers have concluded that marijuana smoking may lead non-smokers to cigarette smoking,'3 0 Recent US research found a strong relationship between smoking cigarettes and daily use of cannabis: smokers there were 7 times more likely to use cannabis daily than non- smokers.4 0 ln Ontario, research from 2015 found that 38% of current smokers had used cannabis in the past year compared to 10% of never smokers.5 0 ln the same 2015 survey, 31% of cannabis users reported mixing cannabis with tobacco, and 15% of non-tobacco smoking cannabis users reported mixing tobacco with cannabis.5 For the first time in 2019, the CAMH Ontario Student Drug Use and Health Survey (OSDUHS) asked grades 7- 12 students about their use of cannabis mixed with tobacco. About 5. 2% of students surveyed or about 41, 800 students in grades 7- 12 across Ontars'io reported smoking cannabis mixed with tobacco at least once during the past year. 0 There is strong evidence that cannabis use when young impacts brain development: the brain continues to develop into early adulthood until age 25.2 0 Now that cannabis has been legalized, related policy should always prefer and specifically endorse safer modes of consuming cannabis - such as consumption of edibles and drinkables over smoking,? These results demonstrate the importance of not loosening current restrictions on smoking or vaping of cannabis products, especially in light of the many non-smokers smoking cannabis who mix tobacco in their joints, and risk addiction to tobacco products as a result. Any future loosening of the prohibition of smoking and/or vaping of cannabis indoors may lead to direct health consequences from cannabis use itself, and also to increased nicotine addiction and use of tobacco products, with health consequences and costs of which the government is well aware. The Ontario Campaign again urges the government to publicly commit to no future authorization under any circumstances of smoking or vaping cannabis in any of the settings where use is now prohibited under the SPCA. Finally, this proposal refers to ?the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. Since the government has stated that allowing smoking or vaping of cannabis in these establishments is not part of this consultation, the Ontario Campaign recommends that any further government statements on this matter refer to the sale of ?edible and drinkable forms of cannabis?. No comments The SFOA regime prohibits smoking or vaping of cannabis in a number of prescribed outdoor places g. restaurant and bar patios or within 9m of these patios). lt is not clear whether the government?s SOP proposal would or would not include permission to sell and consume combustible cannabis products at festivals and other large-scale outdoor events open to the public. lf the SOP process in any way permits the use of combustible cannabis at events permitted by SOPs, several problems will arise: Non-cannabis users will be exposed to second-hand cannabis smoke, which is toxic to non-users; The use of combustible cannabis in public places will be further normalized; A significant group of cannabis users at such events will mix their combustible cannabis with tobacco, with resulting negative health and addiction consequences. (Please see references to this issue in our earlier comments) Cannabis Consumption Establishments. No comments SOPs: No comments No comments No other comments or suggestions. 1 Schwariz, Robert. Legalize marijuana without the smoke. Canadian Medical Association Journal 2017 January 2 Ontario Medical Association (2018). Clearing the Air About Recreational Cannabis Use. 3 Weinberger AH, et al. Is Cannabis Use Associated With Increased Risk of Cigarette Smoking Initiation, Persistence, and Relapse? Longitudinal Data From a Representative Sample of US Adults. Journal of Clinical 4 Goodwin R, et aI. Trends in Daily Cannabis Use Among Cigarette Smokers: United States, 2002-2014. American Journalof Public Health. Published online ahead of print November 21, 2017:e1-e6. 5 a omiteanu AR, Hamilton HA, Adlaf EM, Mann RE (2016). CAMH Monitor e-Report: Substance Use, Mental Health and Well-Being Among Ontario Adults, 1977?2015 (CAMH Research Document Series No. 45). Toronto, ON: Centre for Addiction and Mental Health. 5 Boak A, Elton-Marshall T, Mann RE Hamilton HA (2020). Drug use among Ontario students, 1977-2019: Detailed findings from the Ontario Student Drug Use and Health Survey (OSDUHS). Toronto, ON: Centre for Addiction and Mental Health. March 10! 2020 Ministry of the Attorney General Policy Division Legatization oi Cannabis Branch 720 Bay Street, 11?? Floor Toronto, ON NEVA 289 Subject: OMA Submission on Potential for Cannabis Consumption Establishments and/or Specie! Occasion Permits Dear SirIMadam, The OMA is pleased to provide feedback on the potential impiementation of additional cannabis business opportunities for consideration. The OMA submission is written using public hesith and harm reduction approaches. The document primarily focuses on the foiiowing sections outiined by the Ministry of the Attorney General: the sale of cannabis for consumption in establishments; Additional products permitted for sale in cannabis consumption establishments; Administration of cannabis Special Occasion Permits. The OMA has also included some additionai considerations, with a total of 18 recommendations We hope our comments wit! be useful and would be pleased to discuss the issues raised in greater detail. dinoerety. er? . MJ onset. James Wright, CM, MD, MPH, Chief, Economics, Policy 8: Research 150 Bioor St. West, Suite 900. Toronto, Ontario M58 301 t: 416.599.2580 ti: 1.800.268.1915 omecrg i Dedicated to Doctors. Committed to Patients. 1 ??imm Mgd?m? ?ggmm?m Sum?gg?mz ??ag :?g?ni?m as?? ma Mia-may ?gmm?: Pagan-"Em Camm?g um pig-rams gigmb? gamma Gama-335$ ?ggm Maw}: 2532:? can Submission on Potential tor ?annebis Soneutnption anoint Speciai {secession The Ontario Medical Association (OMA) appreciates the opportunity to comment on the potential implementation of additional cannabis business opportunities in the future, including: 1. the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. Cannabis special occasion permits. This submission proposes recommendations to the key issues and questions identified by the provincial government. The recommendations on the potential implementation of additions! cannabis business opportunities are based on public health and harm reduction approaches. Recommendations and key learnings front other stakeholders, including otherjurisdiotions were considered in the writing of this submission. The content of this submission will focus specifically on: facilitating the sale of cannabis for consumption in establishments; additional products permitted for sale in cannabis consumption establishments; administration of cannabis speciai occasion permits and additional considerations. P3931 are March 2020 Despite its popularity, recreational cannabis is associated with a number of negative health risks, especially for those who use it frequently or begin to use it at an early age. These health impacts include addictive consequences, 8 range of respiratory and circulatory diseases and disorders; cognitive effects as well as harrnful effects on the mental health of some individuals. Recreational cannabis is an inherently harmful substance and must be treated as such when it is used legally and recreationally. Recommendation: The health risks caused by recreational cannabis use can best be avoided by abstaining from cannabis use. importance of the Smokewhrea ?ntarto not, East We understand that changes to the Smoke~Free Ontario Act, 2017 (SFOA, 20W) are not being considered as part of this consultation, but would like to take this opportunity to underscore the importance of the public health measures put in place under the SFOA, 2017. The SFOA, 20l7 currently prohibits the smoking and vaping of cannabis anywhere the srnoking of tobacco and the vaping of any substance is prohibited. For ease of enforcement and to reinforce existing public messaging, no amendments be made to these provisions in the SFOA and that vaping continue to be prohibited anywhere smoking is currently prohibited. Ontario has been a leader in its efforts to develop regulatory frameworks that reduce exposure to secondhand smoke and protecting youth from the dangers of smoking and vaping tobacco, nicotine based products as well as recreational cannabis and the OMA would like to ensure that this con?nues. Recommendation: The province should not consider the sale of cannabis for consumption in establishments if it should in any way violate the SFOA, 201?. it}? Wl?lgump?w in Legalizing additional recreational cannabis products enables regulation together with the opportunity to mitigate some of the associated health risks Implementing a strategic regulatory framework that dictates access and the sale of recreational cannabis has been key to the overall success of legalization. Given the negative health impacts? maintaining restrictions on where recreational cannabis can be purchased and used should continue to be implemented. Given that the MAG has noted that changes to the SFOA, 2017 are not being considered as part of this consultation, it is important to note that for the purpose of this portion of the submission recreational cannabis refers only to edible cannabis (including beverages). Again, the province should not consider the sale of cannabis for consumption in establishments if it should in any way violate the SPCA, 2017. page 2 Of 9 SI: 5: Should the province move forward to perrnit lounges or cafes for cannabis consumption, the Alcohol and Gaming Commission of Ontario (AGCO) should be responsible for administering licences for such establishments. Regulations will need to be developed that establish the licensing and regulatory regime for most aspects relating to the sale and service of recreational cannabis in Ontario similar to those established for alcohol under the Liquor Licence Act and the Liquor Control Act. Restrictions on the promotion and display of establishments and products} and the amount of cannabis that can be purchased and used (including samples) will need to be developed and in place before said establishments are permitted to open. Further, OMA would like to ensure owners and operators as well as employees at cannabis consumption establishments are well trained and knowledgeable around the following areas: a! The negative health risks associated with recreational cannabis use; 0 Products sold and how they may impact users (including the difference between edible cannabis and cannabis that is smoked and or vaped); 0 Identification of customers who are already under the influence; and 0- Identification of customers who are under the minimum ago. Should the province enable lounges or cafes for cannabis consumption, the Ontario Cannabis Store (008) should serve as the chief suppler to these establishments. The 008 has an established supply~chain in place to ensure that only cannabis products that are permitted under federal legislation are sold (1). Another advantage of the DOS distribution model is that retail data can be more easily collected and centralised. This would allow for better data collection around types of products in demand, some consumer demographics and density of product use. This information could help to inform future legislation, policy as well as health and social-welfare programs; Recommendation: The government of Ontario should maintain current restrictions on where recreational cannabis can be purchased and used. Recommendation: Should the province move forward and decide to allow lounges or cafes for cannabis consumption, the Alcohol and Gaming Commission of Ontario (AGCO) should be responsible for administering licences for such establishments. Recommendation: Owners and operators as well as employees at cannabis consumption establishments should be well trained and knowledgeable Recommendation: Should the province move fonlvard and decide to allow lounges or cafes for cannabis consumption, the Ontario Cannabis Store (008) should serve as the chief suppler to these establishments. Page 3 of 9 March 2020 Additionai products permitted for sets in cannabis consumption estabiiehrnents Parameters around product ingredients are key elements regulated at the federai levei to mitigate some of the negative health impacts of recreational cannabis use. The federal government has introduced appropriate safeguards to restrict the addition of caffeine, nicotine, alcohol, vitamins and minerals, sugar, colours and sweeteners to the new ciasses of cannabis products. Products that include these elements as the main ingredients shouid not be sold in cannabis consumption establishments as having them sold alongside recreational cannabis would be counterproductive to these restrictions. Further, should cannabis consumption lounges be established for the purpose of consuming edible cannabis there is no need to sell cannabis accessories that wouid support other means of consumption (is. dried cannabis, pre-roiis, seeds, vapes or vape accessories) Recommendation: The sale of alcohol, caffeine, tobacco, nicotine-based vape products should not be permitted in cannabis consumption estabiishrnents. Recommendation: The sale of cannabis accessories (vaporizers, bongo, pipes, rigs, rolling papers, cones, filters, grinders, rolling trays, tools, scales, cleaning and storage accessories and infusers) should not be permitted in cannabis consumption establishments, Recommendation: Ail cannabis products provided to patrons at such establishments should be in the originai, federally regulated packaging to prevent cross-contamination, mixing and! or accidental misplacement of cannabis edibles with other food and beverages. Administration of cannabis Qcoasion Permits Given that recreational cannabis is an inherently harmful substance and that the health risks caused by its use can best be avoided by abstaining, the province shouid not allow Special Occasion Permits (SOPs) for recreational cannabis. Should the province move forward and decide to allow SOPs for events where recreational cannabis can be sold and or consumed, the AGCO should be responsible for administering SOPs The A600 should foliow a similar framework that is used to administer SOPs for alcohol on speclai occasions. This framework shouid inciude an age limit for entry to the event that mirrors the minirnurn age of 19 for sate and possession of recreational cannabis. Further, the framework should outline a structure for events that wish to ailow products to be sampled, A SOP should be required any time recreational cannabis is offered for sale or consumption anywhere other than a licensed establishment or a private place. Should SOPs for recreationai cannabis come into effect, different permits should be issued for private events, public events, tailgate events and industry promotional events. It should be noted that events where aicohol is sold or served other than a private place or an establishment that has a liquor licence under Ontario?s Liquor Licence Act requires a SOP for the event. Similar regulations will need to be developed for recreational cannabis under the Cannabis Licence Act, 2018. Should the province rnove fonaard with permitting SOPs for recreational cannabis, the OMA recommends that restrictions on the way recreational cannabis is consumed at SOP events to only allow for edible cannabis. Exposure to all smoke, including cannabis smoke, can trigger acute and chronic health issues, including cardiovascular events, asthma, cancers, chronic obstructive pulmonary disease, and a range of respiratory conditions. Exposure to secondhand smoke contains many of the same toxins found in cannabis smoke that is directly inhaled, including carcinogens (2). For indoor events, restricting events to edible cannabis will mean that the SFOA, 2017 is followed. For events that are held outdoor or partially outdoors, this restriction would prevent the effects of secondhand smoke to event goers as well as staff and vendors working the occasion. Further, this option would support events and festivals that are proactively deciding to go smoke~free. Again, the federal government has introduced appropriate safeguards to restrict the addition of caffeine, nicotine, alcohol, vitamins and minerals, sugar, colours and sweeteners to the new classes of cannabis products. Events with a SOP for recreational cannabis should prohibit the sale or supply of products with these as rnain ingredients as they are known to interact with cannabis. Further, the OMA would like to ensure event organizers and operators as well as vendors and employees at the events are well trained and knowledgeable in the following areas: a The negative health risks associated with recreational cannabis use; or Products sold and how they may impact users (including the difference between edible cannabis and cannabis that is smoked and or vaped); Identification of customers who are already under the influence; and Identification of customers who are under the minimum age. Should the province allow SOPs for cannabis consumption, the QCS should serve as the chief suppier to these events. The (JCS has an established supply-chain in place to ensure that only cannabis products that are permitted under federal legislation are sold (1 Recommendation: The A600 should be responsible for administering cannabis SOPs and follow a similar framework to that of permits issued for alcohol on special occasions. Recommendation: Minimum age for entry to a cannabis event should mirror the minimum age of 19 for sale and possession of recreational cannabis. Recommendation: The AGCO should outline a structure for cannabis events that wish to allow products to be sampled. Recommendation: The province should restrict the way recreational cannabis is consumed at cannabis SOP events to only allow for edible cannabis. P39350f9 March 2020 "i d. C: {vi 2 i. 330?; ix'ti? 5:354: Recommendation: Events with a SOP for recreational cannabis should prohibit the sale or supply of products with these as main ingredients as they are known to interact with cannabis. Recommendation: The Ontario Cannabis Store should serve as the chief supplier to cannabis SOP events. Additional Minimum age for possessing, using and purchasing recreational cannabis The federal government has outlined that one of the key reasons for legalizing cannabis is to protect youth and to establish safeguards so that illegal cannabis is not accessible to underage individuals. in order to achieve this goal, a rninimum age to purchase, possess, and use recreational cannabis has been set at 18 with the ability for provinces and territories to adjust the minimum age upward. Establishing a minimum age has been an important control measure for both alcohol and tobacco in Canada. Regarding a minimum age for recreational cannabis, the government must focus first and foremost on health risks. There is strong evidence showing recreational cannabis use impacts brain development. it is known that the brain continues to develop through early adulthood, until the age of 25 Adopting a minimum age of under 25 for recreational cannabis use ignores scientific evidence around the permanent, negative health impacts on brain development. Therefore, the OMA advocates that the federal government reconsider the minimum age for purchase, possession and use of cannabis and adjust it to 25. Recommendation: The minimum age for purchasing, possessing and using recreational cannabis should be reconsidered and set at 25, given the negative impact that recreational cannabis can have on health, particularly on brain development. Regulating recreational cannabis sales There must be strict regulations implemented on the marketing of recreational cannabis, using the current regulations for marketing tobacco as the minimum. Regulatory frameworks that address marketing for tobacco, vaping products and recreational cannabis should be updated in lockstep. Recommendation: There must be strict regulations implemented on the marketing of recreational cannabis, using current regulations for marketing tobacco as the minimum. Planning public education and research it is critical that the provincial government integrate new access points for recreational cannabis into existing public education campaigns andlor develop new campaigns for cannabis consumption establishments and or cannabis SOP events. Regardless of whetherthe government expands its current campaign or develops a new one, any public education campaign should use a public health approach that focuses on prevention and increasing awareness of the risk factors associated with recreational cannabis use. General education and awareness campaigns should be geared toward the general public. [3an 6 0f 9 . . Successful campaigns used in the past have increased awareness of the health impacts of tobacco and alcohol and have led to greater public knowledge around the issues as well as a decrease in the number of users. Principles from these campaigns could serve as a foundation to underpin current and future work around public awareness of the harmful risks of recreational cannabis use, no matter the consumption method. Physicians play a critical role in planning and executing education on harmful health impacts that cannabis can have. Patients turn to physicians as a trusted voice on a wide array of health issues, including the impacts of cannabis in all forms of consumption. Additional national resources should be put towards researching cannabis impacts. To date there is limited evidence-based information, which poses a public health risk and leaves physicians iliwequipped to inform and best support patients. Recommendation: Public education campaigns should be developed or updated to integrate new access points for recreational cannabis. Public education campaigns should focus on prevention and increasing awareness of the risk factors associated with recreational cannabis use and should be deployed before additional cannabis products become legal. Keeping our roads safe Whiie the effects of cannabis are different from alcohol, it similarly impairs reaction times and the ability to concentrate on the road. When a person consumes recreational cannabis, it can increase their heart rate, impair short?term memory, and reduce attention, motor skills and the organization of complex information. All these impacts are crucial for driving a vehicle (3, 4). Given this information, should cannabis consumption establishments and or SOPs for recreational cannabis be established, it will be imperative to ensure that cannabis and impairment are properly communicated to users and establishments, organizers and vendors that will some recreational cannabis. It would be proactive for establishments and event organizers to ensure safe transportation programs are in place. These could include designated driver programs, promoting use of taxis, ride share and public transportation. Recommendation: The health risks caused by recreational cannabis use can best be avoided by abstaining from cannabis use. Recommendation: The province should not consider the sale of cannabis for consumption in establishments if it should in any way violate the SPCA, 201?. Recommendation: The government of Ontario should maintain current restrictions on where recreational cannabis can be purchased and used. Recommendation: Should the province allow lounges or cafes for cannabis consumption, the Alcohol and Gaming Commission of Ontario (AGCO) should be responsible for administering licences for such establishments. Page 7 of 9 March 2020 {Ji?i'tg?xt?iti} Iv: E. [Ri?e-?ti. :Pti?iiJI-i Recommendation: Owners and operators as weii as empioyees at cannabis consumption estabiishrnents must be welt trained and knowledgeable Recommendation: Sherrie the province aiiow lounges or cafes for cannabis consumption, the Ontario Cannabis Store (008) shouid serve as the chief to these establishments, Recommendation: The sale of caffeine, tobacco, nicotine-based vape products shonid not be permitted in cannabis consumption estabiishments, Recommendation: The sate of cannabis accessories (vaporizere, bangs, pipes, rigs, roiling papers, cones, fitters, grindersi roliing trays, tools, scalesa cleaning and storage accessories and infosers) shooid not be permitted in cannabis consumption establishments. Recommendation: All cannabis products be provided to patrons at such establishments in the original, federaiiy regulated packaging to prevent cross-contamination, mixing and! or accidental misplacernent of cannabis edibies with other food and beverages? Recommendation: The A600 should be reepcnsibie for administering cannabis SOPs and foltow a similar framework to that of perrnite issued for atcohoi on special occasions. Recommendation: Minimum age for entry to a cannabis event shouid mirror the minimum age of 19 for sale and possession of recreational cannabis. Recommendation: The AGCO shouid outline a structure for cannabis events that wish to allow products to be sampled. Recommendation: The province restrict the way recreational cannabis is consumed at cannabis SOP events to only allow for edible cannabis. Recommendation: Events with a SOP for recreational cannabis shonid prohibit the sale or suppiy of products with these as main ingredients as they are known to interact with cannabis. Recommendation: The (Ontario Cannabis Store should serve as the chief suppiier to cannabis SOP events, Recommendation: The minimum age for purchasing, possessing and using recreational cannabis should be reconsidered and set at 25, given the negative impact that recreational cannabis can have on heaith, particuiariy on brain development, Recommendation: There rnust be strict reguiations implemented on the marketing of recreational cannabis, using current regulations for marketing tobacco as the minimum. Recommendation: Public education campaigns should be developed or updated to integrate new access points for recreational cannabis, Pubiic education campaigns should focus on prevention Pageants and awareness of the risk factors aeacciated with recreationai cannabis use arid shcuid be deployed before cannabis products become legai. ?eiereecee 1, A Resource fci Licensed in Ontario [internet]. 008 thiesaie. [cited Availabia from: 2i Qataricca [interact]. Oaiaricica [cited 2020Feb14]. Available from: 3. American Medical Association. Report an the Ccuacii on Science and public health: Use of cannabis far medicai purpcsea (CSAPH Report 2009 4. National Cannabis Preveaiicri and information Ceatre Austraiia. Marijuana and driving - research brief. 20: Avaiiabie at: hii ?ier-:13: aceei-ei-ririuiiccre Page 9 cf 9 March 2020 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit As part of Ontario?s transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres ofthese patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. 1 The government is not considering changes to the SFOA regime as part ofthis consu?a?on. For more information on Ontario?s cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada?s rules for edibles, extracts and topicals, please visit: cannabis-topicals.html Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. 2 Contact Information The responses below are the recommendations of the City of Ottawa?s Medical Officer of Health, Dr. Vera Etches. The recommendations are derived from staff?s professional review and analysis ofthe available evidence on cannabis as well as lessons learned from the regulation of other substances. The recommendations have been circulated to Members ofthe Board of Health for the City of Ottawa Health unit, however they have not been formally considered or approved by same, nor has the Board had an opportunity to receive public delegations on same. The recommendations described below will be presented to the Board at its meeting on April 20, 2020, after which the Board Chair will forward any additional recommendations and comments that may arise from the Board meeting. The Medical Officer of Health?s contact information is as follows: Dr. Vera Etches, MD, CCFP, Medical Of?cer of Health Ottawa Public Health 100 Constellation Drive Ottawa, Ontario K2G 6J8 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous Law enforcement organization/community Other Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial 3 As the medical officer of health for the city of Ottawa, recommend that the Government of Ontario not consider facilitating the sale of cannabis for consumption in establishments at this time. There are public health concerns with increasing access and normalization of cannabis consumption. Research related to alcohol and tobacco policies has shown that increased access to these substances leads to an increased prevalence of use and the harms associated with the use of these substances.?2 Regular use of cannabis, especially at a young age, can lead to health and social harms, including changes to brain development in youth, poor lung health when smoked or vaped, mental health illnesses and challenges, physical and dependence leading to cannabis use disorders.3 In addition, there are immediate risks with allowing the public consumption of cannabis because ofthe intoxicating effects and resulting harms and impacts to the community. I commend the Government of Ontario for maintaining the Smoke Free Ontario Act, 2017 (SFOA), which protects people from exposure to second-hand smoke and vapour in public places. recommend the Government of Ontario maintain existing SFOA restrictions as it considers cannabis establishments, now and in the future, based on the known health risks of second-hand smoke exposure and emerging evidence on the impacts of vaping, especially to youth and young adults.4?5?6 The Government should also take into consideration any local restrictions on smoking, vaping and the use ofwaterpipes that have already been enacted by municipal councils for purposes of public health and safety, protection of persons, and nuisance control. For example, in 2019 the City of Ottawa harmonized its smoke-free by-laws to consistently prohibit smoking and vaping oftobacco, cannabis and any other substance, as well as the use of waterpipes in enclosed public places, enclosed workplaces, and City parks, beaches and outdoor areas of City facilities. As a result, any facilitation of cannabis consumption by the Government should not infringe upon local municipal rules regarding smoking, vaping and waterpipe use. 4 The Board of Health for the city of Ottawa Health Unit has previously recommended that the Government ban the public consumption ofall forms of cannabis in the same manner it prohibits the public consumption ofalcohol. While smoking and vaping is restricted in public places and workplaces under the SFOA, there are currently no restrictions to where ingestible or edible cannabis can be consumed in public, other than in a vehicle or boat. The risks associated with ingestible and edible cannabis, as described below, warrant provisions to restrict the public consumption ofthese products. Cannabis contains tetrahydrocannabinol (THC), which is a chemical that can impair a person?s attention, judgement and coordination in much the same way as alcohol. The intoxicating effects of cannabis, when ingested, are delayed and prolonged. The onset of effects can be delayed from 30 minutes to 2 hours or more, peak at 4 hours, and last up to 12 hours or longer. The health risks associated with ingesting cannabis pose a challenge to serving these products in public, in a socially responsible manner, and consideration must be given to mitigate the risks to health and safety. recommend the Government of Ontario considerthe following before moving fonNard with cannabis consumption establishments: 1) Ingestible and edible cannabis have delayed and prolonged intoxicating effects 7?39 The delayed effects limit the ability to monitor and control for intoxication, which can cause consumers to ingest additional servings of cannabis, resulting in an unexpected, cumulative effect. The delayed onset and prolonged duration of effects can increase the risk of impaired driving. As demonstrated in case law pertaining to the service ofalcohol, this can result in a longer duration for which the establishment and/or service clerk would be held accountable and responsible for actions taken by the consumer that resulted in injury or harm.10 2) There is a lack of research about the intoxicating effects of cannabis Research is needed to know how cannabis products can be served and consumed in a socially and responsible manner in public. The responsible service ofalcohol is possible because ofthe gradual, accumulative effect when alcohol is consumed slowly, and intoxication can be predicted based on a standard unit ofalcohol. The same type of research is needed for cannabis. There is no standard dose of THC and CBD (cannabidiol) per serving size of 5 cannabis that results in a predicable level of intoxication. What is known about cannabis intoxication is that it depends on several factors, including: - How cannabis is consumed (smoked/vaped/eaten); - The concentration ofthe THC and CBD in the product; - The timeframe during which cannabis is consumed; and - Individual biological factors of the consumer. 3) Inability to control for the public co-consumption of alcohol and cannabis. As alcohol is widely available in communities for consumption in public establishments, it would be very difficult to implement effective controls, policies or enforcement that would prevent or prohibit the public co-consumption of alcohol and cannabis. Simultaneous alcohol and cannabis use have shown to have harmful effects on cognitive and performance, impaired driving performance, and significantly increase the risks of collision. 4) More time is needed to monitor the outcomes associated with the legalization of cannabis The Government of Ontario should take a precautionary approach by monitoring for the outcomes of legalization and emerging evidence on cannabis. As well, the Government should apply lessons learned from the regulation of tobacco and alcohol to minimize the impact that normalization and increased access can have on our communities. Evidence from alcohol research demonstrates that a sales- driven or privatized system results in greater access, higher density of outlets, extended hours of sale, reduced attention to preventing service to minors or intoxicated patrons, and increased promotion or advertising, all of which can encourage an increase in alcohol use and alcohol-related harms.11 Understanding the impacts of legalization in Ontario will happen over time. The potential unintended consequences are not yet known as cannabis has only been permitted for sale and consumption in Canada since October 17, 2018. Further, new cannabis products, such as edibles and beverages, have only been permitted in Ontario as of January 2020. A public health approach to regulating cannabis is needed to minimize the potential health and social harms. A public health approach requires a long-term commitment to evidence-informed decisions about regulations that prioritizes protecting the public?s health and safety. This should include investments in health assessment, surveillance, research, health promotion/protection activities and support for early identi?cation and treatment. 6 Health Canada established regulations for cannabis production to prohibit the consumption of cannabis with other products, including alcohol, tobacco and caffeine and prevent the cross contamination of cannabis products with non-cannabis products during production by requiring that such products be produced at separate facilities. These regulations should be considered by the Government of Ontario if cannabis consumption establishments be permitted. It is recommended that consumers not co-use cannabis with other harmful and/or intoxicating substances, such as alcohol, because the potential for synergistic and addictive effects of substance use is highest when substances are consumed Simultaneous use ofalcohol and cannabis is already prevalent in Canada, especially among youth, and is associated with more harmful consequences than using either substance As stated in the response to question 1, simultaneous alcohol and cannabis use has shown to have harmful effects on cognitive and performance?, impaired driving performance23?29 and significantly increase the risks of collision and odds of impaired driving.30 Alcohol and cannabis use can also cause abnormal changes to brain function and structures when used for a prolonged period. These effects are more prominent with co-use than when each substance is used separately.31 Additionally, individuals who engage in simultaneous use of alcohol and cannabis may experience increased levels of THC. Unlike with alcohol, there is no evidence to suggest that serving cannabis products alongside non-cannabis food or beverages has a positive impact to diminish the intoxicating effects, such as delayed absorption of THC or reduced level of intoxication. 7 As demonstrated in the response to question 1, there are health risks associated with ingesting cannabis in public places, including events, which pose a challenge to serving these products in a socially responsible manner. Controlling access and consumption of cannabis can protect the health and safety ofthe public and manage risk and liability for the event operators and property owners as well as for municipalities. Permitting cannabis consumption in public areas may further normalise use and hinder the public's enjoyment ofthese areas, particularly in family- or child-oriented areas and natural spaces such as conservation areas. The designation of public areas for the consumption of cannabis through SOPs may increase the risk of injury and harm. Further to the considerations outlined in the response to question 1, the Government of Ontario should also consider how to establish controls to reduce underage consumption and the consequences with normalization of public cannabis consumption. The Government should also consider the safety risks in permitting cannabis consumption at events. At this time, with alcohol sale and consumption permitted, events are faced with a safety and security environment that is evolving, and mitigation measures are already seen as challenging and costly. Cannabis is a drug that can cause negative health and social impacts. In addition to the immediate, short term risks that have been outlined in the responses to questions 1 and 3, there are also long-term consequences with regular, prolonged use of cannabis. These risks include poor lung health when smoked or vaped, risks for physical dependence or developing a substance use disorder or other mental health challenges, increased risks for vulnerable populations such as youth, pregnant or chest feeding persons and older adults.32 The governmental objectives in legalizing and regulating cannabis have been to protect youth, provide restricted access to a regulated product, reduce the burden on the 8 criminal justice system and enhance public awareness of the health risks associated with cannabis use. A public health approach to the regulation of cannabis is needed to minimize the risks. The Government of Ontario should consider the health evidence presented throughout this response when making changes that would increase access and normalize public consumption. Due to the evIdence outlined above and the potential impacts on communities, it is recommended that the Government of Ontario consult municipalities prior to and throughout the process of establishing a framework for cannabis consumption establishments or a cannabis SOP. Public health units, associations or groups must also be included to ensure a public health approach to cannabis regulation. Should the creation of cannabis consumption lounges, cafes or other establishments be facilitated or speci?cally authorized by the government, consideration should be given to the municipal role in regulating such establishments. Municipal law enforcement of?cers (by-law officers) will not be able to enforce any provincial or federal rules regarding the manufacturing, preparation, serving, sale or consumption of cannabis edible products, oils or tinctures in a lounge or cafe setting. Municipal law enforcement of?cers will not be able to distinguish between products containing cannabis and those that don?t, nor will they be able to determine composition, limits, or quality of these products. In addition, the regulation of location and number ofany cannabis lounges, cafes or other establishments authorized by the Government should be considered. The municipal business licensing function, under Part IV of the Municipal Act, 2001 does not allow a municipality to refuse to issue business licenses based on the location ofthe establishments (with the exception of adult entertainment parlours and payday loan establishments) nor does it allow the municipality to restrict the number of licenses issued to a particular class of business (with the exception of taxicabs and payday loan establishments). The Government should therefore considerthe potential land use impacts and community consequences ofauthorizing cannabis consumption lounges and set out clear rules for their locations and numbers to minimize any negative land use impacts or community consequences. Should the Government not establish provincial rules regarding the location and number of cannabis consumption lounges, cafes or other establishments, clari?cation would 9 been needed with respect to the municipal government?s role in doing so. This should include consideration of providing municipalities with speci?c authorities in this regard beyond current land use planning and zoning considerations. Engagement with Municipalities will also be critical in determining the parameters for cannabis SOPs and establishing mitigation strategies for unintended consequences. 10 References 1 Popova, S., Patra, .J., Sarnocinska-Hart, A., Gnam, W.H., Giesbrecht, N., Rehm, .J. (2012). Cost of privatisation versus government alcohol retailing systems: Canadian example. Drug and Alcohol Review; 31, 4-12 2 Tilson M, Cohen, .J., McDonald, K., Giesbrecht, Maga W., Mercedy, G., Chaiton, M. Reducing Tobacco Retail Availability. 2013. Toronto, ON: The Ontario Tobacco Research Unit. 3 National Academies of Sciences, Engineering and Medicine. (2017). The Health Effects of Cannabis and Cannabinoids: The current state of evidence and recommendations for research. The National Academies Press. Available from 4 O, Plecas D. Clearing the smoke on cannabis: Respiratory effects of cannabis smoking - An update. Canadian Centre on Substance Abuse. 2016. Available from: [Accessed: 18th .July 2017]. 5 Repp KK, Raich AL. Marijuana and health: A comprehensive review of 20 years of research. Washington County Oregon Department of Health and Human Services. Hillsoro, OR: Washington County. 2014. Available from: review ReppRaich Oct2014.pdf 5 Moir D, Rickert WS, Levasseur G, Larose Y, Maertens R, White P, Desjardins S. A comparison of mainstream and sidestream marijuana and tobacco cigarette smoke produced under two machine smoking conditions. Chem Res Toxicol. 494-502. doi: 10.1021/tx700275p 7 Benjamin, D. M., Fossler, M. .J. (2016). Edible cannabis products: it is time for FDA oversight. The .Journal of Clinical Pharmacology, 56(9), 1045-1047. Available from: 3 Barrus, D. G., Capogrossi, K. L., Cates, S. C., Gourdet, C. K., Peiper, N. C., Novak, S. P., &Wiley, .J. L. (2016). Tasty THC: Promises and Challenges of Cannabis Edibles. Methods report Press), 2016. Available from 9 National Academies of Sciences, Engineering and Medicine. (2017). The Health Effects of Cannabis and Cannabinoids: The current state of evidence and recommendations for research. The National Academies Press. Available from 3 10 Alcohol Gaming Commission of Ontario. (2018). Liability: There's more to lose than your licence. Toronto, ON: Queens Printer for Ontario. Accessed from: liability more to lose then your licence dec2018.pdf 11 Popova, S., Patra, .J., Sarnocinska-Hart, A., Gnam, W.H., Giesbrecht, N., Rehm, .J. (2012). Cost of privatisation versus government alcohol retailing systems: Canadian example. Drug and Alcohol Review; 31, 4-12 12 Subbaraman MS, Kerr WC. Simultaneous versus concurrent use of alcohol and cannabis in the national alcohol survey. Alcohol Clin Exp Res. Available from: 11 13 Briere FN, Fallu .JS, DescheneauX A, .Janosz M. Predictors and consequences of simultaneous alcohol and cannabis use in adolescents. Addict Behav. 14 Ramaekers .JG, Berghaus G, van Laar M, Drummer OH. Dose related risk of motor vehicle crashes after cannabis use. Drug Alcohol Depend. 15 Kelly E, Darke S, Ross .J. A review of drug use and driving: epidemiology, impairment, risk factors and risk perceptions. Drug Alcohol Rev. ?5 Asbridge M, Hayden .JA, Cartwright .JL. Acute cannabis consumption and motor vehicle collision risk: systematic review of observational studies and meta-analysis. BMJ. 2012;344:e536. Available from: bmj. com/conte nt/344/bmj .e536 17 Kleczkowska P, Smaga I, Filip M, Bujalska-Zadrozny M. Cannabinoid ligands and alcohol addiction: a promising therapeutic tool or a humbug?? Neurotox Res. Available from: 13 Lukas SE OS. Ethanol increases plasma (THC) levels and subjective effects after marihuana smoking in human volunteers. Drug Alcohol Depend. 2001 19 Hartman RL, Brown TL, Milavetz G, Spurgin A, Gorelick DA, Gaffney G, et al. Controlled cannabis vaporizer administration: Blood and plasma cannabinoids with and without alcohol. Clinical Chem. Available from: 2? Metrik .J, Caswell AJ, Magill M, Monti PM, Kahler CW. Sexual risk behavior and heavy drinking among weekly marijuana users. .J Stud Alcohol Drugs. Available from: 21 Kleczkowska P, Smaga I, Filip M, Bujalska-Zadrozny M. Cannabinoid ligands and alcohol addiction: a promising therapeutic tool or a humbug?? Neurotox Res. Available from: 22 Government of Canada. Canadian cannabis survey 2017 - summary [Internet]. Ottawa, ON: Government of Canada; 2017 [cited 2018 Mar 26]. Available from: 23 Patrick ME, Veliz PT, Terry-McElrath YM. High-intensity and simultaneous alcohol and marijuana use among high school seniors in the United States. Substance Abuse. 24 Boak A, Hamilton HA, Adlaf EM, Mann RE. Drug use among Ontario students, 1977-2017: detailed findings from the Ontario Student Drug Use and Health Survey (OSDUHS) (CAMH Research Document Series No. 46). Toronto, ON: Centre for Addiction and Mental Health; 2017. Available from: DrudUseReport f7. 25 Richardson C. BASUS report: year 3 waves 5 6: BC Adolescent Substance Use Survey [Internet]. Vancouver BC: Canadian Institutes of Health Research; University of BC, School of Population and Public Health; Michael Smith Foundation for Health Research; [2013] [cited 2018 Mar 26]. Available from: year3 2?5 Pape H, Rossow I, Storvoll EE. Under double influence: assessment of simultaneous alcohol and cannabis use in general youth populations. Drug Alcohol Depend. 12 27 Ramaekers JG, Berghaus G, van Laar M, Drummer OH. Dose related risk of motor vehicle crashes after cannabis use. Drug Alcohol Depend. 23 Ibid 29 Kelly E, Darke 8, Ross .J. A review of drug use and driving: epidemiology, impairment, risk factors and risk perceptions. Drug Alcohol Rev. 3? Asbridge M, Hayden .JA, Cartwright .JL. Acute cannabis consumption and motor vehicle collision risk: systematic review of observational studies and meta-analysis. BMJ. 2012;344:e536. Available from: bmi. com/conte nt/344/bmie536 31 Kleczkowska P, Smaga l, Filip M, Bujalska-Zadrozny M. Cannabinoid ligands and alcohol addiction: a promising therapeutic tool or a humbug?? Neurotox Res. Available from: 32 National Academies of Sciences, Engineering and Medicine. (2017). The Health Effects of Cannabis and Cannabinoids: The current state of evidence and recommendations for research. The National Academies Press. Available from 13 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SPCA, 2017 regime as part of this consu?a?on. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts? cannabis products that are produced using extraction processing At this time no other Canadian jurisdict: consumption establishments like loung The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Hallie Atter, Manager Family and Community Health Peterborough Public Health Jackson Square 185 King Street Peterborough, Ontario K9J 2R8 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area LI 4. Northern Ontario I 5. Southeastern Ontario LI 6. Southwestern Ontario 7. Western Ontario LI 8. Provincial Due to multipleb?blic health concerns posed by cannabis lounges and caf?s, including but not cannabis use, and cannabis regulatory system, Peterborough Public Health does n_ot support the salao?cjahnabis for consumption in these establishments. Moreover, it also amplifies our concernsiiabout the ongoing liberalization and normalization of the use of harmful substances without proper consideration of their health consequences. Retail expansion of alcohol sales, unrestricted promotion of e-cigarettes and proposals such as this should not be considered without the offsetting health promotion policies to mitigate their measureable negative health and social impacts. Providing a space for the consumption of cannabis edibles in a public setting enhances the risk of unpredictable intoxication due to individual levels of tolerance, varying levels of and the delayed onset of intoxicating or effects. Compared to inhaled forms of cannabis, edible cannabis products may take up to 2 hours for an individual to start feeling the effects, with a peak effect onset time of up to 4 hours. The effects of edibles may also persist for 3 6-12 hours. The unpredictability and delayed onset of effects poses safety risks not only for the consumer, but also liability risks for the establishment operator for any incident that occurs once the patron leaves the establishment motor vehicle collision or illness associated with overconsumption such as vomiting, fainting, severe anxiety or panic attack, loss of reality or paranoia). The cannabis regulatory system in Ontario has only been established since late 2018. Since that time, a significant expansion of cannabis access points is undenNay. Research shows that increased availability of and exposure to the use of substances, such as alcohol and tobacco, results in increased consumption, which can lead to significant health and social harms and costs. As such, a precautionary approach would be prudent until a more fulsome with the SPCA, 2017 by patrons and employees, making it more difficult for the proprietor/owner of these establishments to meet their legal obligations to ensure that smoking and vaping is not permitted. Prohibiting the sale and consumption of cannabis in these types of establishments will also protect the interests of neighbouring businesses. Despite solid public health evidence against the sale of cannabis products in caf?s and lounges, if the government chooses to proceed with expanding the retail framework to include these establishments, the following considerations could help to mitigate the public health risks and harms: 0 Products sold and consumed: Only the sale of non-smoked or non-vaped cannabis products from federally licensed producers should be permitted. Such products should be sold only in their original packaging and not be removed from their packaging by anyone other than the consumer. This will ensure consumers know the levels of THC and CBD that they are consuming, as well as other ingredients, and protect against overconsumption. In this regard, preparation ofthese products onsite should not be permitted, and patrons should be prohibited from bringing in and/or consuming their own cannabis which was purchased or obtained elsewhere. Products available for sale should be restricted to those with low levels of THC. These mitigating factors will help to reduce the risk of over-intoxication and harms, as well as reduce the liability risk to the establishment. these establishments that they are not to entice entry into the establishment by way of promoting them as an entertainment venue. The promotion of their use as an event space or entertainment venue movie or trivia nights, live music performances, etc.) would entice patrons to use the establishment who may otherwise prefer not to be exposed to cannabis consumption. 0 Sponsorship prohibitions: Sponsorship of any lounge or caf? use of celebrity endorsements or branded promotional exhibits and displays) or the sponsorship of events within the lounge or caf? should remain prohibited. A cannabis retailer or licensed producer operating a cannabis lounge or caf? should be required to follow the promotion and advertising restrictions outlined in Section 21 of the federal Cannabis Act. 0 Protection from second-hand smoke and vapour: Any smoking/vaping of products should be prohibited in the establishment and on the patio, and within 9 metres of any patio or outside area operating in conjunction with a place where food and/or drink is served, sold or offered for consumption. 0 Municipal Controls: Municipalities should be empowered to enact zoning and licencing regulations to prohibit or have an influence over where these establishments are located contain nicotine should be strictly prohibited in these establishments. This will prevent harmful co-use of substances which may lead to higher levels of impairment, addiction, and increased levels of harm. This is in alignment with the prohibited substances named within subsection 34(1) of the federal Cannabis Act, whereby it is prohibited to sell any mixture of substances that contains cannabis and any substance that is referred to in column 1 of Schedule 5. In terms of accessories, only those that relate to non-smoked and non-vaped cannabis should be permitted for sale to reduce cross-marketing inducements for cannabis use. resulting in emergency visits, and the use. As a result, there could be an impact on our local emergencyisej" ices policeiEMS and hospital serViiCes). The sale and consumption of cannabisEat-Isiti?hgevents wouldpose unique risks as they are not protect employees, volunteers, contracted agents and patrons from the negative health effects of exposure to second-hand smoke and vapour. Smoking and vaping prohibitions also help to prevent substance use; they promote smoke-free and vapour-free living while supporting those who have recently quit and/or are trying to overcome their addiction. While the federal Cannabis Act, 2018 includes measures to limit the promotion of cannabis to youth, consideration should be given to the promotion of cannabis to non-cannabis users. Every effort should be made to visually and physically separate cannabis and cannabis promotions from the intended special event to reduce enticing those attending events from consuming cannabis who would not have othenNise. Restrictions on substance use at special events encourages a focus on the event itself concerts, food festivals, etc.), and not the promotion of substances and substance use. Despite solid public health evidence against the sale of cannabis products at SOPs, ifthe government chooses to proceed with expanding the retail framework to include the retail sale at special events and festivals, please refer to the public health mitigation measures outlined in question 1. Lack of Enforcement Capacity department must be notified as well if a tent, marquee, pavilion or tiered seating is used. If the government chooses to expand the retail availability of cannabis as proposed above, operators of these establishments and SOPs should be required, by law, to post government- approved health information including warnings on the risks of cannabis consumption, low-risk 8 cannabis use guidelines, and information specific to the products being sold to reduce the potential for health harms. If the government should choose to move fonIvard with this expansion, taxes from the sales of cannabis should be used for health promotion strategies to help mitigate the risk of health harms as well evaluation efforts to monitor the health impacts. ln Ontario, the regulations for cannabis use more closely align with the regulation of tobacco and vapour product use, compared to alcohol. Individuals are legally permitted to possess 30 grams of dried cannabis (or equivalent) and are legally permitted to consume cannabis in many public spaces, therefore, permitting the consumption of cannabIs In cafes, lounges and through SOPs Is not required in Ontario. -- REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis?ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Monica Hau, MD CCFP Associate Medical Officer of Health Region of Peel Public Health 7120 Hurontario Street, Mississauga, ON L5M 2C1 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) LI 2. Eastern Ontario LI 3. Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial Given the potential risks to public health and safety, the Region of Peel Public Health does not support the proposed sale of cannabis for consumption in establishments such as lounges and caf?s. Allowing the sale of cannabis for consumption in specified establishments would present the following public health concerns: 0 Risks of second-hand smoke and vapour exposure: Any current or future efforts to loosen the Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulation pursuant to the Act (Ontario Regulation 268/18) should be strictly prohibited to protect against the risks of exposure to second-hand smoke and vapour. Expanding the number and type of places where cannabis could be smoked/vaped would undermine local restrictions that aim to further protect residents from exposure to second-hand smoke in public places. For example, the Region of Peel enacted a by-law to prohibit smoking waterpipes in various indoor and outdoor places, as well as a region-wide by-law to prohibit smoking of tobacco/cannabis and vaping of any substance outdoors within nine metres of indoor public places/workplaces and certain outdoor areas. Evidence indicates that smoking cannabis, similar to smoked tobacco, can be harmful to the lungs and may pose health risks from second-hand exposure}2 Such changes would also cause confusion about the legislation among all parties, including patrons, health units, enforcement staff, and the general public. This would create confusing circumstances in situations where cannabis could be smoked/vaped in enclosed public spaces and workplaces, but tobacco could not be smoked/vaped. Therefore, any potential measures by the Province of Ontario to loosen regulatory restrictions related to smoking and vaping in enclosed public spaces or workplaces (such as lounges or cafes) would pose risks to patrons, employees, and the general public. Increased access and implications for consumption and related harms: Evidence from other legalized substances, such as alcohol, has linked increased availability to higher consumption and related harms,3 which may create similar issues in an expanded cannabis retail market. more Canadian adults used cannabis in the first full year after legalization than prior to legalization with Ontario rates being 18%.4 According to the 2019 Ontario Student Drug Use and Health Survey, about 1 in 5 Ontario students in grades 7-12 reported past year cannabis use.5 Among high school students, consuming cannabis edibles significantly increased from 11% in 2017 to 14% in 2019.5 Based on lessons from tobacco and alcohol control, widespread retail availability of tobacco and alcohol products can also increase normalization of use while undermining health risk messaging.6 Sale of cannabis should remain in government authorized cannabis retail stores to balance availability with adequate controls, which may mitigate risks of increased access and normalization, consumption and related harms. Overconsumption: Cannabis use, particularly the use of edible forms, may be associated with an increased risk of overdose cannabis poisoning).7 Due to the delayed absorption and onset of effects associated with edible cannabis products, patrons may be inclined to purchase and consume greater amounts in order to feel the desired effects, and unintentionally overconsume.7?8 Overconsumption could lead to impaired driving, increasing the risk of injury and harm, as well as an increased burden on the health care system and law enforcement. Impaired Driving: Substantial evidence indicates that cannabis use is associated with an increased risk of motor vehicle crashes,7 which may place public safety at significant risk. Cannabis use acutely impairs functions that are important for driving, including cognition, attention, memory, decision-making and functioning.7?9 The degree and duration of impairment depends on various factors, including those related to the individual, the product and use behaviour.7?9 Edible forms of cannabis can produce effects that are initially delayed yet long sustained in comparison to other forms, meaning that patrons may not feel the peak effects until they have left the establishment and could already be driving impaired.8 Co-use of cannabis with alcohol may further increase the risk of impairment.9 Responsibility of establishments to ensure the safety of customers and risk of liability: By selling cannabis for consumption in establishments, servers may face challenges in determining the level of impairment of those being served. This could place patrons at risk for overconsumption and related harms impairment and increased risk for motor vehicle collisions), while creating potential liability issues for the establishment owners. For example, under Ontario?s Liquor Licence Act, it is illegal to serve customers to intoxication, promote practices that may encourage customers to become intoxicated, or serve someone who is showing signs of intoxication.? Challenges would exist for servers in identifying cannabis impairment, which is further complicated by different routes of exposure inhalation and ingestion) that impact the timing of peak levels and intoxication and can vary from person to person.11 Despite the potential risks, if the provincial government decides to permit the sale of cannabis for consumption in establishments like lounges and caf?s, strict measures should be taken to protect public health and safety. Consider the following: Regulatory Framework 0 If permitted, authorize, license and regulate the sale of cannabis through stringent processes under a government-run regulatory body, such as the Alcohol and Gaming Commission of Ontario (AGCO). This may increase accountability as the AGCO would be responsible for administration and enforcement as set out by the Ontario government. 0 Within the regulatory framework, define ?consumption.? Consumption is currently not defined in the SFOA, 2017 (or prescribed by Ontario Regulation 268/18 pursuant to it), the Cannabis ControIAct or the Cannabis Licence Act, which could create confusion for the public and business owners about what is permitted for use in the proposed establishments. Prohibiting Smoking and Vaping Prohibit smoking and vaping of cannabis, as well as the sale of products for combustion or vaporization in the proposed establishments to protect people from exposure to second-hand cannabis smoke/vapour}2 Age Restrictions Prohibit access to those less than 19 years of age to align with the minimum age for purchase, possession and use of cannabis in Ontario.12 0 Ensure mandatory age verification through a process of identification checks before entry to avoid underage access to establishments or events. Product Restrictions to Mitigate Risk for Harms 0 Permit only government regulated cannabis products (excluding smoked or vaporized products) for sale. Maintain products in their original packaging while stored, sold and served, only to be opened by the consumer. This could help with consumer safety by ensuring that pertinent information and health warnings remain available to the consumer and are not removed. 0 If patrons are unable to finish the purchased cannabis products and take them outside of the establishment, the labelled packaging may act as a safeguard by reducing the risks of unintentional consumption by others if the product were otherwise unidentifiable cannabis edible mistaken for regular food). This is especially important to avoid unintended use and protect vulnerable populations, such as children and pregnant/breastfeeding women.9 This may also prevent the risk of cross-contamination within establishments if other non-cannabis products are permitted for sale. 0 Limit the sale of cannabis products to small amounts only and prohibit the sale of high potency products to reduce the risk of adverse effects. For example, cannabis consumption establishments in the Netherlands lowered the sale of cannabis to five grams, after originally being able to sell up to 30 grams of cannabis per person per clay.13?14 Also prohibit product sampling within the proposed establishments. 0 It is recommended that personal cannabis products be prohibited from being brought into the establishments to deter patrons from bringing in their own personal supply or sharing illicit products that could have unknown ingredients. This may help mitigate the risk of patrons ?double dosing? by consuming their own personal cannabis and consuming the cannabis they have purchased on site, which could increase the risk of overconsumption. Enforcement and Inspections 0 Ensure that appropriate enforcement efforts are in place with clear identification of roles and authorities for inspections and investigations. 0 Instate strict processes to verify product safety and specifications. For example, if there are reasons to believe that non-cannabis food/beverages sold at an establishment may be contaminated with cannabis, it will be important to identify procedures for sampling and testing, including the identification of accredited testing laboratories. 0 Consider building requirements, similar to those outlined by the AGCO Registrar's Standards for Cannabis Retail Stores,15 for the proposed establishments. For example, ensure that establishments have secure surveillance systems and measures such as tinted glass to prevent the inside premises from being visible from outside of the store.15 This may help to curb normalization and promotion, especially to protect youth. Prohibiting Display and Promotion 0 Prohibit the display and promotion of cannabis products and any cannabis-related accessories to reduce exposure and normalization, particularly among youth. 0 Such measures would also help to ensure that there is no confusion or conflict with the SFOA, 2017, as public health experiences with tobacco and vapour sales have historically presented challenges based on vague parameters around the promotion and display of products/accessories. Prohibit tobacco promotion at point-of?sale to eliminate sensory cues for buying and using tobacco and support denormalization.16 Education, Awareness and Staff Training 0 Given the risks associated with overconsumption of cannabis, particularly those associated with edible cannabis products, provide mandatory staff and server training to educate workers on how to handle issues of overconsumption, including signs that a patron may require medical attention. This may be similar to training provided for those serving alcohol to patrons through the Smart Serve Ontario program.17 Require mandatory re-certification to ensure that staff remain current with updated knowledge and skills as requirements or best practices evolve. 0 Ensure mandatory education and awareness efforts that address the health risks of cannabis to create awareness among consumers. Consumers should be made aware of potential issues such as overconsumption, impairment, and the implications of co-using alcohol and cannabis. Educate patrons about factors that could potentially increase health risks differences in effects based on product form, potency, tolerance).9 0 Display clear signage regarding potential health risks of cannabis, particularly for vulnerable groups such as pregnant and breastfeeding women.9 Co-Location and Outlet Density 0 Do not co-locate the proposed cannabis consumption establishments with premises that serve alcohol bars, clubs). This will prevent potential harms associated with the co-using these substances.9 0 Restrict the number of establishments permitted within jurisdictions. Research from the sale of alcohol indicates that communities with higher numbers of alcohol retail outlets are more likely to have higher rates of consumption and associated harms such as violence, injuries, and public disturbances.3?18?19 If the sale of other products is permitted in the proposed cannabis consumption establishments, the government would need to balance options for patrons in attendance who do not wish to consume cannabis, with attempting to avoid other potential health harms. There are important risks and unintended consequences to balance when considering the introduction of additional products to be sold in the proposed cannabis consumption establishments. While there could be potential risks involved with providing a variety of food/beverage options enticing entry of individuals who were not otherwise interested in using cannabis, or introducing individuals to cannabis use as a new social experience), there may be greater risks in restricting sales solely to cannabis products in such establishments. The latter option could encourage overconsumption and intoxication due to the lack of non-cannabis options available. If food or beverages that do not contain cannabis are sold, implement measures to minimize on-site food handling, remove risks of cross-contamination, and separate edible cannabis from other foods/beverages that do not contain cannabis. It would be imperative to prevent food/beverages that do not contain cannabis from being inadvertently contaminated with cannabis to protect patrons from unintentional exposure. A key component of Health Canada?s regulations to control the legal production and sale of edible cannabis involves prohibiting the production of food and cannabis in the same facility to ensure the safety and integrity of Canada?s food system.20 Similarly, in the case of the proposed establishments, if any food is prepared on-site it should not contain cannabis, and no exemptions should be made to allow for cannabis and food to be produced/prepared in the same building. To further avoid risks associated with cross-contamination, the allowance of pre-packaged foods/beverages not containing cannabis pre-packaged sandwiches and snack foods, bottled non- alcoholic beverages) would offer non-cannabis food options while avoiding the risk of cross- contamination involved with on-site prep kitchens. Cannabis products should be stored, sold and served to consumers in their original packaging, to be opened only by the consumer in an effort to avoid cross-contamination between cannabis products and regular food/beverages. No cannabis plants for personal cultivation should be grown within the establishment. If the sale of non-cannabis food products is permitted, strictly prohibit other substances including alcohol, nicotine and tobacco products, and caffeine (excluding the allowance for naturally occurring caffeine) to avoid potential adverse effects and align with the federal regulations for edible cannabis.21 For example, the co-use of cannabis with alcohol increases the risks for harm, particularly for impaired driving.9?22 Other prohibitions should include vitamin and mineral supplements, probiotics, energy drinks, and any e-liquids/additives that enhance the flavour/odour of food. Patrons should also be prohibited from bringing their own food into the establishment, as the contents of the food would be unknown or could contain substances/ingredients that should be avoided in use with cannabis alcohol). Water should be available at all proposed establishments. Prohibit the sale of accessories or promotional items, particularly items that could be considered appealing to youth cosmetics, digital accessories, graphic t-shirts, etc.). The sale of vape and vape products, including e-liquids and additives that add or enhance flavour or odour, should be prohibited. Vaping THC has been associated with a wide range of health effects, particularly with prolonged frequent use. The U.S. Centers for Disease Control and Prevention (CDC) discourages the use of THC- containing e-cigarette/vaping products.23 If the Province chooses to permit the sale of accessories, they should only pertain to the forms of cannabis being sold on site to avoid additional unwarranted promotion prohibit the sale of bongs and blunt wraps if smoking/vaping is prohibited within the proposed establishments). Peel Public Health does not support the establishment of a special occasion permit (SOP) program for cannabis to be sold and consumed at festivals and events. Such events may allow opportunities for display and promotion, expose the public to second-hand cannabis smoke and vapour, increase normalization and social exposure to vulnerable populations such as youth, and create liability risks for the event/permit host. SOPs may also increase potential challenges for enforcement and health responders due to concerns of overconsumption and intoxication, and impaired driving after leaving the event/festival. If SOPs are permitted, ensure no permit is granted for places where smoking of tobacco or cannabis and the use of electronic cigarettes are already prohibited under the SFOA, 2017 (or, where additional by-laws exist, the more restrictive provision would prevail)?? Peel Public Health recommends that smoking and vaping cannabis be prohibited under the proposed SOPs to protect the public from the potential risks of second-hand exposure to cannabis smoke/vapour. For example, individuals of all ages may attend public events and festivals, yet restricting smoking and vaping to a designated area within the event will not prevent smoke/vapour or odours from drifting into other areas of the event. If a designated enclosed area was created to circumvent this issue, it would be a direct contravention of the SFOA, 2017 and the regulation pursuant to the Act. Peel Public Health does not support any measures that would loosen the regulatory restrictions that are in place to protect the public from second-hand smoke and vapour exposure in public places. SOP events should be age-restricted to those 19 years and older to align with the minimum age for purchase, possession and use of cannabis in Ontario,12 and to avoid normalization and exposure to youth. Entry into the event should be verified through identification checks. In alignment with the federal regulations for cannabis promotion, the SOP event should be blocked off in such a manner that it is not audible or visible from outside a place where young persons are not permitted by law.25 This may help reduce normalization and deter youth and non-users of cannabis from initiating use. If the Province decides not to place age-restrictions on the entire event, then, at minimum, a dedicated age- restricted area for those 19 years and over should be designated within the event to protect youth. Similarly, cannabis event licences in the state of California require age-restricted access (21 years or older) to the area where cannabis consumption is permitted and require that the event should not be visible from any public place or non-age-restricted area.26 Prohibit the display and promotion of cannabis in any form edibles, extracts or topicals) as well as any cannabis accessories to avoid any confusion or conflict with the SFOA, 2017 and reduce the risk of normalization. As with tobacco and vaping, sales may be connected to the display of products and product accessories, and promotion through various means including product association. This provides opportunities for the event itself and sponsors to possibly promote consumption, which is not permitted under the SFOA, 2017.24 Section 5(1) of the SFOA, 2017 also prohibits promotion of tobacco products and vapour products at places of entertainment.24 Because tobacco and vapour accessories can also be used to consume cannabis rolling papers or tanks for vaping), this could lead to inconsistencies and non-compliance with the SFOA, 2017. Any promotional tactics such as cannabis product sampling and sponsorship should also be prohibited at these events. Prohibit the sale and consumption of alcohol and tobacco at the same event to help avoid the potential adverse effects of co-using these substances. Co-use of cannabis and alcohol may further increase impairment and the risk for motor vehicle crashes.9 This requirement has been similarly established through the State of California?s cannabis event licences, whereby consumption of alcohol or tobacco is not allowed on the cannabis event premises.26 Due to potential risks for overconsumption, intoxication and public nuisances, additional enforcement and first responders police and paramedics) should be available on site to address public safety concerns. It will be important to assess the capacity and resource requirements for on-site enforcement and first responders prior to approving a SOP to ensure adequate measures are in place to protect public health and safety. Given the risks associated with cannabis use, provide mandatory staff and server training to educate workers, and information on health risks should be provided to consumers. Training should be provided to staff and servers on how to handle issues of overconsumption, including signs that a patron may require medical attention. This may be similar to training provided for those serving alcohol to patrons through the Smart Serve Ontario program.17 Education and awareness efforts should be mandatory and address the potential health risks of cannabis use to create awareness among consumers. Consumers should be made aware of key issues such as overconsumption, impaired driving, and the implications of co-using alcohol and cannabis. Patrons should be educated about factors that could potentially increase risks differences in effects based on product form, potency, tolerance, etc.).9 Clear signage should also be displayed regarding potential health risks of cannabis, particularly for vulnerable groups such as pregnant and breastfeeding women.9 0 Issues related to outlet density and community harms: The design of cannabis retail systems can greatly affect population health behaviours and outcomes. Although evidence on the experiences of otherjurisdictions is limited, literature from the Netherlands on long-standing 9 ?coffee shops? where cannabis is sold and consumed indicated some nuisance-related issues for the surrounding communities, such as traffic problems, noise and loitering.13?27 Research from the sale of alcohol indicates that communities with higher numbers of alcohol retail outlets are more likely to have higher rates of consumption and associated harms such as violence, injuries, and public disturbances.3?18?19 We recommend against the co-location of proposed cannabis consumption establishments with premises that serve alcohol bars, clubs) to prevent potential harms associated with the co-using these substances. 0 Enforcement challenges: The sale and consumption of cannabis at specified establishments and at events/festivals would pose challenges from an enforcement perspective. For example, it would be difficult to determine whether patrons have exceeded possession limits if they are entering an establishment with a personal supply of cannabis and leaving with an added supply of unfinished product. Law enforcement could also face additional issues with nuisance complaints and impaired driving, as patrons may leave establishments experiencing intoxication or delayed effects. If establishments are permitted to conduct food preparation in the same building where cannabis edibles are sold, public health inspection for food premises may be further complicated by concerns of cross-contamination. If permitted, Peel Public Health recommends that municipal involvement be required to determine aspects of the proposed requirements for cannabis consumption establishments and SOPs, including decisions regarding location, density, and setback distance requirements from sensitive land use areas schools, daycares and youth-serving facilities). A potential framework for cannabis consumption establishments would have direct implications for local municipalities in Ontario. In 2018, prior to determining the current provincial framework for cannabis use in Ontario, the Association of Municipalities of Ontario (AMO) had reported their interest in being involved in future decisions regarding proposed cannabis consumption venues.28 The AMO indicated that municipal governments should be able to control whether these venues are desirable in a given community, and the location and circumstances under which they may be able to operate.28 Municipal governments should be given the authority to decide whether to host the proposed consumption establishments and grant SOPs within their respective municipalities. In January 2019, Ontario municipalities were similarly given the opportunity to determine whether to opt-out of hosting cannabis retail stores in their communities.29 It would be important for the Province to work closely with municipalities to support them in determining local needs during this process. SOP applications should also be required to adhere to municipal requirements to ensure compliance with city by-laws and conditions of use for municipal properties. The AGCO should not have the ability to override municipal decisions on SOP applications in cases where the municipal requirements are more restrictive. The Province should also provide municipalities with the authority to prohibit incompatible land uses. For example, this would support municipalities in preventing incompatible business venues, such as bars or child/youth-serving facilities, from being located directly next to the proposed cannabis consumption establishments. This may help mitigate potential issues such as increased risk for harms, co-use of substances, and other public nuisances or community complaints. 10 Business licencing should be required by all proposed cannabis consumption establishments with the ability to revoke a licence if concerns arise, such as issues with compliance. Under the MunicipoIAct, 2001, municipalities in Ontario can provide a licence system in which they have the ability to grant, revoke or suspend a business licence.30 Under such licencing, proprietors will be responsible for ensuring compliance at their establishment, with proper procedures such as signage and documentation. For example, as outlined by the State of California for the purposes of obtaining cannabis event licences, written approval from the local jurisdiction authorizing on-site cannabis sales and consumption is required for all temporary cannabis events.26 Concerns regarding cannabis retail market expansion in Ontario: We are concerned about the Province?s considerations to continue expanding the cannabis market within what remains a relatively new regulatory regime. Privatization of cannabis sales must be carefully managed, especially as research on other legalized substances such as alcohol has repeatedly identified availability as a critical determinant of consumption levels and subsequent related harms.3 Cannabis consumption establishments and cannabis SOPs increase the complexity of the potential population health risk associated with increasing access to cannabis. It is important to ensure that public health and safety remain at the forefront of all policy decisions related to cannabis legalization to avoid health risks and allow time for the legal market to mature prior to implementing changes. Monitoring and surveillance: f cannabis consumption establishments and SOPs are permitted, the Province should ensure that monitoring and surveillance measures are in place to assess the implications of these changes, such as the impacts on consumption, impaired driving, perceptions/attitudes, and cannabis-related hospitalizations and emergency department visits.. It is challenging to draw from the experiences of other jurisdictions to inform direction, given that no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, and jurisdictions in the United States that have implemented such frameworks have done so under different contexts in jurisdictions where consumption is restricted to private residences only). As new data and evidence emerges, measures should be taken to make improvements to the framework when they are in the best interests of protecting the health and safety of communities and vulnerable populations, in consultation with the public and organizations such as public health. Reinvest tax revenues into prevention efforts: The government should re-direct revenues generated from sales taxes back into essential programs and services to protect public health and safety, particularly at the local level. With the introduction of the proposed cannabis consumption establishments and SOPs, it is anticipated that there would be a continued need for public health units to educate the public on the potential risks of cannabis use, support local municipalities to protect public safety, and play a role in enforcement. Additionally, police may be asked to respond to legal issues such as impaired driving. There may also be an increased need for mental health and addiction treatment services, which could place a greater burden on the health system We appreciate that the provincial government has provided the opportunity to comment on the potential for cannabis consumption establishments and/or cannabis special occasion permits. Peel Public Health also welcomes opportunities to participate in future consultations regarding potential changes to the cannabis retail market. ?l?l References: 1) Cannabis in Canada: Get the facts [Internet], Ottawa, ON: Government of Canada [updated 2018 Oct 26; cited 2020 Feb 28]. Available from: 2) Marijuana and Public Health: Cancer Risk [Internet]. Atlanta, GA: Centers for Disease Control and Prevention [updated 2017 Dec 13; cited 2020 Feb 27]. Available from: 3) Babor TF, Caetano R, Casswell S, Edwards G, Giesbrecht N, Graham K, et al. (2010). Alcohol no ordinary commodity: Research and public policy (Second New York, USA: Oxford University Press 4) Health Reports: What has changed since cannabis was legalized? [Internet]. Ottawa, ON: Statistics Canada [updated 2020 Feb 19; cited 2020 Mar 2] Available from: 5) Boak A, Elton-Marshall T, Mann RE, and Hamilton HA. Drug use among Ontario students, 1977-2019: Detailed findings from the Ontario Student Drug Use and Health Survey (OSDUHS) [Internet]. Toronto, ON: Centre for Addiction and Mental Health. 2020 [cited 2020 Mar Available from: osduhs/drugusereport 6) Reducing the availability of tobacco products at retail: Policy analysis [Internet]. Tilson Non-Smokers? Rights Association: Non-Smoker?s Rights Association. 2011 Apr [cited 2020 Feb 28]. Available from: 7) Region of Peel Public Health. Understanding the health effects of recreational cannabis use: A focused practice question. Mississauga, ON: Region of Peel Public Health; 2019. Available from: 8) What you need to know if you choose to consume cannabis [Internet]. Ottawa, ON: Government of Canada. 2019 [cited 2020 Feb 28]. Available from: 9) Fischer, B., Russell, C., Sabioni, P., van den Brink, W., Le Foll, B., Hall, W., Rehm, J. Room, R. (2017). Lower-Risk Cannabis Use Guidelines (LRCUG): An evidence-based update. American Journal of Public Health, 107(8). DOI: 10) Liability: There?s More to Lose Than Your Licence [Internet]. Toronto, ON: Alcohol and Gaming Commission of Ontario; 2018 [cited 2020 Feb 28]. Available from: 11) Evidence Brief: Driving Under the Influence of Cannabis and Risk of Motor Vehicle Collision [Internet]. Toronto, ON: Public Health Ontario; 2017 Sept [cited 2020 Feb 28]. Available from: 12) Cannabis Control Act, SO. 2017, c.26, Sched 1 [Internet]. 2019 Dec 10 [cited 2020 Feb 28]. Available from: 13) Regulation of Cannabis Edibles and Cannabis Cafes: Literature Search and Environmental Scan [Internet]. Edmonton, AB: Alberta Health Services. 2018 Oct [cited 2020 Feb 27]. Available from: cafes. 14) Monshouwer K, Laar MV, Vollebergh WA. Buying cannabis in 'coffee shops.? Drug and Alcohol Review. 15) Retail Store Pre-Authorization/Opening Inspection [Internet]. Toronto, ON: Alcohol and Gaming Commission of Ontario [cited 2020 Feb 27]. Available from: inspection 16) Evidence to Guide Action: Comprehensive tobacco control in Ontario (2016) [Internet]. Toronto, ON: Public Health Ontario; 2017 Apr [cited 2020 Feb 28]. Available from: 17) Liquor Sales Licences Employees: Mandatory Server and Sale Training [Internet]. Toronto, ON: Alcohol and Gaming Commission of Ontario [cited 2020 Feb 28]. Available from: 18) Controlling Physical Availability of Alcohol: Strategies to Reduce Alcohol-Related Harms and Costs in Ontario [Internet]. Toronto, ON: Ontario Public Health Association; 2015 [cited 2020 Feb 28]. Available from: 19) Livingston, M. 2012 Livingston, M. (2012). Implications of outlet density, type and concentration on alcohol consumption 8: harm. Seminar presentation, Centre for Addiction and Mental Health, Toronto, April 25, 2012. 20) Backgrounder: Final regulations on new cannabis products [Internet]. Ottawa, ON: Government of Canada; 2019 Jun 14 [cited 2020 Mar Available from: 12 21) 22) 23) 24) 25) 26) 27) 23) 29) 30) Final regulations: Edible cannabis, cannabis extracts, cannabis topicals [Internet]. Ottawa, ON: Government of Canada. 2019 Jun 14 [cited 2020 Feb 28]. Available from: Cannabis impairment [Internet]. Ottawa, ON: Government of Canada [updated 2019 Jun 17; cited 2020 Feb 28]. Available from: Outbreak of Lung Injury Associated with E-cigarette Use, or Vaping [Internet]. Atlanta, GA: Centers for Disease Control and Prevention [updated 2020 Feb 25; cited 2020 Mar Available from: Smoke-Free Ontario Act, 2017, 5.0. 2017, c. 26, Sched. 3 [Internet]. 2019 Jun 6 [cited 2020 Feb 28]. Available from The Cannabis Act and Cannabis Regulations: Promotion prohibitions [Internet]. Ottawa, ON: Government of Canada [updated 2019 Nov 5; cited 2020 Feb 28]. Available from: Cannabis Event Fact Sheet [Internet]. Rancho Cordova, CA: Bureau of Cannabis Control California [updated 2019 Feb; cited 2020 Mar Available from: Van Ooven-Houben, M. M., Bieleman, 8., 8L Korf, D. J. (2016). Tightening the Dutch coffee shop policy: Evaluation of the private club and the residence criterion. International Journal of Drug Policy, 31, 113-120. doi: 10.1016/j.drugpo.2016.01.019 What You Need to Do to Focus Action in Ontario [Internet]. Toronto, ON: Association of Municipalities Ontario; 2018 [cited 2020 Feb 28]. Available from: Retail Store Location [Internet]. Toronto, ON: Alcohol and Gaming Commission of Ontario [cited 2020 Feb 27]. Available from: Municipal Act, 2001, 5.0. 2001, c. 25 [Internet]. 2019 Dec 10 [cited 2020 Feb 28]. Available from: 13 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Penny Sutcliffe, MD, Medical Officer of Health and Chief Executive Officer Public Health Sudbury Districts 1300 rue Paris Street Sudbury, Ontario P3E 3A3 sutcliffep@phsd.ca Phone 705.522.9200 ext. 291 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario LI 3. Greater Toronto Area 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial Public Health Sudbury Districts understands that changes to the Smoke-Free Ontario Act (SFOA) 2017 are not being considered as part ofthis consultation. Further it is strongly recommended that the government ?consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. Research shows that cannabis use carries significant health risks, especially for frequent users or those who initiate use at a young age. The visibility and proximity of cannabis lounges and cafes to youth-serving facilities can normalize use and increase harms to the public (Canadian Paediatric Society, 2016; US. Department of Health and Human Services, 2016). Regular use of cannabis during adolescence or young adulthood is associated with changes to brain structure, function, and development which may limit a young person's educational, occupational and social potential. The proposed cannabis consumption lounges and cafes will not only further normalize cannabis use but, in conjunction with the current cannabis retail outlets, will increase the visibility and access to cannabis and expose young people and vulnerable populations to the promotion of cannabis use. Public Health Sudbury Districts recommends that the government does not amend the SFOA to allow for the consumption of cannabis in establishments. Currently, the SFOA prohibits the smoking of tobacco and cannabis and the use of vapour products in enclosed public places and workplaces including restaurants, bars, and patios. Employees are protected, by law, from exposure to second-hand smoke and vapour in an enclosed workplace. Allowing for the smoking or vaping of cannabis in places of work or where employees frequent puts workers at increased risk of harms. Additionally, given that the long term health impacts associated with cannabis consumption continue to be an emerging area of study, it is unknown how cannabis may be metabolized among some individuals. Establishments therefore may encounter challenges in how to serve products to the public not knowing potential outcomes as well as in determining who is legally responsible (host liability) should an incident occur. Moreover, due to the delayed onset of physiological and effects of edibles, the sale of edible cannabis for consumption in establishments can pose the risk of increased motor vehicle collisions, injuries, and death risks that are more challenging to mitigate. Locations of said establishments may further contribute to these increased risks as well as co-use of cannabis and alcohol. Substance co- use is advised against in the Lower Risk Cannabis Use Guidelines as it is known to increase health implications and risk of injury. In an ideal environment, cannabis establishments would ?be created in order to reduce outlet density which has been known to increase consumption and normalization of substances. In the event that establishments do proceed, it is essential that products such as alcohol and tobacco not be permitted for sale alongside cannabis products. Non-cannabis and non-alcoholic food and beverage items should be available in accordance with the current regulations for alcohol sales in restaurants and bars set out by the Alcohol and Gaming Commission of Ontario (AGCO). However, options would need to be evaluated for potential contraindications. For example, there is a lack of research on which foods may enhance the effects of edible cannabis orange juice increases the absorption of certain medications could there be similar interactions between food and beverages with cannabis?). Other regulations set out by the AGCO for alcohol should also be maintained for cannabis consumption establishments, including but not limiting to prohibiting the removal of cannabis products from the premise for future consumption or consumption beyond designated areas. Cannabis should not be consumed or sold on the same premise with alcohol, and individuals under 19 years of age should not be permitted access to cannabis consumption establishments. A Special Occasion Permits program for cannabis conflicts with the SFOA and by-law in key event spaces and several jurisdictions. For example, you cannot smoke or vape on publicly owned sporting areas, or in the reserved seating area of entertainment venues. Additionally, many municipalities have by-laws against smoking, vaping, or consuming cannabis in parks or public places. Should the government consider establishing a SOP program for cannabis, employees should be protected from second-hand smoke and vapour. The use of corrals should be considered at an adequate distance from areas where employees frequent. Furthermore, cannabis and alcohol should not be mixed. SOPs for cannabis and alcohol should not be approved for the same event. According to the federal regulation of edible cannabis, cannabis extracts and cannabis topicals, product rules state that edible cannabis have no added alcohol or no elements that would associate the product with alcoholic beverages, tobacco products, or vaping products. The physiological, and intoxicating effects of both substances are amplified when consumed on the same occasion. Offering both alcohol and cannabis for sale at the same event will promote co-consumption and increased health hazards associated with consumption. Additionally, making cannabis available at festivals or events requiring a SOP normalizes consumption to children and youth attending festivals and events. Whether or not alcohol is restricted at events where cannabis is permitted, individuals under 19 years of age should not be permitted access. Additionally, SOPs should not be issued to campuses or properties with a smoke-free policy. Cannabis Consumption Establishments and SOPs-may create additional population level health impacts over and above those of authorized cannabis retail stores. lnitial risks include those associated with the creation and location of establishments. lncreased access, normalization, and exposure (including second hand) to cannabis consumption are risks for individuals under 19 years of age and persons who do not consume cannabis. Employees of these establishments may be at risk on increased second-hand smoke exposure while neighbouring residents may be impacted by both health and societal risks. Retail outlet proximity to sensitive areas has been found to negatively influence vulnerable residents by increasing substance misuse, dependence, injury and harm (Alberta Health Services, 2018; Mair et al., 2015). From a consumer perspective, there may be increased risk leading to risky decision-making or infection and illness. Unlike Sandy's Law, there are no current protective messaging to pregnant and breastfeeding women about the risk associated with cannabis use. There is also risk linked to drug impaired driving. The National Cannabis Survey found that 14% of drivers polled admitted to driving after consuming cannabis at some point in their lives. In the cases of edible cannabis, products may take up to 4 hours before feeling the full effect and effects can still be felt up to 12 hours later, this will increase risk for impaired driving as well as host liability. Moreover, should establishments permit reusable or shared equipment for rent, there is risk for infection. lnfection prevention and control guidelines should be enforced similar to those for hookah. Also, in the event that individuals are permitted to bring their own products to establishments, there may be increased risk of contamination that would need to be mitigated. Also, considerations would need to be given on how medicinal cannabis could be used or not in these establishments. The following should also be considered when authorizing cannabis consumption sites and SOPE 1. Reduce cannabis retail outlet density through minimum distance requirements between cannabis retail outlets and place limits on the overall number of outlets. 2. Prevent the role-modelling of cannabis use and reduce youth access through minimum distance requirements from youth-serving facilities such as schools, child care centers and community centers. 3. Discourage the co-use of cannabis and other substances by prohibiting co-location and enacting minimum distance requirements between cannabis, alcohol and tobacco retail outlets. 4. Protect vulnerable residents by limiting cannabis retail outlets in low socioeconomic neighbourhoods and enacting minimum distance requirements from other sensitive areas. 5. Reduce cannabis consumption and harms by limiting late night and early morning retail hours. Overall, additional funds should be made available to public health agencies for training to recognize risks associated with cannabis and food preparation and/or consumption on the same premise, and to increase health promotion initiatives to mitigate the increased risk to injury in the community associated with cannabis consumption establishments and SOPs. Smoke-Free Ontario Act Inspectors and by-law officers should maintain the authority to respond to complaints and infractions relating to the SFOA and local by-laws, including those concerning cannabis consumption establishments and SOPs. Municipalities should also maintain authority to create, update, and amend local by-laws to be responsive to potential changes to the SFOA and those relating to a transition to an open cannabis market. The municipality should have the opportunity to prohibit cannabis consumption establishments and SOPs, including through local bylaw, similar to opting out of cannabis retail stores. Furthermore, Public Health Sudbury Districts recommends that the AGCO be responsible for the inspection of cannabis consumption establishments, the same entity responsible for the authorization and inspection of cannabis retail stores. Public Health Sudbury Districts appreciates the opportunity to provide input in this consultation process and to ensure that population health impacts are considered when determining next steps for cannabis establishments and special occasion permits. Recognizing that expansion of alcohol retail outlets and unrestricted promotion of vapour products have contributed to increased product consumption and negative health impacts in the past, it is also recommended that we learn from these situations when it comes to cannabis establishments and promotions. Public Health Sudbury Districts encourages the development of provincial strategies including health promotion policies to mitigate the negative health and social impacts associated with cannabis consumption. References Alberta Health Services (2018). AHS recommendations on cannabis regulations for Alberta municipalities. Retrieved from: .M.u.niei9e.iiti.e?.9d.f Canadian Paediatric Society. Cannabis and Canada's children and youth (2016) Ottawa, ON: Canadian Paediatric Society. Retrieved from: Mair C, Freisthler B, Ponicki WR, Gaidus A. The impacts of marijuana dispensary density and neighborhood ecology on marijuana abuse and dependence (2015). Drug Alcohol Depend 154:111-6. Available from: Statistics Canada. (2018). National Cannabis Survey. [data set]. Retrieved from US. Department of Health and Human Services (HHS), Office of the Surgeon General (2016). Facing Addiction in America: The Surgeon General's Report on Alcohol, Drugs, and Health. Available from: REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Shelley Aretz, RN, Public Health Nurse Thunder Bay District Health Unit 999 Balmoral St Thunder Bay, ON P7B 6E7 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial While there is a clear demand for consumption establishments currently permitting cannabis consumption on their premises through loopholes in the SFOA), the government should not facilitate the expansion of cannabis sales without strong public health policy in place to mitigate harms associated with substance use. There are local cafes/lounges that are already providing a designated smoking/vaping/use area and providing equipment rental (bongs). This designated area is >9m from the establishment's patio (as per SFOA), it does not allow food or beverage and doesn't allow seating, so it is not captured as a patio in the SFOA definition. Facilitating such establishments does present an opportunity to regulate existing establishments to protect the health of the public. Conversely, potential risks as a result of increased access to cannabis and normalization of it's use in public places such as consumption establishments, include risks to youth and other vulnerable populations, increased impaired driving, cross contamination, accidental consumption or overconsumption and drug interactions. Increased cannabis access through lounges and cafes will likely lead to increased consumption and cannabis-related harms for communities social, economic, health). 0 Alcohol sales should be prohibited at cannabis consumption establishments due to the risks associated with the consumption of alcohol and cannabis together. 0 Beverages containing both alcohol and cannabis should be prohibited 0 Cannabis consumption establishments should be required to serve non-cannabis containing food and drink to discourage overconsumption and to encourage a sober driver. 0 Cannabis consumption establishments should only serve prepacked cannabis edible products from the Ontario Cannabis Store. This will reduce the risks associated with making cannabis edibles on site including the risk for cross contamination with non- cannabis edibles and subsequent inadvertent cannabis consumption by consumers. Cannabis use is not without risk. If lessons are to be learned from increased access to alcohol in Canada, increased access to cannabis via SOP's for events/festivals will likely lead to increased cannabis consumption and increased cannabis-related harms to vulnerable populations and communities. However, the establishment of a SOP program for cannabis may encourage the public to purchase cannabis from the legal market rather than from the black market. If the government opts to establish a SOP program for cannabis to be sold and consumed at festivals and events the following should be included to mitigate potential harms from increased access to cannabis: Only those with a Cannabis Retail Operation Licence should be permitted to sell cannabis with a SOP. There should not be changes to SFOA prohibitions on smoking and vaping of cannabis. Patrons of special events always have the option to leave the premises to smoke or vape. Due to the delayed onset of action and delayed peak effect with edibles, it will prove difficult to prevent over serving a person purchasing cannabis to consume on site. To 4 mitigate this risk there should be limits on the THC content per serving and also limits on the number of servings allowed per person. Education on safe use of edibles for first time users is key as local EMS has reported an increase in calls to assist first time and naive users. Serving end time should take into consideration the delayed onset and delayed peak time for effects of cannabis edibles. The sale of cannabis edibles should end at least two hours prior to the end of the event. The event should be age restricted to ages 19+. If this is not the case then there should be established use areas with controlled entrance and exits. There should be signs at exits that state ?cannabis consumption is prohibited beyond this point?. This will help ensure that edibles cannot easily be given to minors or be accidentally consumed by minors. Cannabis edibles should be served in easily identifiable open containers in the restricted area only. Alcohol sales should be prohibited. Mixing alcohol and cannabis beverages should be prohibited. Consideration should be given to safety planning for events with a cannabis SOP to ensure proper first aid is available in case of overconsumption of cannabis or over intoxication due to mixing cannabis and alcohol or other substances and that there are procedures in place to reduce impaired driving. This should included screening vehicles exiting the premises for open containers of cannabis and for signs of impairment. Serving staff should be a required to complete a training program to recognize signs of intoxication, education on serving and educating na'I've users and around cannabis and pregnancy. Cannabis Consumption Establishments: Potential risks as a result of increased access to cannabis include risks to youth and other vulnerable populations, increased impaired driving, cross contamination, accidental consumption or overconsumption, drug interactions, and second hand smoke exposure. Expanding the legal market for cannabis to include cannabis consumption establishments normalizes cannabis use. Local data shows that youth are already mixing alcohol and cannabis with negative effects. Normalizing cannabis use and increasing availability may lead to negative health outcomes for vulnerable populations including youth, people with a history of or substance use problems and pregnant women. The District of Thunder Bay has high rates of mental health and addictions issues and a lack of access to services to address these needs. Increasing access to cannabis may further exacerbate these challenges and strains on the health care, emergency response and social support systems. The risk for impaired driving when using cannabis is complicated by the delayed onset of effect and delayed peak effect of cannabis edibles. If other substances alcohol) are also served, this will further increase risk. This could be mitigated by prohibiting the sale of alcohol, serving non-cannabis food and drinks, providing education on cannabis effects, specific to consumption method, and implementing THC limits per person. Serving end times for edible cannabis products should take into account the delayed onset and peak of effect. Thunder Bay Police Service already reports recent increasing rates of drug impaired driving. Establishing cannabis consumption establishments and SOPs may lead to further increases in impaired driving. To reduce the risk of cross contamination of cannabis containing products and non-cannabis containing products, the sale of cannabis edibles at cannabis consumption establishments should be restricted to prepackaged products from the Ontario Cannabis Store. If production is allowed on site, then further consultation should be required to develop regulations around the safe food handling of cannabis edible products. Regulations for cannabis consumption establishments need to include provisions for the safe disposal of cannabis products to prevent accidental consumption by both the public and wild life. Drug-nutrient interactions (edible cannabis in food) are not fully understood and may cause synergistic effects and increased health risk in the public setting. Smoking or vaping cannabis products in cannabis consumption establishments should not be considered under any circumstance as the health risks from second hand smoke to employees and the public are well established. SOPs: Permitting cannabis SOP's may have the benefit of regulating the use of cannabis at events such as festivals where consumers are likely already consuming cannabis. However, first time or na'I've users could benefit on guidance on consuming edibles safely. The risks and approaches to mitigating them are much the same as noted above for cannabis consumption establishments. Municipalities are uniquely aware of their local context and needs and should have regulatory mechanisms available to utilize to control density of cannabis establishments and SOPs and to control the location and proximity to areas of concern in each community. Municipalities may regulate location to ensure that cannabis consumption establishments are not located near schools and childcare facilities, facilities that treat mental health or substance use, youth group homes, shelters, facilities offering youth programming, community centres, libraries, playgrounds, and retail alcohol outlets. There may be other areas of concern identified by individual municipalities where there are already frequent substance use related harms waterways in Thunder Bay). Municipalities should have the ability to regulate cannabis consumption establishments and SOPs in response to their local needs. Enforcement is a critical in keeping the public safe. The availability of enforcement services varies widely by geographic region. There is only one AGCO enforcement officer for Northwestern Ontario. One person simply will not be able to inspect SOPs that may be occurring at the same time 8 hours apart geographically. Municipalities are aware of the enforcement capacity in their communities and should be able to grant or deny cannabis consumption establishments and SOPs based on this. Municipalities may incur costs associated with increase access and availability to cannabis through the establishment of cannabis consumption establishments and SOPs. There may be increases costs for liability insurance for events with SOPs that take place on municipal property. Cannabis consumption establishments and SOPs may lead to an increase police and EMS calls and therefore impact municipal budgets. This may be particularly true in Northwestern Ontario where most communities lack public transit and taxi service to get home safely from events. This is even further complicated by the cold climate which may deter some people from walking to and from a cannabis consumption establishment or SOP event. If the province is going to facilitate greater access to cannabis then there needs to be simultaneous equal investment in health promotion, prevention and education initiatives as well as enforcement to reduce cannabis-related harms. No consideration of changes to SFOA to allow smoking or vaping of cannabis products in any indoor workplaces or public spaces including cannabis consumption establishments or organizations granted an SOP. 0 Consider establishing THC limits per serving and a max serving per person. 0 Prohibition of preparing cannabis edibles on site. Prepackaged edibles from the Ontario Cannabis Store should be the only permitted cannabis edibles served at cannabis consumption establishments or SOPs If cannabis edibles will be produced on the premises then further consultation, especially with public health inspectors, should be undertaken to create a robust regulatory framework to reduce the risk for cross contamination and ensure safe food handling. 0 Pricing of cannabis should compete with black market. 0 Mandatory training program for staff serving cannabis should be established. At minimum this should include recognizing signs of intoxication, education on serving and educating na'I've users and around cannabis and pregnancy 0 Serving end time should take into consideration onset of effect and peak times based on use (ie cannabis edibles should not be served at closing time). Prohibition on products that appeal to youth. 0 Maintain restrictions on advertising and display that currently apply to cannabis retail establishments to minimize exposure to youth and other vulnerable populations. 0 Require the posting of health information including warnings on the risks of cannabis consumption in pregnancy, low risk cannabis use guidelines, and information specific to the products being sold, ie harm reduction information re: cannabis edibles and naive users. 0 Training for staff around not serving pregnant women (consider creation similar regulations and requirements already in place for alcohol) Government of Ontario Consultation: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Final response due: March 10 Consultation Questions: Recommendation: Do not facilitate nor permit the sale of cannabis for consumption in establishments. Rationale: Timiskaming Health Unit is part of Northern Ontario, where 31% of students grades 9-12 living in Northern Areas reported using cannabis in the past year compared to 25% in Ontario.1 Additionally, the percentage of Timiskaming residents age 12 and over that reported using cannabis more than once (38.5) was statistically higherthan the provincial percentage (31.2).2 Timiskaming Health Unit highlights the need to continue to monitor for unintended health and social consequences since cannabis legalization. The regulatory system is still new and we caution moving too quickly. Increasing access to cannabis and related products can lead to increased consumption and potential harms, especially in youth3. We know that the intoxicating and effects of ingesting cannabis are delayed when compared to inhaling cannabis4. Delayed onset and ongoing effects of edibles/ingestible cannabis can result in challenges to prevent intoxication; public intoxication has immediate risks for the consumer and the public impaired driving, overconsumption). Also, one could not control for co-consumption of alcohol and cannabis beyond the establishment. We encourage the government to look back at lessons learned with alcohol and tobacco legislation, and not rush into normalizing the use of harmful substances without proper consideration of related health consequences. Strong public health policies need to be in place in orderto mitigate cannabis? negative health and social impacts. Such a change in legislation could lead to increased instances of impaired driving. This could result in an increase of impaired drivers on our highways. There is already a lack of enforcement capacity and measures within the 1 Boak, A., Hamilton, H. A., Adlai, E. M, Henderson, J. L., Mann, R. E. (2018). The mental health and well-being of Ontario students, 1991-2017: Detailed ?ndings from the Ontario Student Drug Use and Health Survey (OSDUHS) (CAMH Research Document Series No. 47). Toronto, ON: Centre for Addiction and Mental Health. 2 Canadian Community Health Survey 2015-16. Statistics Canada, Share Files, Ontario Ministry of Health and Long-Telm Care 3 Canadian Public Health Association P08 i i STATE Public Heaith Approach to the Legalization, Regulation and Restriction ofAccess to Cannabis, OCTOBER 2017 4 Timiskaming Health Unit 1 March 9, 2020 current cannabis market. Additional expansions will lead to increased potential of illegal and underage cannabis use, and related harms. Timiskaming Health Unit does not support facilitating the sale of cannabis for consumption in establishments (see rationale in Should government decide to proceed, we suggest the following to help mitigate the public?s health risks and harms: Prohibited alcohol sales due to risks associated with co-consumption of alcohol and cannabis5 0 Only serve pre-packaged products from the Ontario Cannabis Store 0 Require staff to be properly trained 0 Implement age restriction to match current legislation 0 Prohibit exterior promotion and advertising 0 Limit proximity to areas frequented by youth such as schools, recreation facilities and libraries. Recommendation: Do not consider establishing a SOP program for cannabis to be sold and consumed at festivals and events (see rationale in 1) 5 Pubtr'o Heatth Ontario, EVIDENCE BRIEF Risk Factors for Simultaneous Use ofAloohol and Cannabis, 2018 Timiskaming Health Unit 2 March 9, 2020 Yes - refer to rationale in 1 Other potential risks include use of unregulated/tainted cannabis products as well as unintended consumption due to lack of supervision and enforcement. Municipalities should have the authority to allow, locate, license and regulate cannabis consumption establishments and SOPs. The same protocols should be in place as alcohol related establishment and SOPs. Healthy public policy is an essential element of a comprehensive public health approach. As provincial government leaders, you can make significant contributions to the health and well-being ofthe people you serve. We ask that the provincial government provide assurancesthat there will be no reversal ofany ofthe SFOA prohibitions on smoking or vaping in public places at any time in the future. We also ask that provincial strategies be considered to clearly communicate the health risks associated with cannabis consumption in general and implement measures to mitigate them. March 9, 2020 Timiskaming Health Unit 3 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Dr. Eileen de Villa Medical Officer of Health Toronto Public Health 277 Victoria Street, 5th Floor Toronto, Ontario M58 1W2 email: Eileen.deVilla@toronto.ca phone: 416-338-7820 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial I The Province?s decisions related to the sale of cannabis for consumption on?site should be guided by public health principles and social responsibility, and should not be profit?driven. The City should play a central role in any decisions regarding the sale of cannabis for on? site consumption in Toronto. It is important that the Province conduct comprehensive consultations with municipalities, public health entities and community stakeholders to inform drafting of rules and regulations for cannabis lounges/ cafes. It is recommended that the Province not consider the sale of cannabis for consumption in establishments if it should in any way violate the Smoke?Free Ontario Act, 2017 (SFOA) prohibitions and City of Toronto bylaws. 0 Evidence on the public health impacts associated with consumption of edible cannabis is evolving and there is much that is unknown. Although consumption of THC?infused (cannabis) edible products may eliminate respiratory risks associated with smoking or vaping, consuming edible products may result in increased and unique adverse health effects such as consumption of larger doses because of the delayed onset of effects, and more intense and longer lasting effects compared to smoking or vaping The SFOA currently prohibits the smoking and vaping of cannabis anywhere the smoking of tobacco and the vaping of any substance is prohibited. For ease of enforcement and to reinforce existing public messaging, Toronto Public Health recommends no amendments be made to these provisions in the SFOA and that vaping continue to be prohibited anywhere smoking is currently prohibited. 0 The sale and consumption of cannabis would have to be in a format that does not violate the places of use prohibitions in the SFOA. 0 Alcohol should be prohibited in establishments that allow the consumption of cannabis edibles. Co?consumption of cannabis and alcohol increases intoxication and impairment. 0 Smoking, vaping, or "dabbing" of cannabis should be prohibited in such establishments and therefore, the sale of cannabis accessories for customer use only on?site should be prohibited. It is recommended that all cannabis products be provided to patrons at such establishments in the original, federally regulated packaging to prevent cross? contamination, mixing and/ or accidental misplacement of cannabis edibles with other food and beverages. It is recommended that preparation of food is not permitted at such establishments. Non? alcoholic beverages, with limitations on caffeinated drinks, and ready?to?eat food may be considered for sale. 0 If the provincial government does establish a similar SOP program for cannabis, then conditions to ensure the health and safety of patrons and staff at such events should be implemented. This would include measures such as prohibiting cannabis co?use with alcohol or tobacco, enforcement of the Smoke?Free Ontario Act (SFOA, 2017), encouraging own ers/ operators to facilitate safe transportation for customers, and restricting opening hours, and enforcement of regulations on marketing and promotion of cannabis, among other health harm reduction approaches. Cannabis Consumption Establishments Impaired driving is a key public health concern related to cannabis consumption. The provision of safe transportation for intoxicated patrons should be considered. Safe transportation options include a designated driver program in place (including advertising of such a program at the event/ venue), providing free non?alcoholic drinks for designated drivers, promoting the use of taxis, public transportation. It is recommended that adequate staff training, that meets specific requirements to minimize risks for patrons from overconsumption ofTHC?infused products and impairment, is required similar to Smart Serve training for bartenders and servers). SOPs: 0 The comments above for establishments apply to SOPs as well. 0 While changes to the SFOA regime are not being considered, the proposed cannabis consumption establishments/SOPs introduce the need to consider how to regulate and enforce compliance with the SFOA at these venues/ events. There may be challenges with enforcing the SFOA, especially for events held in outdoor locations. 0 Given that youth are at a higher risk for negative health and safety effects associated with cannabis use, specific measures should be taken to minimize these risks and to prevent normalizing cannabis use for this group. It is important that the Province conduct comprehensive consultations with municipalities, public health entities and community stakeholders prior to developing a framework for cannabis consumption establishments or SO Ps. Edible cannabis are new cannabis products to the legal market. The regulatory framework must also be flexible and adapt policies based on emerging evidence. To this end, it is recommended that the Province monitor and report on the full range of health impacts (negative and positive), consumption rates and unintended consequences of the new classes of cannabis products. IVIoreover, given that edible cannabis may be an unfamiliar method of consuming cannabis for many people, it is recommended that public education also focus on establishing youth?protective, healthy social norms for the consumption of cannabis products. If SOPs are for events/ venues where children and people from sensitive populations could be attending, additional population?specific harm reduction messaging youth, pregnant or breastfeeding individuals, etc.) should be required. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis?ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Amy Estill Manager, Health Promotion Wellington-Dufferin-Guelph Public Health 160 Chancellors Way Guelph ON N1G 0E1 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Because of multiple public health concerns posed by cannabis consumption establishments, WelIington-Dufferin-Guelph Public Health does not support the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. More cannabis availability will lead to more cannabis-related harms. has concerns about increased normalization of cannabis use without proper consideration of the associated health consequences. Lessons from alcohol and tobacco have shown that increased availability of substances results in increased consumption, which can lead to significant health and social harms and costs?. The delayed onset and longer-lasting effects of cannabis edibles can lead to public intoxication, over-consumption and impaired driving. It can take 30 minutes to 2 hours after consumption to begin to feel the effects of edible cannabis products, but up to 4 hours to feel the full effects. Effects can last up to 12 hours, and some residual effects could last up to 24 hours after use3. In otherjurisdictions that have legalized edible products, edibles are responsible for a significant number of healthcare visits due to cannabis intoxication?. In a 2019 study that described and compared adult emergency department visits related to edible and inhaled cannabis exposure 3 at a large urban academic hospital in Colorado, it was found that emergency department visits attributable to edible cannabis were more likely to be due to acute intoxication and cardiovascular Another Colorado study that examined surveillance of emergency department visits for acute adverse effects of marijuana found that cases were significantly more likely to report edible cannabis use rather than smoke cannabis uses. Should the government facilitate the sale of cannabis for consumption in a lounge or caf? establishment, the following considerations should be made: 1. Products sold and consumed: Only the sale of non-smoked or non-vaped cannabis products from federally licensed producers should be permitted, such as edible or beverage products. Such products should be sold only in their original packaging and not be removed from their packaging by anyone other than the consumer. Products purchased in the establishment must be consumed onsite, and any leftover product must be left in the establishment to be safely discarded. Patrons should be prohibited from bringing in and/or consuming their own cannabis purchased or obtained elsewhere. Currently, the Lower-Risk Cannabis Use GuIdeIInes (LRCUG) do not provide recommendations on quantity of use in? 22:22 . .-2 Alcohol Drinking Guidelines provide daily/weekly recommendatIons based on the quantity of standard alcohol units. Research is undenNay to determine a standard unit measure that reflects the dose of 22:22::52222::2253:22:22" key pharmacological constituent, THC, that applies to all cannabis products and methods of administration7. Just as standard alcohol units equals grams of alcohol, standard THC units should equal milligrams of THC. The question that must be answered to minimize public risks is, how many mg of THC should form one standard unit? Current research suggests 5 mg, which is half of the THC limit allowed for edibles (per package) or ingested extracts (unit/dispensed amount)7. Further research is needed before specific recommendations can be made on maximum amounts of cannabis that should be purchased/served. 2. Establishment operators: Only locations with an approved Cannabis Retail Store Authorization should be permitted to operate as a cannabis consumption establishment. All regulations under the current Ontario Cannabis Licence Act, 2018 should be applied to the operations of a cannabis consumption establishment in terms of operation and training requirements, permitted cannabis products, purchase and possession limits, display and promotion and security measures. 3. Prohibition of alcohol: Using alcohol and cannabis together can lead to more harmful and unpredictable health consequences than the use of either substance alone8=9=1?=11. Additionally, one of the biggest concerns with simultaneous use of cannabis and alcohol is the increased risk of impaired driving and the risk of collision8=9=12. Consequently, a cannabis consumption establishment should be prohibited from selling alcohol. 4. Responsible staff training program: An additional cannabis service training program should be developed and required for all operators and employees of cannabis consumptIon estab Ishments to complete mm to the operation start date Such a .. 2;aining program for alcohol service and Include safety protocols lImIts on service of cannabis to patrons, and how to respond In an emergency situation incident of over- consumption that requires medical attention). 5. Age restrictions: To align with current restrictions on cannabis retail sale regulations, cannabis consumption establishments should be restricted to allow only those 19 years of age and older to enter the premises, to purchase or consume products and to sell products. 6. Promotion prohibitions: To align with the Ontario Cannabis License Act, 2018, public promotion visible outside of the establishment should not be permitted. It should also be explicitly noted in regulations related to these establishments that they are not to encourage entry into the establishment by way of promoting them as an entertainment venue movie, trivia nights, or live performances) because this could encourage patrons to visit the establishment who may otherwise not be exposed to cannabis consumption. 7. Health information requirements: Posting of health information including potential effects of use; risks of over-consumption, co-use with alcohol; consumption during pregnancy; the Lower-Risk Cannabis Use Guidelines (LRCUG) and information specific to the products being sold should be required in all cannabis consumption establishments. 8. Protection from second-hand smoke: Although it was noted on the Regulatory Registry that the government is not considering changes to the SFOA regime as part of this consultation, it must be emphasized that no considerations should ever be given to loosenIng any of the regulatory restrictions that protect OntarIans from second hand exposure to cannabIs smoke or vapour in enclosed pub Ic places are based on well- known, well- documented and significant health risks associated with inhaling smoke of any kind. Any motion towards considering exemptions for combustible or vapourized cannabis in any enclosed public place would be an unacceptable step backwards. Any smoking/vaping of products should be prohibited in the establishment as well as prohibited within 9 metres of any patios or outside area operating in conjunction with food or beverage sale. 9. Municipal Controls: Because we know that high outlet density can contribute to increased consumption and harms13=14=15=16 and that proximity to youth-serving facilities can normalize and increase substance usema, municipalities should be empowered to use licensing or land-use by-laws to control the placement and number of cannabis consumption establishments. References 1. Babor T, Caetano R, Cassell S, Edwards G, Giesbrecht N, Graham K, Rossow l. (2010). Alcohol no ordinary commodity: Research and public policy (Second New York, USA: Oxford University Press. Ottawa, ON. 2. Smoke-Free Ontario Scientific Advisory Committee, Ontario Agency for Health Protection and Promotion (2017). Evidence to guide action: Comprehensive tobacco control in Ontario. Available from: FullReport.pdf. 3. Health Canada. What you need to know if you choose to consume cannabis [Internet] 2019 June [cited 2020 March Available from: choose-to-consume- cannabis.html?utm source=mailchimp&utm medium=edibles en&utm content=infog cntk&utm campaiqn=cannabis-19 5 4. Monte AA, Zane RD, Heard KJ. The implications of marijuana legalization in Colorado [Internet]. 2015 [cited 2020 Mar Available from: 5. Monte AA, Shelton SK, Mills E, Saben J, Hopkinson A, Sonn B, et al,. Acute Illness Associated With Cannabis Use, by Route of Exposure: An Observational Study. Ann Intern Med. 2019 March 26; 6. Marx GE, Chen Y, Askenazi M, Albanese BA. Surveillance of Emergency Department Visits for Acute Adverse Effects of Marijuana, Tri-County Health Department, Colorado, 2016-2017. Pub Health Reports. 2019; 134(2): 132-140. 7. Freeman T. Cannabis and cannabinoids: Health effects and lower risk use. 2019 December 4. Ontario Public Health Collaborative on Cannabis teleconference meeting. 8. Public Health Ontario. Evidence Brief: Risk factors for simultaneous use of alcohol and cannabis [Internet]. 2018 August [cited 2019 May 24]. Available from: 9. Subbaraman MS, Kerr WC. Simultaneous versus concurrent use of alcohol and cannabis in the National Alcohol Survey. Alcohol Clin Exp Res. [Internet]. 2015 [cited 2019 May 24]. Available from: 10. Parent Action on Drugs. Stats, facts and talking points about alcohol and other drugs: Parent Action Pack [Internet]. 2018 [cited 2019 May 24]. Available from: ENG 2018 FINAL sinqle paqes.pdf 11. Canadian Students for Sensible Drug Policy Sensible Cannabis Education: A toolkit for educating youth [Internet]. 2018 [cited 2019 May 24]. Available from: Youth.pdf 12. Canadian Centre on Substance Use and Addiction (CCSA). Clearing the smoke on cannabis. Cannabis use and driving: an update [Internet]. 2017 [cited 2019 May 24]. Available from: Driving-Report-2017-en.pdf 13. Popova S, Giesbrecht N, Bekmuradov D, Patra J. (2009). Hours and days of sale and density of alcohol outlets: impacts on alcohol consumption and damage: a systematic review. Alcohol 14. World Health Organization (2010). Global strategy to reduce the harmful use of alcohol. Available from: 15. Borodovsky JT, Lee DC, Crosier BS et al. (2017). US cannabis legalization and use of vaping and edible products among youth. Drug Alcohol Depend 177:299-306. Available from: 16. Mair C, Freisthler B, Ponicki WR, Gaidus A. The impacts of marijuana dispensary density and neighborhood ecology on marijuana abuse and dependence (2015). Drug Alcohol Depend 154:111-6. Available from: ncbi. nih. qov/pmc/articles/PMC4536157 17. U. S. Department of; Health and Human SerVIces (HHS) Of?ce of the Surgeon General (2016). and Health. AvaIIable from l/addIctIon surqeonqeneral qov/surqeon qenerals- eport ON CanadIan PaedIatrIc AvaIIable from cps. children-and-vouth. lf cannabis consumption establishments were considered in Ontario, the following products should be permitted for sale: Cannabis accessories: To align with current Ontario cannabis retail regulations which specify that licensed cannabis retailers may only sell products and accessories which are directly related to cannabis, cannabis accessories that relate to edible and/or beverage products should be permitted for sale. At this time, it is unclear what these accessories might be, as most cannabis accessories relate to inhaled forms of cannabis, but supports consistency across regulations. Food/beverage products that do not contain cannabis: Absorption of cannabis edibles occurs more slowly and the amount of THC absorbed varies based on what has previously been consumed?. Consuming an edible on an empty stomach results in greater effects because the proportion of THC to other bioproducts is larger1. This evidence provides rationale for permitting the sale of food/beverage products that do not contain cannabis; however, it is imperative that cross-contamination of cannabis and non-cannabis food/beverage products be avoided. Therefore, only pre-packaged items for both cannabis and non-cannabis food/beverage products should be permitted to be sold in their original packaging. The preparation of non-cannabis beverage and food items should be prohibited to reduce the risk of cross-contamination with products containing cannabis. According to Ontario Cannabis Act regulations, edible cannabis products are allowed to have up to 30 milligrams of caffeine, if it is naturally occurring (for example, in chocolate, coffee and tea) and must contain no nicotine or added alcohol. To align with these regulations, the sale and consumption of alcoholic beverages should be prohibited along with high-caffeine beverages energy drinks) and products that contain nicotine. References 1. Caulkins JP, Kilmer B, Kleiman MAR. Marijuana Legalization. Second. New York: Oxford University Press; 2016. 2. Huestis MA. Human Cannabinoid Pharmacokinetics. Chem Biodivers. 1804. Similar to our response to question 1, does not support establishing a SOP program for cannabis to be sold and consumed at special events and large-scale public events. An SOP program may lead to an increased risk of public intoxication, over-consumption and impaired driving in addition to concerns around normalization of cannabis use. The sale and consumption of cannabis at festivals and events poses unique risks, as event organizers are not likely to have the capacity to provide the necessary levels of security currently required of retail stores, including measures to verify age and to ensure that patrons do not exceed possession limits. Should the government establish an SOP program for the sale and consumption of cannabis at festivals and events, the following should be considered: 1. Products sold and consumed: Only the sale of non-smoked or vaped cannabis products from federally licensed producers should be permitted, such as edible or beverage products. Such products should be sold only in their original packaging and not be removed from their packaging by anyone other than the consumer. Products purchased at the event must be consumed onsite, and any leftover product must be left at the event to be safely discarded. Patrons should be prohibited from bringing in and/or consuming their own cannabis purchased or obtained elsewhere. To prevent over- consumption, there should be limits on the amount of cannabis consumers are permitted to purchase and vice versa. As stated earlier, research is currently undenIvay to determine a standard dose (standard THC unit) that applies to all cannabis products and methods of administration. At this time, however, specific recommendations can not be made on the maximum amount of cannabis that should be permitted to be purchased/sold. Serving end time should take into consideration the delayed onset and delayed peak time for effects of cannabis edibles. The sale of cannabis edibles should end at least two hours prior to the end of the event. 2. Vendors: Only retailers with an approved Cannabis Retail Store Authorization should be permitted to set up as a vendor at a public event. Protocols for age verification should be required along with security measures for the storage of cannabis products not on display and not accessible to the public). 3. Prohibition of alcohol: The sale and/or consumption of alcohol at the same event should be prohibited to prevent co-use and increased public health risks over- consumption, impaired driving). 4. Responsible vendor training program: An additional cannabis service training program should be developed and required for all vendor operators and event staff to complete prior to the event date Such a program should be similar toiiE we? training program for alcohol service and include safety protocols, limits on service of cannabis to patrons and how to respond in an emergency situation incident of over-consumption that requires medical attention). 5. Age restrictions: All grounds and premises related to the SOP event should be restricted to only those 19 years of age and older. This includes individuals permitted to purchase and/or consume any cannabis product or accessory, any person involved in handling or selling a cannabis product, as well as any person involved in the operations of the event, including volunteers or event staff. 6. Promotion prohibitions: Provisions would need to be made to require that there is no public promotion outside of the SOP area which would be visible to youth under 19 years of age. To protect youth exposure, the conditions of the SOP should adhere to the Federal Cannabis Act, section 17, which states that the promotion of cannabis, a cannabis accessory or a service related to cannabis are prohibited where the promotion may be audible or visible from outside a place where young persons are not permitted by law. While it would be difficult to fully obscure viewing of the activities which take place on the premises of a special event, efforts should be made to ensure cannabis use is out of view of the public. 7. Sponsorship prohibitions: The sponsorship of any event by a cannabis retailer or licensed producer should remain prohibited to align with the Federal Cannabis Act. Section 21 of the Act states that it is prohibited to display, refer to or othenIvise use any of the following, directly or indirectly in a promotion that is used in the sponsorship of a person, entity, event, activity or facility: a brand element of cannabis, of a cannabis accessory or of a service related to cannabis; and the name of a person that produces, sells or distributes cannabis, sells or distributes a cannabis accessory, or provides a service related to cannabis. 8. Health information requirements: Posting of health information including potential effects of use; risks of over-consumption, co-use with alcohol, and consumption during pregnancy; the Lower-Risk Cannabis Use Guidelines (LRCUG) and information specific to the products being sold should be required at all SOP events. 9. Smoking/vaping in Designated Smoking Areas (DSA): Any smoking or vaping activity should be prohibited unless in a DSA and should be restricted to areas outside those prohibited in the SFOA, 2017 or a municipal by-law. Cannabis Consumption Establishments There are many lessons from jurisdictions that currently permit cannabis consumption establishments and/or SOPs that can be considered in the Ontario context. A literature search and environmental scan on the regulation of cannabis edibles and cannabis cafes completed by Alberta Health SerVIces In 2018 descrIbed cannaii; .. use cannabIs products SInce theIr InceptIon cannabIs coffee shops have faced increased restrictions because nuisance issues (including traffic problems, noise, loitering and large numbers of tourists) were problematic. In response to these issues, policy measures have been implemented to relocate coffee shops away from city centres, and in some instances, have been closed by local authorities1. In addition, coffee shops were originally permitted to sell up to 30 grams of cannabis per person per day, which was eventually reduced to five grams2. This example illustrates the importance of determining a standard THC unit for cannabis products as well as limits on maximum amounts of cannabis that can be purchased/sold. In the United States, California and Colorado allow cannabis consumption lounges. Also referred to as 'i?cannabis social use venues?, they are indoor businesses where customers can legally smoke, vape or ingest cannabis. California allows local jurisdictions the option to approve cannabis lounges if the business does not sell cannabis and is attached to a licensed cannabis retailer3. This model should be assessed for feasibility in Ontario, as only permitting cannabis consumption establishments within licensed cannabis retail outlets addresses some public health concerns around increased access to cannabis and normalization of cannabis use, especially among youth. It should be noted, however, that smoking or vaping indoors should not be permitted in Ontario, in accordance with the SFOA, 2017. - - -: also allows restaurants, hotels and other businesses to apply for cannabIs consumptIon licenses. The law includes an allowable exemptIon . . Clean Indoor Air Act, a state lawthat bans public indoor smoking. Local jurIsdIctIons can opt in to the new licensing program and can prohibit certain forms of consumption, such as indoor smoking or vaping3. There are several practical challenges associated with allowing existing food/beverage establishments e. ,restaurants) to hold cannabis consumptIon lIcenses Although the cannabis consumption lounge Is required to be in an . . restaurant (which may be partitioned with a wall or other barrier), and th e there mIght be restrictions to access this area, there are no limits e. ,age) to accessing the restaurant itself. In this sense, there are a lot of parallels to designated smoking areas, espeCIally if smokIng and/or vaping are permitted Another Issue with this model is that iti: store loophole In other words, even though one estab Ishment Is not permItted to hold a liquor and cannabis consumption license, if the cannabis consumption area inside the restaurant is treated as a separate establishment within the larger restaurant establishment, in theory, it could then hold both licenses. This means that patrons could consume cannabis and alcohol within the same restaurant, even if they must go to separate areas within the restaurants. For these reasons, licenses for a cannabis consumption establishment should be prohibited within an establishment which also has a liquor license or serves any form of alcohol.4 In the United States, there is a growing trend for states to allow exceptions for indoor public cannabis use in venues that are currently required to be smoke-free A concern is that allowances for?. on- site cannabis consumption may roll back existing smoke-free protections that -- i 111:; i-hand smoke and aerosols3. Consequently, it must be re- Iterated that no consIderatIons should ever be given to loosening any of the regulatory restrictions outlined In the SFOA, 2017. SOPs Best practices from the development of Municipal Alcohol Policies (MAPs) can also be applied to potential cannabis SOPs. The following MAP components should be considered for cannabis SOPE Management Strategies5: Permit holder (event sponsor) and/or designate is not to consume cannabis before or during the event Event staff are not to consume cannabis before or during the event Prevention Strategies5: Safe transportation provision designated driver, RIDE sign, etc.) 10 No caffeinated energy drinks to be sold Appropriate and sufficient non-cannabis food is available (recommended to be pre- packaged to avoid cross-contamination with cannabis edible products) Prohibit patrons from entering with cannabis products purchased off permit Signs5: Statement of intoxication Safe transportation Acceptable ID RestrIcted (cannabIs IneIIgIble) areas or conditions of area posted .-: {Ii I- l. preg a 0y) InformatIon on the LRCUG References 1. Van Ooyen-Houben MM, Bieleman B, Korf DJ. Tightening the Dutch coffee shop policy: Evaluation of the private club and the residence criterion. International Journal of Drug Policy, 2016; 31 :1 13-120. 2. Monshouwer K, Van Laar M, Vollebergh WA. Buying cannabis in coffee shops. Drug and Alcohol Review, 2011; 30(2): 148-156. 3. Steinberg J. Unger JB, Hallett C, Williams E, Baezconde-Garbanati L, Cousineau MR. A Tobacco Control Framework for Regulating Public Consumption of Cannabis: Multistate Analysis and Policy Implications. Am Public Health, 2020; 110: 203-208. 4. Moscetti CW. A Time and Place for Everything? Marijuana Social Use Policies. 2019 September 24. International Public Health Forum on Cannabis. Quebec City, Quebec. 5. Adapted Municipal Alcohol Policy Quality Measure Form (Adapted by Peterborough Public Health, September 2016). Original Source: Narbonne-Fortin C, Rylett M, Douglas RR, Gliksman L. (2003). The Municipal Alcohol Policy Guide: a practical resource for successfully managing drinking in recreational settings. Centre for Addiction and Mental Health, Toronto, p. 197. camh. Iibrarv/Documents/Repositorv ?/20 20D I Cannabis Consumption Establishments Because we knowthat high outlet density can contribute to increased consumption and harms and that proximity to youth-serving facilities can normalize and increase substance use, municipalities should be empowered to use licensing or land-use by-laws to control the placement and number of cannabis consumption establishments. Municipalities should be given the opportunity to: Control cannabis consumption establishment density. This could happen through minimum distance requirements between cannabis consumption establishments and limits on the overall number of establishments; Prevent the role-modeling of cannabis use and reduce youth access through minimum distance requirements from youth-serving facilities such as schools, child care centres and community centres; 11 Discourage the co-use of cannabis and other substances by prohibiting co-location and enacting minimum distance requirements between cannabis consumption establishments and alcohol or tobacco retail outlets; and Protect vulnerable residents by limiting cannabis retail outlets in low socioeconomic neighborhoods and enacting minimum distance requirements from other sensitive areas, such as mental health facilities. SOPs Municipalities should be granted the authority to enact by-laws that permit or prohibit the sale and/or consumption of cannabis on municipal property and include additional conditions based on the needs of each municipality. Applications for SOPs should be required to abide by any municipal policies to ensure compliance with by-laws and conditions of use of municipal property. Municipalities should be informed of any applications in the same fashion as alcohol SOPs where at least 30 or 60 days notice must be provided by the permit holder to the local municipality, police, and fire and health departments notifying them of the event. The building department must be notified as well if a tent, marquee, pavilion or tiered seating is used. does not support the sale of cannabis for consumption in establishments like lounges and cafes or the establishment of an SOP program for cannabis at large-scale public events. More cannabis availability will lead to more cannabis-related harms. Lessons from alcohol and tobacco have shown that increased availability of substances results in increased consumption, which can lead to significant health and social harms and costs. Because of the delayed onset and longer-lasting effects of cannabis edibles, there are concerns around public intoxication, over-consumption and impaired driving. Should the government facilitate the sale of cannabis for consumption in a lounge or caf? or establish an SOP program for cannabis, the following key considerations should be made: 1. Products sold and consumed: Only the sale of non-smoked or vaped cannabis products from federally licensed producers should be permitted, such as edible or beverage products. Only pre-packaged cannabis and non-cannabis food/beverage products should be permitted to be sold in their original packaging. The preparation of non- cannabis beverage and food items should be prohibited to reduce the risk of cross-contamination with products containing cannabis. Products must be consumed onsite, and any leftover product must be left behind to be safely discarded. Patrons should be prohibited from bringing in and/or consuming their own cannabis purchased or obtained elsewhere. To prevent over-consumption, there should be limits on the amount of cannabis consumers are permitted to purchase and vice versa. Research is currently undenNay to determine a standard dose (standard THC unit) that applies to all 12 cannabis products. At this time, specific recommendations can not be made on the maximum amount of cannabis that should be permitted to be purchased/sold. To align with current Ontario cannabis retail regulations which specify that licensed cannabis retailers may only sell products and accessories which are directly related to cannabis, cannabis accessories that relate to edible and/or beverage products should be permitted for sale. Serving end time should take into consideration the delayed onset and delayed peak time for effects of cannabis edibles, and the sale of cannabis edibles should end at least two hours prior to the end of a SOP event. Prohibition of alcohol: Using alcohol and cannabis together can lead to more harmful and unpredictable health consequences than the use of either substance alone. Additionally, one of the biggest concerns with simultaneous use of cannabis and alcohol is the increased risk of impaired driving and the risk of collision. Consequently, a cannabis consumption establishment/SOP event should be prohibited from selling alcohol. Responsible staff/vendor training program: An additional cannabis service training program should be developed and requIred for all operators/vendors and employees/event staff .- 1 - -- - protocols lImIts on service of cannabIs to patrons and how to? respond in an emergency situation incident of over-consumption that requires medical attention). Protection from second-hand smoke: Although it was noted on the Regulatory Registry that the government is not considering changes to the SFOA regime as part of this consultation, it must be emphasized that no considerations should ever be given to loosening any of the regulatory restrictions that protect Ontarians from second-hand smoke and vapour in enclosed public places. Municipal Controls: Because we know that high outlet density can contribute to increased consumption and harms and that proximity to youth-serving facilities can normalize and increase substance use, municipalities should be empowered to use licensing or land-use by-laws to control the placement and number of cannabis consumption establishments. Applications for SOPs should be required to abide by any municipal policies to ensure compliance with by-laws and conditions of use of municipal property. 13 14 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit As part of Ontario?s transition to an open market, the government would like yourfeedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being dn'ven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario?s cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: . cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) . cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) . cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada?s rules for edibles, extracts and topicals, please visit: the-p nnabis-extracts-a nd-cannabis-topicals. Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Eric Nadalin Manager; Chronic Disease and Injury Prevention Windsor-Essex County Health Unit 1005 Ouellette Ave, Windsor, ON, NQA 4J8 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Due to multiple public health concems posed by cannabis lounges and cafes, including but not limited to the high risk for intoxication and normalization of cannabis use, the Windsor-Essex County Health Unit does not support the sale of cannabis for consumption in these establishments. Providing a space for the consumption of cannabis edibles in a public setting enhances the risk of unpredictable intoxication due to individual levels of tolerance and the delayed onset of intoxicating or effects. Compared to inhaled forms of cannabis, edible cannabis products may take up to 2 hours for an individual to start feeling the effects, with a peak effect onset time of up to 4 hours. The effects of edibles may also persist for 6-12 hours. The unpredictability and delayed onset of effects poses safety risks not only for the consumer, but also liability risks for the establishment operator for any incident that occurs once the patron leaves the establishment motor vehicle collision, illness associated with overconsumption such as vomiting, fainting, severe anxiety or panic attack, loss of reality or paranoia). Moreover, the current regulations under SFOA, 2017, have carried forward the progress of SFOA, 2006, by prohibiting the smoking of cannabis and e-cigarettes in enclosed workplaces and enclosed public places. This movement has been well adopted and continues to be accepted by Ontarians as an effective way to prevent exposure to second-hand smoke. In order 3 to continue this progress of both protecting individuals from the negative health effects of exposure to smoke and second-hand smoke, and de-normalizing smoking behaviour, the government should, in particular, not consider facilitating the sale of smoked or vaped forms of cannabis for consumption in establishments like lounges and cafes. Prohibiting this sale and consumption will not only protect the patrons of such establishments, but also those of neighbouring businesses. Additionally, there would be a disproportionate impact on those who sought employment in these establishments. Long-term exposure to second-hand smoke and its known toxins and carcinogens could exacerbate existing conditions or lead to chronic illness among those seeking employment low socio-economic status) and who may already be at an increased risk for several negative health outcomes. Should the government facilitate the sale of cannabis for consumption in a lounge or cafe establishment, only the sale and use of non-smoked or vaped products should be considered. In addition, the following considerations should be made: 1. Products sold and consumed: Only the sale of non-smoked or non-vaped cannabis products from federally licensed producers should be permitted, such as edible or beverage products. Such products should be sold only in their original packaging and not removed from their packaging by anyone other than the consumer. This will ensure consumers know the levels of THC and GED that they are consuming, as well as other ingredients, and protect against overconsumption. In this regard, preparation of these products onsite should not be permitted and patrons should be prohibited from bringing in and/or consuming their own cannabis which was purchased or obtained elsewhere. This will reduce the risk of over-intoxication and harms, as well as reduce the liability risk to the establishment. 2. THC and serving size limits: Limits on the amount of THC in products sold and maximum servings per person, per visit, should be established to prevent overconsumption (for example, 2.5mg THC serving sizes). 3. Hours of product sales: The sales and service of edible cannabis should end a minimum of 2 hours before the establishment closing hours to account for the delayed onset of effect and peak times based on the product and individual variances. 4. Establishment operators: Only locations with an approved Cannabis Retail Store Authorization should be permitted to operate as a cannabis consumption lounge or cafe. All regulations under the current Ontario Cannabis Licence Act, 2018, should be applied to the operations of a cannabis consumption lounge or cafe in terms of operation and training requirements, permitted cannabis products, purchase and possession limits, display and promotion, and security measures. 5. Prohibition of alcohol: Licenses for a cannabis lounge or cafe should be prohibited within an establishment which also has a liquor license or serves any form of alcohol. 6. Staff training: An additional cannabis service training program should be developed and required for all operators and employees of consumption establishments to complete prior to the operation start date. Such a program should be similar to the ?Smart Serve? training program for alcohol service and include safety protocols, and limits on service of cannabis to patrons to protect them from overconsumption/over- intoxication and harm. Staff would also need to be educated on a process to determine 4 whether patrons are fit to leave the establishment and operate a motor vehicle. Ultimately there may be liability for business owners should an intoxicated or impaired individual leave their establishment and cause a motor vehicle collision. 7. Age restrictions: The establishment should be age restricted to allow only those 19 years of age and older to enter the premises, to purchase or consume products, and to sell products, in line with current restrictions on cannabis retail sale regulations. 8. Promotion prohibitions: Provisions would need to be made to require that there is no public promotion visible outside of the establishment, as currently stated in the Ontario Cannabis License Act, 2018. It should also be explicitly noted in regulations related to these establishments that they are not to entice entry into the establishment by way of promoting them as an entertainment venue. The promotion of their use as an event space or entertainment venue movie or trivia nights, live music performances, etc.) would entice patrons to use the establishment who may otherwise prefer not to be exposed to cannabis consumption. 9. Protection from second-hand smoke: Any smoking/vaping of products should be prohibited in the establishment, and prohibited within 9 metres of any patios or outside area operating in conjunction with the food or beverage sale. 10. Municipal Controls: Municipalities should be empowered to enact zoning and licencing regulations to have an influence over where these stores are located away from sensitive land uses like schools, parks, day cares, or addictions treatment centres). If cannabis consumption establishments were considered in Ontario, the sale of food/beverage products that do not contain cannabis should not be permitted in order to reduce the cross-promotional inducement to purchase cannabis products, and reduce exposure to cannabis use behaviours of this legal but potentially harmful product for those who would othenNise not be interested in consuming cannabis. Should such products be permitted, individuals who are not cannabis users and have no intention of using cannabis may enter these establishments and be exposed to cannabis use, and possibly enticed or pressured to purchase and consume it when they otherwise may not have. Under subsection 24(1) of the federal Cannabis Act, it is prohibited for a person that sells cannabis or a cannabis accessory to provide or offer to provide any service if it is provided or offered to be provided as an inducement forthe purchase of cannabis or a cannabis accessory. Disallowing non-cannabis items to be sold would be in line with the prohibitions for promotion set out at the federal level. It would also align with current Ontario cannabis retail regulations which specify that licensed cannabis retailers may only sell products and accessories which are directly related to cannabis. Similar restrictions exist within the Smoke-Free Ontario Act, 2017 (SFOA 2017), whereby specialty stores Tobacconists and Specialty Vape Stores) are permitted to sell a ratio of specialty products relative to those which are reasonably associated with those products. These regulations are considered to be effective as they do not promote entry into the establishment for anyone not interested in purchasing the specialty product or associated product. Should the sale of food/beverage products that do not contain cannabis be considered in potential consumption establishments, only pre-packaged items for both cannabis and non- cannabis products should be permitted and sold in their original packaging. The preparation of non-cannabis beverage and food items should be prohibited to reduce the risk of cross- contamination with products containing cannabis. In addition, the sale of alcoholic beverages, high-caffeine beverages coffee, tea or energy drinks), and products which contain nicotine should be strictly prohibited in these establishments. This will prevent harmful oo-use of substances which may lead to higher levels of impairment, addiction, and increased levels of harm. In terms of accessories, only those that relate to cannabis should be permitted for sale to reduce cross-marketing inducements for cannabis, which may be created by allowing the sale of non-cannabis related items. A similar ratio to that described above in the SFOA 2017 may be effective in ensuring appropriate products are available for sale in these establishments. The Windsor-Essex County Health Unit is not in support of the sale and consumption of cannabis at largescale public events such as festivals. Permitting the sale and consumption at such events may cause risks to public health and safety from an increase of use and harms from cannabis, increased risk of public intoxication and impaired driving, and the normalization of the use of cannabis. The consumption of cannabis edibles in a public setting poses a risk of unintentional or unpredictable effects due to individual levels of tolerance, and the delayed onset of intoxicating or effects. Compared to inhaled forms of cannabis, edible cannabis products may take up to 2 hours for an individual to start feeling the effects, with a peak effect onset time of up to 4 hours. The effects of edibles may also last from 6-12 hours. The unpredictability and delay of effects poses safety risks not only for the consumer, but also liability risks for the municipality and the permit holder for any incident that occurs once the patron leaves the event motor vehicle collision, illness caused by over intoxication such as vomiting, fainting, severe anxiety or panic attack, loss of reality or paranoia). In addition, the sale and consumption at such events would pose unique risks as they are not likely to have the capacity to provide the necessary levels of security currently required of retail stores, including age verification measures, and ensuring that an individual does not exceed possession limits from buying and using products from multiple vendors over a short time penod. The Windsor-Essex County Health Unit strongly recommends that SOPs for smoked or va ped cannabis, in particular, to be sold and consumed at festivals and events not be considered. The current regulations under SFOA, 2017 have made great progress since the ?rst enactment of the SFOA in 2006 to reduce exposure to second-hand smoke, denom1alize smoking behaviour, and create healthier environments for all. In particular, SFOA, 2017 prohibits the smoking of cannabis and e-cigarettes in playgrounds, recreation and sports centres, and within 20 metres of those properties. Locally, in Windsor-Essex County, municipalities only allow smoking or vaping at fairs and festivals in a Designated Smoking Area (DSA) which is outside of the grounds of the event and also in compliance with municipal bylaws. Permitting the DSA is in compliance with the SFOA, 2017 and municipal by-laws. As many fairs and festivals have large sections of property that are considered a patio with the sale and consumption of food and beverages, DSAs are typically located 9 metres away from the patio. Should the government consider establishing a SOP program forthe sale and consumption of non-smoked/vaped cannabis, the following should be considered: 1. Products sold or consumed: Only the sale of non-smoked or vaped cannabis products from federally licensed producers should be permitted, such as edible or beverage products. Such products should be sold only in their original packaging and not removed from their packaging by anyone other than the consumer. This will ensure consumers know the levels of THC and CBD that they are consuming, as well as other ingredients, and protect against overconsumption. As multiple vendors may be present, limits should be put into place to restrict the amount of cannabis an individual can purchase while in attendance and a system would be required to ensure consumption limits are adhered to across multiple vendors. 2. THC and serving size limits: Limits on the amount of THC in products sold and maximum servings per person at the event should be established to prevent overconsumption (for example, 2.5mg THC serving sizes). 3. Hours of product sales: The sales and service of edible cannabis should end a minimum of 2 hours before the event closes to account for the delayed onset of effect and peak times based on the product and individual variances. 4. Vendors: Only retailers with an approved Cannabis Retail Store Authorization should be permitted to set up as a vendor at a fair or festival. They would need to have proper protocols for age verification and reasonable levels of security for the storage of products products would not be able to be out in the open, but would need to be stored securely and not accessible to the public). 5. Prohibition of alcohol: The sale and/or consumption of alcohol should be prohibited at the event under the SOP to reduce co-use and increased risk of overconsumption, over- intoxication, and associated harms. 7 6. Staff training: An additional cannabis service training program should be developed and required for all operators and employees selling cannabis products for immediate consumption to complete prior to the event date. Such a program should be similar to the ?Smart Serve? training program for alcohol service and include safety and first aid protocols for responding to over-intoxication, and limits on service of cannabis to patrons to protect them from and harm. 7. Age restrictions: All grounds and spaces related to the SOP event should be age restricted to only those 19 years of age and older. This includes individuals permitted to purchase and/or consume any cannabis product or accessory, any person involved in handling or selling a cannabis product, as well as any person involved in the operations of the festival (including volunteers or event staff). 8. Promotion prohibitions: Provisions would need to be made to require that there is no public promotion visible outside of the SOP area which would be visible to youth under 19 years of age. To protect youth exposure in particular, the conditions of the SOP should specify adherence to the Federal Cannabis Act, section 17, which states that the promotion of cannabis, a cannabis accessory or a service related to cannabis are prohibited where the promotion may be audible or visible from outside a place where young persons are not permitted by law. While it would be difficult to fully obscure viewing of the activities which take place inside the grounds ofa special event, efforts should be required to limit exposure for non-patrons. 9. Sponsorship prohibitions: The sponsorship of any event by a cannabis retailer or licensed producer should remain prohibited to align with the Federal Cannabis Act. Section 21 of the Act states that it is prohibited to display, refer to or othenrvise use any of the following, directly or indirectly in a promotion that is used in the sponsorship of a person, entity, event, activity or facility: a brand element of cannabis, of a cannabis accessory or of a service related to cannabis; and the name of a person that produces, sells or distributes cannabis, sells or distributes a cannabis accessory, or provides a service related to cannabis. 10. Smoking/vaping in DSAs: Any smoking or vaping activity should be prohibited unless in a Designated Smoking Area, but should be restricted to areas outside those prohibited in the SFOA 2017 or a municipal by-law. Risks from the delayed intoxication effects of edibles: In any situation where cannabis edibles are consumed in public, there is a risk of unintentional or unpredictable effects due to individual levels of tolerance, and the delayed onset of effects. Should the sale and consumption of non-smoked/vaped cannabis products be considered, consumers will need to be first educated about the potential effects of use, the risks of overconsumption, and the risks of over-intoxication from the co-use of alcohol. Conservative limits on the amount of THC in products sold should be maintained, and consumers would need 8 to be urged to start small with what they consume, and to delay consuming more by at least 2 to 4 hours to see how it will affect them. They will also need to be encouraged to secure safe transportation home if they plan on consuming as the effects of edibles can last from 6-12 hours. Given the above risks, staff who work in any capacity involving selling cannabis for consumption would need to be specially trained on how to handle a situation of a consumer being over- intoxicated and having a bad reaction which requires medical attention (for example, panic attacks, fainting, and uncontrollable vomiting). Unique risks of SOPs: As the potential exists for an SOP request on a large boat vessel or other motorized vehicle, this should be strictly prohibited in a SOP. Being located on the Detroit riverfront, Windsor- Essex has already experienced an incident with a cannabis consumption event taking place on a cruise boat which included the smoking and vaping of cannabis. This is strictly prohibited in the Highway Traffic Actas well as the SPCA, 2017 and these types of operations pose serious risks to passengers and the operators of the vehicle. Regulations for any SOP should explicitly prohibit any event taking place on any form of motorized vehicle in operation. Municipal licensing and zoning restrictions Municipalities should be granted the authority to establish licensing and zoning criteria to ensure that cannabis consumption establishment locations are appropriate and meet the needs of the community. The Windsor-Essex County Board of Health also endorses buffer distances between cannabis retail stores and sensitive land uses such as parks, playgrounds, recreation centres, day cares and addictions treatment facilities and similar consideration should be made for special occasion permits and consumption lounges if permitted. Special Occasion Permits Municipalities should be granted the authority to enact by-laws that permit or prohibit the sale and/or consumption of cannabis on municipal property. Applications for SOPs should be required to abide by any municipal requests to ensure compliance with city by-laws and conditions of use of municipal property. Municipalities should be informed of any applications in the same fashion as alcohol SOPs where at least 30 or 60 days notice must be provided by the permit holder to the local municipality, police, and fire and health departments notifying them of the event. The building department must be noti?ed as well if a tent, marquee, pavilion or tiered seating is used. Health education and harm reduction In order to reduce unintentional harms of use by consumers, the province should require the posting of health information at consumption establishments and events where cannabis is sold, including warnings on the risks of cannabis consumption in pregnancy, low risk cannabis use guidelines, risks of impaired driving, and information speci?c to the products being sold delayed effects of edibles, safer use strategies such as starting with 2.5mg of THC and waiting 2?4 hours before having more). THC and serving limits For any cannabis product sold at a consumption establishment or SOP event, the province should consider establishing THC limits for products consumed and maximum servings per person, pervisit (for example, 2.5mg THC serving sizes) to prevent overconsumption. Special Occasion Permits Any promotion of cannabis use or a brand visible outside of the SOP area should be prohibited to protect against youth exposure. Within a SOP permit, the applicant should be required to specify the measures that will be taken to prevent promotions from being visible outside of the event space. All smoking or vaping activity should be strictly and expressly prohibited, unless within an approved Designated Smoking Area. 10 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis?ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Jeff Jacobson General Manager, Canada Europe Cronos Group, Inc. 720 King Street West, Suite 320 Toronto, ON M5V 2T3 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Licenced Producer Region (please refer to map and check appropriate box) 1. Central Ontario LI 2. Eastern Ontario 3. Greater Toronto Area LI 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial Ontario should facilitate the sale of cannabis in lounges and/or cafes operating under a provincial licence. We can see examples of successful implementations of this practice in countries like the Netherlands, which has a proven track record of success with cannabis lounges despite the ?aw that these operators source from the illicit market. Ontario must require that any such establishment purchase all cannabis from a Licensed Producer (LP). For LPs, these establishments would create an additional distribution channel and consumer demand for products that are specifically tailored for this consumer experience single use, single serving, pre-rolls, fast-acting edibles, etc.) From the government?s perspective, benefits will include increased cannabis tax revenue, enhanced social responsibility in the form of licenced and regulated consumption venues, and further downward pressure on the illicit market. Food and beverage, cannabis accessories, and infused meals are all examples of products that must be permitted in consumptions venues to enhance the consumer experience and possibility of success. Without a variety of non-cannabis offerings these lounges would not have much value as a destination for consumers. Historically, cannabis consumption happens at these events in the absence of an SOP. There is a significant opportunity for tax revenue and the ability to ensure a legal, regulated, and safe supply of cannabis to event attendees under a new SOP program in Ontario. It is unrealistic to believe that any event host would choose a cannabis-only SOP over an alcohol-only SOP. Cronos Group suggests that a single SOP for all age- restricted products (alcohol and cannabis) or an addendum to the existing SOP framework for alcohol be implemented in Ontario. An SOP should permit both the onsite consumption and the onsite sale of non-combustible products. The onsite sale and consumption of dry flower (or vapes) should be permitted under the rubric of existing restrictions/permissions on smoking areas or lounges as identi?ed under an SOP. For reference, a recent festival experience in Calgary (2019) resulted in the following observations: a) People were reluctant to give up their alcoholic beverage, and therefore reluctant to spend time within a cannabis-only boundary; b) It was impossible to distinguish cannabis and tobacco users, making the entire area smoky and generally unpleasant; and c) A cannabis-only area further contributed to the stigma of cannabis use by relegating its consumption to a smoking area. 4 Consumption Establishments. The advertising and promotion of cannabis products, as permitted by federal law, should not be prohibited in any age-gated environment and/or consumption establishment. If a venue has age-restricted access then the province should not implement prohibitions on advertising and promotions beyond existing federal guidance. SOPs: The advertising and promotion of cannabis products, as permitted by federal law, should not be prohibited under any special occasion permit (subject to existing age-restriction requirements under the SOP). No areas of an age-restricted venue or event (under an SOP) should be subject to provincial restrictions on advertising and promotions beyond federal guidance. Municipalities should be involved at the licensing level for consumption establishments. Enforcement should also be under existing public health and municipal licencing authorities. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. 1 VANTAG 2694.1 For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Tamara Macgregor Chief Corporate Affairs Officer, Aphria Inc. Tamara.Macgregor@aphria.com 437-343-4000 aphriainc.com 2 VANTAG 2694.1 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Ex Other: Licensed Cannabis Company Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario X6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial . We agree that the government should consider facilitating the sale of cannabis for consumption in lounges and cafes in Ontario. . Since the October 2018 legalization of recreational cannabis across the country, the substance has become a part of many Ontarians? lifestyles. . Similar to how individuals are able to enjoy alcohol in safe, regulated social environments, individuals should be allowed the opportunity to engage with each other over recreational and/or medical cannabis. . In many communities of individuals facing unique barriers, cannabis has replaced alcohol as an avenue for bringing often-isolated individuals together. 0 Further connection ofthese groups should be facilitated by legislation that promotes safe, regulated spaces for cannabis consumptions, such as the ones that currently exist for alcohol consumption bars and restaurants). 0 In our answer to question 6 below, we highlight the potential of cannabis consumption spaces as places to promote community and wellness for Ontario's Veterans. 3 VANTAG 2694.1 . It is not permitted to sell alcohol in establishments that do not also provide water and some food of sorts, under the province's Liquor Licence Act. . Potential negative reactions to substances like alcohol and cannabis can be mitigated alongside proper hydration, and the consumption of food. . Similar to alcohol, any kind of cannabis consumption establishment should facilitate the sidelong sale of beverages and food. . Consider integrating community-building or educational opportunities similar to other sectors breastfeedin clinics rovide social su orts to moms) . The government should consider establishing an SOP program for cannabis to be sold and consumed at festivals and events. . This consumption should happen in a safe, regulated environment away from minors. . Cannabis use should be permitted in areas that are sectioned off to a 19+ crowd, to ensure the safety of all those who are attending the event. Cannabis Consumption Establishments and SOPs: . Smart Serve Ontario in an incredibly successful workforce training program with regards to ensuring the safe consumption of alcohol on licensed premises. CanSell was similarly designed to ensure cannabis retail employees are trained to ensure safe cannabis consumption. . It is our hope as cannabis consumption establishments and/or cannabis SOPs come into play, the Smart Serve Ontario and CanSell programs will be updated and expanded to educate licensees on safe cannabis consumption and distribution, in order to mitigate risk and ensure the safety of consumers. SOPs: . Although the SFOA permits the smoking and vaping of substances outdoors, proper protection for employees and/or participants must be ensured. 4 VANTAG 2694.1 . Municipalities played, and continue to play, an active role in the rollout ofthe federal and provincial legalization of recreational cannabis, concerning where individuals are permitted to purchase andlor consume substances. . It is our hope that the province, and the municipalities, can continue to have a cordial working relationship on issues regarding cannabis; specifically, regarding cannabis consumption establishments, SOPs andlor zoning requirements. THE OPPORTUNITY: Aphria Inc. would like to have a preliminary discussion with the Government of Ontario to explore the possibility of piloting a Wellness Lounge for Veterans an Ontario-based pilot project specifically designed to support the mental health of Veterans. While medical cannabis consumption may be the entry point for Veterans visiting the Wellness Lounge, the pilot would specifically provide an opportunity to begin to deliver much-needed wrap-around mental health and community support services for Veterans (with a focus on Veterans who served in Afghanistan). Aphria Inc. has undertaken early outreach with key stakeholders to explore the validity of the concept as a mechanism for mental health support in Ontario with leading Veterans groups and medical experts. The concept has been enthusiastically supported by the groups that have been consulted to date. . Preliminary feedback from these early consultations underscore that the pilot would play an essential role in helping Veterans: Re-establish a lifeline of community support and peer engagement; 8 Consume medical cannabis safely; 8 Learn about responsible use, as well as alternatives to medical cannabis use; and, 8 Access wrap-around community and mental health supports with on-site professionals social workers, community engagement professionals, and more) . We applaud the Government of Ontario's recent announcement of a Roadmap to Wellness: A Plan to Build Ontario?s Mental Health and Addictions System. This pilot concept aligns with the government's pledge to engage with ?other communities with unique needs? . Aphria Inc. is also working to garner additional input to the concept from Veterans. Stakeholder consultations underscored the need to co-create the actual design of the pilot in collaboration with Veterans themselves not just the groups that represent them THE CONTEXT: Ontario?s Veterans are facing a mental health crisis. . Ontario is home to over 230,000 of Canada's Veterans (Veterans Affairs Canada, 2019 link bate) . It is estimated that one in 6 Veterans suffer from post-traumatic stress disorder (PTSD) (Michael DeGroote Centre for Medicinal Cannabis Research, 2018 link here). This rate of PTSD is five to tenfold higher than the general population (Journal of Military, Veteran and Family Health, 2018 link . A further 21% of Veterans experience depression and 15% are living with anxiety (Life Alter Service Studies Survey, 2016 link here) . The majority of Veterans attribute their mental health conditions to military service attribution rates were 97% for PTSD, and 81% for anxiety disorders (Veterans Affairs Canada, 2015 link here) 5 VANTAG 2694.1 . Diagnosed physical health conditions were very common in those with mental health conditions: 90% in Regular Force, 92% in deployed Reserve and 63% in non-deployed Reserve Veterans (Veterans Affairs Canada, 2015 link here) Feelings of isolation and disenfranchisement are rampant amongst Veterans, especially those that served in Afghanistan. . Less than 30% of Veterans reported a high level of social support was available for them upon their return to civilian life (Journal of Military, Veteran and Family Health, 2018 link here) . Canada's younger generation of Veterans, particularly those who served in Afghanistan, often do not have a community of support or may feel disenfranchised from existing community spaces (Aphria lnc. Stakeholder Outreach, 2020) A shocking 20% of all Veterans receive disability supports for a mental health condition. . As of September 30, 2017, of all Veterans who received a benefit from Veterans Affairs Canada, 20% received a disability benefit for a mental health condition (Veterans Affairs Canada, 2018 link here) . 73% of Veterans who received a benefit from Veterans Affairs Canada for a mental health condition, received it specifically for PTSD (Veterans Affairs Canada, 2018 link here) Death by suicide is disproportionately higher in the Veteran community. . Male veterans are 40% more likely to die by suicide than male members of the general population (Veteran Affairs Canada, 2017 link here) . Female veterans are 80% more likely to die by suicide than female members of the general population (Veteran Affairs Canada, 2017 linkhere) . More than 70 Veterans have died by suicide since their return from Afghanistan (The Globe and Mail investigation, 2016 link here) Increasingly, Veterans are turning to medical cannabis. . Cannabis use is a common choice for Veterans facing mental health challenges (Journal of Military, Veteran and Family Health, 2018 link here) . Although access to cannabis for certain medical conditions has been legal since 2001, legislative changes in 2014 and 2017 substantially increased access and produced a network of regulated suppliers (Journal of Military, Veteran and Family Health, 2018 link here) . The number of Veterans being reimbursed by Veterans Affairs Canada for medical cannabis more than doubled over 2017 to 2019, from 4,474 to 10,079 (iPolitics, 2019 link here) . It is estimated that more than 50% of Canadian Veterans seeking PTSD treatment use cannabis (Journal of Military, Veteran and Family Health, 2018 link here) Medical cannabis has demonstrated promising results for helping Veterans manage their . Cannabis modulates the release of certain neurotransmitters related to mood and memory, providing support for its use as a treatment option (Behavioural Pharmacology, 2016 link here) . In some instances, cannabis may help prevent stress, manage fear responses and produce anti- anxiety effects (Behavioural Pharmacology, 2016 link here) . The legalization of medical cannabis is also associated with reductions in opioid, antidepressant and anti-anxiety prescriptions (Journal of Military, Veteran and Family Health, 2018 link here) Ontario?s Veterans face unique barriers to accessing much-needed mental health supports. . Members ofthe military are particularly affected by stigmatization because the predominantly male- oriented culture in the armed forces may lead members to put forward an image of strength and control that is incompatible with the initial acceptance that one may have a mental health issue and the subsequent decision to seek assistance (Report of the Standing Committee on Veterans Affairs, 2017 link here) . While the Federal government has worked to establish medical services for veterans in addition to those offered through OHIP to the general population, there is no standard of care across the Province for Veterans using medical cannabis to treat their mental health challenges (Aphria lnc. Stakeholder Outreach, 2020) 6 VANTAG 2694.1 . While the Federal government is responsible for the cost of Veterans care, the Ontario Government does play a key role in the delivery of many mental health services for Veterans (doctors, nurses, etc.) . New mental health models to better serve and standardize Veterans? care can also help optimize delivery and access in Ontario There is a clear and present opportunity to bring Ontario?s Veterans together and help them focus on resolution, not just reduction. . Aphria lnc. would like to propose an Ontario-based pilot Wellness Lounge project specifically designed to support the mental health of Veterans Again, while medical cannabis consumption may be the entry point for Veterans, the pilot would specifically provide an opportunity to begin to deliver much-needed wrap-around mental health and community support services for Veterans (with a focus on Veterans who served in Afghanistan) Aphria Inc. would like to have a preliminary discussion with the Government of Ontario to further explore the possibilities for piloting this concept. About Aphria Inc. . Aphria Inc. is a leading global cannabis company. . As a purpose driven Company, Aphria lnc.'s commitment to people, the planet, product quality and innovation helps the Company create stronger, healthier communities. . Aphria is committed to the needs of its patients and consumers whether they are looking for natural options for medical needs, exploring the options in wellness, or seeking alternatives to their lifestyle. Driven by a desire to help others live their best life. . Aphria Inc. is dedicated to the well-being of patients, rooted in quality, consistency, and effectiveness and will always strive to provide both education and understanding where it makes sense to Canadians, helping to better understand the ever-evolving cannabis landscape. 7 VANTAG 2694.1 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Aaron Denhartog, Manager, Government Relations Aurora Cannabis Floor, 15 John Street, Toronto, ON, Canada M5V 3G6 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other -Licensed Producer Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Aurora believes the Ontario market Is best served by a model which responds to consumer and retail demand, enables competition between players of all sizes, drives innovation and supports job creation and economic growth. To that end, Aurora encourages the provincial government to implement a regulated framework for the sale of cannabis products for consumption at establishments and events throughout Ontario. Doing so would provide a safe, regulated space for sales and consumption of legal cannabis products while educating on responsible consumption. According to Deloitte, the Canadian consumer market for edibles and other alternative products will be worth more than $2.5 billion annually. As noted in the consultation document, businesses in Ontario can already operate establishments where patrons bring their own cannabis (BYOC) for consumption on-site if compliant with the Smoke Free Ontario Act, 2017 (SFOA). This includes edibles and topicals already for sale in Ontario. With almost one in four Canadians consuming or likely to consume cannabis edibles and other alternative cannabis products, we believe Ontario can be a global leader by establishing a regulatory framework allowing for cannabis product sales at (but not limited to) lounges, sporting events, concerts, spas and movie theatres. This would follow in the precedent of Denver, San Francisco and Amsterdam which permit some form of licensed consumption. These changes would also provide a unique opportunity to the legal industry that is not available to the illicit market. A core element of any reforms to Ontario's cannabis system needs to be maintaining the high standards for social responsibility that exist today and encourage responsible consumption. Research suggests that many of the new or ?cannabis-curious? consumers will be older Canadians who will prefer more familiar consumption formats, notably edibles such as baked goods. Ensuring consumers are informed about the products they are consuming is essential in promoting responsible consumption and reducing adverse health and safety effects. Allowing for onsite sales and consumption will permit further educational opportunities while enabling monitoring of new customers. Finally, the government should consider changes to the SFOA, 2017, as part of this consultation to allow for safe consumption spaces, with proper ventilation for medical patients and consumers. Current regulations around use in public and rental property restrictions landlords being able to prohibit consumption in units, use in hotels) put disadvantaged populations, low-income consumers and tourists at risk. If patients, consumers and tourists do not have a legal place to consume, they will be forced to consume in public places. This would ultimately disservice the SOFA regulations already established to deter the normalization of public smoking and provide-smoke free environments in public. Aurora believes that the onsite sale and consumption of cannabis edibles should be permitted at concession stands at establishments such as sporting events, concerts, and theatres alongside other food consumer packaged goods. Doing so would enable greater consumer choice, increased sales and provide unique partnership opportunities that are not available to the illicit market. Given that consumers are already known to be consuming cannabis products at these types of events, we believe it provides an additional opportunity for consumer education. Aurora supports the provincial government implementing a cannabis SOP program similar to alcohol. Last year there was significant attention paid to the potential for cannabis consumption spaces at summer festivals. Most notably, Ontario Place hosted what was branded as Ontario's first ever during the Toronto Craft Beer Festival. Hosted by the Hot Box Cafe, the was presented as an opportunity for festival-goers to ?come down? from beer while being educated on responsible consumption. As the Cannabis Act allows Ontarians to smoke cannabis wherever tobacco smoking is permitted, we believe the smoking and vaping of cannabis products at festivals and events is already legally permissible under provincial laws allowing for the smoking and vaping of tobacco and cannabis in such areas. Furthermore, allowing the sale of cannabis products at such festivals would provide vendors and consumers greater choice. Given the public is already consuming cannabis in numerous forms at these events, Ontario should allow their sale to ensure the public has access to safe, regulated products. Onsite consumption at licensed establishments or through SOPs offers additional opportunities to educate customers. Furthermore, the longer interaction found in a consumption scenario can provide important data that can be used to further develop and improve staff training modules and improve product safety. While it is important to work with municipal partners across the province, we believe the municipal retail opt-out provisions contained in Bill 36 and the accompanying regulations have created access issues across the province and strengthened the illicit market. The provincial licensing requirements for alcohol consumption at bars and restaurants administered by the AGCO are sufficient for similar cannabis sales and consumption. Aurora Cannabis recommends the OntarIo Government permIt farmgate stores off-sIte from Health Canada licensed facilities. The Cannabis Act and its Regulations provide, among other things, the framework for legal access to cannabis and the control and regulation of its production, distribution and sale. Part 4 of the Cannabis Regulations sets out physical security measures that are required and are necessary to secure sites where licence holders conduct activities with cannabis. As a result, licensed cannabis production facilities are highly secure and generally not built for public access. Many are also located in remote or industrial areas away from high-traffic public areas. Allowing farmgate stores only at the facilities licensed by Health Canada would be significant disadvantage for many Licensed Producers. If yes, what considerations should the government take into consideration when determining where off-site farmgate stores should be located? By prohibiting Licensed Producers (LPs) from engaging in traditional advertising and promotional activities, Health Canada has established a remarkably restrictive regulatory environment for LPs who are looking to connect with customers and build brand loyalty. LPs are unable to establish distinct brand recognition through packaging and labelling like other consumer product companies. Therefore, Aurora requests that in addition to a farmgate location, LPs be allowed to build one flagship store anywhere in the province. In November 2019, Aurora proudly opened an 11,000 square foot flagship store in Edmonton's West Edmonton Mall which will be a centre of excellence for cannabis education, community engagement and a venue for events. The $10 million investment has created 100 newjobs and provides a footprint in Alberta's number-one tourist attraction. As noted, the current rules in Ontario restrict LPs to having one store, which must be located at an Ontario-based production facility and thus prohibit us from building a similar flagship store in downtown Toronto. The creation of a flagship store will support us in growing our global brand in the country's largest recreational marketplace, create jobs and support tourism by making Ontario a hub for the world's leading cannabis brands. Other global companies, such as Apple and Tesla, enjoy the presence of retail stores to grow their brands and sell their products. Meanwhile, comparable companies in the alcohol and pharmaceutical sectors are permitted to participate in television and radio commercials, naming rights for stadiums, or sponsorship of events, all of which are strictly prohibited for cannabis companies under federal regulation. We believe the changes contained in the Fall Economic Statement are a step in the right direction towards permitting LPs to open flagship stores anywhere in the province. Respectfully, we ask that as you prepare additional regulatory controls you include changes to permit flagship stores for Licensed Producers. Are there any additional risks created by farmgate stores when compared to authorized cannabis retail stores? From a product safety, compliance and availability standpoint, no. These stores would still fall under the regulatory guidelines that current cannabis stores fall under. Staff operating the stores would follow the same training requirements as staff employed at current retail stores. Are there other potential changes to the regulatory framework for farmgate stores that the government should consider? Under the Cannabis Licence Act, 2018, licensed retailers can only sell cannabis purchased from the Ontario Cannabis Store while LPs in Ontario can only sell cannabis products intended for recreational sale to the Ontario Cannabis Store. There is no distinction in the current law if the retailer and producer are the same company, as would be the case under farmgate or flagship store scenarios. Aurora, therefore, requests that LPs be able to sell directly to consumers, through either flagship or farmgate stores, without first having to sell to the 008. The model can be set up to ensure that the province receives a percentage of revenue per sale but should reflect the lack of distribution and warehousing role typically played by the 008. It is noteworthy that Ontario already has a similar regulatory model in place for the province's wine industry. Currently, provincially licensed wine manufacturers are permitted to engage in sales of VQA wine to consumers in the Ontario market. From a licensing standpoint, sales are permitted as an extension of the winery's ?farmgate? licence (issued by the AGCO) and do not first pass through the LCBO. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments andlor Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail?market.html. As part of Ontario?s transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in speci?ed social settings caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e?cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario?s cannabis consumption rules, please visit cannabis. Other Forms of Cannabis Products 1 On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts? cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals? cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada?s rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). EMelissa Rolston Board Member BTS Stories Inc. Ph6-666 Spadina Ave EToronto, 0N About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement [3 Other Nonprofit Region 3. Greater Toronto Area . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial as an alternative mind alternating experience to alcohol amongst adults. Human beings are bound to the plant as we have an endocannabinoid system that is as sophisticated as our nervous system that is in charge of keeping our bodies in homeostasis. Please visit these links for research on alcohol related crimes: m/e?l 33/1 33h e. In addition to allowing lounges and cafes, the government should also considerthe public bene?t of allowing cannabinoid assisted treatments in establishments such as: Spas, Massage Parlours, Beauty Salons, etc. 3 EAlcohol, Cannabis accessories, food/beverages, cannabis related art, and clothing/merch. EYes. The festivals and/or special events can be 19+ event or have sectioned off Cannabis? gardens for consumption. Being sold alongside alcohol shouldn?t be a problem. As consenting adults, Canadian?s are competent and capable in making responsible decisions in relation to Etheir substance consumption. There are plenty Canadians who do not consume alcohol and only consume cannabis. To discriminate against cannabis consumer?s would be a lack of Eforesight on the governments part and prove that the stigma surround cannabis is still very much present although we are post prohibition. 4 Cannabis Consumption Establishments: There staff need to be trained in the case that there is ever a customer who experiences adverse effects from over consumption. ESOPE Physician?s should be consulted to create an if there is ever a case of over consumption. They should have the same involvement that they have with liquor licenses and Spas, Massages Parlours, Beauty Salons, etc. need to be considered while drafting any sort of framework for a cannabis consumption establishment. 5 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments andlor Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail?market.html. As part of Ontario?s transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in speci?ed social settings caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e?cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario?s cannabis consumption rules, please visit cannabis. Other Forms of Cannabis Products 1 On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts? cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals? cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada?s rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). EMelissa Rolston Board Member BTS Stories Inc. Ph6-666 Spadina Ave EToronto, 0N About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement [3 Other Nonprofit Region 3. Greater Toronto Area . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial as an alternative mind alternating experience to alcohol amongst adults. Human beings are bound to the plant as we have an endocannabinoid system that is as sophisticated as our nervous system that is in charge of keeping our bodies in homeostasis. Please visit these links for research on alcohol related crimes: m/e?l 33/1 33h e. In addition to allowing lounges and cafes, the government should also considerthe public bene?t of allowing cannabinoid assisted treatments in establishments such as: Spas, Massage Parlours, Beauty Salons, etc. 3 EAlcohol, Cannabis accessories, food/beverages, cannabis related art, and clothing/merch. EYes. The festivals and/or special events can be 19+ event or have sectioned off Cannabis? gardens for consumption. Being sold alongside alcohol shouldn?t be a problem. As consenting adults, Canadian?s are competent and capable in making responsible decisions in relation to Etheir substance consumption. There are plenty Canadians who do not consume alcohol and only consume cannabis. To discriminate against cannabis consumer?s would be a lack of Eforesight on the governments part and prove that the stigma surround cannabis is still very much present although we are post prohibition. 4 Cannabis Consumption Establishments: There staff need to be trained in the case that there is ever a customer who experiences adverse effects from over consumption. ESOPE Physician?s should be consulted to create an if there is ever a case of over consumption. They should have the same involvement that they have with liquor licenses and Spas, Massages Parlours, Beauty Salons, etc. need to be considered while drafting any sort of framework for a cannabis consumption establishment. 5 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis?ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) Name: Sabine Kilajian Title: Project Manager Organization: byMinistry Address: 298 Markham St, Toronto, ON, M6J 266, Canada About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _Matcha Bar/Cafe Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial (insert comments if necessary the box will expand as you type) Yes, the government should facilitate the sale of cannabis for consumption in establishments like lounges and cafes in Ontario because there currently is no safe place for users. V\?th proper rules and regulations cannabis consumption lounges and cafes could become a safe haven for those in need. (insert comments if necessary the box will expand as you type) There would be no harm in also selling cannabis accessories and food and beverages that do not contain cannabis. Consumables containing cannabis would have to be clearly marked as such. I do not recommend allowing to serve alcoholic beverages in these establishments. (insert comments if necessary the box will expand as you type) Yes, the government should establish a similar SOP program for cannabis and administer it in a similar fashion as it does for alcohol. I think creating an SOP program for Ontario is a logical next step following legalization. It will be a good way to regulate consumption at events and special occasions. I believe that the two SOP's should be mutually exclusive. A special occasion should either have an alcohol or cannabis SOP. Only consumables should be allowed in orderto keep in line with the SFOA, 2017. Cannabis Consumption Establishments. (insert comments if necessary the box will expand as you type) The additional risks and opportunities would be similar to serving alcohol in bars as opposed to only selling alcohol at the LCBO. SOPs: (insert comments if necessary the box will expand as you type) The additional risks and opportunities would be similar to serving alcohol in bars as opposed to only selling alcohol at the LCBO. (insert comments if necessary the box will expand as you type) The municipality would need to form a governing board like the AGCO to monitor cannabis consumption establishments and SOPs. (insert comments if necessary the box will expand as you type) I believe that this is the next phase of legalization and normalization for cannabis. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. 1 For more information on Ontario's cannabis consumption rules, please visit wvvwentario.caicannabis. Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: bade: .caie nihea ithuoanadainews??": ?f??ihea Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. 2 Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). About You or Your Organization Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region 1. Central Ontario 6 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 6 5. Southeastern Ontario 6 6. Southwestern Ontario 6 7. Western Ontario 6 8. Provincial The government should facilitate the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. As more Canadians use cannabis for medical and recreational purposes, we have a right to purchase and consume cannabis in diverse, safe and public spaces. This will create opportunities to increase access (especially in rural areas), build community, spread education, and dispel associated with cannabis use. It will also offer locations to individuals who are not permitted to consume at home (for example, in condominiums where cannabis use is prohibited). 3 Other products for sale should include cannabis accessories, food/beverage products that do not contain cannabis, and most importantly, food and beverages that do contain cannabis. This is the perfect opportunity to provide education to the masses on what happens to the body after ingesting edible cannabis and how it differs from inhaled cannabis. It also presents an opportunity to educate people on the importance of microdosing, dose titration, and the approach of ?start low and go slow?. 4 The government should establish a similar SOP program for cannabis to be sold and consumed at festivals, concerts and other special events. Clearly marked wristbands should be provided to those who have proof of age (19 to ensure restricted access. All methods of cannabis consumption should be permitted however, cannabis smoking could be limited to outdoor events. For indoor events, vaporizing (at minimum) should be allowed in designated areas. Cannabis consumption will likely increase sales from other vendors (ex: food vendors) and will likely decrease irresponsible/uninhibited behaviours that are commonly associated with alcohol consumption. EMS professionals should be trained on how to manage over consumption of cannabis: provision of lemon water, quiet, dark space and messaging that waiting will resolve unpleasant effects. Cannabis Consumption Establishments: Unlawful infused dinners are happening all over Canada and the demand continues to grow. Cannabis consumption establishments present an incredible opportunity to expand food services offerings, create communities for like-minded cannabis users and provide legitimacy, structure and standards to an already uncontrollably burgeoning market. SOPs: Given that these are transient permits, they offer an opportunity to enhance events around Ontario. They pose no real threat nor direct competition to retail stores. Given the excessive availability of alcohol at events, and known effects (drunken and disorderly behaviour at sporting events, for example), it seems only reasonable that cannabis be offered as an alternative option. The municipality should be involved in the provision of licenses to cannabis consumption establishments but they should not be involved in any other capacity. The framework should be designed and implemented by industry experts with first hand experience and a vested interest in the long term success of the program. 5 There is a huge demand for cannabis consumption lounges in Canada, and specifically in Ontario. As alcohol use continues to be promoted on air, on line and in print ads, cannabis advertisements are subjected to an unreasonable double standard. What's more, cannabis users are forced to consume in private, giving the impression that this remains an illicit or socially unacceptable act. Bringing cannabis consumption establishments to the fore represents one monumental step towards normalizing cannabis consumption. Edible cannabis consumption in restaurants stands to be a multi billion dollar industry that has the potential to appeal to people from all ages, classes and backgrounds. 6 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments andlor Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail?market.html. As part of Ontario?s transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in speci?ed social settings caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e?cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario?s cannabis consumption rules, please visit cannabis. Other Forms of Cannabis Products 1 On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts? cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals? cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada?s rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (it you are submitting comments on behalf of an organization). Tamara Lilien, Cannabis Sommelier, Educator, Curator and Consultant. Founder, CannaLily Consulting, CIO and Director of Education, Cannabis Cooking Company. 2 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial The government should facilitate the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. As more Canadians use cannabis for medical and recreational purposes, we have a right to purchase and consume cannabis in diverse, safe and public spaces. This will create opportunities to increase access (especially in rural areas), build community, spread education, and dispel associated with cannabis use. It will also offer locations to individuals who are not permitted to consume at home (for example, in condominiums where cannabis use is prohibited). 3 Other products for sale should include cannabis accessories, food/beverage products that do not contain cannabis, and most importantly, food and beverages that docontalncannabls This is the perfect opportunity to provide education to the masses on what happens to the body after ingesting edible cannabis and how it differs from inhaled cannabis. It also presents an opportunity to educate people on the importance of microdosing, dose titration, and the 1 approach of ?start low and go slow?. The government should establish a similar SOP program for cannabis to be sold and consumed at festivals, concerts and other special events. Clearly marked wristbands should be provided to those who have proof of age (19 to ensure restricted access. All methods of cannabis consumption should be permitted however, cannabis smoking could be limited to outdoor events. For indoor events, vaporizing (at minimum) should be allowed in designated areas. Cannabis consumption will likely increase sales from other vendors (ex: food vendors) and will likely decrease irresponsible/uninhibited behaviours that are commonly associated with alcohol consumption. EMS professionals should be trained on how to manage over consumption of cannabis: provision of lemon water, quiet, dark space and messaging that waiting will resolve unpleasant effects. 1 4 Cannabis Consumption Establishments: Unlawful infused dinners are happening all over Canada and the demand continues to grow. Cannabis consumption establishments present an incredible opportunity to expand food services offerings, create communities for like?minded cannabis users and provide legitimacy, structure and standards to an already uncontrollably burgeoning market. ESOPE Given that these are transient permits, they offer an opportunity to enhance events around Ontario. They pose no real threat nor direct competition to retail stores. Given the excessive availability of alcohol at events, and known effects (drunken and disorderly behaviour at sporting events, for example), it seems only reasonable that cannabis be offered as an alternative option. The municipality should be involved in the provision of licenses to cannabis consumption establishments but they should not be involved in any other capacity. The framework should be designed and implemented by industry experts with ?rst hand experience and a vested interest in the long term success of the program. There is a huge demand for cannabis consumption lounges in Canada, and specifically in Ontario. As alcohol use continues to be promoted on air, on line and in print ads, cannabis advertisements are subjected to an unreasonable double standard. What?s more, cannabis users are forced to consume in private, giving the impression that this remains an illicit or socially unacceptable act. Bringing cannabis consumption establishments to the fore represents one monumental step towards normalizing cannabis consumption. Edible cannabis consumption in restaurants stands to be a multi billion dollar industry that has the potential to appeal to people from all ages, classes and backgrounds. 5 6 Martin, Ashley (MAG) From: Brent Leitch (via Google Docs) Sent: March 9, 2020 12:57 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Regulatory Registry Feedback Form (1) Follow Up Flag: Follow up Flag Status: Flagged Categories: Pro Licensed Est, Individual submission brent@cannabiscookingcompanyca has shared a link to the following document: Regulatory Registry Feedback Form (1) lSnapshot of the item below: REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments andlor Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings cafes, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 1 . cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) . cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) . cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Brent Leitcb, Executive Chef, Cannabis Cooking Company. Please reach outwith any questions or concerns. Brent@cannabiscookingcompanvLa 647-575-4476 About You or Your Organization Municipality (please check the appropriate box/boxes) Indigenous organization/community Health organization Other Educator Law enforcement Region (please refer to map and check appropriate box) . 1. Central Ontario . 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial The government should facilitate the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. The main reason for the legalization of cannabis was to keep it away from children, and eliminate the illegal market. By allowing greater access to those of age is the fastest way to eliminate the illegal market. If this is done in a responsible way, as it is with alcohol, allowing more access, consumer choice, lower prices, well educated staff (which in turn consumers will be better educated) we will carry forward the initial reason for legalization. By also taxing it correctly, it will create more revenue for the government, and allow greater education programs to exist surrounding cannabis use. Other products for sale should include cannabis accessories, food/beverage products that do not contain cannabis, and most importantly, food and beverages that do contain cannabis. This is the perfect opportunity to provide education to the masses on what happens to the body after ingesting edible cannabis and how it differs from inhaled cannabis. It also presents an opportunity to educate people on the importance of microdosing, dose titration, and the approach of ?start low and go slow?. The government should establish a similar SOP program for cannabis to be sold and consumed at festivals, concerts and other special events. Clearly marked wristbands should be provided to those who have proof of age (19 to ensure restricted access. All methods of cannabis consumption should be permitted however, cannabis smoking could be limited to outdoor events. Cannabis consumption will likely increase sales from other vendors (ex: food vendors) and will likely decrease irresponsible/uninhibited behaviours that are commonly associated with alcohol consumption. EMS professionals should be trained on how to manage over consumption of cannabis: provision of lemon water, quiet, dark space and messaging that waiting will resolve unpleasant effects. The honest fact is that cannabis is being used in an unrestricted manner at all sorts of events and festivals already. This should be acknowledged, and regulated, rather than ignored. Again, the tax revenue would be a major plus for government bodies, and people educated to consume responsibly. Also, people who are using cannabis in turn consume less alcohol, and as it is a more benign substance than alcohol, there is less issues associated with overconsumption. Ex. No one has ever died from cannabis use. The same is not true with alcohol. Cannabis Consumption Establishments: Unlawful infused dinners are happening all over Canada and the demand continues to grow. Cannabis consumption establishments present an incredible opportunity to expand food services offerings, create communities for like-minded cannabis users and provide legitimacy, structure and standards to an already uncontrollably burgeoning market. SOPs: Given that these are transient permits, they offer an opportunity to enhance events around Ontario. They pose no real threat nor direct competition to retail stores. Given the excessive availability of alcohol at events, and known effects (drunk and disorderly behaviour at sporting events, for example), it seems only reasonable that cannabis be offered as an alternative option. The municipality should be involved in the provision of licenses to cannabis consumption establishments but they should not be involved in any other capacity. The framework should be designed and implemented by industry experts with first hand experience and a vested interest in the long term success of the program. There is a huge demand for cannabis consumption lounges in Canada, and specifically in Ontario. As alcohol use continues to be promoted on air, online and in print ads, cannabis advertisements are subjected to an unreasonable double standard. What's more, cannabis users are forced to consume in private, giving the impression that this remains an illicit or socially unacceptable act. Bringing cannabis consumption establishments to the fore represents one monumental step towards normalizing cannabis consumption. Edible cannabis consumption in restaurants stands to be a multi billion dollar industry that has the potential to appeal to people from all ages, classes and backgrounds. Edible cannabis, when consumed responsibly (micro dosing, as our company promotes), is also the safest method of consumption. Training chefs to cook with cannabis safely and responsibly is an EXTREMELY important step towards safe consumption lounges, and educating the public on correct and low dose methods. I would love to invite any of your staff to a class we teach, so you can see how education is the most important thing, in our view, to a better public understanding of cannabis use. Once the public is well educated, there is no reason for an unregulated market to exist. Google Docs: Create and edit documents online. Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA You have received this email because someone shared a document with you from Google Docs. owned ?eguiatnd. of {Zambia haste-aft; March 10, 2020 Ministry of the Attorney General Policy Division Legalization of Cannabis Branch 720 Bay Street, 11th Floor Toronto ON M7A 289 Submitted via email to: cannabis@ontario.ca Ref: Potential for Cannabis Consumption Establishments andlor Cannabis Special Occasion Permits To Whom it May Concern, The Cannabis Council of Canada (?the Council') is pleased to provide its submission as the government solicits feedback to inform potential decisions about opportunities in an open cannabis market, specifically: cannabis consumption establishments and cannabis special occasion permits. The Council's submission outlines opportunities to grow and sustain significant capital investment by Ontario's licensed cannabis producers, create new entrepreneurial prospects, and generate opportunities to attract tourists to Ontario. The Council is the national organization of Canada's licensed producers of cannabis under the federal Cannabis Act. With over 20 members, we represent approximately 90% of the legal industry which employs thousands of Canadians directly, and indirectly, nationwide. In my newly-minted capacity as President CEO of the Council, and a proponent and contributor to the Smoke Free Ontario Act, I strongly support the premise of this consultation. I believe it affirms earlier policy commitments to create a parallel regulatory universe between adult-use cannabis and tobacco within a public-use setting. On behalf of the membership and Board of Directors of the Council, wish to again thank you for this opportunity to provide input on behalf of Canada's licensed producers. I look forward to working with the Government of Ontario as it works to enact parallel regulatory regimes to allow for cannabis consumption establishments and SOP permits. Please do not hesitate to reach out with any comments or questions you may have. Sincerely, :1 Java: 1 o? 13? ?cm-?x George Smitherman President CEO Cannabis Council of Canada Cannabis Council of Canada r: 21:: bis-c.5533 no?! newest; Regulated. of {Imam mag-a C.C.: The Honourable Doug Downey, M.P.P. Attorney General of Ontario Joseph Hillier Chief of Staff to the Attorney General of Ontario Cannabis Council of Canada r: 21:: bis-c.5533 no?! REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit Zionistr?o-opan?ngwcanraabas- As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit wvm. :3 rats n3 . Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: raada cafe ?f?f?iheaith~ca Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to canraabisi??ontarioca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). George Smitherman, President CEO, Cannabis Council of Canada 111 Albert Street, PO. Box 81071 Ottawa, Ontario, K1 181 Canada anrgea?i??cannab?s?canada.ca 416-816-7118 About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other: Industry association Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial The Cannabis Council of Canada (?the Council') strongly encourages the government of Ontario to establish a regulatory framework that would facilitate the sale of cannabis for consumption in establishments like lounges and cafes. This would serve to provide Ontario's adult-use consumers with greater choice and convenience and alleviate the discomfort of consuming in public outside of one's dwelling. The development of such a framework would help the government of Ontario achieve a wide range of public policy objectives, including: 0 Growing and sustaining the significant investment that Ontario's cannabis sector has made in communities across the province including the sizable capital investments in manufacturing facilities for ?Cannabis 20' products (primarily cannabis edibles) alongside expanded production capacity, processing facilities, and the hiring and training of skilled workforces. The provision of new points of sale would provide licensed cannabis producers with new streams of revenue to offset these investments and sustain the jobs that have been created at their Ontario facilities. 0 Creation of new entrepreneurial opportunities for those who may wish to establish and operate venues that serve non-combustible, edible cannabis products and provide safe, controlled, age-gated environments. Creation of such venues will encourage consumers to gather in a supervised social setting to enjoy regulated cannabis products, 3 diverting sales away from the illicit market and contribute significant taxation revenue to the province. lf Ontario were to develop a regime to allow for the development of cannabis-related businesses, it would be the first Canadian jurisdiction to do so. This ?first mover' advantage would enable Ontario entrepreneurs to develop brands that could be expanded to other provinces when they develop a similar framework. Generating opportunities to attract tourists to Ontario from other jurisdictions that do not currently allow on-premise consumption of adult-use cannabis. For comparison's sake, in 2015, Ontario wineries played host to 3 million visitors, generating $1.2 billion in revenue. Through the expansion of places of use regulations for adult-use cannabis, it's likely the province would see a similar boon to its tourism revenues and with it significant economic drivers for rural and remote communities. The Cannabis Council of Canada strongly believes that cannabis food and beverage products should be sold in establishments which also permit the sale of beverage alcohol and food/beverage products that do not contain cannabis. This will allow a broad variety of entrepreneurs to build new businesses or augment existing businesses by participating in the cannabis sector. The Council acknowledges there are perceived public health risks around co- location. As demonstrated in Nova Scotia, these challenges can be mitigated through limitations on cross-promotion and extensive training for licensed servers. To license a new class of establishment solely for cannabis consumption would be counter to the mission to normalize cannabis and serve to further isolate Ontario's cannabis consumers. In addition, like licensed cannabis retail stores (and similar establishments in the beverage alcohol sector, including craft breweries and wineries) these establishments should also have the ability to sell merchandise and other accessories. This will contribute to the fostering of a sense of community akin to that of other hospitality operations, position these entrepreneurs for a greater chance of long-term sustainability, and provide a host of other revenue streams to support their businesses. Finally, the Council posits that cannabis consumption establishments should not be restricted to establishments where food or beverages alone are sold (ex. Cafes). These establishments may also provide other services, which are known to be complementary to cannabis consumption, including spas or yoga studios. Rather than allowing for continued regulatory uncertainty for entrepreneurs interested in expanding their lines of business, these establishments could offer an opportunity for existing small businesses to grow their bottom line with products known to be of interest to their consumer base. The Cannabis Council of Canada supports the development of a SOP program for cannabis. In the spirit and intent of the previous questions within this consultation document, the Council also asks that the government consider a replicated SOP program for cannabis food and beverage products. Noting the average consumer's preference from dried flower consumption to a wide range of delivery methods, and considering the existing framework permitting the sale of alcohol at special occasions, the Council believes a mirrored SOP program for cannabis would provide additional opportunities for Canada's licensed producers. All members of the Cannabis Council of Canada are interested in the opportunity to apply for cannabis SOPs. If a licensed producer has a supply agreement with the OCS, it should reason that that producer's product would flow through to the venue authorized by the SOP. A cannabis SOP program should include public/private events, promotional events, concerts, festivals and sporting events. Allowing consumers the opportunity to purchase cannabis food and beverage products within special occasion spaces will serve to redirect sales from the thriving illicit market towards the legal industry and generate considerable tax revenues for the province of Ontario. As the act of smoking cannabis at outdoor venues is already permitted under the Smoke Free Ontario Act (though dependent on the venue's individual policy on the matter), the Council believes the sale of combustible cannabis should also be permitted at those events. This would encourage consumers to consume regulated cannabis products rather than those which are obtained through illicit sources. Specific to certain conditions under which a cannabis SOP program might be enacted, the Council has appended some considerations based on our members' expertise. In the context of an all- ages event, the Council proposes the inclusion of designated, age-gated consumption zones. These zones would be constructed so as to ensure youth may not enter. In a 19+ context, the Council proposes an age-restricted site similar to what is currently deemed a ?defined perimeter venue'. Open consumption in public spaces that can be secured for adult use, such as Fort York, will provide a setting for discreet use by mature audiences who have elected to enter it. We believe that this approach artfully blends key public policy objectives. Primarily, the visible consumption of cannabis can be restricted to limit the appeal to youth. Moreover, and similar to the emergence of Ontario's craft brewery sector, we believe this model creates opportunities for businesses within the cannabis industry to expand their reach within the province. In particular, it is vital to ensure fair and equitable spaces for smaller growers and micro-processors to showcase their offerings to adult audiences, notwithstanding the restrictive environment for other forms of brand representation. Cannabis Consumption Establishments The Council acknowledges that when compared to authorized cannabis retail stores, cannabis consumption lounges and SOPs carry proportionate risk. The development of specialized training for individuals serving cannabis to adult patrons, equivalent to the Smart Serve Ontario program, can be instituted to provide venues and servers with a system of checks and balances. The Council believes this is an appropriate safeguard to offset risks associated with the implementation of responsible cannabis food/beverage service including: understanding the policies associated with the legislation, avoiding violations, checking ID, preventing intoxication, etc. Ontario's cannabis sector has seen exponential growth in its early infancy the significant uptake of cannabis products incentivizes the development of new product forms. Cannabis consumption establishments have the potential to provide opportunities for consumers to consume legal cannabis within authorized spaces and will serve to ultimately displace the illicit market and contribute to provincial tax revenues. A Statistics Canada study noted that licensed cannabis producers have offset the illicit market by 11% since legalization in October 2018. As a result, the legalized market generated in excess of in tax revenue for the federal and provincial governments in the first five and half months of sales. Regulatory regimes governing the sale and distribution of cannabis within authorized establishments will continue to contribute to this decline in illicit sales. As previously mentioned, the opportunities associated with establishment of cannabis consumption venues and SOPs will provide: 0 attraction to visitors who enjoy the consumption of cannabis products in a regulated social environment, contributing to the province's tourism industry; 0 creation of newjobs and a growing source of tax revenue for Ontario; 0 allow entrepreneurs the ability to establish new businesses, augment services within their establishments and expand existing operations into otherjurisdictions; establish physical spaces offering the opportunity to educate on safe, responsible cannabis consumption; 0 a viable opportunity for consumers to purchase and consume regulated cannabis in controlled, age-gated facilities, further diverting cannabis sales in the illicit market; 0 additional opportunity for cannabis-specific events, festivals, tasting fairs, further encouraging tourism within the province, and the carving of a healthy cannabis culture in accordance with stated government policy objectives. SOPs: See above. Following the legalization of adult-use cannabis, Ontario municipalities were tasked with determining whether or not they would opt in or out of retailing cannabis in their communities. Given this stringency, the Cannabis Council of Canada believes further consideration is not necessary municipalities which have chosen to opt in should apply the same considerations to establishments authorized for cannabis consumption as they would to those governing licensed cannabis retail stores. The Council proposes that the AGCO continue direct oversight in issuing special occasion permits, wherein municipalities will be involved solely in permitting events/festivals when they are held on city property. Municipalities may designate policies outlining requirements for event organizers when cannabis is permitted on municipally-owned land, but would have no jurisdiction or permitting authority over SOP events held on private property. Given that this process is a precedent for alcohol beverage occasion permits, the Council believes a similar model is suitable for implementation pertaining to cannabis. Specific to cannabis consumption establishments, the Council asks the government of Ontario to consider an avenue for combustible cannabis consumption within exterior, discreet zones that are not visible at the street level. The chief reason for this position is that the dried flower category has proven to reign supreme in adult-use jurisdictions within the United States. To enact a regime for cannabis consumption lounges without acknowledging the dominant product category would be disingenuous to Ontario's cannabis consuming population and potentially detrimental to the future success of these establishments. The Council agrees that any regime for cannabis consumption establishments would remain aligned with the original intent of the Smoke-Free Ontario Act. However, it is also important, as this consultation process moves fonNard to enactment, to acknowledge the realities of consumer preferences and the stronghold of the dried flower category within the social fabric. We look fonNard to working with the government of Ontario and commit to making Council staff and members available to the government as a partner throughout this policymaking exercise. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) Goran Janjanin President Cannabis Cup Canada Inc. Retail Store Applicant w/ AGCO About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _Retail Store Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEECEI: (insert comments if necessary the box will expand as you type) Sure Caf?'s Lounges are fine but places where they sell Alcohol is not a good idea. Just as they teach you in driving school, the level of intoxication can multiple when Cannabis mixed with Alcohol. lf Caf?'s Lounges are a point of sale areas, they should be just like restaurants and sold at a premium. This is an area where creativity in the Arts can be something of new and interesting thing. You can see trends pop up with Musical Open Mic nights on a regular basis. This might also increase foot traffic because people are seeing music in it's purest and basic form. Instead of getting Justin Bieber from youtube, you will definitely change up the landscape of how artist are noticed by these type of establishments. (insert comments if necessary the box will expand as you type) Anything that can be an add on. If you have these type of establishments, you will still probably see the same odds of succeeding as restaurants except if you have a good variety of products and social atmosphere. Considering restaurants are some of highest risk businesses to start, more emphasis could even be down with new Cannabis Retail Stores and the branch off they can possible accommodate. (insert comments if necessary the box will expand as you type) People are consuming Cannabis a lot more freely then Alcohol at festivals and events so it doesn?t make sense to over regulate and enforce on it. Most important keys maybe to remember is to be considerate of others and not let children or retirees in direct exposure to. Getting permits by Cannabis Retail store operators should be easier. As they are more prone to protect their brand and license. Cannabis Consumption Establishments. (insert comments if necessary the box will expand as you type) Over-exposure of too many consumption establishments. Art, Music, Creativity. Have music jam-gyms where young people meet and become creative. Support of the community and Arts. SOPs: (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) Making sure places are renovated to building code and to protect the legitimacy of the industry. (insert comments if necessary the box will expand as you type) It might be a good idea to allow a multiple of different changes and forms of operating a Cannabis business. That way you have a large group of entrepreneurs competing with the same standard of rules and options to survive in thrive in this new industry. You will see the differences of how people go about starting these businesses instead ofjust copying one after another which will bore the public and could pose threat to the industry. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominiumlbuilding policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Alexandra Maxwell Communications Manager Cann Trust lnc. P. O. Box 92068, 9200 Weston Road, Vaughan, Ontario, L4H 3J3 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario LI 3. Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario 8. Provincial Yes, the government should consider caf? and lounge style cannabis establishments in Ontario. Ultimately, an establishment like this supports public safety and would be beneficial to cannabis consumers, thereby reducing black-market consumption. This kind of establishment would provide a consumption location that is guaranteed to be 19+. The Cannabis Act has a core focus on preventing underage consumption, however this is hard to enforce in a public space or private residence. This kind of establishment would help prevent underage visibility of cannabis consumption, as consumers would have a safe, a ge-gated, secure location to consume products. This would also reduce the number of consumers that are consuming in public places, which in the case of smoking and vaping, would prevent second- hand smoking impacts for minors. Lounges and cafes of this kind also provide a safe space for people to consume. There is not currently a space like this available in the legal market, which can leave new users vulnerable. With the beverage alcohol industry, a bartender can provide a recommendation on how much to try, while keeping an on the patron as they consume, but this is currently not available for 3 cannabis. With the addition of these kind of establishments, Ontario can support the consumer and overall public health more thoroughly as an experienced staff member within the lounge or caf? can provide this same function providing a recommendation on a safe starting point and monitoring the patron during consumption. They will also be able to assist in case of any difficulties. We can ensure that each establishment has properly trained medical personnel in case of any unexpected incidents. This kind of establishment also provides a unique public education opportunity to reinforce correct and safe consumption. Public education is a big focus due to the inexperience of a lot of consumers. The current sales model does not always provide an environment (or staffing) with the time to educate consumers on safe consumption. A lounge environment would add another touchpoint in the buying process, so people understand what different products are available and how much they should start with. Lounges and caf?s also provide a different level of accessibility for the general public. There remains a level of taboo and unease associated with legal cannabis retailers. These establishments would provide a more comforting environment, that is more accessible for broader range of potential users. This helps break down the stigma of cannabis consumption and reinforce cannabis consumption as legitimate, while simultaneously providing another opportunity to educate the broader public to feel more at ease. Finally, on public health, this kind of establishment would provide a valuable service to public safety. Employees of these kind of establishments can monitor consumption, but also ensure that no consumer is choosing to operate a vehicle while impaired. Employees can provide a secondary check to make sure no one is driving high, but also can assist in arranging safe transportation to get patrons home. On SFOA, it is worth noting that aside from smoking and vaping cannabis products, there are a number of ways to consume cannabis without SFOA applying. With the launch of Cannabis 2.0 products, edible items including beverages, chocolates and baked goods are now for sale through licensed establishments. These lounges and cafes have the option to serve cannabis while still being SFOA compliant. This will also likely increase the number of consumers choosing a none-combustible cannabis product. Driving education and familiarity of new formats of cannabis such as edibles, which will help transition cannabis users from more traditional forms dried flower) into ?healthier? options tinctures, edibles, beverages, etc. which will have a broader benefit to public health. Legislation for these kinds of establishments should follow the Cannabis Act. From a safety perspective, establishments should not serve both alcohol and cannabis in the same space, to prevent over-consumption. Those working at the establishment should be educated to not serve anyone who has been drinking alcohol within the location, or prior to entry. Caffeine should be limited for those consuming cannabis to within those outlined by Health Canada in the Cannabis Act, to prevent any adverse effects. While a caf? may imply that coffee is requirement, decaf or low-caffeine options can be explored. Food and beverage should be permitted within the space, however there is some concern about ?home baking? in a cannabis environment. All food and beverage sold on-site should be cannabis free, unless purchased through the existing retail framework and quality tested per Health Canada?s guidelines. THC infused items should be stored separately to other food and beverages being sold and should all be well labelled. Cannabis accessories should be allowed to be sold, so long as they meet Cannabis Act guidelines. Sales of additional non-cannabis items, ie. music records, items of clothing, games, etc. should also be permitted. This provides an experience within the establishment, which will provide a more open and welcoming space. This helps with accessibility to the broader public which long- term would help educate people on the cannabis space. Yes, a cannabis SOP program would make a lot of sense and be very beneficial to the province. Ultimately, this would provide a check on where consumption is allowed that is currently missing from existing events. People are already consuming cannabis at events. lmplementing an SOP program with a sales component on-site would help regulate the number of people consuming and help the province understand consumption at events of this kind. An implementation framework needs to be established that is very clear, with strict conditions e. blacked out fencing, security requirements) that ultimately regulates and controls event consumption to the same extent as legal cannabis retailers. This ensures public safety in consumption. Having an SOP program would also provide event organizers with the flexibility to opt-in or out of people consuming cannabis at their event. While people cannot enter an event with their own alcohol, this could help reinforce that people cannot enter an event with their own cannabis. All legal consumption methods should be allowed, providing correct disposal methods are provided. Providing the event is outdoors/ has an outdoor section, smoke-related consumption should be permitted, so long as it fits within the existing SFOA requirements. For events that do apply for an SOP, conditions should mirror Cannabis Act regulations. All permitted areas should have security and be 19+. Although the event may be open to all ages of the public, permitting for specific areas will ensure that minors do not have access or any 5 visibility to cannabis consumption. These areas should also have blacked out fencing to any non-permitted areas for the same reason and safe disposal areas. Finally, similarly to the SOP process, event organizers should prove they meet specific conditions based on size of event i.e they have notified the Emergency Services of the event. At events where alcohol is sold, the two consumption areas should remain separate. Additional security should be hired to monitor for over-consumption of any attendees who may frequent both areas during the event. Finally, no cannabis sponsor logos or promotion of cannabis sales should be visible outside of the permitted section (per Cannabis Act). Promotion of the event should not include any activity contrary to the Cannabis Act unless it is guaranteed to be age-gated. The current alcohol SOP system is already successful. lt?s understood, well executed and correctly regulated. This means a similar system for cannabis consumption should be easy to add on and adopt for the broader public. Both of these opportunities provide a number of key benefits to the Province of Ontario. All activity of this kind will also help tackle cannabis stigma on a broader level, making this more accessible for Ontario residents. This will help us, as a province, to provide a more secure, safe space for consumption. With the inclusion of trained medical professionals at licensed events, or establishments of this kind, we are better supporting the public and ensuring fewer health concerns. Having cannabis accessibility outside of brick mortar legal cannabis retailer will also help us manage supply issues in the province. More lo cations can better support customer demand, which will de?ect users currently relying on the black market and help supply smaller communities that may not have a legal cannabis retailer close-by, with a legal point of purchase. The Province of Ontario also has the opportunity to increase tourism revenue by creating a first- of-its-kind Canadian destination of cannabis lounges. While Edmonton is also looking at implementing similar licensing for the caf? environment, Ontario would be a significantly bigger draw for canna-tourists. lt is worth note that several U. S. states do have successful cannabis lounges, including California, Alaska and Michigan, proving there is a demand for this kind of establishment. Finally, this kind of framework would also help us more accurately understand who is consuming cannabis and learn more about provincial consumption habits. This research and information will help the province in demand mapping and planning for future initiatives. The muniCipalities should have the opportunity to opt-in or opt-out on the overall framework. However, they should not be able to restrict on an event-by-event basis, mirroring the retail licensing set-up under the Cannabis Act. These kind of caf? environments already exist within the black market. Opening up legalization of similar establishments provides a way to intercept, redirect and ultimately take-over these non-licensed establishments, which are not meeting current safety standards. Secondly, we know people are already consuming in public, without any monitoring and in full sight of minors. These establishments provide an opportunity to control this, ultimately, protecting the public. March 10, 2020 Mr. Alexander Bishop Director, Policy and Program Development Legalization of Cannabis Branch Ministry of the Attorney General 720 Bay Street, 11th Floor Toronto ON M7A 289 Dear Mr. Bishop, Please find appended Canopy Growth Corporation's submission to the Ministry of the Attorney General consultation on the potential for Cannabis Consumption Establishments and Cannabis Special Occasion Permits. We appreciate the opportunity to participate in this consultation, and look fonNard to working with you and your colleagues and other officials within the Government of Ontario on any regulations that may result from this process. Please don't hesitate to contact me should you have any questions or comments. Yours sincerely, Sean Webster Director, Government and and Stakeholder Relations 335%- ?3 fl 613666.566? Submission to the Ontario Ministry of the Attorney General: Potential for Cannabis Consumption Establishments and Cannabis Special Occasion Permits Contact Information Sean Webster, Director, Government and Stakeholder Relations, Federal and Ontario Canopy Growth Corporation 1 Hershey Drive Smiths Falls, ON K7A 0A8 About You or Your Organization (please check the appropriate box/boxes) Health Organization Municipality a?y Educator a?y Indigenous organization community Law Enforcement Other - LP Region (please refer to map and check appropriate box) $57 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area $57 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario $57 7. Western Ontario 8. Provincial Cannabis Consumption Establishments/Special Occasion Permits 1. Taking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not? We strongly encourage Ontario to establish a regulatory framework that would facilitate the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. The development of such a framework would help the government of Ontario achieve a wide range of public policy objectives, including: 0 Growing and sustaining the significant investment that Ontario's cannabis sector has made in communities across the province; including the significant capital investments in manufacturing facilities for ?Cannabis 2.0? products (foods and beverages) alongside expanded production and processing facilities and hiring and training skilled workforces. 0 Creation of new entrepreneurial opportunities for those who may wish to establish and operate venues that serve cannabis beverages and food products and provide safe, controlled, age-gated environments, where consumers can learn more about cannabis, its effects and how to consume it in a responsible manner. 0 Generating opportunities to attract tourists to Ontario from jurisdictions that may not currently permit the enjoyment of cannabis for recreational purposes, and to compete with those jurisdictions that already permit cafes and lounges to serve cannabis beverages and food. Growing and Sustaining Cannabis Investment in Ontario Canopy Growth Corporation was established in Smiths Falls in 2012, initially to serve medical cannabis patients and as of October 2018 serving Canada's domestic recreational cannabis market. We are actively engaged in global cannabis markets in 12 countries across five continents and operate 13 cannabis production and processing facilities in seven Canadian provinces, including four in Ontario in Smiths Falls, Niagara-on-the-Lake, Clarington and Toronto. We have invested over in Ontario alone and currently employ more than 2,600 in the Province. The development of a regulatory framework to allow for the provision of new venues, as well as special occasion sales, for the responsible sale and consumption of regulated cannabis products would allow Canopy Growth, and other licensed cannabis producers, to broaden the market for these products. It would signal that Ontario is supportive of its cannabis sector, which would assist in encouraging other provinces to also develop frameworks for permitting of cannabis consumption establishments. The provision of new points of sale would also provide licensed cannabis producers with new streams of revenue to offset their significant capital investments and sustain the jobs that have been created at their Ontario facilities. Creation of New Business Opportunities for Ontario?s Entrepreneurs Deloitte Canada has estimated that the Canadian cannabis edib es market alone is estimated to be worth at least $1.6 billion a year, with cannabis-infused beverages worth an additional $529 million1. Given the potential scope of the market for edible and beverage cannabis products, significant opportunities exist for entrepreneurs to develop new businesses to allow consumers to enjoy these products in safe, age-gated environments. Aside from traditional cafes and lounges, other opportunities exist that may attract entrepreneurial investment, including yoga studios, spas, barber shops, salons and galleries. Creation of such venues will encourage consumers to gather in a supervised social-setting to enjoy regulated cannabis products, diverting sales away from the illicit market and contribute significant taxation revenue to the province. As cannabis and cannabis food products are relatively new to Canadian consumers, there exists significant opportunities for the development of establishments that will both serve cannabis food and beverage products as well as providing education on the responsible enjoyment of these products. A recent survey reported that likely Canadian cannabis consumers are especially eager to try three new cannabis formats: edib es topicals or ointments and cannabis-infused beverages The same survey reported that for nearly one third of likely cannabis consumers, cannabis edib es and beverages are a safer alternative to other cannabis products and that the clear majority intend to purchase edib es from government stores, licensed private retailers or directly from licensed producers.2 These survey results illustrate a significant business opportunity for the establishment of cannabis-related businesses and offers potential points of entry for those entrepreneurs wishing to provide expertise on these products for new cannabis consumers. Other North American jurisdictions have already developed regulatory frameworks to allow the sale of cannabis in cafes or lounges, including Alaska, California, Colorado and Nevada. lf Ontario were to develop a regime to allow for the development of cannabis-related businesses, it would be the first Canadian jurisdiction to do so. This ?first mover? advantage would enable Ontario entrepreneurs to develop brands that could be expanded to other provinces when they develop a similar framework. 1 Nurturing new growth: Canada gets ready for Cannabis 2.0. Deloitte LLP. Toronto, June 3, 2019 2 Nurturing new growth: Canada gets ready for Cannabis 2.0. Deloitte LLP. Toronto, June 3, 2019 Training for staff on the safe serving of Cannabis 2.0 products will be key for the long-term success of these businesses. Canopy Growth has already partnered with New Brunswick to develop and implement cannabis training for their retail network. We would be pleased to work with Ontario to develop similar curriculum, comparable to Ontario's successful Smart Serve Ontarios program for alcohol service. Attracting Cannabis Tourists As noted, no other Canadian province has developed a regulatory framework to allow for the sale of cannabis in cafes or lounges, and only four US States have done so. The development of such businesses in Ontario would serve to attract visitors to the province who wish to enjoy cannabis products in a regulated social environment. Cannabis tourism in Colorado accounted for 6.5 million visits in 2016. Overall Colorado has generated an estimated $1 billion USD in tax revenue through cannabis sales.4 In comparison, cannabis related tourism could look to Ontario's wine industry as an example of a sector that attracted 3 million visitors to Ontario wineries in 2015, generating $1.2 billion in revenue. Recognizing this potential lead Smiths Falls to develop a strategy to attract cannabis tourism as a key economic driver for the town5. 2. If cannabis consumption establishments were considered in Ontario, what other products should be permitted for sale in those establishments cannabis accessories, food/beverage products that do not contain cannabis)? Cannabis food and beverage products should be sold in establishments which also permit the sale of alcohol and food. Cannabis products are manufactured under stringent regulatory conditions, supervised by Health Canada, and should be treated no differently than beverage alcohol. The ability to sell food should also be permitted. This will allow restaurants to develop unique menu offerings to complement their cannabis beverage offerings and attract diners. In addition, like cannabis retail stores (and micro-breweries, wineries, craft distilleries) these establishments should also have the ability to sell clothing, books and other accessories. This will enable them to build brands for long-term sustainability as well as exploit other revenue streams to support their businesses. Finally, cannabis consumption establishments should not be restricted to be just cafes or lounges. These establishments may also provide other services, which may be complementary to cannabis consumption, including; spas, yoga studios, salons and barber shops. This will allow a broad variety of entrepreneurs to build new businesses or augment existing businesses by participating in the cannabis sector. 3. In Ontario, the Alcohol and Gaming Commission of Ontario (AGCO) oversees the administration of an alcohol SOP program, which allows for the sale and service of alcohol at special occasions, including large scale events that are open to the public, such as festivals. Should the government consider establishing a similar SOP program for cannabis to be sold and consumed at festivals and events? Why or why not? If yes, what conditions should be included should alcohol consumption at the same event be restricted, should the event be age-restricted to 19+, what methods of cannabis consumption should be permitted)? For more information on the current alcohol SOP program, please visit: The SOP program currently in place for alcohol should be replicated for cannabis food and beverage products. This would include public private events, tailgate events and industry promotional events. Cannabis consumption is no less harmful than the consumption of alcohol, which is already widely promoted in the province. Concerts, festivals and sporting events are already heavily promoted by the beverage alcohol sector. The ability for consumers to purchase and enjoy regulated cannabis food and beverages at special occasions will divert sales away from the illicit market and generate significant tax revenues for the province. Further, Health Canada's regulations for cannabis promotion are very stringent, which will preclude any advertising or promotional activities at special events which may be considered to be ?appealing to youth?. At outdoor venues, smoking cannabis is already permitted in the same manner as smoking tobacco under the Smoke Free Ontario Act. Accordingly, the sale of combustible cannabis should also be permitted at those events. This would encourage consumers to smoke regulated cannabis rather than cannabis obtained through illicit sources. 4. Are there any additional risks I opportunities created by cannabis consumption establishments or SOPs when compared to authorized cannabis retail stores? Cannabis Consumption Establishments: The risks associated with the creation of cannabis consumption establishments are comparable to the risks associated with the creation of cannabis retail stores, as well as establishments which are licensed to sell beverage alcohol, including bars and restaurants. As previously referenced, the creation of specialized cannabis training, comparable to the Smart Serve Ontario beverage alcohol training program, would be recommended to provide safeguards to cannabis consumption. Ontario already has a sophisticated regulatory regime to govern the sale and service of alcohol in the province through the LCBO retail network (including agency stores) and bars, restaurants and at sporting events as well as at micro-breweries, wineries and small craft distillers. Further, the province has recently expanded this network through the sale of beer and wine in grocery stores with plans to expand to corner stores. Although still in its infancy, Ontario's cannabis sector is quickly growing and developing new products and is displacing the illicit market. In fact, a recent Statistics Canada study noted that licensed cannabis producers have offset the illicit market by 11%6 since legalization in October 2018, which generated in excess of in tax revenue for the federal and provincial governments in the first five and half months of sales7. Providing additional options for consumers to purchase and consume legal cannabis will serve to continue to offset the illicit market and significantly contribute to provincial tax revenues. According to data from Beer Canada, in the first year of cannabis legalization beer consumption in Canada dropped by Previous trends seen between 2014 and 2018 show beer volumes fell an average of 0.3% year over year.3 This suggests that consumers are looking for alternatives to traditional beverage alcohol products and on that basis we are anticipating significant uptake of cannabis beverages when they are introduced to the Ontario market. As already noted, the opportunities associated with establishment of cannabis consumption venues will provide: 0 entrepreneurs the ability to establish new businesses - creating jobs and growing tax revenue for the province - and expanding those businesses into other jurisdictions from their Ontario base; 0 incentive for consumers to purchase and consume regulated cannabis in controlled, age-gated facilities, further diverting cannabis sales in the illicit market; more opportunities education on the safe and responsible use of cannabis; and attraction for tourists visiting Ontario. SOPs: Like cannabis consumption establishments, the risks associated with the sale and consumption of cannabis food and beverage products through the SOP program are comparable to the risks associated with the creation of cannabis retail stores, as well as the sale and consumption of beverage alcohol under the program. Similarly, the opportunities associated with the potential for cannabis sales and consumption through the SOP program is comparable to those for cannabis consumption establishments. In particular, additional opportunities exist for the creation of special events focused on cannabis culture, including tasting fairs, concerts and other special events which would allow Ontario consumers to attend and purchase regulated cannabis and encourage tourism to the province. 5. What should be a municipality?s involvement, if any, in a potential framework for cannabis consumption establishments or In 2018 2019 Ontario municipalities were given the option of opting in or out of cannabis sales in their communities. These decisions were taken after significant research, open public consultation and debate. In our view, there is no need for further consideration by municipalities in this respect. For those municipalities which have ?opted-in?, the same licensing regulations that exist for the location of cannabis retail sales should be applied for establishments serving cannabis. As for SOPs, we feel the AGCO should continue to handle SOPs outright. Municipalities will have involvement in the permitting of these events and festivals when they are held on city property. For events held on private property, the municipality would have no jurisdiction. Currently for alcohol, municipalities do not participate in the SOP process, however, they have alcohol policies that outline the requirements for event organizers when alcohol is permitted at events held on municipally owned land. We are interested in any other comments or suggestions you wish to make about cannabis consumption establishments and/or SOPs. As already noted, we are strongly of the view that the development of a regulatory framework to permit the establishment of cannabis consumption venues as well provisions for the sales and consumption of cannabis under the SOP program will significantly benefit Ontario's licensed cannabis production sector and will enable entrepreneurs to build new cannabis-focused businesses. 0 Ontario has the potential to harness ?first mover advantage? by allowing entrepreneurs to build and develop cannabis consumption ?brands? in Ontario that can be replicated in other jurisdictions, when they develop their own regulatory framework. 0 Businesses now not usually associated with cannabis sales and consumption, such as yoga studios, spas, etc, may also be encouraged to establish or expand their existing businesses to include cannabis as part of their service offerings SOP permitting for cannabis sales and consumption will encourage the development of new festivals and concerts. 0 Opportunities to encourage tourism to Ontario will be developed for visits to cannabis consumption venues as well as concerts and other events permitting the sale and consumption of cannabis under the SOP program. 0 The significant capital investment and jobs created by Ontario's cannabis sector will be recognized, and streams of revenue will be created to help them recoup and sustain their ongoing investments. Potential New Business Development - Cannabis Home Delivery Services We also encourage Ontario to consider other lines of cannabis businesses that may also be created in the province under a progressive regulatory system, including the development of cannabis delivery services, which could augment the evolving food services sector which is increasingly focused on ?in-home? dining experiences.9 The growth of services such as UBER Eats and SkipTheDishes has been embraced by existing restaurant chains who are evolving their business models to embrace these offerings, which grew 44% between between 2018 and 201910. In addition, new business-lines are being developed, including ?ghost kitchens?11 who will have the ability to produce food for multiple brands exclusively for home delivery services. The inclusion of cannabis delivery services would add to the service offerings provided by these businesses and would directly divert sales from the illicit cannabis market, for whom cannabis home delivery has been a standard service offering for several decades. Finally, the development of a framework to permit home delivery would further add to Ontario's tax revenue streams and further recognize the contribution of Ontario's cannabis sector to the provinces economyFruit" Fl." 1" rtl".' v.3" "33? ivo??uvv? .L. (Join) . . 5: x433); I . LEU- rn . .. 5'REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Contact Information Jonathan Carley, Executive Vice-President Director, Canadian Cannabis Retailers Union Inc. 1 Yonge St., Suite 1801 Toronto, ON, M5E 1W7 M: 905-320-6260 jonathan .carley@ccru .ca About You or Your Organization Health organization Municipality Educator Indigenous organization/community Law enforcement Other: Industry Association Region . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Yes. The consumption of cannabis products should be permitted according to standards and regulations which ensure safety and protect youth, while allowing for a consumer experience that is not overly restrictive or detrimental to the growth of the marketplace. Any regulations should allow the serving of all quality-controlled cannabis products, notjust existing pre- packaged retail products. Cannabis brands should be allowed to educate consumers in cannabis consumption areas. There should be no restriction on the types of cannabis products that can be consumed at consumption establishments. Many cannabis users are also consuming alcohol along with cannabis in a responsible manner. We believe that the serving of alcohol and cannabis together can be done in a safe manner that benefits consumer choice and would allow establishments much more flexibility in using existing venue space. Yes, all of the above. Yes. This will benefit everyone and create a safer environment for attendees and staff. Currently event organizers and security are forced to spend time on managing those consuming cannabis products. By allowing an SOP program, an event organizer will be able to create safe and comfortable areas for those who would like to consume and Security will be able to focus their energy on other items related to the safe execution of the event. We do not believe that consumption areas should be limited to a small area of the event. It should be up to the organizer to section off their event based on the needs of their attendees. Alcohol should be able to be consumed at the same events. Events should be 19+. Cannabis brands should be allowed to educate consumers at these events and cannabis consumption areas should not be visible to minors outside of the event grounds. There should be no restriction on the types of cannabis products that can be consumed under the SOP. Cannabis Consumption Establishments: We believe the introduction of cannabis into the bar, restaurant and hospitality industry has less risk than is currently posed by the serving of alcohol. Consumers of cannabis are less aggressive and less prone to violent acts. However, like with alcohol, patrons need to served responsibly, and anyone who is showing obvious signs of significant intoxication should be denied service. Consumption establishments should be 19+ and should not be visible to minors outside of the venue. SOPs: We believe the introduction of consumption SOPs present less risk than is currently posed by alcohol SOPs. Consumers of cannabis are less aggressive and less prone to violent acts. However, like with alcohol, patrons need to served responsibly, and anyone who is showing obvious signs of significant intoxication should be denied service. Additionally consumers leaving events should be taking the necessary steps to prevent driving under the influence. Municipalities should have the ability to set their own standards and regulations as they see fit. These may be more or less restrictive than any provincial or federal requirements. The Canadian Cannabis Retailers Union (CCRU) is the voice of the cannabis retail and consumption venue marketplace. As advocates for safe and reliable cannabis distribution, the CCRU's goal is to represent retailers and establishments across Canada and to enlighten and educate industry participants on how to responsibly sell and serve cannabis to create safer stores and communities. The CCRU's member programs include best practices and education for the safe and responsible operation of their businesses that keeps product out of the hands of minors, promotes effective principles of harm reduction and community protection, and allows members a balanced approach to provide a superior experience to their customers. The CCRU is in favour of free and open access for all Ontarians 19+ to all quality-assured cannabis products, including from independent cannabis product producers and manufacturers. We also believe that private property rights must be respected and that adult Ontarians should be able to responsibly enjoy any cannabis product at their individual discretion. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Robin Ellins, 3279 Lenworth Drive, Unit C, Mississauga, Ontario, L4X 266 416?951?1251 2 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement $1 Other: Cannabis Professional Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario I: 6. Southwestern Ontario 7. Western Ontario 8. Provincial Lounges Create spaces tailored to consumers? needs and dissuade public use 0 Are ideal for tourists who wish to consume cannabis Create an opportunity for consumers to sample government product 0 Encourage consumption outside of condos and apartments 0 Increases accessibility for medical patients that require aid with consumption 0 Smart Serve certified employees minimize risk of intoxicated driving 0 Create more jobs in small business and cannabis sectors 0 Increase tax generation 3 Legitimizing and regulating existing consumption at bars and clubs can be achieved by permitting cannabis consumption at existing venues Other food and beverages should be served with cannabis on the premise of inc usivity to others, social normalization, and increased sales 0 A wide variety of cannabis accessories should be available at lounges 0 Should use the current SOP framework for alcohol with regulated cannabis consumption and sale 0 19+ ?Beer Garden? model should be used for cannabis at events I Cannabis Consumption Establishments. 4 More access points to legal cannabis quashes black market 0 Permitting lounges and cannabis SOPs helps to change social stigmas toward cannabis that will encourage legal procurement and eliminate the need for secrecy and the black market SOPs: Designated consumption spaces at events respects non-smokers 0 Sale of legal cannabis at events limits black market Municipalities that have ?opted-out? of dispensaries should be not be considered for lounge licences Municipalities should have the same 15 day period to express concerns to the AGCO about lounges as they do with dispensaries (insert comments if necessary the box will expand as you type) 5 6 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) Long VP of Marketing Communications - Friendly Stranger Holdings Corporation 2 Bloor Street West, Suite 1804 Toronto ONT - 416-817-1927 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other? Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEECEI: (insert comments if necessary the box will expand as you type) Yes they definitely should there is definitely a need for these consumption lounges/sites; providing safe consumption areas within communities (therefore alleviating concerns for condo boards in many municipalities), chance to break stigma/allowing for like minded people to gather and of course a chance to educate. (insert comments if necessary the box will expand as you type) Absolutely. Humans inherently want to congregate and enjoy each others company with like minded individuals and restaurants and bars have been doing this with alcohol for hundreds of years. Allowing for safe consumption establishments allows for regulations around minors and education through ?budtenders' furthering the possibility of Canadians and Ontarians to enjoy this legal substance. Allowing for cannabis accessories, food/beverage products that do not contain cannabis and the like will allow further enjoyment and a chance to break down the stigmas associated with consuming cannabis. (insert comments if necessary the box will expand as you type) Absolutely. Having purchased many special occasion permits in the past from the Alcohol and Gaming Commission, Cannabis too should have the ability to throw community events allowing for safe consumption. Right now, unregulated parties are being executed in private establishments with no regulation undercover. This continues to harm the industry and feed the black market. Why not open this up to regulation (and income avenues for the AGCO) allowing for safe consumption sites for all those who prefer to partake in cannabis vs. alcohol. ?II-Cannabis Consumption Establishments. (insert comments if necessary the box will expand as you type) Opportunities: increased business opportunities for a failing casual dining sector in the industry. Many small to mid-sized businesses are hurting with the number of Canadians not going out to eat anymore and instead eating at home. By allowing these cannabis consumption sites we are furthering education and breaking the stigma associated with this industry/plant. Canada can become a leader in this for all other G8 countries. SOPs: (insert comments if necessary the box will expand as you type) Further training at all levels of existing public establishments (JUST LIKE SMART SERVER WHERE ALCOHOL lS SOLD) to ensure Smart Serve/CanSell are reviewed together to ensure over consumption isn't an issue (insert comments if necessary the box will expand as you type) None. Feds and Provincial government should decide. Municipality intricacies will just create further confusion and issues with those applying again stunting the growth of this market further. (insert comments if necessary the box will expand as you type) Not at this exact moment. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) Bentata, 410-16 Carluke Cres, North York, ON, M2L2H9 - Highlifemedia.ca About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial (insert comments if necessary the box will expand as you type) Allowing sale of cannabis in areas of consumption just makes logistical sense. Retailers can offer an area to consume or lounges can offer an area to purchase cannabis. Both establishments are age restricted and safe. Amsterdam has had similar businesses work successfully for decades. Similarly, Bars offer adult patrons the ability to purchase and consume alcohol, which is 1. far more dangerous than cannabis and 2. offers no health benefits. cannabis accessories, food and drink, novelty items, apparel, merchandise, etc. No tobacco or alcohol needs to be served in the same establishment. cannabis should be allowed to be consumed by any adult in an age restricted establishment or event if there is appropriate ventilation or if the consumption is outdoors. cannabis and alcohol interaction does have to be watched out for, but no more than over consumption of alcohol Consumptlon there have been various ?cannabis lounges? in operation before which ensured age restricted access, proper ventilation, and the ability for patrons to purchase food or drink. This is crucial for those ingesting cannabis as it can offset any negative effects from consumption. Food and drink can help someone manage the effects of cannabis and can be used as an aid for anyone having a negative reaction to ingesting cannabis. SOPs: Staff should be experienced with cannabis and have experience with customer service so that any guests can be serviced effectively when it comes to cannabis, their needs, and any negative consequences from consumption such as paranoia/loss of energy. This is even more crucial if alcohol is being served on site as the interaction of alcohol and cannabis can sometimes cause sickness and disorientation. SOP should not have to be very different to What any establishment serving alcohol has to go through, except for staff having experience With cannabis too. municipal involvement should be minimal. bars and establishments offering alcohol already have an effective sop that can be transitioned into cannabis lounges Which can serve as an effective model. adults have been using cannabis lounges safely for many years now and overregulation in this area is unnecessary. people involved in these businesses can easily be consulted for feedback and valuable insight. people consuming cannabis in a lounge are at less risk and offer less danger than individuals consuming alcohol in bars. people Who consume cannabis should have access to drinks and food as it helps to manage the effects of cannabis. establishments for cannabis consumption are crucial for so many canadians Who are unable to consume at home or outdoors. cannabis is often used medicinally and users cannot be expected to consume outside in the cold or if they have physical disabilities that make it difficult for them to move. many apartment and condo buildings restrict cannabis use indoors Which is unfair, especially to the elderly or disabled. There are also many users Who do not want to consume around their children Which is another reason Why cannabis consumption establishments are necessary, REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit mm," raswsmatario E's; Zioratariouo behind-ca - ra?arketfatm?. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e?cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit WM. :3 nta cafe-a na bis. Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: 54?.th airway-Lam bade. .caia nii'eea iti'emca readainewsi?'} 1 Sines: iti'rca pa (isanii nae iizeswea isat?o nsvio M. Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Jonathon Liedtke Founder and owner - Higher Limits cannabis lounge Windsor Ontario .- About You or Your Organization BHea-It-h?e-rga-niza-t?ie-n EEel-uea-t-e-F Btaw?e-nferee-me-nt Other BUSINESS OWNER Cannabis Consumption Establishments: SOPs: REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Kelly Addison Owner, Founder, Lounge Madam Kelly's Green Lounge 5323 Main St., Orono, LOB1M0 About You or Your Organization (please check the appropriate box/boxes) Health organization Recreational Space Educational space Retail space Region (please refer to map and check appropriate box) 3. Greater Toronto Area We are also quite busy online. Oh yes please! We really do. don?t need to sell dried flower or edibles butl sure would like to sell infused beverages. Like, the way a restaurant has a liquor license. have become a cannabis consultant, work in media andl teach and do everything can to support cannabis. educate people before they consume. educate while they consume. The role of Kelly?s Green Lounge is to help balance the cannabis community. We care about the plant, first We believe in learning about cannabis at the same time as trying it so you don?t get sick! think with our platform, we can help people learn to consume their beverages in a safe space! One third of my lounge is retail. We offer everything from what you need to consume cannabis to growing supplies. love being able to offer all things to the people looking for answers. also offer non infused snacks and beverages in my lounge. think this should be a liquor license or a speCial permit license. The way the alcohol license is given to those looking for it for a wedding or festival. The same regulations should apply. Same rules for alcohol! As It turns out, cannabls Is actually Again, same as a special permit for alcohol. We need more of an open market for cannabis so we aren?t so regulated. lt is ABSOLUTELY important we keep the dosage low and educate the people but eventually you?re going to have to trust us! Please come visit me or look me Kelly?s Green Lounge. We are doing it the right REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit EH As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit nta no .caica na bis . Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) 0 cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) 0 cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to 222':ranabiegiboratarib .ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Submitted by Andrew Gordon, Senior Vice President - Retail Operations Community licensing@kiaro.com On behalf of Kiaro Brands Inc. #300 - 110 Cordova Street Vancouver, BC V6A 1K9 About You or Your Organization Health organization Municipality Educator Indigenous organization/community Law enforcement Other - Cannabis Retailer Region . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Kiaro is encouraged to see the Ontario government moving forward with opening up the private retail market for cannabis sales in the province. We believe that this policy change will provide consumers with much needed access to a convenient and reliable supply of cannabis, and will prove a positive step forward in improving public health and safety, eroding the presence of the illicit market, and enhancing economic development within the region. We are grateful for the opportunity to provide feedback on the potential implementation of additional cannabis business opportunities that could facilitate the sale of cannabis for consumption in establishments like lounges and cafes, as well as expanding the scope of the current special occasion permit process to include cannabis. Kiaro believes that the government of Ontario should move forward with permitting the sale of cannabis for consumption in establishments like lounges and cafes. Since legalization in October 2018, we have seen a number of entrepreneurs and private businesses across Canada taking steps to move forward with establishing onsite cannabis consumption opportunities through private parties and age-gated events that often incorporate infused food and drink options for their adult patrons. We believe regulating these activities would allow communities to alleviate current consumption issues, along with helping to achieve the positive economic and social goals of cannabis legalization. It is encouraging to see that there is already a strong precedent developing here in Canada to help inform the evolution of these regulations. Cannabis lounges are currently permitted in Nunavut, which maintain the indoor smoking ban, and only allow for non-smoked cannabis options to be consumed. In British Columbia, the City of Victoria has made submissions to the province of BC advocating for consumption lounges, and during the province's public consultation period for cannabis regulation, it urged officials to consider a licensing regime for lounges. Moreover, the City of Edmonton recently passed a zoning bylaw amendment to permit cannabis lounges as a category of permitted usage; and while consumption lounges are not yet operational, this is an important first step in the regulation of consumption sites in that province. In the United States, Alaska is the first jurisdiction with state-wide legislation regulating use in retail cannabis shops. In California, many major cities have begun accepting licence applications for cannabis lounges; and the City of Denver, Colorado has recently granted its first licence to a cannabis caf? that allows vaping and edibles to be consumed. Within these examples, we see a number of emerging advantages gained by moving forward with facilitating the sale of cannabis for consumption in establishments like lounges and cafes, as well as expanding scope to include cannabis under the current special occasion permit process. Social Benefits: 0 Cannabis consumption sites provide a frontline opportunity to help mitigate the risks of impairment, and promote moderation, through direct consumer education 0 Consumption sites can minimize the risk of co-consumption with alcohol and tobacco providing a safe atmosphere in which consumption can be monitored closely by well trained staff 0 Regulated consumption sites encourage consumption away from public spaces such as parks and school zones 0 Product information, educational resources and trained staff available onsite can safely steward the experience for all consumers particularly new and novice ones 0 Cannabis consumption sites support the needs of specific groups that may have limitations in where they can use cannabis. For example, those who do not have a private residence, renters who may be prohibited to use cannabis by management companies, or tourists. We must also consider the experience of vulnerable populations, such as the homeless, who may be more likely to use openly in public. Economic Benefits: 0 According to Stats Canada, cannabis sales since legalization in 2018 have passed one billion dollars, and consumption spaces would further increase commercial opportunities and consumer spending in the sector 0 Consumption sites would help destabilize the entrenched unregulated market by enabling regulated businesses to provide an experience that illegal operators ca n?t offer which would help convert more consumers to the regulated industry 0 Deloitte estimates that cannabis beverage sales could be worth as much as $529 million annually and would be greatly amplified through consumption spaces 0 Consumption sites save taxpayers money by reducing overall enforcement costs by decreasing funds that governments spend deterring public consumption 0 Consumption sites and permit fees can increase tax revenue to fund schools, healthcare and other social benefit programs 0 Legal cannabis consumption sites help municipal governments by saving taxpayer money that would otherwise be spent deterring public consumption 0 Cannabis consumption sites provide an opportunity for increased tourism We believe that if consumption establishments were considered in Ontario that cannabis products, cannabis accessories, as well as apparel, and non-cannabis food and beverage products should be permitted for sale. Permitting the sale of both cannabis products and non-cannabis products would create more viable revenue streams, and thus a more secure and sustainable business opportunity for the operators of these establishments over the long-term. We do caution against allowing the sale of alcohol at consumption establishments due to the increased risk of impairment, and the public health and safety risks associated with combining cannabis with other intoxicants. By offering licensed consumption spaces, that include the sale of only regulated cannabis products, patrons and community stakeholders can enjoy a safer experience because consumers will be consuming quality assured and analytically tested products while being monitored by specially trained staff. This would significantly decrease the potential for any adverse reactions, decrease harm from adverse reactions with immediate support from staff, as well as decrease the costs of enforcement and prosecution of cannabis related infractions. The sale of regulated cannabis products within these proposed consumption spaces, also reinforces the position that licensed retail operators are the best to manage these sites as either components of their existing businesses, or as an adjacent business, because of the security and financial integrity checks they have gone through, as well as the experience they have with managing the inventory of a strictly regulated product. sr; Ifgi Kiaro believes that the government of Ontario should leverage its considerable experience overseeing the administration of alcohol sales and services to move forward with permitting the sale of cannabis for consumption in establishments like lounges and cafes, as well as develop SOPs for special occasions that include large scale events that are open to the public. The reality is that at many festivals and events there will always be a degree of cannabis consumption and therefore permitting it in a regulated and supervised setting would help promote the key objectives of the Cannabis Act (keeping cannabis out of the hands of youth, keeping profits out of the pockets of criminals and protecting public health and safety by allowing adults access to legal cannabis). Event planners have to undergo extensive risk assessments for provision of all elements of their event (food beverage, liquor sales consumption, smoking areas). The extension of these measures to cover cannabis sales consumption is a natural progression. The City of Calgary already allows event organisers to apply to include a designated cannabis consumption area within their festival/event. A cannabis sales area at an event or festival would be very analogous to areas within the event where liquor is served and consumed. This would allow visitors to access the lawful sale of cannabis products within a regulated environment in much the same way as they are able to within a provincially licensed brick mortar store. An outdoor area where the smoking and va ping of cannabis is permitted alongside tobacco products would enable event organisers to offer visitors who consume cannabis a secure, monitored area to do so safely. This would enhance the event experience for cannabis users and at the same time enable the event organisers to monitor and safeguard the users of cannabis while at the event. Conditions 0 Public for cannabis should be limited to holders of both a Retail Operator Licence and a Retail Store Authorization because they?re already provincially regulated, have met rigorous background checks and have a proven track-record for the safe compliant sales of cannabis. This would also enable the AGCO to apply their Registra r?s Standards for Cannabis Retail Stores to SOP holders during the event. 0 The Registra r?s Standards for Cannabis Retail Stores were developed to enable the retail sale of cannabis in compliance with the objectives of the Cannabis Act and are largely as appropriate to sales of cannabis taking place in temporary locations as to traditional brick mortar outlets. 0 Additional conditions can be added to cover the consumption area (such as it being obscured so people outside cannot see the consumption, it being open air to allow vapour to dissipate, only cannabis purchased on site can be consumed within the area, the staff have direct access to on-site event medical staff, access limited to those 19 yea rs and older, additional training requirements for staff, times that the consumption area is open). Kiaro recognizes that there are some additional risks to consider when creating opportunities for cannabis consumption sites, and SOPs for special events. The primary one being the issue of the additional liability caused to the event host or consumption establishment owner by their duty of ca re towards people that would be consuming a regulated product while on their property. This liability is analogous to the different liability upon liquor store operators when compared to that of operators. The AGCO has identified many of these liability issues and published ?Liability: There?s More to Lose Than Your Licence?. Risks highlighted to liquor licensees through this document include the liability for personal injury claims when over-service is a contributing factor to motor vehicle accidents, slip and falls or acts of violence. A similar advisory document could easily be drafted for Cannabis Consumption Lounge operators. These risks cannot be eliminated. They can however be insured against and can be mitigated through professional and compliant management. The logical starting point is that a Cannabis Consumption Establishment should be a seperate licence that can be applied for only by Retail Operator Licensees. By doing so the operator can be carefully vetted and appropriate conditions attached to the Cannabis Consumption Establishment to ensure diligent management standards are in place. Retail Operator Licensees already demonstrate an ability to comply with the Registra r?s Standards for Cannabis Retail Stores. An extension of these Standards could easily be drafted to cover Consumption Consumption Establishment. Retail Operator Licensees would then assess their exposure to risk and innovate best practices accordingly to mitigate them. These best practices would necessarily evolve over time as experience and expertise incrementally develop. Municipal involvement in Cannabis Consumption Establishments should mirror those of a Cannabis Retail Store. The province should establish which municipal zones are suitable for cannabis consumption establishments across the province and allow municipalities to opt-in or out. Residents should be allowed to voice concerns during a 2 week notification period for new Cannabis Consumption Establishments. Cannabis Consumption Establishments should be distinct from a Cannabis Retail Store but operated by an approved cannabis retail operator. For example, in the US the Marijuana Control Board in Alaska permits an endorsement to a Marijuana Establishment Licence to provide for the onsite consumption of cannabis with certain conditions. Those conditions include the consumption area being separated from the retail area by a secure door and accessible only from the retail area and that only cannabis products purchased in the retail store may be consumed on the premises. Provincially regulated and authorised retailers already have compliance protocols in place regarding age verification, secure storage and disposal of cannabis products and the mandated sales reporting requirements. It is therefore a natural extension of their retailing function to permit holders of Retail Operator Licences to be the exclusive operators of Cannabis Consumption Establishments. Public Event SOPs for Cannabis consumption should also follow the established protocols for municipal approval. Currently, a Public Event SOPs for alcohol without a charitable purpose requires that the event be of municipal, provincial, national or international significance. A municipal resolution or a letter from a delegated municipal official designating the event as ?municipally significant? is required. This procedure should be replicated for Public Event SOPs involving cannabis. Klaro belIeves that PublIc CannabIs SOPs should be Issued only to CannabIs Retall Operator LIcence holders. This will ensure organizers are fully familiar with federal and provincial regulations, that all cannabis on site is from the regulated supply chain, that all cannabis sold at the event is properly reported, and that event staff are Cannsell trained. ROL holders must have a comprehensive and applied understanding of the Cannabis Act (Federal), The Cannabis Control Act, The Cannabis Licence Act 2018 and its regulations, and the Registrar?s Standards, this level of knowledge will support compliant special events. Successful public SOPs will require the on-site sale of cannabis to ensure all cannabis consumed on-site is from the regulated supply chain. Licensed Retail Operators are the best positioned to provide this service and use existing systems to track and report all sales to the AGCO. ROL holders associated with public cannabis SOPs will also have access to, and payroll established, with trained staff to work the event. We believe these synergies make ROL holders the best positioned to hold public event SOPs in Ontario. About Kiaro: Kiaro is a Vancouver-based cannabis retail brand that carries a variety of curated products appealing to individuals who wish to enhance their life enjoyment. Kiaro was launched by a group of industry leaders with extensive experience in both the cannabis sector and traditional retail. Our mandate is to ?stand up and stand out to inspire stories of enjoyment?, and we were proud to be recognized as a Finalist for Top Retailer in the Canadia Cannabis Awards 2019. We currently operate four licensed retail cannabis stores, with two in British Columbia and two Saskatchewan, and have submitted an application for a Retail Operator Licence in Ontario. Kiaro is committed to reducing the stigma surrounding cannabis use by working with regulators and stakeholders across the country to advocate for meaningful revisions to provincial policies and municipal by- laws with respect to access and consumption of cannabis. We strive to offer a customized omni-channel cannabis experience that is inviting, convenient and appealing, allowing both the cannabis curious and the connoisseurs to choose safe and reputable products. Kiaro?s name derives from the Italian word chiaroscuro, meaning ?to emerge from the darkness into lightcannabis legalization. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit ?l Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Mark Pinnock, CEO. Kingston 12 Ganja Corp. 1389 Danforth Ave. Suite A, Toronto, ONT. M4J-1 N2 2 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area+ . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Yes. Consumption of cannabis in establishments have been happening in cafes and lounges around the world like Amsterdam and other Dutch cities for decades. Although their laws differ in relations to Canada recreational rights, its progressive knowledge can use these European city models to create its own. Herbal tea houses, Ganja Yoga Lounges, Starbuck type edible cafes, Comedy shows are just various venues for which smoking and vaping is not a necessary focus but can in deed be optional so a business owner could work with SFOA, 2017. 3 Other products that could be sold in establishments are cannabis retail brand accessories, cannabis literature, magazines, published books, music, clothing, topical cosmetics, hemp. Food and Beverages not containing cannabis should be sold in these establishments to help With stabilizing and control overhead cost running a business. 4 Yes the government should consider a similar SOP program for cannabis consumed at festivals and events. The same way alcohol events would have designated areas to drink, cannabis events should be too in regards to all age functions. However an event wants to be promoted should be optional to a promoter in deciding if alcohol and cannabis will be at the event. Age restricted events 19+ should be able to consume cannabis freely within the boundaries specified by a permit. Traditional Festivals that celebrate cannabis Ganja Festivals) like Rastafarians of the Jamaican culture should be able to have free use of cannabis at these religious events and special occasions to recognize these methods of cannabis consumptions g. chalice smoking. peace pipe ceremonies) Cannabis Consumption Establishments: There are much more opportunities than risks cannabis consumption establishments will have in helping brands reach more people and diversify the industry a lot better. The interpersonal relationship in retail stores will never help brands as much as they would want to because the are only used entirely as POS point of sale posts. A bud tender can only do so much. SOPs: Special Occasion Permits will offer supreme opportunities for cannabis companies to shine as much as many alcohol sponsored events do and will be much lesser a risk than what alcohol events produce. g. drunken fights, alcohol poisoning, riots) The risk of young people getting hurt at cannabis events is far low to that of any other functions. (Clubs, raves, concerts) This issue should be only provincially regulated due to the fact of how the retail process was handled by municipalities. The option to opt out of retail store operations in few municipalities hindered the industry in the Greater Toronto Area GTA . The Provincial Govt. should decide to set the rules and have everyone follow municipality and all to avoid rhetoric. 5 Music is an integral part of cannabis culture. This is truly prevalent in the Jamaican way of life first introduced by the reggae musicians Bob Marley and the Wailers. Ganja is so popular to Jamaica that tourism has become one of its main by product. Jamaican Ganja concerts, Ganja festivals and Ganja consumption establishments in Canada can contribute greatly to its tourism development in the nascent cannabis industry. We can add dynamics to the marketplace Which in effect could create feasible transparency and be seen as maturity being the world leader. 6 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments andlor Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit As part of Ontario?s transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings cafes, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke?Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e?cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario?s cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada?s rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide yourfeedback to the questions below on this form and submit to can{eabis?i?v?ontarioca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Jo Vos Managing Director, Leafly Canada jo@leafly.com 50 Carroll Street Toronto, ON, M5M3G3 About You or Your Organization Health organization Municipal ity Educator Indigenous organization/community Law enforcement Other (tech/media platform) Region . Central Ontario . Eastern Ontario . Greater Toronto Area* . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial *Noting we are based in Toronto, but service all of the Ontario market Leafly believes that facilitating the sale of legal and regulated cannabis for consumption in establishments like lounges and cafes supports the government?s current mandate of eradicating the black market in Ontario. In order for this to happen, the legal market needs to be an accessible and convenient market, offering the type of shopping experiences that consumers have come to expect (physical stores that also support digital shopping, ie. click and collect, etc). Consumer convenience is a very large factor in the decision point for purchasing. It is also worth mentioning that increasing points of sale would lead to additional tax revenue to the treasury. Ontario has the opportunity to be a global market leader in the cannabis sector. Allowing for this additional point of sale would create a more competitive and robust playing field in the private sector. It would also support adjacent industries in both the creative and technology sectors. From a public health point of view, consumption lounges can be an educational space for both new and experienced cannabis users. It also ?ghts stigma and ignorance. In reality, cannabis is being used as an alternative to alcohol, which is producing better and safer public health outcomes (see references below) Leafly believes the following products should be made available for sale: Cannabis accessories Food and beverage Educational and/or experiential services (tourism) NHPs and services (wellness treatments, cosmetics, massage, fitness classes, etc.) Leafly is of the view that the government should consider establishing a similar SOP program for cannabis to be sold and consumed at festivals, conferences, and events to ensure Canadians have access to licensed, regulated products, alternatives to alcohol, and designated spaces to keep consumption away from minors/workers/etc. Cannabis consumption should be allowed alongside (or as an alternative to) alcohol, in designated 19+ spaces. Non?combustible methods of consumption should be allowed indoors, while smoking and vaping should be designated to outdoor areas. Cannabis Consumption Establishments Opportunity to create a safe place to consume cannabis outside of the home. Ensuring that people who live in places that do not accommodate consumptions (condos, apartments) or people that have minors in the home, have a safe and discreet place to consume their legal products. SOPs: Opportunity to deter illicit market buyers by making legal cannabis accessible from legal sources at events. Designate an area for consuming cannabis, ensuring it is not happening in the presence of minors. Reduce the stigma of the product by allowing it to be sold and regulated at events, in a similar way to alcohol. Similar to the current SOP for Liquor Sales Licenses, municipalities should be required to approve potential cannabis consumption establishments via ?compliance letters? to ensure public safety Building Department (Building Code Act, 1992), Fire Protection Officer or Fire Marshal (Fire Protection and Prevention Act, 1997), Public Health Department (Health Protection and Promotion Act). Municipalities should be allowed to approve extensions of hours of sale and service (for public, private, industry promotional, and municipally significant events.) Potential downside: Decreased access for consumers in municipalities that have opted out if implemented, this should be a consistent policy that extends province wide. The following is a series of studies, reports and media coverage that detail the benefit(s) of consumption establishments and SOPs. ?Cannabis also carries less crash risk than alcohol (1.6 vs 17), with more tolerable effects that peak in eight minutes versus 90 minutes for alcohol. Early data shows access to legal cannabis cuts down on reckless driving, primarily among young, male nighttime weekend drivers who 5 would otherwise be drunk. ?The first full year after coming into effect, [medical] legalization is associated with an 8?11 percent decrease in traf?c fatalities," researchers found in 2013. As for lounge violence, Pearson said ?we haven?t had any problems or concerns." His one incident at SPARC in eight years, involved a person on prescription medication. By contrast, he said, nearly all municipalities ?sanction and permit alcohol establishments, and those have incidents on a basis." 1e6-bb29- bf2701dbe0a3 storv.html ?According to a GreenState public safety review of the 2017 Emerald Cup, there were zero deaths, zero hospitalizations, and zero arrests at the two-day-long, 25,000-person event where hundreds of pounds of cannabis ?owers, edibles, and extracts were consumed. That stands in stark contrast to the average National Football League game in America, where there is an average of six arrests per game, the Washington Post reported. The worst offenders were San Diego Chargers fans (24 average arrests per game) and Raiders fans (17 average arrests per game)? ?Magnolia Wellness adapted state alcohol intoxication protocols to get its Oakland lounge permit. There are four stages of intoxication, said Goldsberry. They?ve cutoff a couple people, and called a couple Ubers. ?Nobody ever gets to stage four. We just don?t allow it.? Most people take mass transit to Bay Area lounges, said Rainin. And with ride sharing apps, people have plenty of alternatives to driving. Cannabis also carries less crash risk than alcohol (1.6 vs 17), with more tolerable effects that peak in eight minutes versus 90 minutes for alcohol.? Early data ?shows access to legal cannabis cuts down on reckless driving, primarily among young, male nighttime weekend drivers who would otherwise be drunk. ?The first full year after coming into effect, [medical] legalization is associated with an 8?11 percent decrease in traffic fatalities,? researchers found in 2013. As for lounge violence, Pearson said ?we haven?t had any problems or concerns.? His one incident at SPARC in eight years, involved a person on prescription medication. By contrast, he said, nearly all municipalities ?sanction and permit alcohol establishments, and those have incidents on a basis.? ?In 2018, cannabis business locations saw a 6% decrease in violent crime compared to a less than 1% increase citywide. (Page 71) In 2018, cannabis business locations saw a 1% decrease in property crime compared to a 9% increase citywide. (Page 72) Recommendation: Based on the decreasing amount of property and violent crime around legal cannabis locations in 2018, the Controller?s Office does not recommend any limits to the number of cannabis operator permits to address public safety concerns at this time.? As shown in Figure 6.6, the number of cannabis-caused admissions and visits to the emergency department are highly variable each month. This is related to their rarity: since legalization the average number per month is 6, or less than 0.1% of all emergency department admissions and visits.109 There may be a slight upward trend over time and continuing after legalization; given the relatively low number of instances, however, it is difficult to state the significance of this increase. Overall, there are low numbers of cannabis-caused admissions and visits, especially when compared to total admissions and visits. This data should continue to be monitored but does not currently signal a drastic increase in use that would require limiting cannabis business permits in San Francisco. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) Nikki Laoutaris Director of Communications On behalf of Lift Co. About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other: Event producers, technology Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario x3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial is a key component for consumers looking to buy and consume cannabis in the legal market. Whether current consumer or curious non-consumers, Canadians are looking for access to trusted information to make smart and safe decisions about cannabis consumption. This is an opportunity to deliver that information in an environment with added guidance about how to consume. Clarity for the SFOA: In that same EY report, you'll notice that all current consumer segments (page 7) prefer to purchase cannabis in a legal setting, but some current consumers still use illegal channels for purchase. Likely, this is due to early limitations around product supply, available product types, and Canadians will purchase cannabis legally when availability is present -- this would extend to legal spaces for consumption. Providing legal, regulated spaces would prevent Canadians from intentionally consuming in spaces restricted otherwise by the SFOA, or unintentionally doing so because they are not aware of where to consume legally. This would contribute to the elimination of the legacy market, one of the main goals of legalization. Training and Employment: A lounge would be an additional educational space where consumers could learn and try cannabis in a space where trained staff are available to assist. Before legalization, Lift Co. alongside our partners MADD Canada developed CannSell, a retail training program currently being used by eight Canadian jurisdictions (government retailers and private retailers), including as the only approved and mandatory program in Ontario. It's our recommendation that cannabis lounges should also be staffed by certified and trained sellers and Ontario's current approved program CannSell could be updated to 1) allow current staff additional employment opportunities in Ontario with their current certifications and 2) ensure a seamless transition for where and how to become certified to sell and serve cannabis. Additionally, this would provide economic opportunities for Ontarians in the form of tourism business, additional sale outlets for Canadian LPs, an alternative business opportunity to retail. Yes. If we consider CannSell education which speaks to the varying onset times for different cannabis formats, the availability of food and non-infused beverages can help ensure a consumer has a safe and enjoyable experience with cannabis, while learning how to combat potentially negative effects. This aligns with the presence of food options in places where alcohol is served. Food could slow down the onset of cannabis consumption, as well as provide an important safe environment for ancillary activities (eating, socializing) while consuming, and moving those out of public spaces like parks where kids and families might be present We would recommend considerations for co-serving with cannabis and/or alcohol that is compliant with the Act. There should also be considerations for non-infused options to allow consumers access without the pressure that the person they are with must also consume at the same time. Yes. Lift Co. strongly supports the establishment of a permit for the consumption and temporary sale of cannabis at events, similar in nature to the existing Liquor Special Events Permit. After nearly 100 years of prohibition on cannabis, despite legalization, according to Lift Co. data, 62% of Canadians feel uninformed about cannabis, different strains and product formats dried flower, oil, edibles, capsules, concentrates). Due to communications restrictions within the current cannabis regulations, there are very few opportunities available for Canadians who are curious about cannabis to compare and contrast different strains, products and formats. Special events such as: trade shows, community festivals, culinary events and manufacturers tastings are key opportunities for Canadians to explore, build familiarity and understand beverage alcohol, these events can be safely replicated for cannabis. Increasing the opportunity for consumers to interact with and be educated by the benefits of the legal market, will inspire ongoing purchasing from legal channels versus a return to the legacy market. Comfort, awareness, and trust will promote consumers to choose the legal market over the legacy market. Lift Co. produces Canada's largest cannabis consumer and industry event. Each year, between our two events in Vancouver and Toronto, we see 40,000+ attendees come through our doors. Cannabis brands choose our show because it's one of the only environments for direct interactions with all levels of cannabis stakeholders, most importantly the consumer. But, there is a major barrier to education and awareness because cannabis companies cannot sample or sell their products to consumers, nor can they even have actual cannabis on-site and on display for consumers to familiarize themselves before making a purchase decision. An SOP at an event like ours, for example, would ensure safe and controlled distribution of cannabis to verified 19+ consumers. This is not unlike the strict age verification done with authorized cannabis retail stores, so this could (in our case) and should always be mirrored with a consumption establishment or where an SOP is in effect. It is not our recommendation to create a situation where consumers may over-consume, or unknowingly go above the public possession limits. We'd recommend targeted training for those who would facilitate and serve in these kinds of environments, as well as a centralized location to pickup/purchase on-site at events like ours (a tradeshow) versus picking up various types of product from individual vendors. We'd recommend careful consideration around: . Transportation permits: An SOP should include a delivery mechanism from the OCS, or involvement by local/private retailers in the province to ensure cannabis is accessed and controlled by authorized bodies . Product availabilities: An event like ours would be the perfect location to showcase products not-yet-available through wide retail to give consumers additional opportunities to explore brands and options (any product available at an event should be HC approved, though). This would also support smaller cultivators, and therefore small business owners who are trying to break through in the new industry. . Protecting Youth: To ensure an SOP adheres to current regulations, it would need to be administered only for 19+ environments (keeping the product out of the reach and eyes of youth). 0 There would need to be considerations for how this interacts with alcohol licensing. we work with the major venues and we'd want to ensure they are not in conflict with their existing alcohol licensing (currently making cannabis sales not possible) . Display license: An SOP could allow for both the display, and the sale of cannabis. Displaying cannabis on-site is an important factor in educating consumers about the cannabis plant (which is nuanced) as well as educating consumers about the differentials from product-to-product and producer-to-producer. Differentiating value is a key factor to allow Canadian cannabis business to thrive, and the simple ability to display at events would contribute to this opportunity . Sampling/Control: We want safe consumption. We don't want consumers to over consume at our events. 0 For this, we recommend looking to established events in other markets. Such as, Hall of Flowers in California requires a ticketing and pickup from a controlled central location for ?sampling and purchasing?. This helps facilitate an ID check as well as possession limit controls . An SOP at an event like the Lift Co. Expo should not preclude brands from sampling freely non-infused versions of cannabis products Cannabis Consumption Establishments: Consideration around packaging. If it's a consumption lounge, how is it being sold and served. Would there be flexibility for something like a mixed drink (without alcohol and caffeine) to allow the server to mix the legal sale limit of THC with other flavours, creating unique economic opportunities for those consumption lounge entrepreneurs. SOPs: (insert comments if necessary the box will expand as you type) In summary: Permit Overview . The permit would allow for the sale of cannabis at a temporary, age restricted, cannabis event . Allow for two types of permits, mirroring what is available for alcohol Industry Promotional Event SOP and Public Event SOP . The permit would be restricted to a specific number of days as outlined in the application. . The permit application would require a designated sales area at the event. 0 The designated sale area would require approval prior to the commencement of the event. 0 Cannabis sales would be strictly limited to the designated approved sale area. 0 The designated sale area would be required, as much as possible, to adhere to all requirements for regular licensed retail stores with respect to purchase limits, entrances, exits, age restrictions, security requirements, and record keeping. Consideration should be given to retailers to run the permitted area because they are already familiar with the restrictions and sale practices . Provincial overview, but other municipal authorizations or designations of event significance may be required. Permitted Retailers . The permit application must include the participation of a licensed or properly authorized retail cannabis store operator or provincial government representative to implement and operate the designated sales area. . All cannabis products must be transported to and from the temporary designated sales area by licensed distributors. We recommend these regulations be set by the province. Consistency among the municipalities would assist with consumer confusion, reducing the power of the black market throughout the province and educate consumers throughout the entire province consistently. This would allow for more education and public safety messaging to be distributed to attendees, and control over consumption levels. A provincial mandate would ensure consistency across communities so the public (and travelers) understand the rules, as well as for businesses to execute and control. (insert comments if necessary the box will expand as you type) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 11:07 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Cannabis consumption lounges and Cannabis SOPs make perfect sense. It?s good for business from locals and for tourists visiting. We have bars why not these. Like bars items purchased should be consumed on site, unless it is something like breweries that allow you to take some home as well. Perhaps attached to a licensed store or LP facilities like a Amsterdam model. Ventilation should be considered and I can see facilities much like smoking rooms used to be in coffee shops in place for Ethis. They should be allowed to serve foods as well like a restaurant. . Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 9:43 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) I?A?nu Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 8:57 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EI support any law that would allow THC infused beverages to be served in any establishment that serves alcohol. Alcohol is a poison that had ruined many lives both literally and figuratively. Cannabis beverages are a safe alternative that can be regulated the same as alcohol. It should also be carried in the LCBO to utilize the high level of control we appreciate now. The 10mg serving is Eabsolutely harmless. I don't understand how cannabis had more restrictions than alcohol or even Etobacco that both kill hundreds of thousands of people annually. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 8:34 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Align with tobacco, Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) It makes sense. Cannabis is safer than alcohol. Wherever alcohol is available to consume, cannabis Eshould be available as well (with the exception of indoors, unless beverages) BUT what really needs to be addressed is the black market and lack of retail stores. Currently I get Eemails every single week from black market establishments. I have attached a screenshot for your review. EYou'll notice that the price is substantially cheaper, and that alone will ensure that it continues to Ethrive. We can better combat the black market by opening retail stores, providing more product variety with cannabis 2.0 products. Government and police enforcement need to do their jobs and Eensure that these online black market dealers don't cause anymore harm. EThe Ford Government has done a terrible job and has jeopardized the lives of thousands of cannabis industry workers that are being laid off, myself included. This current process and Egovernment lag is preventing anything from being done. These ridiculous policies from Health Canada and the steep mark ups imposed on legal products have allowed the black market to thrive. EThe very purpose of legalizing cannabis was to tack this issue; instead created an environment Ewhere it could thrive. EMore retail stores shelved with legal products price legal products competitively with black market Eallow cannabis consumption businesses to operate and allow the consumption of cannabis EEwherever alcohol is allowed (with the exception of smoking indoors) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 7:30 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Make it easy for any group, lounge, restaurant, special event to obtain permission to consume cannabis in any form. Easier than alcohol. And get 300 plus outlets asap as to date provincial govt has done a horrendous job of an easy file that the liberals already had implementation figured out. EPlease get going. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 7:20 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption ,1 establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI think this would create a positive and safe space for people who would like to try or enjoy cannabis. Bars and lounges have been around forever, this should be treated no differently. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 6:51 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Anti Licensed Est, Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EI do not agree with the potential for cannabis consumption establishments and cannabis special .. Eoccasion permits. Not all people are able to tolerate cannabis. There are people out there that have mental conditions and if they take cannabis it will send them into a People that already Esuffer from a mental condition such as depression, schizophrenia, or even an Acquired Brain Injury .. can go into a Please do your homework not everyone can tolerate it! It?s not fair for it to be in an open air environment for everyone to breathe in or smell. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 6:49 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EGreat idea. Ifully support establishments for consuming cannabis and cannabis special occasion I permits. . Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 6:13 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EOpen More stores Immediately before you destroy your potentially fastest growing industry. Or go back to maple syrup. Up to you folks. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 4:11 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: s: 521(1) Rules need to be loosened to at least the level of alcohol with regards to lounges, cafe's or clubs. It Ealso would be a good idea to allow for a more liberal advertising policy similar to alcohol, cannabis Eafter all is far less harmful to your body than alcohol is. By allowing for advertising but maintaining strict quality control, you allow for better education to the new consumer. It will also allow companies who are actually of great quality to get their products into the proper peoples hands. EThis will also allow for a larger dent to the black market. Allow the companies to share the science behind it. By doing this you will also ensure companies have the customers best interest front of mind or they will fall off and go out of business. For the websites i would add a 'email me when Eavailable' option where someone looking for something that is out of stock can be notified and put Einto a queue when it is back in stock. From a procurement standpoint this also makes running the business more efficient and will allow you to analyze and purchase the products that have the highest demand. Thank you. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 3:23 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Cannabis should be treated exactly as alcohol is. Just as many stores as lcbo stores, no opt out by Emunicipalities, cannabis beverages sold wherever alcohol is. If you disagree, it?s because you are a fossil and it?s time to move into a retirement home. With any luck, Conservatives will only be in power for one term as it is not possible for any other party to do a worse job of handling cannabis. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 3:10 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Anti Smoking/Vaping Lounges, Individual submission Title: Description: Comments Due: Contact: Afternoon, Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. 10/03/20 521(1) EHonestly it already is a large reason to avoid certain public areas (especially) around Niagara Falls area where outdoor public smoking of these products are allowed. For years there has been things passed to not be able to smoke nicotine in public but now this It is disgusting, and Esmells, I don't want to breath it in. I want my KIDS to breath it in. PASSING this through is Ejust in favor of a minority, not in the best interests of most. Thank you for your time Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 2:28 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI continue to strongly disagree with and oppose the legalization and essentially unrestricted use of cannabis in our society and in Ontario in particular. By increasing the "places where" and "times when" cannabis is to be allowed and even encouraged by businesses, government is actually going beyond its own mandate and promoting the Ewidespread use and detrimental effects of all forms of cannabis use. This is in my opinion shows extremely poor judgement on the part of government and its policy makers. EThe neighborhood pollution caused by cannabis smoke is especially offensive and unhealthy to me in particular and to other non-participant residents who are being forced to deal with both the increased and lingering air pollution as well as the other negative social behavioral consequences, even in residential environments! If the aim of legalization was only to eliminate illegal sale and use of cannabis, the government has aEn obligation to continue to protect both non-users and nai've users from the detrimental, unknown Eand unexpected effects of this substance, not to encourage it, despite it being a potentially growing source of tax revenue. Government clearly is NOT protecting us as we need to be protected by its Ecurrent laws! EGovernment needs be funding and promoting programs, funding impartial (not pro-cannabis) studies and educating people why to AVOID using, especially smoking, cannabis. Government also needs to do more to protect ALL neighborhood environments from second hand cannabis smoke - something Ontario's current government clearly is NOT doing. Like with cigarette smoke, planners and policy makers should be working towards a "cannabis free" society, not one where cannabis and its addiction replaces or adds to cigarettes and other forms of harmful substances. It is the duty of government to protect all Canadians from the harmful direct and indirect effects of Eall substances, including smoke and related pollution. In the case of cannabis, it appears that pro- cannabis self interest groups are steering the Liberals Federally and the Conservatives provincially to be abdicate their duty to protect Canadians. Not only has smoking been legalized but now it is also intending to expand the environments where non-participants will have to tolerate and take un-natural, drastic and costly measures to counter i its consequences at their own expense! Please carefully consider the damage to our society that legalization has already done and what you Eare about to inflict on the innocent non-participants of Ontario, especially in high density urban settings! . Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 1:02 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EPlease open more brick and mortar stores in Ontario. I?m forced to buy from black market suppliers (Weedmaps) because they are the only convenient option at the moment. We currently only have E29 stores open, with a population of 15 million in Ontario and the closest store is 50km away! Please open more stores! Much thanks for taking the time to hear my concerns. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 10, 2020 11:39 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: s.21(1) Struggling to get information and assistance on dosages for medical cannabis. Doctors are not well informed. We waited 6 weeks for an appt at a cannabis clinic for our elderly mother who we are Etrying to get off opioids for pain. Not really interested in consumption establishments or special occasion permits. Cannabis is a medicine. . Martin, Ashlex (MAG) From: 521(1) Sent: February 21, 2020 11:47 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: progress Categories: Pro Licensed Est, Individual submission CAUTION -- EXTERNAL - Do not click links or open attachments unless you recognize the sender. The idea that people will be able to enjoy alcohol in moderation within public spaces has begun to gain trust and acceptance within many communities across our great province. Burlington residents have long enjoyed our public events such as Ribfest where we have open consumption of alcohol without any widespread misuse. This being the main premise for the argument for the safe moderate consumption of cannabis publicly would mean that acceptance will come with an understanding that we can advance to an acceptance among our population. Repressive community council regimes have stuck to prohibition era nonsense that created dry zones throughout our province that lasted long after the no alcohol era was a repressive dinosaur in places such as Owen Sound, etc. We must realize a biased racially motivated law has kept marijuana in a class of prohibited drugs based on no research or reliable data. With our new laws we now have a chance to research a promising new medical field of cannabis products and de-stigmatize the next generation from the past legal repercussions of social disobedience. A general erasure of previous drug conviction charges from the records of convicted drug offenders is something we must consider if we are to move on in this new acceptance. Clearly no one would want to be downwind of a huge cloud of smoke but the citizens have learned to embrace the public consumption of alcohol at our community events and shown self control from inebriation. We are adult enough to do the same for cannabis so let?s not leave it up to the local politicians to create dead zones around our province and instead leave it to the personal duty of each citizen to use in moderation and self control. After every major social gathering there has been a clean-up of trash and recycling of products to make our city clean again perhaps with cannabis products there will be even less clean-up required. Our policing has focussed on dangerous over consumption of alcohol leading to unruly behaviour by drunken citizens a situation not evident with consumers of cannabis. Our police can take a rest from rounding up peaceful smiling cannabis using residents who are not violent inebriated drunks. We can learn from our past and lead our future in social responsible consumption of cannabis as we have with alcohol. Martin, Ashley (MAG) From: Brent Leitch (via Google Docs) 5-2111) Sent: March 9, 2020 12:57 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Regulatory Registry Feedback Form (1) Follow Up Flag: Follow up Flag Status: Flagged Categories: Pro Licensed Est, Individual submission brent@cannabiscookingcompanyca has shared a link to the following document: Regulatory Registry Feedback Form (1) lSnapshot of the item below: REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments andlor Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings cafes, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 1 . cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) . cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) . cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). Brent Leitcb, Executive Chef, Cannabis Cooking Company. Please reach outwith any questions or concerns. Brent@cannabiscookingcompanvLa 647-575-4476 About You or Your Organization Municipality (please check the appropriate box/boxes) Indigenous organization/community Health organization Other Educator Law enforcement Region (please refer to map and check appropriate box) . 1. Central Ontario . 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial The government should facilitate the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. The main reason for the legalization of cannabis was to keep it away from children, and eliminate the illegal market. By allowing greater access to those of age is the fastest way to eliminate the illegal market. If this is done in a responsible way, as it is with alcohol, allowing more access, consumer choice, lower prices, well educated staff (which in turn consumers will be better educated) we will carry forward the initial reason for legalization. By also taxing it correctly, it will create more revenue for the government, and allow greater education programs to exist surrounding cannabis use. Other products for sale should include cannabis accessories, food/beverage products that do not contain cannabis, and most importantly, food and beverages that do contain cannabis. This is the perfect opportunity to provide education to the masses on what happens to the body after ingesting edible cannabis and how it differs from inhaled cannabis. It also presents an opportunity to educate people on the importance of microdosing, dose titration, and the approach of ?start low and go slow?. The government should establish a similar SOP program for cannabis to be sold and consumed at festivals, concerts and other special events. Clearly marked wristbands should be provided to those who have proof of age (19 to ensure restricted access. All methods of cannabis consumption should be permitted however, cannabis smoking could be limited to outdoor events. Cannabis consumption will likely increase sales from other vendors (ex: food vendors) and will likely decrease irresponsible/uninhibited behaviours that are commonly associated with alcohol consumption. EMS professionals should be trained on how to manage over consumption of cannabis: provision of lemon water, quiet, dark space and messaging that waiting will resolve unpleasant effects. The honest fact is that cannabis is being used in an unrestricted manner at all sorts of events and festivals already. This should be acknowledged, and regulated, rather than ignored. Again, the tax revenue would be a major plus for government bodies, and people educated to consume responsibly. Also, people who are using cannabis in turn consume less alcohol, and as it is a more benign substance than alcohol, there is less issues associated with overconsumption. Ex. No one has ever died from cannabis use. The same is not true with alcohol. Cannabis Consumption Establishments: Unlawful infused dinners are happening all over Canada and the demand continues to grow. Cannabis consumption establishments present an incredible opportunity to expand food services offerings, create communities for like-minded cannabis users and provide legitimacy, structure and standards to an already uncontrollably burgeoning market. SOPs: Given that these are transient permits, they offer an opportunity to enhance events around Ontario. They pose no real threat nor direct competition to retail stores. Given the excessive availability of alcohol at events, and known effects (drunk and disorderly behaviour at sporting events, for example), it seems only reasonable that cannabis be offered as an alternative option. The municipality should be involved in the provision of licenses to cannabis consumption establishments but they should not be involved in any other capacity. The framework should be designed and implemented by industry experts with first hand experience and a vested interest in the long term success of the program. There is a huge demand for cannabis consumption lounges in Canada, and specifically in Ontario. As alcohol use continues to be promoted on air, online and in print ads, cannabis advertisements are subjected to an unreasonable double standard. What's more, cannabis users are forced to consume in private, giving the impression that this remains an illicit or socially unacceptable act. Bringing cannabis consumption establishments to the fore represents one monumental step towards normalizing cannabis consumption. Edible cannabis consumption in restaurants stands to be a multi billion dollar industry that has the potential to appeal to people from all ages, classes and backgrounds. Edible cannabis, when consumed responsibly (micro dosing, as our company promotes), is also the safest method of consumption. Training chefs to cook with cannabis safely and responsibly is an EXTREMELY important step towards safe consumption lounges, and educating the public on correct and low dose methods. I would love to invite any of your staff to a class we teach, so you can see how education is the most important thing, in our view, to a better public understanding of cannabis use. Once the public is well educated, there is no reason for an unregulated market to exist. Google Docs: Create and edit documents online. Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA You have received this email because someone shared a document with you from Google Docs. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Aaron Switzer Cannabis Consultant FSHC, Happy Dayz 69 Mississaga St. Orillia, Ontario 705-345-4982 L3V 1V4 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other: Cannabis Professional Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario Provincial 3 - Under the SFOA many municipalities have struggled with the concept of cannabis consumption being permitted on streets and sidewalks under Provincial jurisdiction. Despite passing bylaws limiting or prohibiting consumption in parks and on other municipal properties, cities have been left relatively powerless in their choice for consumption areas. Allowing for consumption bars/lounges gives municipalities a tool to encourage use in specific areas/establishments and limit potential unpredictable and unenforceable public consumption by endorsing specific sites for use. Though public consumption will remain legal, the majority of the public would prefer to utilize establishments tailored to their needs/tastes and would limit excessive spontaneous public consumption. Through bars/lounges visitors and tourists to Ontario will have a space to enjoy consuming cannabis outside of public areas. Hotels, and other places where tourists stay do not provide places for visitors to easily enjoy their cannabis, and having clearly identified lounges nearby creates safe, convenient, and enjoyable spaces for consumption outside of public streets and spaces. Lounges and consumption venues can allow consumers to try new products in a safe and education-based environment in small sample amounts encouraging future larger sales at dispensaries and via the 008. Government licensed sites further guarantee the sale of safe and regulated product via trained professionals who can aid consumers with educated choices regarding the purchase and use of cannabis in real-life on-site experiential and practical means in a controlled environment. In populous areas of the province that have a high concentration of condominiums and apartment blocks, lounges and consumption sites create alternative places to consume cannabis outside of home dwellings. Several condo boards and real estate investors have expressed concern over the proliferation of cannabis consumption in their units, and having spaces tailored to cannabis consumers will alleviate many property owners as well as consumers the concern of excessive cannabis consumption in concentrated dwellings. As it is now with alcohol in bars, oversight of consumption from bar/lounge employees will make instances of consumption and driving less likely. It is instrumental in curbing impaired driving to have spaces staffed with certified smart-serve employees to aid consumers in making safe and correct choices in this regard. For medical consumers of cannabis, lounges provide accessibility for those who require aid with consumption. Many medical consumers require assistance with purchasing, preparing and consuming their medication. Medical cannabis users can rely on lounges for professional and expert assistance with improving patients' quality of life and social experience. More points of sale for legal cannabis equal more small business opportunities in our province. This in turn creates more jobs in the cannabis sector, and thus more money into local economies. The more prolific the sector the higher potential for tax revenue and excise tax benefit for municipalities. Local economies stand to benefit twice from prolific cannabis sector business, first from job creation and local economy influx, and second from increased excise tax dollars from increased tax generation. lnclusivity and equity are paramount values in the cannabis culture. It is in this vein that all other food and beverages should be made available at cannabis establishments. It is already commonplace to observe cannabis consumption in smoking areas at bars and clubs, and this should be legitimized and regulated to continue the social normalization of safe cannabis consumption. It is recommended that a standard unit system for cannabis consumption be put into place at these establishments to measure inebriation in regards to cannabis itself as well as in the context of alcohol. Making available a wide selection of cannabis accessories for purchase at dispensaries, online and in lounges is another method for combating the black market. Cannabis accessory innovation moves very quickly, with fads and fashion moving and changing often like most retail markets. Allowing consumers to easily access a wide selection of accessories where they can then be taught how to use them correctly as in the context of a lounge would create a huge advantage over the black market. Giving consumers everything they need to make informed and educated decisions with a wide variety of options is the most ideal environment for those in the cannabis community whether brand new, or with decades of experience. Catering to this cannabis culture is exactly the tactic necessary to delegitimize and destabilize the illicit market. This variety extends past a wide array of cannabis itself, and to cannabis accessories and ancillary products. Black market cannabis is currently rampant at concerts and events. By providing a space for consumption and an access point for legal cannabis to be purchased this a) aids non-smokers by preventing in-crowd smoking by providing a designated area and b) can limit the sale of black market cannabis at events by providing a legal point of sale and putting a limit on the amount of cannabis (if any) allowed to be brought into said event to avoid illicit sale. For private events and functions it stands to reason that cannabis use is already prolific and commonplace. To allow the sale of government regulated cannabis at these events as is now the case with alcohol, will extend the common practice of consuming legal cannabis, and will further guarantee the safety of consumers and the diminishment of the black market. Using the current model utilized for alcohol in regards to private events, event coordinators should be able to purchase and sell 008 cannabis and products at these events and to return unsold product the same as alcohol is currently permitted. SOP events should purchase the cannabis for sale at the event from the 008 or from a licensed dispensary upon the issue of an SOP license. While the event itself may not be 19+, a separate age-gated area should be provided as a cannabis purchasing and consumption area much like the beer tent models utilized with alcohol at events today. Combating The Black Market Providing a wider selection of cannabis available to the public via the 008, dispensaries and lounges, directly competes against the limited options provided by black market sellers, thus rendering the old illicit cannabis infrastructure out-dated, narrow and unattractive to consumers. Legal cannabis access points including bars and lounges grants consumers an open, safe, and 5 connoisseur purchasing experience that discourages black market sale. Lounges/cafes/etc. are effective tools to combat black market cannabis in the province. By encouraging consumers to go to government licensed establishments with government approved cannabis for sale on-site, they are provided with a tertiary access point to purchase easily accessible legal cannabis beyond dispensaries and direct from the 008, further choking out the inconvenient methods of purchasing black market cannabis. Lounges and government approved consumption venues will also help to combat the social stigmas that surround cannabis use, and will further drive use out of the arms of black market dealers whom offer cloak and dagger business practices to those who feel shame or displacement through their cannabis use. Creating safe and healthy social attitudes toward cannabis consumption will eliminate the need for consumers to seek out illegal and secretive access points for cannabis and places to consume it. In stark contrast to alcohol, recreational cannabis consumption is not associated with instances of violence. It is the hope of the cannabis community that the proliferation of cannabis lounges/bars reduces the recreational consumption of alcohol to the extent that there is a marked reduction of reported acts of violence as seen often at our drinking establishments and events. With the popularity and proliferation of age-gated cannabis dispensaries and lounges, the only customers left for the black market sector are those who are under age. With the increased federal and provincial punishments for selling to minors, the risk will be too great to continue lucrative black market operation. Again, low prices and effortless ease of access cannot be stated enough as the two-fold tactic to combat and triumph over the illicit cannabis market. With the 008 accounting for at- home purchasing, the proliferation of dispensaries for retail experience, and lounges for purchase, sampling, and consumption a perfect trifecta of access is created leaving little for the black market left to offer. Municipalities that have chosen to ?opt-out' of accommodating cannabis dispensaries should automatically be considered as ?opted-out' for lounges, but this should not extend to single event and/or private functions that can apply to the AGCO for a temporary license as is the case with alcohol. In line with the dispensary model, municipalities should be granted a 15 day period to express their concerns with a forthcoming lounge in an ?opt-in' community to the AGCO for review before the issuing of an operating license. It is of the utmost importance that we work to take on the black market at every juncture. One of the big advantages of buying illicit cannabis is fast at home delivery. We ask that the province and AGCO create a permit system for delivery services that can provide consumers with fast, at home access to government licensed cannabis. A plethora of these services already exist for alcohol and we believe that this is a logical step fonNard in cannabis accessibility for both medical users with limited mobility as well as the general consumer. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other: farmer/student at law Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEECEI: YES. believe it is necessary to accommodate venues for public consumption (like a bar equivalent) for cannabis. This ensures competitiveness with the black market, a safe and discreet place to buy and consume, facilitates a market demand creating economic opportunity for providers With a higher degree of utility for consumers and decreases the historical prejudice against cannabis by regulating it at least as freely as alcohol. With the exception of alcohol and tobacco products, all products should be available at the consumption establishments due to the multiplying of intoxication that occurs with their mixture. YES. This should be allowed with the condition that alcohol is sold in a separate section of the event. This allows for not encouraging the consumption of both at the same time, while also not limiting the scope of service for the diversity of attendees at any particular event. This ensures equality in economic opportunity, attendee preference, and ensures competitiveness with the black market. Cannabis Consumption Establishments Allows for a whole new industry of cannabis licensed venues, including entertainment, cafes and restaurants, physical activity and wellness (yoga, etc. and much more. This will greatly enhance Ontario as a place of freedom, innovation, economic opportunity and enjoyment. SOPs: By also allowing alcohol at the same events, but in different sections, it allows for the above opportunities while not restricting the existing freedoms as it relates to alcohol and their many existing satisfied consumers. The least involvement as possible to ensure a free and efficient market which is standardized across the province. do not believe it is appropriate to have significant restrictions beyond requiring separate sections for alcohol, tobacco and cannabis products as this Will drastically limit the competitiveness With the black market and Will result in diminishing returns in effectively reducing their combined consumption. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality I Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario I Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial Yes. Allowing the sale and consumption of cannabis in venues makes sense economically and will help this industry that is currently struggling become more profitable. Additionally, on the subject of harm reduction and public safety, allowing cannabis consumers to use inside of lounges will stop them from using in public, in parks and on the streets as much. Thus protecting children and public safety. Food and beverages 100% - these things are essential when people are consuming cannabis. Cannabis accessories and all things related to cannabis should be available for purchase in these venues as well. Yes. Age-restricted events makes sense. Ian-Cannabis Consumption Establishments. No. Allowing these lounges and venues will serve to minimize any risks of cannabis storefronts. SOPs: No. (insert comments if necessary the box will expand as you type) Municipalities should potentially have the right to opt out, just like they can with cannabis retail. (insert comments if necessary the box will expand as you type) REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other :individual Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEECEI: Yes if it is legal to have an alcohol license, it should operate under the same framework for cannabis products. This is especially true for edibles and beverages that do not infringe on the SPCA lt would depend on the specific layout, but could definitely offer other products for sale including non-cannabis related food and beverages similar to what a bar would offer (wearables, snacks, etc. Yes, for the same answers as Question 1 if it is legal for alcohol, why not cannabis if it is federally legal? Especially for outdoor events. lf people want to mix alcohol and cannabis, they are going to do it anyway, might as well have it be done safely and knowing what will be consumed. lt could either be a 19+ event or similar to a wristband situation with all-ages events that serve alcohol. Again, all methods of consumption should be considered equals with cannabis being legal and also having a very much alive black market, whatever combination people choose to consume, it is very easy to acquire. May as well have it for sale and done without feeling the need to hide it. Cannabis Consumption Establishments The smoking of flower/vapes with the SPCA is obviously a contradiction, but it is not like cigarette smoke and only some people being okay with it. lf you are going to a cannabis consumption establishment, feel like you know what you are setting yourself up for. SOPs: As long as it is strictly adhered to like the SOPs for alcohol and POP needs to be provided, it would be another revenue stream for something that is now 100% federally legal why not capitalize and further remove the stigma of cannabis? Putting safeguards on something that is legal feels like holding on to some semblance that it is still taboo, which it isn?t. think each municipality has the right of refusal if they do not want such establishments in their neighbourhood, much like retail stores. My main comment is towards everything that does NOT result in smoke (flower, oil, vapes etc. all other consumption methods (cannabis-infused food, beverages, capsules) does not infringe on that SFOA and it also is a recreational/social activity. To have the option of a cannabis infused cooking class with an SOP, or to go to the movies and purchase a cannabis cookie, or to go to a concert and have a cannabis infused beverage instead of a beer, think makes sense for both the individual consumer, the economy, and legislation. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other: Lawyer/Investor Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial The government should consider facilitating the regulated sale of cannabis for consumption in establishments like lounges and cafes in Ontario. A. Business Opportunities/Consumer Experience Allowing for lounges and cafes in Ontario will create significant business opportunities throughout the Province of Ontario and will allow for a variety of entrepreneurs to enter this new industry. Providing for regulated consumption establishments such as lounges and cafes is the best way to determine what the consumer wants and expects from this newly emerging industry. Therefore, I believe in allowing the Ontario consumer to have the ability to find a location near them to consume cannabis is whatever form that may be would be advantageous in establishing what types of cannabis Ontarians wish to consume as well as provide real competition to the illegal market. Furthermore, this would allow Ontario to be an industry leading Province in regards to cannabis tourism. The ability to persuade Ontario cannabis consumers away from the illegal market is vital but in addition, the ability to establish lounges and cafes would create incentives for out of 3 province cannabis consumers to come and spend some time in Ontario. Tourism trends have been seen to increase in various US states that have legalized cannabis. Therefore, I believe that cities within close proximity to the United States would see a greater increase in tourism simply due to the availability of lounges and cafes. This premises is predicated on the notion that as the law stands right now, people from out of province have no legal available place to consume cannabis as they are permitted from consuming cannabis in there hotel room or condo (Airbnb). B. Current System in Place The Smoke?Free Ontario Act, 20] 7 prohibits the consumption of cannabis in enclosed workplaces and enclosed public places thereby providing that the primary location for adults to consume cannabis to be there residences. This ultimately creates various problems/ concerns for cannabis users as well as those affiliated with cannabis consumers. Without the regulation and licensing of cafes and lounges the only place for Ontarians to consume cannabis is their own residence. Therefore, people living with them are impacted (possibly negatively) by this restriction. Not to mention the strict regulations and laws in place with regard to consuming cannabis in condominiums. Additionally, as mentioned above, people from out of province have no place to consume cannabis as well. If cannabis consumption establishments were considered in Ontario, other products that should be for sale, I believe would depend on the type of venue permitted to sell cannabis. For example, cafes should be allowed to carry various types of edibles for consumers and therefore I believe that those type of establishments Cafes) should be permitted to sell of food and drink products which do not contain cannabis as well. For types of venues such as lounges, devices to consume cannabis should be allowed alongside as the actual cannabis products. This will allow for different entrepreneurs to enter this market and provide the greatest variety and products to the consumer which I believe is ultimately essential in defeating the black market The creation of an administration to oversee the SOP program such as alcohol, I believe is necessary for the same reasons it is necessary for alcohol. Therefore provided that events would be permitted for the sale and consumption of cannabis, so long as the proper permit has been applied for and obtained, I believe that the consumption of alcohol and cannabis should be allowed to happen at the same event, again, provided all permits were obtained. Cannabls Consumptlon The greatest opportunity that I can perceive is having the greatest amount of competition and convenience for the cannabis consumer to pick from and thereby will be the biggest detriment to the illegal market. Currently, I believe as I am sure as do many others, the reason for the illegal market to still be performing so well, is due to convenience. Once it is more convenient to acquire your cannabis from a legally operated and licensed retailer, I strongly believe the people will choose to do so. SOPs: The additional risk I can perceive is that it would be increasingly difficult to prevent illicit cannabis from entering the SOP and thereby is not a preventative measure to combat the illegal market. Municipalities should be heavily involved in the potential framework for cannabis consumption establishments. For example, those municipalities who choose to opt-out of having a OCS store within their municipality, I do not believe would agree to have a cannabis consumption establishment although the choice should again be put to them. Municipalities should be the best to know what is best for their community simply because there are the representatives of those communities REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit ?l Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are 521(1) submitting comments on behalf of an organization). 2 About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other: Budtender (Customer Experience Rep) Region (please refer to map and check appropriate box) - 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial 3 The government should definitely consider facilitating the sale of cannabis for consumption allow patrons to bring their own cannabis instead of forced to purchase products at a cannabis consumption establishments. I am in favour of cannabis consumption venues because there are no legal venues allowing this legally speaking, the public can only consume in the privacy of their home (if permitted by their landlord) or wherever cigarettes are allowed. As a person who works on the frontlines of selling cannabis, we are constantly asked from locals to tourists where people can consume after purchasing products. Building legal establishments would alleviate a first time consumer's concerns about consuming as well as the residual taboo of smoking cannabis by allowing the public to consume in a relaxed environment akin to a local pub/bar. I also believe it is the government's responsibility to open up lounges cafes because they are the ones who facilitated enacted policies on allowing cannabis to be consumed in the first place. We are able to consume legal cannabis but have no venues to consume them in except in a person's home or somewhere outside. Given Canada's weather conditions we are left out in the cold - literally. I would like to see privately run cannabis consuming venues that are NOT affiliated to any of the big cannabis corporate conglomerates like Canopy Growth, MedReleaf, Aleafia, etc. The other products that should be permitted for sale in cannabis consumption establishments are: food beverage products, cannabis accessories (for sale AND to rent), a limited selection of dried flower, edibles pre-rolled joints. 4 (insert comments if necessary the box will expand as you type) The government should definitely establish a similar SOP program for cannabis to be sold consumed at festivals events. The government needs to destigmatize cannabis by stripping away the negative social connotations through events. This will help the public transition from viewing cannabis as a taboo look at it on the same playing field as alcohol. One or two-day events that sell cannabis on-site would be a fantastic addition to the public's experience. One of the things to note is mixing alcohol cannabis can cause an adverse reaction, but this should not stop the government from allowing both alcohol cannabis to co-exist. The method of consumption should be left to the public without any government interference or else risk babying the public having a heavy hand on the autonomy of people. There should be two individual places to consume cannabis alcohol to at least create some type of separation between cannabis consumers non-cannabis consumers. The events should not be age-restricted as cannabis has been consumed at festivals before (albeit illegally) but the same can be said for the presence of alcohol at all-age event. The consumption of cannabis at events should not be treated any different than alcohol in regards to purchasing it in sanctioned areas the consuming it freely. The methods of consumption that should be available are select dry herb, pre-rolls the accessories that would be needed in order to consume. The cannabis consumers should wear wristbands to give them an OK anytime they want to purchase at a licensed vendor. 5 Cannabis Consumption Establishments: The additional risks created by cannabis consumption establishments (referred to as CCEs here on out) may include increased foot traffic in around the area, respiratory issues occurring if the space is not properly ventilated newbies who may not be able to handle their first cannabis experience (therefore a standard procedure should be set in place if a patron is "tripping out"). The additional opportunities created by CCEs would exponentially increase Canadian/Ontarian cannabis culture - elevating the experience to something akin to a club on King Street in Toronto. Many different niches of people would emerge connect with one another in the same way a bar or pub connects a local neighbourhood. The increase ofjobs would allow people to explore uncharted careers, give the public a chance to own a CCE as most other jobs are highly saturated. Cannabis focused events could be hosted around the province, building Ontario's reputation as a place to explore consume cannabis. SOPs: The additional risks created by SOPs would be the sudden increase of plastic packaging if purchased at a licensed vendor. The packaging is already a problem on the retail side since many complain about the amount of plastic or materials used for even just a 0.5g pre-roll. By selling cannabis in an outdoor event or even an open public space can create tons of litter. The one thing many people don't know is that the plastic used for the packaging cannot be recycled by standard methods since each municipality has different standards on recycling, there has not been one standard procedure for collecting used cannabis containers/packaging. There needs to be clearly visible recycling stations signs stating littering will not be tolerated. lf seen doing so, it can incur a fine. They should be able to purchase their products leave with it if they want, but if they are done with the container, it should be disposed of correctly. There should also be clearly marked "ashing" stations where people can throw their "roaches" (end of the joint/filter paper). The additional opportunities created by SOPs would be job growth/creation, increase in cannabis Ontarian culture extra money through licensing agreements. The municipality should not be involved other than sanctioning areas or spaces where CCEs can be established. They can not prevent CCEs from ever becoming established. Municipalities should not be involved in SOPs as there would be a lot of NA 6 7 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Developing new cannabis brand Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial (insert comments if necessary the box will expand as you type) Over a century ago following the end of alcohol prohibition, bars were created as a space for safe consumption, away from youth and children. Similarly, with the legalization of cannabis, a space is required where cannabis can be consumed out of the purview of children and youth. The future of cannabis is not about smoking, but rather it's about a seamless integration into one's everyday life. In the not too distant future, cannabis will be treated like any other adaptogen be it ginseng, collagen or cordyceps and lion's mane. Our morning smoothies will not only have one of these super foods but in all likelihood, CBD or micro-dosed THC. While clinical trials and research are still somewhat limited, many believe that cannabis can help support health and wellness. In particular, the Generation Baby Boomer Generation are spending a disproportionate amount of money on health, wellness, and vitality. This demographic isn't interest in extreme impact. But just like having one or two glasses of wine, they want something to feel relaxed and at ease that also doesn't cause weight-gain, hangovers or cause other negative side effects. The cannabis consumer is not only a millennial who is looking for a high-dosed THC product, but so too, a 53 year old woman who prioritizes her health; juggles a high pressure job with raising a family; and who is entering into a new stage in life and sometimes needs a relaxing evening out of the house. Cannabis normalization is a space that is beautifully designed serving thoughtfully produced and plant-fonrvard food carefully and conservatively infused with cannabis. This can be both in a permanent venue as well as at pop-ups at festivals, summer resort destinations or winter get- aways. Further thoughts on this can be found here: edibles-backwards-high-society insert comments if necessary the box will expand as you type) Health and wellness items such as body care; food items like adaptogens lsuper foods and plant-fonrvard pantry items; prepared foods; onsite prepared hot and cold drinks (ie tea lattes and smoothies), cooking accessories, lifestyle and home accessories. However, it should ?be permitted to sell alcohol and cannabis from the same location. (insert comments if necessary the box will expand as you type) Cannabis should be treated the same way as alcohol ie age-gated/restricted areas for 19+, rather than the whole event being age-restricted.This keeps the product away from kids and youth while also making it available for adults who would like to use it. A similar process should apply to pop-up summer retail and food/beverage experiences in shipping containers at summer retail and entertainment tourist areas. Consumption Establishments: (insert comments if necessary the box will expand as you type) These provide a safe space for consumption in an age-gated environment. It creates a safer option to what currently exists. As long as the same controls are in place, there shouldn't be an issue. Similar to a bar/restaurant, servers and handlers should have smart serve cannabis certification. SOPs: (insert comments if necessary the box will expand as you type) These will help to discourage the illicit market. The higher the number of legal touch points, the less that people will rely on the illicit market. (insert comments if necessary the box will expand as you type) Licensing should follow the same SOPs as alcohol establishments. (insert comments if necessary the box will expand as you type) Similar to any other consumer packaged good, we are beginning to see market differentiation. Not only will brand become more relevant but so too, brand experience. if we want to create a sophisticated cannabis market, we have to provide the tools and create the opportunities to facilitate it. Othenrvise, it will never escape the stigma of its past. If Ontario would like to generate significant tourism revenue from the cannabis hospitality market, it behooves us to work together - government, industry and the public so that we are able to set the bar and implement best practices for other provinces, states and even countries to emulate. Most importantly, this will result in safe and social consumption the end goal that arguably, we all desire. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Individual Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario LI 3. Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial No. The Government would be making cannabis a main stream drug. This could very well become a gateway drug to other more harmful drugs for people who would not normally be interested. ln effect, the Government would be promoting drug use. Apart from which, smoking is not currently allowed in cafes and lounges, so why would you allow smoking of cannabis is any public place. personally would be extremely offended to have to smell cannabis being smoked anywhere in my vicinity or that of my children. Totally against this. Again, no. For the same reasons provided in 1. 2. Cannabis Consumption Establishments These establishments may not enforce the age requirement and it will be accessible by minors. SOPs: Same as above. None Making cannabis available at a Wide range of events Will, Without doubt, create more opportunities for driving under influence accidents and possible fatalities, as well as, potential adverse health issues that Will put additional cost strains on the health system. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other - Member of the public Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial Yes, the government should allow facilities to operate for the purpose of cannabis consumption in establishments such as; lounges and cafes in Ontario because people who smoke marijuana have the right illegal drug and should not be continued to be treated as such which only continues to purport the reefer madness type of stigma. By restricting this part ofthe cannabis industry to members ofthe public it is a great injustice. When thinking about the amount of alcohol promotions that are everywhere in public, the amount of Store/Wine Rack locations that are available, the amount of bars/pubs that are in the Greater Toronto Area why is it that alcohol which is responsible for tens ofthousands of deaths annually gets front page advertisements and different status compared to marijuana which has not caused any deaths is odd. By having these types of venue?s it will help normalize marijuana, and not treat is like a dirty little secret. Cannabis, cannabis accessories, THC infused food/beverages, non-THC infused food/beverages. Cannabis consumption establishments should be viewed just the same as bars, and be liable to have food and drink to help ensure the sobriety of the patrons. The typical caf? in Amsterdam has the following; cannabis, cannabis accessories, THC infused goods, regular snacks and cafe like hot food items, tea/coffee and cold drinks. It keeps the patrons in one place with everything that they need. Yes, the government should establish a similar SOP program for cannabis because they should be legally treated the same. At festivals and events now you can smell people smoking cannabis and doing other drugs, it would be better to ensure that they have a safe area where they can consume marijuana at these events. lt's baffling to think that society has come to a point where we can openly consume; large clear cups of beer, red party cups of alcohol, and cigarettes in front of minors yet for some reason cannabis is. Alcohol should be permitted, as it is up to the individual not to make themselves intoxicated. There should be checks done by the staff monitoring that no one is inebriated or impaired by alcohol or drug. The event does not need to be 19+, but lD's would still need to be checked. Smoking, vaping, edibles and drinks should be permitted. Cannabis Consumption Establishments: The opportunities created by cannabis consumption establishments or SOP's would hopefully allow the public to engage in these opportunities and allow the members of the public to engage in the industry for business. We need members of the public to be able to have the right to engage in any type of business that they would like as long as they meet Health Canada or whatever requirements are needed for their business. SOPs: SOP's will allow members of the public their right to consume whilst not infringing upon anyone else's rights. I do not think that the municipality should have any involvement in a potential framework for cannabis consumption establishments as it would be too convoluted to imagine with the inability of the government as a whole to phase in the legalization of cannabis. There needs to be consultation of people who have been in the cannabis industry to best make recommendations for these ideas. Having people who have no knowledge about the cannabis industry does not make sense having them make legislation that will control it. I would like to ?nally say that I believe that these amendments will not ensure more choice, convenience, or a safe reliable supply of marijuana. This will actually restrict the class of people able to make capital, and provide an income for themselves. These amendments only favour the Licensed Producers, and the Ontario Cannabis Store. It enables price ?xing, and establishes a monopoly in the cannabis industry. If the cannabis market is to be opened responsibly as possible, then this is a clear demonstration of how to do it incorrectly. The cannabis market, should be open to any natural person to have the ability to engage in for the purposes of business. As long as they comply with all ministry; standards, polices, and training it should an available choice for them. This proposed legislation is much to the bene?t of Licensed Producers, and even more so the OCS. It is quite asinine that a Licensed Producer will have to technically sell any product to the OCS ?rst to buy it back at a marked-up price, then ?nally sell it to the customer. It does not seem like any of the legislation has the scope of allowing regular members of the public to partake in the cannabis industry and continues to come out with knee- jerk like reaction amendments. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit ?l Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) 2 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _Cannabis retail educator Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Yes do think the government should consider facilitating the sale of cannabis for consumption in lounges, cafes etc. think this is the next step to moving forward in the growing cannabis industry. ln Ontario Beer and alcohol are sold in at events in age gated areas. am hoping the cannabis industry Will be similar to the alcohol industry in the future. 3 I think both THC and CBD products should be sold in establishments. I think infused drinks should be sold, as well as non infused drinks, as well as non infused foods. Yes do think the government should establish similar SOP program for cannabis to be sold and consumed at festivals and events. feel at this point most people are doing it already especially With legalization of cannabis. lf the government approves the proposal feel there Will be more control and safety to the use of cannabis at these events. The events should defiantly be age-restricted 1 9+ just like is is for alcohol. 4 Cannabis Consumption Establishments: (insert comments if necessary the box Will expand as you type) SOPs: (insert comments if necessary the box Will expand as you type) "t think municipalities should have any involvement because think that limits the opportunity for business and or events. In this current time we are In with the legalization of cannabis and cannabis retail stores In Ontario I think not only would it be beneficial to allow establishments for cannabis consumption and special occasion permits, but it is also away to progress the legal cannabis market further. I think this would be the next step in legalization. I think the government and the AGCO have done a great job in the way they have mandated the laws ofthe retail cannabis industry. As we move forward in the industry I hope one day the cannabis industry in Ontario will be similar to the Alcohol industry. I hope one day you can go into a LCBO or a bar, or a cannabis consumption lunge, have a cannabis tent and an outdoor event; the same way you can have a beer tent at an outdoor event. As long as these areas are age gated and and government compliance is followed. 5 6 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) Luc Lagrandeur 581 Attlee Avenue Sudbury, ON, P3A 552 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario LI 3. Greater Toronto Area Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial (insert comments if necessary the box will expand as you type) Yes, the sale of cannabis for consumption in establishments like lounges and cafes in Ontraio should be allowed, just like the sale of alcohol. (insert comments if necessary the box will expand as you type) I believe in free enterprise, the sale of any product should be permitted in those establishments. The onus is on the owner to meet the needs and demands of his clientele in regards to products and services of cannabis accessories, food, beverages that can and do not contain cannabis. (insert comments if necessary the box will expand as you type) I agree that cannabis should be sold and consumed ?like alcohol?, thus, follow the same guidelines of alcohol at special occasions, including large scale events that are open to the public, such as festivals. As per the alcohol guidelines, cannabis should mimic the same: age limit of 19+ for consumption and purchase; allowed at the same time as alcohol at same event but must be in a separate area (section) of the alcohol in the case of use of a tent; if alcohol can be consumed publicly in the streets during a festival or event, then cannabis can be smoked or vaped or eaten in those same streets; cannabis consumption can be smoked, vaped or eaten in public places. Mandatory use of monitors or security would be required for large public events to ensure that minors are not permitted in tents; if a large open public event, then to monitor the streets and enforce the regulations. CannabIs Consumption Establishments: (insert comments if necessary the box will expand as you type) The risks are same as those selling liquor, beer (The Beer Store), and the likes. It?s simply retailing with a specific product type. That?s it, that simple. SOPs: (insert comments if necessary the box will expand as you type) If alcohol is allowed, so why not cannabis products. Society is evolving, and let?s just accept it. SOPs are in a specific market, let the market dictate what?s going to happen. (insert comments if necessary the box will expand as you type) Municipalities should not restrict the sale and consumption of cannabis products in establishments and SOPs under the umbrella of the Provincial Government. Municipalities may not present the Control Board of granting SOPs, for example, and/or uses other means to prevent the event from happening because cannabis would be consumed. (insert comments if necessary the box will expand as you type) The point is simple, alcohol cannabis, follow the same rules and regulations. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 5.21m About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Yes. There is no difference between consumers of alcohol or cigarettes vs cannabis. Cannabis is better in most cases. Plus, it's a medicine so I feel should be less restrictive. Cannabis does not give the same aggressive effects as alcohol does but rather is more of a laid-back effect. Most consumers I know are aware that they cannot drive while high and in most cases don't want to, while alcohol seems to increase carefree behaviour. don?t feel there needs to be a restriction on sale of any item and these establishments. really don?t understand why there should be. By allowing it will help the businesses establish more sales. would really like to see more branding allowed as well so these businesses can thrive and be creative. don?t feel it?s necessary to have a special permit just for cannabis as we don?t for smoking. lt sounds like a lot of waste of time and effort on taxpayer money. lt also sounds like a government money grab. was at a wedding last year which allowed cannabis and alcohol. The cannabis posed absolutely no problem. The alcohol, even with a permit, create a more interesting behaviours. However if it?s the only way it will be allowed then yes. lt should less restrictive than the AGCO. Cannabis is not an addiction. lf you do go this route consider making an alcohol and cannabis combined permit. Cannabis Consumption Establishments: For one, don?t understand why lD needs to be checked at the door at a cannabis store when it?s not done at the LCBO. lt should only be checked upon purchase. Allowing youth in the stores will allow them to learn about cannabis. wish governments could see that the more you tell the youth they can?t do something, the more they will want to. For example, l?m an open cannabis user but both my teenaged kids have little interest in it. Allowing for more branding to cannabis companies would be great to allow them to grow their business. lt could open up an opportunity for ?bud and breakfasts and special retreats which is great for tourism. SOPs: ?d like to avoid special permits but rather have the same rules as cigarettes. think the municipality should only be concerned with noise levels and other neighborhood concerns, as they do with bars currently. don?t think the municipality level needs to get involved as it just adds more work and hassle. would also like to see farmgate purchases allowed in the future. The rules in place for the future need to be changed to avoid the government getting involved with the exception of the tax. Farmers should not need to sell to the government first before selling to their local community. Farmers need all the help they can get so allow them a good profit margin on cannabis products. ln the future l?d like to see cannabis and infused edibles sold at farmers markets as you would vegetables and fruit. Lower the tax and prices as you are only allowing the black market to thrive. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. I Contact Information 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario Greater Toronto Area\/ 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial Yes definitely 100% there needs to be cannabis consumption lounges. Stop the discrimination against cannabis consumers. Similar to bars or coffee stores. People consume alcohol in bars, coffee drinkers consume caffeine in Starbucks or Tim Hortons, cannabis and it's lawful cunsumers should be allowed the same dignity as consumers of alcohol and caffeine. consumption devices, food, and non-alcoholic beverages should be available. YesbIt defInItely needs to be established. Alcohol consumption should be allowed at these events as well. Keep it 19+ and let adults decide for themselves what and how much they want to consume. All methods of consumption must be allowed. I smoking cannabis Cannabis Consumption Establishment No additional risks but many opportunities for profit and socializing. Ontario could and should be a leader in cannabis tourism. It's easy money. The cannabis tourist trade can be huge especially if we give everyone a place to consume. lnstant leg up on the other Provinces and legal states which have overlooked this opportunity for income and tax revenue. SOPs: No additional risks. Cannabis events are safe. There will be way less "problems" that. Associated with alcohol events. (insert comments if necessary the box will expand as you type) Municipalities should have no say. Typically municipalities only listen to upper class white people with children, and ignore all other residents of the municipality. 2 Consumption lounges and desperately needed. Stop wlr?/rng Ontanans who choose to consume a legal product. Very few problems or fights occur at events. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEECEI: (insert comments if necessary the box will expand as you type) No. I don't want to breath it in. Let them smoke it off site. (insert comments if necessary the box will expand as you type) Offs ite. No sale. (insert comments if necessary the box will expand as you type) NO. You can?t smoke it been deemed unhealthy?what the hell are you doing allowing smoking pot! Cannabis Consumption Establishments. (insert comments if necessary the box will expand as you type) SOPs: (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) Nonell Smoke it in their car!! (insert comments if necessary the box Will expand as you asked a Why they don?t advise people that come to them with anxiety, and said they would lose 90% of their business. depression, fears, loss of confidence and hope to stop their marijuana addiction. He laughed REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _Citizen Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEECEI: rt comments if necessary the box will expand as you type) Absolutely NOT, you are promoting smoking, and people driving high. It's a fact. Do you not realize that more people will die being killed by stoned drivers? I went to the post office recently and man standing behind me had a strong order of POT, it obvious he drove to post office. I should have followed him getting into his car and reported him to the police. I have also smelled people smoking it in cars driving in front of me. People do not obey rules and they do not obey the laws. (insert comments if necessary the box will expand as you type) No other products should be sold stop trying to make it mainstream, do you want kids to go into these stores to by chocolate? Really?? (insert comments if necessary the box will expand as you type) Absolutely I love going to these events and I do not want to smell it, inhale it or it being around my family or children inhaling it. have a right to go these events and I do not want my enjoyment/my rights to be affected. Kids should not be inhaling this second hand smoke. Even if in contained area, the smoke/smell is so heavy that it carry?s to other areas of parks etc.. You cant control the wind and weather. Cannabis Consumption Establishments: (insert comments if necessary the box will expand as you type) Yes, encouraging more people driving high, encouraging more crime SOPs: (insert comments if necessary the box will expand as you type) Encouraging more people driving high, under age kids partaking (they will get it) (insert comments if necessary the box will expand as you type) It shouldn?t be allowed period! (insert comments if necessary the box will expand as you type) Why is this even being considered? People do not have any common sense anymore! No wonder our society is going to hell with increased crime, people drinking driving stoned. Underage kids using, it will affect their brain and development. The only thing the govt is interested in is making Look at the strain the police are going through, the court system. Will cost more in the end with added strain on the health care. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _private_individual Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario x3. Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial Yes, the government should facilitate licensed cafes lounges. Similar to bars Where alcohol is consumed With control of the age of patrons and product it?s a social safe space for adults to enjoy. Keep alcohol separate and not in these lounges. I?m fine with food and beverages i.e. coffee Tea pop etc and accessories aren?t a problem. (insert comments if necessary the box Will expand as you type) Cannabls Consumption Driving While high might be a problem the same as drinking and driving though Where cannabis is consumed doesn?t determine people?s bad behaviour SOPs: Treat the same as alcohol lssuing licences Within the city location bylaws Legal consumption is similar to alcohol. Pass rules and laws and enforce them. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) L75 1k3 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial don believe this is in the best interest of the public. Although we know that establishements that sell alcohol need to follow strict rules, there are always seems to be ways around it, (using someone else?s id, places that don?t card as frequently etc. The reality is that all Employees that work for the LCBO are trained on what to look for in an lD, but the people who serve alcohol or not (bouncers, serving sta?9. feel opening Canabis lounges will make it easier for underage minors to consume Canabis. Also frequent a Caf? that is next to a Cigar shop/lounge. At this establishment it is permitted to smoke on their patio. lha ve left the coffee shop due to the foul smell, and smoke that can see wafting from the patio next door. Would the same exemptions apply for a Canabis lounge? Meaning those who do not want to consume Canabis would be exposed because of their proximity to other stores? (insert comments if necessary the box will expand as you type) (insert comments if necessary the box Will expand as you type) NO (insert comments if necessary the box Will expand as you type) feel you only need to look at the Cannabis events held in Vancouver to see that they often have a problem with over consumption at these types of events (which we also see at events that serve alcohol). There is also the factor of the smoke, which is different than alcohol, in that the people around can be affected by Cannabis smoke, whether or not they want to. Here in Burlington our Festival grounds a butt a park where Children play, as do many others (in Milton it is across the street from an elementary school). Cannabis Consumption Establishments: Yes the risk that people Will be exposed to second hand smoke (such as our old smoking laws, Which is a health risk). We know that second hand smoke is a health risk for everyone around. lt is also hard believe to monitor consumption level, as Cannabis consumption can affect people differently. (insert comments if necessary the box Will expand as you type) SOPs: (insert comments if necessary the box will expand as you type) gagpermuted;"mumapamy ghau'l'abe'an'aa??a and regulations (as well as decided if they should be permitted or not_ (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _Small business owner Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial The sale of cannabis should not be opened up. Minors and children are regularly in cafes and they are not regularly in the L08 0. They need to be protected from peer pressure to take this in an aggressively for profit environment. (insert comments if necessary the box Will expand as you type) Cannabis should not be anywhere sold in public. The rock concerts and such that happen in Burlington are regularly attended by teens Who are able to abuse alcohol When they are under 19. The stipulation that buyers must be 19+ does not protect our young people from alcohol abuse. Nor Will it protect them from peer pressure to consume cannabis in public. Cannabis Consumption Establishments. They Will likely be selling other drugs through the relationships created With the clients at these events. SOPs: (insert comments if necessary the box Will expand as you type) Give them complete freedom to prohibit these establishments from opening. People Will drive to them and Will drive home from them if they are structured like sit down cafes. These establishments do not keep our roads safe. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other individual Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario LI 3. Greater Toronto Area X4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial Yes should be just like liquor in a bar. Buy it there and consume it there if they prefer for a nice social experience. Everything cannabis should be allowed to be sold in any cannabis friendly establishment Yes should be treated just as events involving alcohol are treated because cannabis is actually healthy for the body When used instead of abused so if alcohol Which has no benefits whatsoever is able to be sold and consumed for events, Why on earth shouldn?t cannabis be? Cannabis is a beautiful thing. So happy it?s finally legalized. Pot=Peace Cannabis Consumption Establishments: The only risk is that consumer?s may tarnish their cannabis experience by adding liquor to it SOPs: Same as above so all we can do is check individuals for alcohol or any other drugs other than cannabis Same thing they are currently doing With events involving alcohol. Let as many cannabis stores, lounges, restaurants and events happen as possible and may the best stores etc Win. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial (insert comments if necessary the box will expand as you type) Yes, absolutely. This would allow a safe space for folks to consume, try new strains, and help promote tourism. (insert comments if necessary the box will expand as you type) All of the above. I would suggest restricting alcohol sales in the same space however. (insert comments if necessary the box will expand as you type) Absolutely. Again, I cannot see any good reason not to. It may be wise to limit alcohol sales, however as every person serving it has passed the SmartServe course I see no reason why they could not limit a person?s intake with those skills. Cannabis Consumption Establishments. (insert comments if necessary the box will expand as you type) No. SOPs: (insert comments if necessary the box will expand as you type) No. (insert comments if necessary the box will expand as you type) None I strongly disagreed with the ?opt-out? provisions from the previous legislation. (insert comments if necessary the box will expand as you type) A fantastic idea that should've been included with the initial legalization. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation ofadditional cannabis business opportunitiesin the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. Nochanges to thecannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Actprohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribedplaces restaurant andbar patios or within nine metres of thesepatios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boatsthat are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes,or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedbackto the questions below on this form and submit tocannabis@ontario.ca. The closing date for providing feedback isMarch 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Educator DMunicipality Law enforcement DIndigenous organization/community xDOther _business owner Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario x3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial If done so safely, and if customers and sales staff understand the effect of cannabis. For example, I would expect to only be served what would be safe for me lf we are treating people like adults, we should be able to eat, drink, smoke and vape in a safe environment. lt is important that all guests of these proposed establishments understand the environment they are entering as well believe that Canadians of consenting age should generally have the availability of the cannabis products. would think that smoking should be treated as cigarette smoking is handled. Not to infringe on others Who don?t Wish to be around smoke. lf safe and practical practice is being observed don?t think many would have issue I Cannabis Consumption Establishments: like the idea, especially for tourists Who can?t smoke in hotels SOPs: (insert comments if necessary the box Will expand as you type) lf we are treating people like adults, we should be able to eat, drink, smoke and vape in a safe environment. lt is important that all guests of these proposed establishments understand the environment they are entering as well believe that Canadians of consenting age should generally have the availability of the cannabis products. would think that smoking should be treated as cigarette smoking is handled. Not to infringe on others Who don?t Wish to be around smoke. lf safe and practical practice is being observed don?t think many would have issue REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other: Individual Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Absolutely yes. Alcohol has been prevalent in the lives of Canadians for as long as the country has existed. Even during Prohibition alcohol was rampant. ln fact, certain brands of alcohol brag about how prolific they were during Prohibition. Now that the senseless ban on marijuana has ended consumers should have the right to safely consume it the same way that alcohol is consumed. Cannabis users should be trusted to exercise their rights as responsible, of-age consumers. The legislation should be the same for alcohol as it is for marijuana designated establishments for people to eat, take, and be merry. Marijuana and all related products should be available for consumption for those of legal age. Non-impairing beverages should be made available, as should food. Absolutely yes. lf of-age adults are trusted to consume alcohol at these events marijuana should be treated the same way. The events should follow the same restrictions as those with liquor licenses: the burden of care is on the event organizers. do not condone underage drinking or smoking but of-age adults should not be forced to have their use dictated by the presence minors. All safe methods of consumption should be permitted in all venues. Designated cigarette smoking areas exist in almost all event venues; marijuana smoking should be no different. Consumption of cannabis food and beverages should be allowed in all the same spots as alcohol. Cannabis Consumption Establishments: No additional risks or opportunities are created that are any different than alcohol. SOPs: (insert comments if necessary the box will expand as you type) Whatever rights and influences municipal governments currently have regarding alcohol consumption should be the same for cannabis consumption. For too long marijuana users have been vilified by the general public. We?ve tolerated outdated and ignorant attitudes towards a hobby and passion that affects very few people other than ourselves. We deserve to have the same rights, privileges, and luxuries that alcohol users do. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Consultant Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial I Yes- Cannabis is very much a communal product- the ability to share the experience with friends and strangers (not unlike alcohol) can provide a safe environment as well as business opportunities including lounges and tourism opportunities Cannabis accessories, cannabis on site for sale, non alcoholic beverages and food. (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) Cannabis Consumption Establishments: (insert comments if necessary the box will expand as you type) SOPs: (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) spent some time last year exploring legal cannabis lounges in California (San Francisco) and saw various models. The best model included a licensed retailer with an adjoining lounge that allowed the consumption of cannabis products by smoke and vape. lt became apparent the more we explored that Cannabis tourism was growing in California not unlike wine and brewery tours. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _Resident Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial El: Yes, the government should consider facilitating the consumption (not sale) of cannabis in lounges and cafes in Ontario. The reason for this, is that consumers are limited to Where they are able to consumer cannabis. Consumers Who live in condominiums or rentals are often prohibited from consuming. By establishing consumption in cafes and lounges, this creates a safe place to consume, in addition to creating business opportunities. These lounges and cafes Will help keep consumption away from the streets and people Who are not interested in smelling or consuming through second hand. These should be dedicated cafes and lounges, that specified for this purpose. All by-products of cannabis should be allowed for consumption. However, the lounge should only permit the sale of accessories and food/drinks that do not contain cannabis or alcohol. Yes, the government should allow the sale and server of cannabis at special occasions. This should not be treated any different from alcohol. Normal precautions that are taken With alcohol should be taken With cannabis. Cannabis Consumption Establishments. No additional risks. SOPs: No additional risks. The municipality should be given the option to opt-out or designate certain zones for retail and caf? spaces. SOP should be allowed in any municipality as this Will create an unfair advantage to other venues in other municipalities. (insert comments if necessary the box Will expand as you type) REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _business owner Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial Yes. lt gives consumers more options/ accessibility for making healthier choices ie. cannabis instead of alcohol. They should be treated like existing bars in that the proprietor should be able to offer products to round out a full service offering as defined by its consumer base. This should include foodl beverages and cannabis accessories. Yes, there should be a SOP program similar to alcohol. This would provide the opportunity for consumers to make healthier lifestyle choices. Consumers should be allowed to choose from either alcohol or cannabis at such events. The event should be age restricted, methods of consumption should include cannabis beverages edibles. Combustibles should follow the same rules as cigarettes vaping. Cannabis Consumption Establishments: Opportunity is that it provides for more consumer choice convenience. don?t see any greater risks When compared to authorized cannabis retail stores. SOPs: see no greater risks believe this should be managed at the Provincial level With input from municipalities. don?t believe municipalities Within the province should have the right to reject if Provincial government deems them acceptable. believe legalizing consumption lounges would give consumers greater choice and would drive revenue for business operators and government. At the same time, think consumers Will continue to consume at special events they Will just be more discreet. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments andlor Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail?market.html. As part of Ontario?s transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in speci?ed social settings caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e?cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario?s cannabis consumption rules, please visit cannabis. Other Forms of Cannabis Products 1 On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts? cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals? cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada?s rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Please provide your name, title and the full name and address of your organization (it you are submitting comments on behalf of an organization). (please insert contact information) 2 About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Yes, of course. Legal products should have public and commercial locations to consume them. Available cannabis consumption locations should be a numerous as those for alcohol, by capita. For instance, alcohol consumption locations/ pop. that consumes alcohol) pop. that consumes cannabis. 3 This policy should mirror the legislation and regulation related to alcohol. The conditions should be the same as for alcohol. When cannabis is vaped or smoked the rules should be the same as for when tobacco and alcohol are present together. Keeping the rules similar is both fair and easier for compliance. Any location that currently has notable illicit use of cannabis must be included in the framework, otherwise the policy is responsible for creating the circumstances for a black market. So, places alcohol is consumed party locations), places cannabis users frequent or gather festivals, spiritual gatherings), must be included. All methods should be permitted. 4 Cannabis Consumption Establishments: Less impaired driving; more tourism; stimulates business; allows establishment of churches that use cannabis as a sacrament or spiritual medicine; stop ignoring the not-for-pro?t market and use sectors ESOPE reduction of black market; allows for spiritual use (thus, less human rights infringement); stop ignoring the not-for-profit market and use sectors Less restrictive use environments must be created for non-commercial venues or events (SOP). Any use related to gifting cannabis products non-commercial, spiritual) must be allowed and cost nothing to the users or organizers. This will allow for religious use in church locations or during group ceremonies. EAII regulatory costs or onerous paperwork should be born by tor?pro?t enterprises and purposes, not non?pro?t ones, or ones that are for medical or spiritual purposes. 5 REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other individual box) Region (please refer to map and check appropriate 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial Yes, believe it may be appropriate to allow the sale of cannabis for consumption in establishments like lounges or cafes; however, these establishments should have to abide by the same rules as retail stores 9., distance from vulnerable populations). Given that consumption Will also take place, other considerations Will need to be taken into account such as shared ventilation systems With other units in the same building. Guidelines Will also need to be developed regarding if/When it is appropriate for staff to ?out people off? if they have concerns about the amount of cannabis a customer has ingested. I believe it is reasonable for cannabis accessories and other food and non-alcoholic beverage options to be sold at these establishments. The question about whether alcohol can additionally be sold should be based on input from scientists/researchers in 3 the area of substance use and the impact of multi-substance use on individual and public safety and health. am generally not in support of the sale of and consumption of cannabis at festivals or events unless the specific content of the event is related to cannabis. Allowing this would likely prevent some individuals from attending these events due to not wanting to have exposure to cannabis. The exception to this would be the sale of cannabis products for which there is no second-hand exposure edibles, etc. However, if cannabis products are sold and consumed at events/festivals, it should only be done so at events in which the age is already 19+. Making these products available for use during other events will likely lead others, especially families with children, to not attend these events so as to avoid the exposure. The question about whether alcohol can additionally be sold should be based on input from in the area of substance use and the impact of multi-substance use on individual and public safety and health Cannabis Consumption Establishments: Depending on the size of the establishment and ventilation, there may be a risk of unintentional overconsumption due to exposure to second hand smoke on top of whatever the individual is consuming themselves. SOPs: ln general, lfeel that allowing consumption at events restricts those who do want to be in a setting where cannabis is being used. lndividuals who would like to use can always do so prior to their arrival at the event. do believe that there should be provincial, rather than municipal rules. Having different rules from city to city could result in people driving from one city to another to use such services and then subsequently driving While under the influence of cannabis to return to their home city. ln general, lfeel that the government is moving too quickly on considerations of new cannabis regulations given that legalization has only been very recent and there has been no longitudinal research yet on the public health outcomes related to legalization. Research in particular should look into the effects of legalization on youth attitudes and consumption of cannabis and the related health/mental health and social outcomes. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _consulting firm Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario 3. Greater Toronto Area LI 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial am completely against facilitating more cannabis sales. This was not the purpose of legalizing the drug. Making it more attractive to our young people to consume it should the goal of the government- particularly when it is known that the drug is dangerous for those under the age of 25 to consume. This industry has to find its equilibrium between supply and demand the government should leave this to the free market system and let things fall as they may. This proposal feels like government is supporting an industry that has the potential to generate tax revenue at the expense of the social good of the community. lt is appalling and ill conceived! am a card carrying Conservative but if this passes, it?s enough for me to vote Liberal in the next electon. (insert comments if necessary the box Will expand as you type) Absolutely not, as per my response to Cannabis Consumption Establishments The risk is of increased consumption, particularly among our young people who are at risk by assuming the drug. The government must not do this! SOPs: (insert comments if necessary the box Will expand as you type) (insert comments if necessary the box Will expand as you type) (insert comments if necessary the box will expand as you type) REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit mm," raswsmatario E's; Zioratariouo behind-ca - ra?arketfatm?. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e?cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit WM. :3 nta cafe-a na bis. Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: 54?.th airway-Lam bade. .caia nii'eea iti'emca readainewsi?'} 1 Sines: iti'rca pa (isanii nae iizeswea isat?o nsvio M. Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization Health organization Municipality Educator Indigenous organization/community Law enforcement Other _Medical Consumer Region 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario .. Western 8. Provincial yes absolutely its now a legal plant and its a social plant. No different than alcohol, actually much safer yes accessories, food, drinks, alcohol no restrictions. there have been enough the last 100 years 'Cannabls Consumption Establishments: SOPs: no n'iore risks-than-Alcohol none looking forward to it! REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to The closing date for providing feedback is March 10, 2020. The government should ban such sales for the following reasons: 1. Cannabis mixed with alcohol can be dangerous, so they should NOT be sold in the same establishments. 2. Non-smokerslnon-vapers should be protected from toxic second-hand cannabis smokelvaping residues carried by wind/air circulation, indoors and outdoors. 9:2 9:9! (insert comments if necessa the box will ex and as ou ty e) The government, whether AGCO, SOP, or other forms, should avoid selling cannabis and alcohol at the same places, and should have safeguards to protect people (who do not use cannabis) from toxic second-hand cannabis smokelvaping residues carried by wind/air circulation, indoors and outdoors. Cannabis Consumption Establishments 1. Risk: People who do not use cannabis might be forced to inhale harmful second- hand cannabis smokelvaping residues carried by wind/air circulation, indoors and outdoors. As a result, non-users stop going to such cafes, lounges, and establishments. 2. Risk: Accidents might occur because of toxic combination of cannabis and alcohol sold at the same places. Same as above. Municipalities should protect people (who do not use cannabis) from toxic second-hand cannabis smokelvaping residues carried by wind/air circulation, indoors and outdoors. Cannabis and tobacco smoking/vaping should be prohibited indoors where non- smokers/non-vapers live, work, visit, including inside condo units (not just common areas outside the individual units), to protect the non-smokerslnon-vapers from harmful second-hand smokelvaping residues carried by wind/air circulation. Smokelvaping residues produced in one condo unit moves into other units because of air circulation inside the condos. The government should also prevent people from smoking/vaping outdoors in downtown areas where many non-smokerslnon-vapers are around. I hate that I am often forced to inhale second-hand smokelvaping residues exhaled by passers-by. lnhaling, even momentarily, such toxic substances makes me nauseous. Non-smokerslnon-vapers should NOT be forced to inhale toxic second-hand smokelvaping residues, indoors and outdoors, even momentarily. Vaping should be banned, considering recent vaping-related death incidents. See the CBC news on vaping-related death: illnesses-1 .5386125 See the website on alcohol and cannabis mix danger: Thank you very much for considering my opinions. I hope for healthier lungs and better air quality, free from toxic second-hand smoking, vaping, cannabis, etc. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. 521(1) Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEECEI: Absolutely not. If people want to become intoxicated in their own homes that is their issue. This will create nothing more than more driving under the influence and worsened public behaviour. Intoxication is more difficult to detect than alcohol. I disagree with this proposal under any conditions. Cannabis Consumption Establishments: I disagree with all of it. There is a cannabis store going in to our local plaza, next to Tim Horton?s and Shopper?s Drug Mart. A family neighbourhood type plaza should not contain such a store. SOPs: Public intoxication and risk to safe driving practices. 3 None. I do not agree with either (insert comments if necessary the box will expand as you type) We have a significant problem with people driving under the influence. Cannabis is more difficult to detect and is a greater risk. If people want to intoxicate their brains with alcohol or cannabis they should do so at home. Absolutely no respect for the decision to make these products available publicly. Citizens have a difficult time controlling their alcohol consumption. Innocent victims as a result. REGULATQRY REGESTRY FGRM Potenitiai for Cannabis Consumption Establishments 3111.11111- Cannabis Speciai Occasion Permits On December 12 2019 the .govetnrnent announced that 11 is taking steps to move to an open market 11:11 retail cannabis sales 1'11 Ontario as it originaii'y in1endeci This 1111111 provide consumers with moie choice and convenience and a safe- and reiiabie supply of cannabis For more information, at ease visit 9,11 nco?ce nae: re era-11am"w 1?11 UJ As part of Ontario?s .-.transiticn to an Open market, the government wouici like your teed-back on the potential impiementation of. additional cannabis business opportunities in the future .ihCiuciin-g: 1. facriitating the sets of cannabis for censurnption in estabiishments iike? iounges and cafes (cannabis consumption estabiishmentsi; and 2. cannabis. speciai occasion permits (SOP-.s) The government is potentiai decisions about opportunities 111- an. open cannabis market in the inmate No changes to the cannabis framework are expected at this time not is there a current timetrarne for any additional changes that may be intermed by this feedback. Cannabis- C'onsumnitiori Estabiis-hments and'Sneci'ai Occasion Permits Cannabis consumption establishments and SOPs it brought forward could the purchase and consumption of cannabis in. Specified sociai settings cafes entertainment venues, testivais and events) Cannabis. Consumption Rates Cannabis canbe smoked or'vapeti 111 many outdoor public pieces. and in private residences.- The Smoke- Free Ontario Act, 201? (SFOA 2017') and the reguiations under that prohibit the. smoking of: cannabis and the use of eiect'r-onic cigarettes (e cigarettes) to trace any substance {11113111111119 cannabis} in enciosed workpieces and enclosed 111113111: pieces, as wait as other prescribed pieces restaurant and harps-1111218 or within. nine metres of these patios). The 2017 sites prohibits drivers and passengers from consuming any term of Cannabis (smoking. vaping- eating) in vehicles and boats that are being driven or 1111111 be driven subject to certain exceptions The SFOA 21317 is not the 01113; source of smoking and vapin-g? restrictions. in Ontario. Additionai restrictions on cannabis consumption may be found in municipal byiaws and the policies of e'mpi'oyers and property owners The goVernment'is not'consic'iering changes to the SPCA regime aspart of this consultation. 1? 11"" 1m 1 Flu-U!- "l Iva- ?1 .-. .- 4? .1"va REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _mobile application. Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial I believe that creating spaces that are cannabis friendly such as new coffee shops, lounges, and restaurants would be beneficial to the country because it gives Canadian consumers options on what kind of experience, they want to partake in. It will make both sides of the market happy (non- cannabis consumers, and cannabis consumers) and bring in more revenue at the end of the year to the Canadian economy. By providing a space for everyone to go to base on their needs and wants there will be a decrease in dissatisfaction and division. Not everyone would enjoy having their morning coffee with smoke lingering around, whereas others may love that experience. Times are changing, and so are consumers wants and needs, the country needs to be adapting to these new changes to make Ontario a more pleasant and enjoyable province to live in. Any product that is of relevance to the establishment, for example, a coffee shop selling accessories, or rolling papers and filters makes sense. A restaurant on the other hand could sell cannabis teas, and edibles. A yoga studio could sell cannabis incents and creams to reduce any pain and stress their clients may have. I believe the two can coexist in the same event because not all individuals at an event want to consume alcohol and vice versa not all individuals at the same event want to consume cannabis. Give people the option to choose between the two as it is their decision if they want to consume both alcohol and cannabis at the same time. In addition, the two substances when consumed simultaneously do not result in a fatal incident (ie overdose death) as it would with pain killers and alcohol. Lastly, festival attendees typically bring in their own illegal substances to consume with alcohol so by having legal cannabis present at an event would help reduce the need to bring in other drugs/substances. Smoking, vaping, and consuming edibles I believe are all safe and should be allowed to consume at an event. However, if it is being sold at an event it should be micro dosed to prevent any over medicated experiences for consumers as some are new consumers therefore for sensitive to the effects. Cannabis Consumption Establishments. risk: customers can over consume therefore not feel good and weaken the brand and establishment. 4 Opportunity: Increase in disposable income being spent Happy citizens finally feeling like they belong Consumers who are patients of medical cannabis do not have to feel ashamed or embarrassed. It will help minimize and hopefully completely remove stigma from the society, and encourage people to educate themselves on the product and topics regarding cannabis. SOPs: Risks: Consumers not understanding their limits resulting in over consumption. Consumers not aware of the strength of each product being served Consumers faced with high potency products (there should be labels, and not anything available that will make you so high after one try). Opportunity: Reduction in illegal drugs being smuggled into the events. Bring in a bigger crowd to the event as more people are welcomed. Customer insights on what people enjoyed and didn't enjoy, what can be improved in the cannabis space. I think the only people that should be involved are end consumers, potential end consumers, cannabis specialists, the venue places themselves, and scientists that specialize in substance effects. Do not impose a fear based model of execution towards cannabis, educate consumers on what it actually is, and announce cannabis consumption establishments and SOPs with excitement and positivity, NOT in a negative light making the assumption that it is bad but rather a second option consumers have when going to events, and local settings like a caf?. Thank you. 521(1) From: To: Untarlo Legalization of Cannabis Secretariat (MAG) Subject: Cannabis feedback Date: March 10, 2020 9:26:49 PM REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit cannabis-retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consu?a?on. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Municipality Health organization lndigenous organization/community Educator Other Law enforcement Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8 Provincial (insert comments if necessary the box will expand as you type) Yes it should be considered (insert comments if necessary the box will expand as you type) Ffood and beverage only Yes similar sop process should be applied Cannabis Consumption Establishments: No alcohol should be sold alongside cannabis PrownCIal should handle It Restrictions on sponsors and data mining should be in place to protect consumes REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario LI 8. Provincial Yes, the government should consider the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. Cannabis is now a legal substance and it should be regulated similarly to alcohol, which means allowing adults the option to purchase and consume the product in designated spaces with like-minded adults and providing entrepreneurs a clear and fair regulatory framework so they can build a business that safely caters to public demand. Edibles, cannabis, cannabis accessories and educational materials along with food and beverage products that do not contain cannabis should be permitted in cannabis consumption establishments. The one thing that shouldn?t be sold in cannabis consumption establishment cafes is alcohol, at least in the short term. Cannabis consumption establishments should be treated like any other cafe or retail establishment. Longer term, the government should assess whether vaping should be permissible. Absolutely, the government should establish an SOP program for festIvals and events, similar to the SOP program for alcohol. Smoking and vaping of cannabis should be permitted if the event is outdoors and edibles should also be permitted. The sale of alcohol and cannabis should both be allowed at SOP events. Standard age restrictions should apply. Yes, cannabis consumption cafes and SOPS represent an economic opportunity for entrepreneurs and a new era for consumers, who have been forced for decades to consume cannabis in the shadows and purchase marijuana on the black market, enriching criminals while generating zero tax revenue that could be used to promote the public good. Allowing cannabis consumption cafes is simply a logical offshoot of legalization that will reduce the stigma around cannabis and discourage the black market. 4 Municipalities should have the same control over cannabis establishments and cannabis SOPS as they have over establishments and SOPS that serve alcohol. A century of prohibition hasn?t worked and anything the government does to perpetuate that prohibition will similarly backfire and give a boost to the black market. A century of prohibition has created an unfair stigma around marijuana and people need to be educated. That can?t happen in a regulatory environment that treats it as more dangerous and differently than alcohol. .WT?i-aM-Lzu . WM A0066432 19-000656 Martin, Ashley (MAG) From: 521(1) Sent: February 12, 2020 10:12 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Feedback Categories: Anti Licensed Est, Individual submission REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments andlor Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings cafes, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke?Free Ontario Act, 201 7 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario?s cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: I cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) I cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) I cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: 2 Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Municipality Health organization Indigenous organization/community Educator XOther_parent Law enforcement Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario I 5. Southeastern Ontario I 6. Southwestern Ontario I 7. Western Ontario I 8. Provincial No. It will lead to a decrease in places that offer food and drink Without the drugs. We need citizens Who are engaged, not spaced out. If such establishments are allowed, please have them be required to serve food and beverages that do not contain cannabis or alcohol so that everyone in the group is able to join in and no one feels compelled to start consuming cannabis, and the designated drivers have something available to them. I would not want my son or daughter feeling forced to consume because the others in the group chose that location and the location serves only cannabis. I would prefer it not be allowed. Alcohol is enough of a problem. Given the effects on the young brain, it would have to be restricted to 25+, and it would have to be a method that Cannabis Consumption Establishments: I am concerned for an increase in impaired drivers, impaired work related incidents, impaired life choices. SOPs: This makes it overly easy to obtain. It comes to you, not you have to go get it. I think it would also make it harder to control who is purchasing/consuming it. They would need to be able to have final say if and where such an establishment could be located to operate under the federal rules plus any other rules the municipality chose to require. Student debt is high enough as it is. see these establishments that sell THC containing cannabis as a very serious threat to students being able to apply themselves to their education and complete their studies in the planned time. I do not think that the government wants to support these students for the duration of their lives on welfare or unemployment, and I do not want my taxes one point in history some places allowed opium houses. That was found to be not beneficial. Let's keep our citizens in their right minds and productive. Martin, Ashley (MAG) From: 521(1) Sent: February 10, 2020 2:27 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: government consider facilitating the sale of cannabis for consumption in establishments Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization Municipality (please check the appropriate box/boxes) Indigenous organization/community Health organization Other Educator Law enforcement Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial I strongly believe the government should consider facrlitating the sale of cannabis for consumption in establishments such as lounges and cafes in Ontario. I believe the fact that going into a coffee shop and also be able to purchase cannabis to enjoy with your coffee would entice a certain luxe cannabis lifestyle, a perception that adult professionals who hold high positions would be able to relax after a long day with coffee and a joint. It would allow certain individuals to understand the stigma around the negativity of cannabis and the usual stoner" crowd that are labelled with the flower is not the onl crowd usin cannabis roducts The other products that should be permitted in terms of accessories are rolling papers, filters, lighters. Everything an individual would need if he would like to roll his own joint as he is relaxing with a coffee. I would adopt a luxe cannabis lifestyle. As a person who often attends concerts, I am fully aware that cannabis is being brought to these events already. Allowing these events to have a special section, a lounge or cafe booth would be a great idea. Of course it would have to be a reserved zone, and only allow individuals of correct age. It would attract those who are interested in cannabis and diminish the number of individuals who light up anywhere they want. Cannabis Consumption Establishments: (insert comments if necessary the box will expand as you type) SOPs: . (insert comments if necessary the box will expand as you type) . ab ta The municipality would have to be involved in order to determine allowed space and designate th d' th d' (insert comments if necessary the box will expand as you type) bk Re 029 0066432_28-000665 I, if?? f' :5 2f 0066432_30-000667 ?ggf?? - .54.- . .- .- -: REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). James Hershaw, Founder of LIBOCO Bioscience Developing innovative Cannabis edibles products. About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement EX Other Cannabis Edibles Developer Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario 3. Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial Yes, lounges and cafes that provide cannabis products should be allowed in Ontario. Informed consumption of appropriate regulated cannabis edibles products (food and beverage) can be an alternative to alcohol consumption. Many studies show that reduced alcohol consumption has significant health and safety benefits. Creating an appropriate social environment where people can understand appropriate doses, bioavailability and onset of cannabis products will be beneficial to all users and non- users. Cannabis products should be allowed in any establishment that can serve alcohol. Although initial commentary suggested that cannabis facilities should be separate, this may not be a practical business model. Licensed alcohol facilities have the appropriate training, facilities and social environment to responsibly serve cannabis products. The AGCO should also manage licensing of Cannabis products at special events. The organization has the experience and there is not any practical reason to create additional government overhead with a new organization to administer this reasonably simple licensing step. Cannabis Consumption Establishments. There are not any reasons to suggest that cannabis consumption creates any additional risks compared to alcohol consumption. SOPs: Similar to answer above, there are not any reasons to suggest that cannabis consumption creates any additional risks compared to alcohol consumption. (insert comments if necessary the box will expand as you type) Municipal oversight should be minimized or eliminated as local minor opposition can impede I distort normal business practices in commercial areas. Alcohol sales at commercial facilities is widely accepted without municipal oversight. Allow Ontario to become a world leader in safe and fun consumption of locally produced craft cannabis, beer and wine products. There is an opportunity to create Ontario as a world class festival destination that combines music, dance, song and art from our diverse global communities. We have the talent and spirit! Given that Toronto is Canada?s largest city, there is an opportunity to show case an emerging Canadian Cannabis Culture. Just as Toronto became a world leader through the inclusive Pride Festival, there is an opportunity for Ontario to lead the world with a new form of festival fun. It will draw tourists from around the world. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 21, 2020 10:12 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EThe ignorance shown to cannabis consumers will continue this whole process is a joke ELegalHes want more taxes by opening cannabis up to more locations for sale while ignoring what cannabis patients want and need. wasting my time on deaf ears and closed minds. Every survey on cannabis has been for the purposes of looking like the government was listening Ewhile in the end just doing what they were planning no matter how badly it effects the user. Martin, Ashley (MAG) me? s.21(1) Sent: February 10, 2020 1:57 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Open More Brick and Mortar Stores Immediately Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Hi there, Thank you for taking the time to consider the opinions of this public on this matter. I am from Ontario and live in downtown Ottawa so if I wanted to buy Cannabis it would be convenient however for the other 14 million people in Ontario, that is not the case. We have 24 stores, Alberta has over 400, 1/3 of the population and made just as much money as Ontario in 2019. If we have 600+ LCBOs, we should have 600 cannabis stores, minimum. The best thing to government could do at this time is open more brick and mortar stores so combat the black market as soon as possible. If you really care about protecting the 'children', you would treat a less harmful substance such as cannabis the same as more harmful ones such as alcohol and tobacco. This way it would be harder for the youth to access. That means 600 stores in Ontario at least. The hypocrisy must stop. In reference to the Consultation, there are public houses where people can consume alcohol so we should also have safe consumption lounges where users can vape as there is no smoke involved. We allow events to sell alcohol therefore they should be allowed to sell Cannabis in the same light. Double standards should no longer exist in 2020. Thanks for the opportunity to share my views, s.21(1) From: Aldo Franoo To: Ontario Leoalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishmenls and/or Cannabis Special Oocasion Permits Date: March 10, 2020 11:07:52 AM Attachments: DOCS On behalf of the Board of Directors ofthe Association of Supervisors of Public Health Inspectors of Ontario (ASPHIO) and our members, please find attached the completed feedback template regarding the ?Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits? We appreciate that changes to the Smoke-Free Ontario Act (SFOA) 2017 are not being considered as part ofthis consultation. As an association dedicated to public health protection, we would like to express our concerns regarding the consideration for cannabis consumption establishments or cannabis special occasion permits, and their associated negative health and social impacts. We hope this feedback will be taken into consideration and we would be pleased to discuss further, as decisions or proposals may evolve. ASPHIO represents 100% of the health units in Ontario, representing public health inspection supervisors, managers and directors across Ontario. Our members are responsible for protecting and improving public health by managing and delivering a Wide range of environmental public health programs in food safety, safe water, vector- borne and infectious diseases, environmental and community health hazards, and the Smoke-Free Ontario Act. Sincerely, Aldo Aldo Franco, MBA, ASPHIO Chair (2019-2020) gh.a.l.r.@..a.sph.i.g..9a Manager Health Protection Investigation Region of Waterloo Public Health Emergency Services 99 Regina St. 8., 3rd floor Waterloo, ON, N2J 4V3 519 575 4400 x5337 226 751 3812 Fax: 519 883 2226 Confidentiality Notice: This email correspondence, including any attachments, may contain information which is confidential and/or exempt from disclosure under applicable law, and is intended only for the use ofthe designated recipient(s) listed above. Any unauthorized use or disclosure is strictly prohibited. If you are not the intended recipient, or have otherwise received this message by mistake, please notify the sender by replying via email, and destroy all copies of this original correspondence, including any attachments. Thank you for your cooperation. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 10, 2020 9:00 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal ET'tle' Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EAs someone who doesn't drink alcohol I would love to see cannabis consumption lounges. If 19 year olds are allowed to run wild drinking throughout various bars, why can't an adult over 30 make a responsible choice to consume cannabis socially. Please stop the stigmatization and nanny Estate that's ongoing with cannabis regulations. Thanks! Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 9, 2020 11:43 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI think this decision should be considered because of freedom. The whole idea comes down to Ewhether or not YOU as an individual decide to go to these places or use the substance. If you aren?t Edoing it then it cannot directly effect you. For people that will use it, marijuana is a much less serious and dangerous substance than alcohol. It doesn?t impart movement like alcohol and it Edoesn?t impair decision making like alcohol, which is why I think it would actually be safer than Ealcohol at events like this. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 9, 2020 10:06 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Hello! Let?s get a lot more stores for cannabis in Ontario before these companies go Ontario is a Ejoke in this. So so sad! We should have over a thousand stores open by Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 8, 2020 12:22 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Whom It May Concern EI am writing in regards to the feedback beng sought in regards to Cannabis comsumption lounges Eand spaces. EI fully support the regulating and licensing of such lounges. Studies have already proved that ECananbis use is much safer than alcohol and for those who don consume alcohol and don like theE Eenvironment in bars to partake in something different. Cannabis and food go hand in hand and have a symbiotic relationship. Allowing cannabis restaurants or cafes could provide an interesting alternative option for dining and entertaining. People have been infusing foods and drinks with cannabis for centuries and there are many tried Eand tested procedures for administering this safely to a desiring audience. EThis is definitely something that should be privatized, just like restaurants that obtain an liquor license, the process should be similar but perhaps more accessible. Speaking for myself as a small Ebusiness owner, obtaining a liquor license isn?t necessarily a possibility for everyone. Cannabis Eshould be much more accessible as it is also a cultural component for many people and can help to have a positive impact on the night life experience. Economically, by regulating and offering licenses at a reasonable rate you allow the opportunity for Eoperators like myself who have years of knowledge to enter into the industry. The province would benefit from the influx of new licensees and the community will benefit from new options, jobs and Ethe creation of a more robust economy. ESafety wise, most operators are knowledgeable about dosing and should play that role actively by glimiting doses or servings and monitoring patrons responses. Education, indiividual responsibility Eand liability as always will always be an emphasis. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 8, 2020 9:10 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like a: your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Cannabis lounges will fail without the inclusion of vaporizing and smoking being allowed. Look towards Amsterdam for an example of how this can be done well and down responsibly. ECannabis is not tobacco. Cannabis is not alcohol. We need to treat it as it's own substance and stop Etaking the lazy way out. Trying to regulate it as tobacco or alcohol is useless, backwards, and Esetting us up for failure. EAllow vaporizing and smoking in cafes with special permits and and event with permits. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 7, 2020 3:32 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: ECitizens should have the right to consume cannabis in places like this. Medical patients are having rights taken away. Our ability to consume in apartments etc isnt always feasible. Why not really? It's been taxes. People enter aa re of consumption laws. Hos is this not safer than bars? Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 7, 2020 6:33 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EWhen approaching this matter, I can only imagine the volume of responses either for or against the proposal. i have two groups, one that favors liberal marijuana policies and another that is strongly against. ESimply put, the best resolution is to let the market decide. Lets use a storefront as an example. An independent shop, can declare success when the demand Eoutweighs the supply. Walmart for example, was once just a single grocery store. With high Edemand, and expansion, Walmart has grown into one of the biggest corporations in the world. If Cannabis is in high demand, this allows businesses to grow and expand. If Cannabis is in low demand, such as Coors Light Iced Tea Beer Then it will fall off the map. should Cannabis be allowed in cafe's and restaurants? Yes. If that business gets a permit, and finds that the use of Cannabis helps their business, or hurts their They will choose not to renew such a permit. If it does help, then the government gains tax revenue. The most effective way to implement a program is to select a "Host City" such as Smith Falls. Allow Ethis city if agreed by citizens, to have a rule allowing for concerts and cafes. Monitor this area, the effects on it, and auxiliary effects. If there is no noticeable negative impact, roll out across the rest of the province. EThis protects you from a larger liability and makes you look more responsible than a generalized roll out. This proposal in itself is a piece of liability waiver so you can get enough people to submit Eproposals to shut it down. You have no intention of allowing such a program to roll out. However, if you let the market decide, then we can get a stronger picture. Because if people hate the idea of going to their local Swiss Chalet because it smells, then business Edeclines. Swiss Chalet will then implement a policy of no smoking at all, and chase pot smokers anay. let the market decide. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 6, 2020 5:09 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EI have been a medical patient for 6 years and have been lucky enough to have Vapor Central Research in my community. This lounge is a great option for those of us who, for whatever reason, Ecan?t consume in public or at home, or those of us who just want a legal alternative for getting medicated besides going home or using cannabis in public. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 6, 2020 12:57 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 6, 2020 7:03 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like a: your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI agree with the proposal for safe comsumption lounges for cannabis. I thInk cafe or lounge style venues would be best suited to the cannabis community, but also allowing comsumption at different events would be fantastic! Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 11:58 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI believe permitting having dedicated cannabis consumption places like lounges and cafes is a great idea and will be incredibly beneficial to the community at large. Ontario already allows establishments that allow indoor smoking and vaping in the form of hookah shisha businesses, Eand therefore there is precedent for granting the same kind of permits for cannabis consumption. EA cannabis business that permits consumption indoors is essentially the same kind of business as a bar which allows individuals to try the products in a safe and supervised environment. These businesses can become a great way to create a cannabis tourism industry in Ontario which can Ecreate jobs whole still providing a healthy and safe environment to people that might be curious to explore something new. Economically, the impact can be significant both for businesses, tax revenues, as well as jobs. I hope the Ontario government considers this and looks to already Esuccessful businesses locally and abroad (ie Amsterdam cannabis cafes) as we develop the regulations to allow for the creation of a new class of cannabis businesses. ESimilarly, special occasion permits are also great for allowing consumption in a safe and regulated manner in places such as art and music festivals. Consumption is already popular but having legal regulation to make it safe would be ideal and Ontario can lead the way in doing this. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 7:57 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Cannabis consumption establishments would be an amazing way for people to smoke in a safe Eenvironment. It would attract all sorts of people, all sorts of business, and it would create tons Emorejobs. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 4:48 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) WEhy can I smoke in public in close proximity with many children, but am not aloud to smoke in a lounge with other consenting EI SERIOUSLY HAVE TO Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 3:54 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Canna Dose Cannadose GTAH Email: Dosecp@qmail.com Hello there! Below I will outline the pros and cons of what the government of Ontario is currently considering, and why I believe it is a good idea. The following information stems from my experience as a cannabis enthusiast, activist and cannabis industry independent contractor. E?The government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); *[My Feedback] Ontario implementing cannabis consumption lounges is a great idea as it will bring in more tax Edollars for the province and ultimately help brands, ancillary cannabis businesses and Eentrepreneurs to makes profits. (6) E-Assisting to break down the stigma of cannabis and it?s role in a functioning society. :5 E-Tax (part of which could and should be reinvested in small batch community rehabilitation type Eprograms which can provide an opportunity for legacy/ traditional market growers and distributors I to legitimize themselves - sans any individuals or groups associated with the criminal justice system) E-a variety of ?entertainment consumption social gathering options (which would help get people Eout of the house and interacting and engaging with their communities to combat s.a.d depression mental health and the effects of technology on our social well being) E-job creation and growth for relative industries and fields of ?work? such as construction, interior Edesign, experiential design, music, art, security etc E-increased distribution channels for brands and ancillary businesses E-opportunity to educate (under regulation) the inquiring non-user to the seasoned enthusiast E-the opportunity to develop ?partnership? opportunities with municipal transit systems and Etransportation companies to encourage the adult public?s participation, and safety policies (6) E- public safety (eg. Access for youth, theft etc) and transportation issues E- locations, locations, locations (ie; placing the appropriate restrictions on where these Ecafes/lounges can be located may contradict the ?don?t smoke and drive issue if not adequately Eplanned out properly) E-based on my visits to cannabis lounges in BC, there is always the opportunity for cannabis lounges to become ?stuffy/?Smokey?, therefore proper filtration systems would need to be implemented ?5 Ethus raising costs for business owners and creating potential issues for non - purpose built lease Espaces E-potentially not providing opportunities for underserved, minority, communities etc to participate E-the large corporation vs the small business owner lounge/cafe selection issue depending on Ewhat is decided will ensue in further backlash against legislation E-(to my knowledge) the absence of a regulatory (cafe/lounge) body to ensure all store products, Eand cpg/ good and beverage practices meet the same regulatory standards of the and/or federal governing bodies, combined with the sentiment of the retail distribution issues could be real disaster if not addressed properly Eand, E.2 cannabis special occasion permits. my opinion there would be absolutely no cons for individuals and companies to access ?special Eoccasion cannabis permits? *EThis would only add more events and options to a city?s slate of special events, and have a positive impact on the lives and local economies ?Cannabis consumption establishments and special occasion permits, if brought forward, would facilitate the purchase and consumption of cannabis in specified social settings caf?s, Eentertainment venues, festivals and events). Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 3:29 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 1:48 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI believe that Cannabis consumption bars/lounges are the next step in legalization. At concerts and festivals, there is almost an expectation that people will be consuming during the event. If the public is provided with a safe, comfortable space while doing so it will only add another layer of positivity to the experience. I hope to see these in the future. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 1:33 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) My main concern is how are you going to differentiate c.a.f.e style establishments from the current Retail model brick and mortar system the retailer is forced to operate by. EAre we talking letting people smoke rolled joints along with vaping and consuming cannabis on the premises? How will the government make a loophole around the smoke free ontario act to allow Ethis? speculation" From alcohol establishments point of view why wouldn't they be allowed to reintroduce cannabis tobacco and vaping in their establishments as well Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 1:27 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: my opinion this would be great for business. Seeing how Ontario is now open for business there is 100% good reason to allow all this. Lounges would be alot more docile then bars are and it will make people money!! Jobs and taxes you can't go wrong! Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 1:24 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EI believe it should be consumed anywhere. Lounges, festivals, parks, and events. Please open more legal stores. Cannot believe how slow this roll-out of retail has been. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 1:15 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EWhy would cannabis be treated any differently than alcohol? The government has been fucking the cannabis sector, use your god damn common sense. What the he?ll do you think? Do you honesty Ethink you need to ask rhetorical questions? Make cannabis great again, allow cafes to be smoked Ewithin, permits? Fuck permits, allow people to smoke where ever, when ever. It helps us get Ethrough our day, its a reset button for stress, makes our day better. Also him and cigarettes are Ethe problem, yet cannabis is treated like heroin. Let us do as we please with cannabis, decrImInaIIzel it you selfish scum bagsm Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 9:16 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EYes please, of course we need to have Cannabis Consumption Sites, also known as pot cafes. I Eattended pot cafes before legalization and they were great places to gather and enjoy pot. Never a fight or even an argument any time I was at a pot cafe. You cannot say this about any alcohol serving bar. The pot cafes paid taxes and weren't shut down when weed was not legal. When pot went legal these businesses should have been able to stay open as they are equivalent to alcohol Ebars. It was easier to enjoy pot in these cafes when weed was illegal. It seems a step backward to legalize weed and then shut down the pot cafes. EAny pot products that are allowed for sale in Canada should be able to be purchased at the pot cafe. When pot was illegal you couldn't buy any products at the cafes, you had to bring in your own. You should be allowed to use your own pot or buy some at the cafe. No alcohol should be Eallowed at the cafes. Alcohol and drunk people don't have the same attitude or vibe to them than pot smokers have. This could and likely will cause problems. No tobacco smoke should be allowed in the pot cafes, if indoors. Pot cafes should be allowed to operate indoors and outdoors. The pot cafes should be allowed to sell food and drinks. Concentrates, hash, buds and edibles should all be Eallowed at the cafe and for sale at the cafe. EAs for Cannabis Special Occasion Permits, we deserve this as well. You can smoke tobacco and .. Edrink alcohol at concerts or other events. It is only fair that pot users can enjoy pot at these events too. Weed, booze and tobacco are all legal, so pot needs to be able to be used legally at these events too. You cannot pick and choose from a list of legal substances what can be used at public events. They all have a spot at these events if managed properly. Legalization was brought to Canada in a rushed and improper way please do the right thing here Eand legalize pot cafes and pot enjoyment at special events and concerts. If the Government of Canada wants people to buy non black market weed, the Government needs to issue an apology to the pot smokers that were criminalized and harassed by the police for the last almost 100 years. The Government also needs to issue refunds on all of the legal fees to fight possession of pot charges, all convictions need expunged not pardoned. Pardoning is the wrong wayE to deal with this issue. I have been harassed by the police for my whole adult life for my choice to use and benefit from pot use. I don't have a criminal record due to the fact that I have spent .. roughly $10 000 on lawyers, donations to charities, hotel stays before court in a far away town and Eall court associated costs. For me to trust the government about pot, I need a personal apology for Ethe Prime Minister and a cheque to refund all the money I have spent over the years to defend my right to smoke pot. Also a drug war victim display and a plaque with the names of the pot users Ethat were harassed by the police for the last 100 years for choosing to use and benefit from pot use needs to happen. This display should include all of the ways the police and government hurt and Esuppressed pot users over the years. This issue needs to be taken out of the shadows and into the Elight. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 4, 2020 9:58 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI strongly believe that cannabis consumption establishments are a good thing. It gives people who Esmoke or vape a place to actually partake, considering the stipulations on smoking can be tighter for certain people's circumstances. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 4, 2020 7:37 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like a: your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EWE NEED CONSUMPTION OF WEED MORE THAN ALCOHOL. ETO GIVE A SAFE PLACE TO CONNECT AND CONSUME IS A BIG ASSET TO THE COMMUNITY. PLEASEE PLEASE CONSIDER IT. OTHERWISE PLEASE GO BACK TO PROABITION AND ELIMINATE ALCOHOL. CAUSED ME MOST OF MY MENTAL AND PHYSICAL ABUSE THROUGH OUT LIFE. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: March 3, 2020 8:38 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EAbsolutely, we should have lounge and cannabis friendly spaces to consume. The government has made a royal mess thus far hopefully they can do this part right. Perhaps consult with those in the filed, you know the expert, this time. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 3, 2020 6:50 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) . Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 3, 2020 12:39 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 2, 2020 3:47 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EYes, publicly controlled; no monopolization. craft cannabis should have a place! Medical patients Eand the people didn't fighht for monopolization. We voted for legalization and decriminalization! Martin, Ashley (MAG) 521(1) From: Sent: March 2, 2020 12:20 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission REGULATORY REGISTRY FEEDBACK FORM The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) About You or Your Organization (please check the appropriate box/boxes) Health organization: Educator: El Law enforcement: El Municipality: El Indigenous organization/community: El Other Cannabis advocate Region (please refer to map and check appropriate box) LI 1. Central Ontario: LI 2. Eastern Ontario: LI 3. Greater Toronto Area: YES LI 4. Northern Ontario: LI 5. Southeastern Ontario: LI 6. Southwestern Ontario: LI 7. Western Ontario: LI 8. Provincial: YES 521(1) Cannabis Consumption Establishments/Special Occasion Permits 1. Taking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not? Yes, the government should facilitate the sale of cannabis for consumption in establishments like lounges and cafes in Ontario. Not only will this be a safe and legal place to go to for premium cannabis safe for consumption, but also help the economy with local businesses. 2. If cannabis consumption establishments were considered in Ontario, what other products should be permitted for sale in those establishments cannabis accessories, food/beverage products that do not contain cannabis)? Other non-cannabis related products could include hydration station/cafe, variety of foods non-kitchen related with options for healthy snacks. And a reliable variety of cannabis paraphernalia. 3. In Ontario, the Alcohol and Gaming Commission of Ontario (AGCO) oversees the administration of an alcohol SOP program, which allows for the sale and service of alcohol at special occasions, including large scale events that are open to the public, such as festivals. Should the government consider establishing a similar SOP program for cannabis to be sold and consumed at festivals and events? Why or why not? If yes, what conditions should be included should alcohol consumption at the same event be restricted, should the event be age-restricted to 19+, what methods of cannabis consumption should be permitted)? Because cannabis has been approved for purchase into the system through the logic of the LCBO, in this case there should be no problem with it being restricted from events or festivals in the same way alcohol is with age restrictions. However, personally cannabis is not in the alcohol category and especially would not be served in cannabis lounges. 4. Are there any additional risks opportunities created by cannabis consumption establishments or SOPs when compared to authorized cannabis retail stores? Cannabis Consumption Establishments: There wasn't any risk before, as opposed to alcoholic consumption establishments specifically (SOPs explained below). It isn't a welcoming environment and experience for cannabis users, medical, creatives, or not. Yes, knowledge of management and order are an asset but a family environment is what keeps the community coming back. 5. What should be a municipality?s involvement, if any, in a potential framework for cannabis consumption establishments or Framework should be established towards the goal of the owner/management and the environment they want to create. As long as they are creating the atmosphere that the community needs and helping the economy at the same time, there should be no SOPs to make patrons feel unwelcome, therefore threatening business. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 2, 2020 11:28 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 53 521(1) Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 2, 2020 11:12 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: anonymous Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 28, 2020 9:46 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 26, 2020 10:02 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) first ones trusted to hold a license for cannabis. EI personally have held a liquor license with catering attachment for 24 years. EAII cannabis related foods do not have to have a mood altering affect. Bistro style dining is enhanced by the herbs and alcohol that may be added to foods not overpowered by them. As with any fine dining experience the staff must know if there is alcohol, .. nuts, gluten etc. in the product the client is choosing. It should be clearly listed so that anyone who Ehas a special dietary need is well informed. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 24, 2020 9:30 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Cannabis smoking, vaping or hooka should be treated the same as cigarette smoking so no it Eshould not be allowed at consumption establishments or at special events via cannabis special Eoccasion permits. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 24, 2020 10:25 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Flagged Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) - EThe Word document doesn't work for me (can't check boxes), so will respond via e-mail. Q1 If "sale of cannabis for consumption in establishments like lounges and cafes" includes smoked forms, I oppose this. As it is now, people smoke within 9m of entrances even though it's not permitted, and the potential for spoiling a coffee in a shop is real. QE2: I would not want to see paraphernalia also sold in consumption establishments, such that it Eturns into a "head shop" for cannabis addicts. But edibles are a concern, since the ingested forms ofE cannabis will take a longer time period to reach peak blood levels than if smoked, and the impairment on the user after they leave the establishment and then drive away, only to be hit at 4 hours or so after first ingesting, is a threat to everyone including the user. "Large scale events open to the public" -- cannabis should not be permitted at these. People go to enjoy the festival without having to deal with impaired people at the festival. Example: the Budweiser Stage at Ontario Place. Every time we have gone to this location for a concert, there are prominent signs posted for "no smoking" under the roof area (open sides) and yet there is cannabis being smoked which then has high adverse effects on ourselves clue to smoke allergies, etc. ESECOND HAND SMOKE, as well. I reported a specific individual at a show last summer to the "security" who did nothing to remove that person, as he was clearly smoking (cloud exhaled every .. Etime), and it was cannabis (not regular cigarettes). It is crazy to post signage and then not enforce it, especially when the perp is pointed out to security (some who seem to be "hired school kids" 1 ?who have no training in use of force if needed). Even Metro Police were there and did nothing when ?the smoke being exhaled was clear and identifiable to a person. ?So, I would not want to see these products opened up to be allowed for use and/or sale at such ,5 events, since concerts involve under-age minors who will also be exposed to this type of behaviour. ?That works contrary to the "safeguards" put in place for permitting these products to be sold in ?Ontario in the first place. I doubt that ID will be checked for a purchaser when the lineups before ?and during a concert are huge and time is a vital consideration in getting everyone served in intermissions, etc. Even if you had an age restriction, at such an event one "legal" person would ?end up purchasing and trafficking to minors who are also at the show with them. You won't be able t?o control this. Q4: see #3 in part. Yes, there are risks when you have mass numbers of people leaving a large concert or festival venue and who are going to "mass travel" from the venue (cars, etc.). A concert ?that begins at 7 ends around 10 or 10:30 and if these products are ingested near the start, they I ?will achieve peak blood levels near the end which will continue to impair them as they journey home. This puts everyone on the road at risk. . Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 23, 2020 8:02 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) It is my opinion that the sale of cannabis and cannabis products in a controlled situation ie: lounge Eor caf? is acceptable. EI do not agree with the sale and consumption at festivals. Most festivals and events are family Eoriented and young children do not need to be exposed to these products. Every time I come to Toronto I exit Union Station into a cloud of pot smoke. As with tobacco products I dislike the smoke. I feel that as a non smoker my rights are not being considered here. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 22, 2020 11:38 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EThis is a great idea I find, as someone who would like to potentially invest in the cannabis industry Eand someone who also consumes cannabis, this is good for the legal market and potentially bring Edown the price as well to beat the black market. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 22, 2020 1:38 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Hello There, I agree with the proposals in all regards for the following reasons: E-Marijuana consumption causes far less negative impacts on society than alcohol consumption and Eshould be a viable alternative for people. E-Policing the outcomes of marijuana consumption in downtown locations etc will cost society Edrastically less as compared to alcohol related violence in downtown core areas. BIG POINT: The legal producers of marijuana are letting go of hundreds of workers and going out of business clue to a lack of stores in Ontario as compared to Alberta etc. I know there are two Esides to the story but everyone is pointing at Doug Fords Ontario "Being Closed for Business" and Ethe resulting devastating job loss is being put on Doug. However unfair it is the fact remains that Ewe have around 30 stores for all of Ontario!! All international eyes are on Canada as we roll out marijuana legalization and why not embrace it and take advantage of the potential for safe tourism venues instead of being seen as the province that de-railed everything by being "Not Open For EBusiness". The fact that illegal physical stores and on-line stores are flourishing in Ontario because .. Legal producers can't get their products to market clue to red tape and are going out of business as Ea Looks Bad on Doug's "Open for business" stance. It also goes directly against Eshutting down the black market with their ties to gangs etc and untested product sold to people under age. I think this proposal that the Ontario Government is putting forward is a Massive step in Ethe right direction but I fear it will be too little too late as the legal producers only have months before going out of business. The market really needs to be opened up quickly. The sky will not fall. Legalization has had a very tiny impact on society and policing, hospital visits, family harm, impaired driving etc etc and the truth of the matter is people will be consuming marijuana ANYWAY. EThese proposals would just regulate it in a responsible way, help combat the illegal market, drive legal business sales, jobs, Tax revenue and stop the damage that is being done to Doug's "Open for EBusiness" Brand. My only concern is that it will take too long to roll out and massive opportunity Ewill be lost to the black market as the legal producers go out of business and the black market Ethrives. Ontario needs thejobs and Doug's brand of being open for business to remain strong on an international level 521(1) EThanks for your consideration - Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 22, 2020 12:17 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: are looking at what exactly? Specific lounges that sell and allow you to use cannabis on the property is fine. The person has the option whether or not to enter the establishment and breathe in the fumes. At special events out in the public absolutely not. As a society we have finally regulated cigarette smoke to a point that people can go to events and restaurants and not have to Echoke on the fumes of someone else's habit. Cannabis smoke is just as bad, or even worse if someone can actually become impaired through someone else's smoking. I have asthma, am Eseverly allergic to animals. Smoking is NOT allowed in public places, neither should cannabis joint Eor vapes be allowed. It's bad enough that apparently I will have to watch where I eat in the Esummer as dogs will be allowed to sit beside me at outdoor restaurants. Smoke is smoke and Eshould not be allowed, especially around children. . Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 22, 2020 11:52 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EHello, If this goes ahead, it needs to have significant controls on the location and type of event. I am Egenerally opposed to the widespread approval of this proposal: 1) I still remember the days when cigarette smoking was widespread and coming away from events Ewith my clothes stinking of cigarettes E2) The smell of second- hand smoke while dining is offensive E3) I don't care to be exposed to the intoxicating effects of cannabis from breathing the fumes at an event especially considering Iwould probably be driving E4) My late wife was allergic to the smell, and got nauseated to the point of vomiting when exposed. EI believe there are others who are similarly affected Regards 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 22, 2020 9:32 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI am glad that cannabis has been legalized and agree with the current sales model. I would also like to see cannabis cafes/lounges like we have restaurants and bars where people consume alcohol. However, I do not agree with having cannabis at festivals and events. In Ontario we do not allow .. Esmoking in public places. We cannot accept cannabis smoke where we do not accept tobacco smoke Eand I never want to see tobacco smoke allowed back into open society. If cannabis were consumedE by vape it would fine but you could not possibly control the method people use to consume. non Esmokers, children go to festivals too- we can't impose on their health rights. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 16, 2020 4:38 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI do not agree with this. If I go to festivals I sure as hell do not want to sit and smell weed being Esmoked, or people acting like idiots. If people are not allowed to smoke cigarettes, then weed Eshould not be allowed. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 21, 2020 10:00 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) No, I do not want cannabis Cafe/lounges or cannabis allowed at special events. What is wrong with you people. It took years and years to stop smoking in public places which contributes to causing cancer not only from smoking but second hand smoke plus it stinks. Now you want to do the same Ewith cannabis. I for one have no desire to smell cannabis in public places. I pray to God every night Ethat no one in my condo smokes this crap as it would flow right through the pipes and into my unit. 53 people really need to see how majority of people live and not think so much about how you can make money. You should care about health and welfare of all those who reside in Ontario. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 21, 2020 9:45 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Cannabis is inhaled and expelled and no one wants that blown into the air they breathe nor into Etheir faces. Tobacco smoking now has its firm laws and I believe smoking of any type should follow Ethose guidelines. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 21, 2020 5:51 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Cannabis consumption lounges and Cafes should be allowed in Ontario. Cannabis is medicine for many and an entertainment for many and to have a place where people can relax and socialize is important. The harms of cannabis are much less than alcohol or tobacco and if people are able to Esubstitute cannabis for either, health care costs and highway carnage will go down dramatically. EThe American States who have legalized are already showing that result. Iwould love to be able to have a choice for socializing with my friends that does not leave a bar as the only option. The province has the opportunity to make positive change and give acceptance to many people who Ehave been outcast by our society till now. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 21, 2020 4:13 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) ESince the legalization I have not had to put myself at risk buying on the street in Amsterdam these have been legal for years. i EI believe Many will prosper form having a safe place to smoke. As a parent it also allows got us to make an informed decision as to if we want our kids exposed in public. EI feel legal smoking patio etc are great for Toronto Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 21, 2020 3:47 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) ESince alcohol is so widely available and consumed in public spaces, it seems to be a discriminatory practice to limit cannabis in these same situations. However, if cannabis smoking is allowed in Especial cafes and special permit locations, I feel cigarette smoking must also be allowed. Some may feel that allowing alcohol and cannabis is a slippery slope. Ifeel that the prohibition of all of these Evices by the government is a reach too far. -: EI am a cigarette smoker and a consumer of Dr. prescribed medical cannabis for chronic pain. I have long felt that the restrictions on me as a smoker were unfair. Alcohol causes as much, if not more .. health costs than smoking. Alcohol destroys family units and yet it is socially acceptable to consumeE everywhere and is readily available in Beer Stores and the LCBO. Cigarettes have been priced so high, packages changed, filters changed-all by government intervention, yet alcohol continues Ewithout these interventions. It is not equitable. I would like at least see restaurants or lounges for Ecigarette smokers if cannabis users are allowed this option. Thank you. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 21, 2020 3:10 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Flagged Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Your attached survey form does not open. I am opposed to special permits, cafes and lounges. I Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 21, 2020 3:04 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EThe government should not promote cannabis in any form. It is one thing to remove a criminal record and another to promote its use. The science says Cannabis shrinks the Hippocampus, 5; especially under 19, whether a teen provides false-id at an event or not. Long term use of cannabis Ealso has issues (with lungs) not to mention the pesticide problems. To openly allow cannabis at events such that under 19 are able to ingest cannabis is wrong. I think the gov't was wrong to Eallow cannabis in retail outlets. It is giving false hope to seniors in pain, likely due to the placebo effect. Brain shinkrage in seniors is a known problem today and if cannabis shrinks the hippocampus in the young, it is obviously not good for the brain in the longer term. Keep cannabis private away from healthy people, like me, who want nothing to do with it. Seems are all .. Edrugged up or medicated these days which will likely have long term consequences. Gov't should doE more to get people back on track, living a healthy lifestyle like olden playing and Edrug/med free. We are headed in the wrong direction and the Prime Min should wake up. Bill Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 21, 2020 10:12 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EThe ignorance shown to cannabis consumers will continue this whole process is a joke ELegalHes want more taxes by opening cannabis up to more locations for sale while ignoring what cannabis patients want and need. wasting my time on deaf ears and closed minds. Every survey on cannabis has been for the purposes of looking like the government was listening Ewhile in the end just doing what they were planning no matter how badly it effects the user. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 20, 2020 10:44 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: :2 521(1) We need lounges. And should have a license so we can smoke outdoors. And stop shutting down compassion clubs and dispensarys. You need to include them into the legal market bcuz they have better prices and cannabis! Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 19, 2020 12:58 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI do not think that cannabis should be allowed at outdoor events. You cannot smoke any other types of tobacco at these events. People should not have to inhale pot smoke. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 19, 2020 12:06 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Organization Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI would also like to see things like cannabis markets and topicals allowed for sale from home Eproducers. EThe over regulation of this industry is hurting the opportunity for small business. This shouldn?t have been another government monopoly. We should be making millions from cannabis tourism. EThe inclusion of cannabis to the smoke free Ontario act has left us with less rights than pre legalization. We should be utilizing the legalization of cannabis as an opportunity to diversify our economy. EThousands of earth friendly by products can be made using cannabis fibre and oil. Not to mention the various medical uses, which are safer than almost all of their alternatives. Free the plant. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 18, 2020 9:22 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) . Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 18, 2020 3:18 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) cannabis "consumption venues", tobacco smokers will likely demand tobacco smoke "consumption Evenues". In my 83 years in Ontario, I was forced to breathe other peoples' tobacco smoke and I Edon't want to do that again. Furthermore, how will people get to those venues? Likely by car and to Edrive "impaired" when returning home is not justified unless the police are checking customers as Ethey leave the venue. EAs for special permits for outdoor festivals and concerts, that would magnify the "impaired driving" . Esituation as much more cannabis will undoubtedly be consumed. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 18, 2020 2:14 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear Consultation on topics under the Condominium Act, 1998 Title: . In December 2019 the government announced changes under the EDescription' Condominium Act, 1998 (Condo Act) in conjunction with the introduction of the Rebuilding Consumer Confidence Act, 2020, and committed to consulting with stakeholders and the public on further topics under the Condo Act. EComments Due: 10/03/20 Contact: No contact info provided EEnter comment here Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 17, 2020 7:02 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal ET'tle' Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EI don't agree to this. EI don't want to have our future children smoking drugs and think it's ok, there have been many studies that say brains don't develop properly when smoking. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 17, 2020 6:01 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: s.21(1) Hello, thank you for viewing my request. whom it may concern: EI believe that the government should let municipalities opt to legalize cannabis cafes, lounges and Especial events. My reasoning is simple. If you legalize it, one of either two things will happen. Either establishments will see a precipitous decline in sales following the allowance of cannabis on their patios, or it will in fact drive up business. Should the former occur, businesses would quickly outlaw it on their property, but it would be freedom of choice as opposed to imposed and it would solve theE issue once and for all and we can all move on. But frankly, I dont think it will really change much. We thought the mere legalization of cannabis was going to bring mayhem and cause frenzied Ehordes of high individuals to overrun the town. But that didn't happen. In fact, nothing changed at Eall except for a few store fronts. Which leads me to my next point: we also thought that having dispensaries on street corners would create more violence and poverty. It turns out that half the Eindividuals entering the dispensary are well dressed businessmen and businesswomen. Nothing to see here folks, move along. No matter what happens, the desired outcome will work itself out, and fairly quickly too. So rather than have an uprising leading to even more fractures in our national fabric, let's allow capitalism to sort it out and give the people the choice to vote with their dollar. Regards, s.21(1) Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 17, 2020 1:16 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 16, 2020 4:38 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI do not agree with this. If I go to festivals I sure as hell do not want to sit and smell weed being Esmoked, or people acting like idiots. If people are not allowed to smoke cigarettes, then weed Eshould not be allowed. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 16, 2020 10:39 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Cannabis cafe or lounge for controlled sale of recreational use might be okay in entertainment districts only. I would never support sale at festivals and events. We cannot even control cigarette Esmoking at venues. Both cigarette and marijuana smoking, lst-hand, 2nd-hand, 3rd-hand smoke have serious health risks. If an adult wishes to use drugs recreationally, that is their choice. However, as a bystander at a venue, how do I protect myself from those risks? how do we protect Echildren from being exposed? does a pregnant woman protect her growing fetus? There is evidence to show that cannabis is related to mental health disorders such as bipolar, :5 schizophrenia. There is evidence to show that exposure to children creates neural pathways that cause lifelong addictions. There is evidence to show that exposure to a fetus cause mental retardation and other birth defects. There is evidence to show that exposure causes hallucinations .. Eand impairs driving. The government can ensure public safety with legalizing cannabis. Even selling Ethis at a cafe, requires a great deal of responsibility on the establishment to protect users and the public. That person who uses cannabis in the cafe, still has to find a way home intoxicated. Likewise, cannabis shops who sell drugs have responsibility of where that cannabis ultimately ends My understanding is that this legalization of cannabis has not helped medical patients who need it. It has not made it easier for them to get their prescriptions filled. Further, the cannabis without Ethe TCH, oil that one rubs on temples for pain, does not cause the hallucinations or impair driving but does relieve pain. Therefore, there is no reason for anyone to buy pure cannabis. It is not a . safe drug. Period. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 16, 2020 9:23 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Cannabis consumption establishments are not a good idea. How will people consume cannabis Ethere? If smoking that is a health hazard for all those involved and smoking is banned indoors anyway. If edibles, why do people need certain place to have a cookie if they can do this at home? We do not have special places to have chocolates with liquor, why for cannabis? Besides, where will these centers be located? Will people need to drive there. which creates road hazards. Near schools, terrible idea. We can drink in bars because we know exactly how we will react to one or two or three beers and manage accordingly but with cannabis it's impossible, you Eare either high or you are not. g; Consuming cannabis is a private decision and action, let's keep it that way! Any politician that goes Eahead with this idea has lost my vote! Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 14, 2020 10:01 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal ET'tle' Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Has anyone considered taxing it at a higher rate than Since it's new and in demand, tax it at a higher rate now because you'll never be able to raise the tax later. '5 Let's collect the tax dollars to invest in services for the people of Ontario. It will be legalized soon anyway so, let's get on with it. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 14, 2020 7:37 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) We don't need any more Cannabis facilitation, Thanks very much. Availability is already far in excess of what is needed. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 14, 2020 3:49 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Fully support expanding the ability for additional establishments to have permits to consume cannabis on-site. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 14, 2020 3:12 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) so should cannabis and if tobbaco/alcohol not banned neither should cannabis. Licensing should follow same rules as liquor Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 14, 2020 3:08 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) I do not think that Cannabis Consumption cafes, lounges, etc., or Special Occasion Permits Eshould be allowed.. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 14, 2020 2:32 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: s.21(1) 1) I do not support the establishment of cannabis lounges for smoking or edible consumption of cannabis. As we?ve moved hard to change attitudes to much more moderate alcohol use balanced consumption of alcohol Ifight the concept of Canabis lounges repulsive. This is just a very bad idea E2) I do not support Special Occasion permits for the smoking or consumption of alcohol. The whole concept harkens back to the days of Chineses opium dens Canadian smoke filled bars. Those Edays are long gone. Let?s not condone them for the future. s.21(1) Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 14, 2020 2:01 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 14, 2020 1:54 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EUnlike alcohol, cannabis has a strong smell which many people, myself included, find noxious. For Ethis reason, I would not attend any event where they allowed cannabis consumption, particularly by way of smoking. We do not allow smoking in parks etc. and we should not allow the smoking of cannabis either. I certainly would not want children breathing in the second hand smoke. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 14, 2020 1:43 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special ii Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 13, 2020 7:19 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EThe rules for cannabis should be no different that the rules for smoking. The very thought of such a Eproposal takes us back many years.. Second hand smoke is harmful . Why would people attend a festival if they are going to have to breathe the stench of cannabis? This should be an easy decision Esince smoking has been banned in public events. We should all be able to breathe clean air no i matter where we are. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 9:02 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: all for allowing cannabis to be enjoyed in lounges and cafes, just like alcohol is enjoyed in bars every where. From my experience there will be less trouble, fighting, vomiting and bad behaviour Eoutside a cannabis lounge at the end of the night, then there is outside a large night club. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 5:31 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI think opening a a cannabis cafe and restaurants would be a fantastic idea. There would be cameras too, that way to catch impaired drivers, it might even reduce impaired driving because of Ethat fact. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 5:23 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI have a severe allergy to cannabis, and since the legalization I no longer can enjoy any outdoor venue. Also, indoor concert venues have had issues as well. I would be glad to fill out the survey if you could email it to me. Thank you Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 4:41 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Flagged Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EI am fully in favour of allowing non-smokable cannabis products to be consumed within all licensed Ebusiness (and other establishments) that meet all required health safety criteria, provided that Ethere is clear signage/ other indicators at the front of the premises that notifies anyone who may Eenter, that such cannabis products are sold and/or allowed to be consumed inside. EThis applies as well to Special Occasions permits, for events that wish to permit cannabis consumption in some form. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 1:15 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 11:14 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: It is bad enough that cannabis has been legalized in Canada and it just shows how badly this .. country has declined in what is wrong with our society, which has gone to hell in a basket, as far as EI am concerned. I am 73 old and have have watched our country lose it perspective of what is morally right and wrong, to the point that it is no wonder the citizens in this country have no respect for anyone but themselves. People learn by example and if our government cannot show proper examples to the people of this country how can you expect the same in return. You Ethoroughly disgust me. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 9:21 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 5:23 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like 5, your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 53 521(1) EYES YES is a legal product so let's move is ridiculous that we do not have more stores and that these regulations for special occasion permits and caf/ and lounge was not put in place from the beginning. Since Ontario decided to go private sector way as oppose to LCBO then It Eshould follow the Alberta mode.. t.hey already have over 125 stores for a population of 4 are we waiting for.. I feel this conservaTIVE APPROACH IS JUST PROVIDING TIME FOR THE BLACK MARKET TO ADJUST. let's accept that it is legal and do what we have to Martin, Ashlex (MAG) From: 521(1) Sent: February 12, 2020 9:17 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: approve Categories: Pro Licensed Est, Individual submission I approve to all cannabis use indoor or out door Mike Ayers 400 main St. north apt.212 Callander Ontario Northeastern I am just one individual sharing my opinion. code POH 1H0. Sent from Mail for Windows 10 Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 4:16 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Attachments: Categories: Unclear, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI KNEW SMOKERS A TIME AGO IN WHEN THEY WERE EADULTS. 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NV 99 0L ..9999GISN03..E 99 ..A'I'Ian3v.. 91 nom 93199 9HL 0L AHL Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 11:24 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) should check out Kelly's Green Lounge in Orono. It is a safe and wonderful place and it is a cannabis Lounge. Where you can learn all about cannabis, there's wonderful products no cannabis, but lots of products and it is a lounge and I think there should be more like it. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 11:02 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EWithout cannabis lounges there?s no where to get proper education on how to medicate properly Ewith cannabis. It?s a place for people to feel safe and educating themselves further on how to better Ethemselves physically and mentally. It?s a place for me to feel comfortable and able to ask 2 Equestions about all the different aspects. If we could smoke in these lounges we wouldn?t have towns raging war against us because we have no choice but to smoke outside and force our choices Eon others that might not agree with our choices on how to medicate. Kelly?s Green lounge in Orono is my safe haven and everyone should be able to have a place like that. It?s only going to make Ethings better for everyone, we?re off the streets and the public is happy. We need more places like EKelly?s Lounge to spread the vast knowledge, I do plan on opening one myself and do hope the rules have changed by the time I open my doors. . Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 10:49 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like a: your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI like to attend festivals with my kids. I'm already uncomfortable around them breathing in Ecigarette smoke. I'm certainly not alright with them being around a bunch of people who are high Eand breathing in their smoke. This entire thing is just a disaster waiting to happen. Now people Earen' tjust drunk driving, they are drunk AND high driving. Legalization of marijuana is probably theE most unintelligent law passed in the recent years and making it okay at public events is ridiculous. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 10:01 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) ESelling cannibas in public bars or establishments is not a problem if all the same rules are Eimplemented as in outlets that are now selling it. EThe use of it in these public ares should not even be up for discussion if you remember the Eand costly battle to restrict cigarette smoking in these areas. This was implemented to protect the people around them from the second hand smoke. It is a known fact that people in close proximity of people using cannibas can actually show levels of cannibas in there system. For some people this may jeopardize there job if they have zero tolerance levels for employment. Also this could become Ea health and safety issue for employees of these establishments.. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 9:25 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Align with tobacco, Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI have no objection to people using cannabis at public events if it is in edible form, but I do object If It is being smoked or vaped. It stinks, plus there are the health effects of second hand smoke (or vaping residue) to be concerned about. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 9:19 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Align with tobacco, Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) WEhy should cannabis users get special treatment? You guys made sure that smokers couldn't Esmoke anywhere at any time. I also don't want my kid to be down wind of some pothead inpublic. ESame rules should apply as tabacco. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 8:39 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) First off, I?m not sure why in today?s modern day you are still asking people to upload a word Edocument. Not not make it easier by allowing an online form? EI hope the government considers allowing business to allow the sell and consumption of cannabis products. Please also consider people with medical needs. It seems like Canada is way behind on Ethe medical and recreational in the same ecosystem. I?d like to see discounted rates at any Edispensary, this is a common practice in many places around the world. Why do medical patients need to order online, when it can be more convenient to walk into a store. Best of luck. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 8:16 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers .. Ewith more choice and convenience and a safe and reliable supply of cannabis. For more information, Eplease visit EAs part of Onta rio?s transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, i cannabis special occasion permits (SOPs). EThe government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at Ethis time nor is there a current timeframe for any additional changes that may be informed by this Efeedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward could facilitate the purchase Eand consumption of cannabis in specified social settings g. caf?s, entertainment venues festivalsE Eand events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. EThe Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the Esmoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). EThe SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. EThe SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of Eemployers and property owners. EThe government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario?s cannabis consumption rules, please visit Other Forms of Cannabis Products June 26, 2019, Health Canada published regulations for the production and sale of three new Eclasses of cannabis products: cannabis edibles cannabis products that can be consumed in the same manner as food food Eor beverage) :g Ecannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) Ecannabis topicals cannabis products that can be used on a body surface lotion) EThese new federal regulations came into force on October 17, 2019 and the new classes of cannabIs products became available for sale in Ontario on January 6, 2020. For more information on Health Canada?s rules for edibles, extracts and topicals, please visit: Other Ju risdictions this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. ESome jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption . of recreational cannabis is restricted to private residences only cannabis consumption is not 2 permitted in any public place). In thesejurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per ?condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to ?cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are ?submitting comments on behalf of an organization). (please insert contact information) ?About You or Your Organization (please check the appropriate box/boxes) Municipality Indigenous organization/community 5:11:21 Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial Cannabis Consumption Establishments/Special Occasion Permits 5 ?Taking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in :5 establishments like lounges and cafes in Ontario? Why or why not? (insert comments if necessary the box will expand as you type) Of course, this should most definitely be considered. This would only promote the proper use and consumption of cannabis among those who partake. Much like a whiskey or cigar lounge does not breed misuse this would be the same. Although rules like operating times and affiliations with ride services should also be considered. If cannabis consumption establishments were considered in Ontario, what other products should be permitted for sale in those establishments cannabis accessories, food/beverage products that Edo not contain cannabis)? (insert comments if necessary the box will expand as you type) EI feel anything that is currently sold in the OCS accessory department would be fair use in these establishments, I.e. rolling paper, pipes, etc. Ontario, the Alcohol and Gaming Commission of Ontario (AGCO) oversees the administration of Ean alcohol SOP program, which allows for the sale and service of alcohol at special occasions, including large scale events that are open to the public, such as festivals. EShould the government consider establishing a similar SOP program for cannabis to be sold and consumed at festivals and events? Why or why not? EI do not see why law abiding citizens should not be allowed to consume cannabis at festivals and event much like alcohol. This would promote the responsibility use of cannabis among attendees Einstead of it existing in a sort of grey area among event planners. If yes, what conditions should be included should alcohol consumption at the same event be restricted, should the event be age-restricted to 19+, what methods of cannabis consumption Eshould be permitted)? EI think somewhat more strict policies should exist around these events. For example, I wouldn?t want someone smoking a joint in the stand or a soccer game like alcohol is consumed around Echildren. I think event should be restricted to 19+. For more information on the current alcohol SOP program, please visit: (insert comments if necessary the box will expand as you type) EAre there any additional risks opportunities created by cannabis consumption establishments or ESOPs when compared to authorized cannabis retail stores? Cannabis Consumption Establishments: EThe risk of impaired driving is always a risk with such establishments but proper education for the Epublic is key. (insert comments if necessary the box will expand as you type) Making sure everyone is of age is important and should not be taken as loosely as alcohol. I don?t Ethink a under aged spit of wine with dinner is the same a under aged toke of a joint but that still Eshouldn?t limit the autonomy of the public during such occasions. (insert comments if necessary the box will expand as you type) EWhat should be a municipality?s involvement, if any, in a potential framework for cannabis consumption establishments or (insert comments if necessary the box will expand as you type) ESimilar to that of a whiskey or cigar lounge. We are interested in any other comments or suggestions you wish to make about cannabis consumption establishments and/or SOPs. (insert comments if necessary the box will expand as you type) EA setting for the sales of legal cannabis edibles in restaurants would be amazing for educating the public on proper use and dosing. Please submit your feedback on the Regulatory Registry by March 10, 2020 Privacy Statement Please note that unless requested and agreed otherwise by the Ministry of the Attorney General all materials or comments received from organizations in response to this consultation will be Econsidered public information and may be used and disclosed by the ministry to assist the ministry in developing potential amendments to the cannabis framework. This may involve disclosing materials or comments, or summaries of them, to other interested parties during and after the request for public comment process. individual who provides materials or comments and who indicates an affiliation with an Eorganization will be considered to have submitted those comments or materials on behalf of the Eorganization so identified. Materials or comments received from individuals who do not indicate an Eaffiliation with an organization will not be considered public information unless expressly stated otherwise by the individual. However, materials or comments from individuals may be used and Edisclosed by the ministry to assist in developing potential amendments. Personal information of those who do not specify an organizational affiliation, such as an individual's name and contact details, will not be disclosed by the ministry without the individual?s consent unless required by law. If you have any questions about the collection of this information, please contact the Legalization of Cannabis Branch at cannabis@ontario.ca. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 8:09 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EAbsolutely agree with cafes etc but the government needs to ORDER the municipalities about the rules of Ontario offers to open more dispensaries and now they are considering opening Ecaf?s, where do they expect to get this Cannabis From? When citizens are allowed to get these imposed.? 90% of initial businesses are going out of business because they went in too fast Eand too hard and the people that are trying to go in with a practical mindset, are being shut down Eafter they?ve already spent millions of dollars. The provincial/federal government needs to get .. Einvolved in this Not only that, people are losing their life savings because the municipalities are not consistent with their rulings and all shut down, after being told that they were allowed to build. Stop it with the moratoriums already, cannabis is legal now Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 7:42 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI think this is a logical step forward for the industry and province. Greater access will help reduce black market reliance. It will also generate more tax revenue Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 7:06 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI think that opening coffee like shop for cannabis consumption and for buying things like in EAmsterdam would be benificial for the governement, help people to consume legaly in a safe place Eand help to remove buying opportunity for criminal organisation. EAnd I would love to open, one day, this kind of shop! THANK Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 6:57 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) my humble opinion the government should immediately allow municipalities to opt back in as easily as they opted out. It would be better if the province, in the interests of public safety and to reduce the blackmarket, immediately disallowed municipalities from banning cannabis sales within Etheir borders. Cannabis is being consumed regardless and any type of prohibition has been shown to be bad public policy. EAs for lounges or sites of public consumption cafes, adult arcades or dance venues/ clubs should Eabsolutely be allowed to sell and allow cannabis consumption on premises no different that alcohol. EAfter all, alcohol has been shown and proven to make people violent and dangerous while the same cannot be said for cannabis. Public consumption such as at beer tents or festivals has always needed to be a police catered event because of the depressant effects of alcohol on the human brain. Yet, the last 6 420 events have never needed police presence to be enjoyed peacefully and respectfully. Allowing public consumption will be a win win for the municipalities, and surrounding businesses as cannabis users have never shown themselves to be disrespectful of authorities, the rule of property and nothing but avid consumers of food products. Restaurants and attractions near consumption locations wouldE see multiple benefits one if which would be increased business. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 6:47 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) . Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 6:05 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EI feel cannabis should be allowed to be consumed at special events. It should be treated as alcohol is. Alcohol has been legal and is consumed in many places and has been for years. Yet people still Edrink and drive, become too intoxicated and cause disturbances requiring police interference. Please do not discriminate and think that cannabis will be worse or needs some very strict Eguidelines as compared to alcohol consumption. EThank you. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 4:56 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EThe black market must be shut down by making more choices available to consumers. People will Econtinue using the black market until 1. It is more convenient and widely accessible. 2. Vapes of tobacco and Vapes from THC should be treated with similar restrictions. 3. THC beverages and beerE EPublic should have equal access at licenced bars Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 4:45 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI support both facilitating the sale of cannabis for consumption in establishments like lounges and cafes and cannabis special occasion permits. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 4:40 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: how often and how much stores can resupply. The lottery system for store licenses and the cap on Ethe daily resupply amount are both extremely ineffective and do not make good business sense. Both have throttled sales. There is an extremely high demand for legal cannabis in Ontario. Of the two stores I know of in Toronto (Tokyo Smoke on Dundas and Yonge) and Hunny Pot (on Queen St W), there are long lines out door almost everyday. :5 By throttling the sales channels, producers are left with excess inventory (which have to be Edestroyed), consumers are left with no choice but to purchase from the black market and the Egovernment misses out on tax revenue. Nobody wins and in fact, this is economically Emalproductive. For legalization to be effective, consumers must be able to access legal products easily. They are Ewilling to pay a premium over black market products but this is not possible if: (1) there are no stores in their area and (2) what stores they may get to are constantly out of product. So, please, facilitate the opening of more stores. The sooner you do this, the sooner many producers can remain solvent. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 4:12 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Unclear, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EThe idea of a pot or smoking lounge is something that I consider to be a bad idea. If there 5 a .- Especial event involving alcohol, a licensed server is required for safety reasons including of over consumption. I don know the full effects of pot, and don know if it 5 possible to E.overconsume Hiring a licenced server to serve cannabis is a great idea, but to segregate servers Ethat don?t want to be exposed to second hand smoke from being able to be employed by an event Esuch as this is discriminatory. This subject falls in the same category as tobacco smoke. The smell lingers and possible residues can have effects as well. It?s not proven otherwise. If this was an Eoutdoor event, can it be proven that others not wanting to engage in cannabis smoking wont be Eaffected by this product? I think further studies on cannabis products needs to be made before? pot lounges? are allowed. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 3:58 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EThis is long overdue and must be implemented in a timely fashion. Legalization in Ontario has not been executed wisely, allowing the black market to flourish. If something is legalized for :5 E"recreational use" it shouldn't be treated as something so dangerous that the market is suppressed Eand the process is stagnated through excessive red tape and regulations. Most people, including medical experts, agree that while not entirely harmless, marijuana is a much safer alternative to Ealcohol, yet it remains difficult to purchase legally, and there is no place to consume it in a social setting. At the same time, the entire marijuana industry is at risk because of lack of revenue clue to EOntario's slow rollout of stores etc. We have an opportunity to lead the way, but we are dragging Eour feet. Marijuana is legal, there is no going backwards. The longer Ontario waits to open more .. stores and consumption lounges etc. the stronger the black market gets and the more the industryE Esuffers. No one wins. Already, cannabis companies are laying off employees in an industry that Eshould be thriving and creating jobs. Opening up this market will serve to weaken the black market Ebring in revenue, and allow a new industry to thrive, creating jobs and wealth for Ontarians. EEnough of sitting on our hands, get Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 3:57 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) There, Please consider this email as my support for the opening of Cannabis Cafes. Cannabis Cafes are a aEn incredible business opportunity that would immediately inject revenues into the economy. EImagine not having Bars for alcohol - how much revenue, jobs, and good times would never have been had? It makes complete sense to have cafes as it also encourages the separation of Cannabis Eand Alcohol. Cannabis consumers will seek out cafes that may not have been the types to go to a bar in the past. For example I don't drink and I hate bars. But I smoke cannabis like a Woody Nelson branded Chimney and would support the hell out of any Cannabis Cafe. Don't turn down what is a clearly great idea to inject revenue and jobs into the economy. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 3:39 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) NO NO NO NO NO. The smell of cannabis smoke is as bad as cigarette smoke. I personally am .. Eallergic to the smoke and despise the smell of it as it is a total irritant and headache maker for me. Festivals have kids and families and cannabis smoking should not be allowed. If smoking cigarettes Ein parks, beaches, businesses, at work, arenas, etc are not allowed the same should go for cannabis. You can't smoke in an alcohol bar so cannabis should not be allowed either. It is difficult Eenough working in the customer service industry and smelling a customer come in with the smell of cannabis on them. As far as cannabis as the fumes will escape and many will be walking out smelling of cannabis and not to mention end up driving home like that. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 3:21 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 3:05 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Cannabis lounges and permits for special events should absolutely be sanctioned for. Cannabis Ecreates demonstrably less societal harm than alcohol and should be treated as such. To do otherwise would be hypocrisy and would make one wonder about the relationship the alcohol industry has with our provincial government. Simply put, if there are public spaces to consume . Ealcohol, then there should be public spaces to consume cannabis. This should not be complicated orE Erequire a long and drawn out legislative process. Create legislation that permits cannabis lounges Eand permits cannabis use for special events. EMoreover, cannabis has proven medicinal uses and benefits. Allowing patients to come together andE consume and share their medicine creates a positive environment for healing and promoting good health. The social stigma these medical marijuana patients face could also be reduced by the Eavailability of socially acceptable places to consume cannabis. The government should be doing it's part to reduce this stigma and produce a safe environment for cannabis consumption. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 2:49 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI am extremely opposed to allowing marijuana to be smoked in parks, at festivals, in fact Eanywhere. In particular, not in the workplace. We have worked over the years to provide smoke- free environments. This is most definitely a step backward! I sincerely hope Ontario does not take Ethis backward step. ESincerely EBev Campbell Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 2:31 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EAlthough Ontario is the largest province in Canada we somehow have fallen behind in sales compared to a smaller province like Alberta. Their open market method has proven to take money anay from the black market, creative lucrative jobs and enhance user experience. It is frustrating in Ontario where users are driven to the black market clue to lack of accessibility. Entrepreneurs are not rewarded for the risk they take on. I hope this committee uses this opportunity to make the right decision in opening up the floor for business owners to create something where consumers can enjoy the experience. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 2:24 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EOntario should implement cannabis consumption sites like lounges or cafes as well as approve permits for use at events and festivals. . Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 2:10 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EThe black market continues to use cannabis to fund illegal activities and cause crime in our neighborhoods. The licensed producers are going bankrupt because of Ontario's rollout and the factE Ethey can only wholesale to the OCS who then marksup the product costs above the black market. I aEm all for these changes and insist Ontario give our producers the tools they need to fight the illegal market and make our neighborhoods safer. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 1:40 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI think in order to create a hospitality industry around One similar to the alcohol Eindustry. We need to allow a place for vaping cannabis and serving food or edibles, it would create a lot of Ejobs and a public consumption site would keep it out of the streets and take in a lot of tax dollars. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 1:29 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: If cannibis is legal then the govt should be responsible to the constituents to provide a safe and legal lounge for consumption just as alcohol is managed. Not necessarily in the same location but perhaps in the same manner as the European model as cannibis cafes and bars are separate Eentities. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 1:13 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EYes, cannabis lounges, special permits, and venues should become legal. Make it a true free market and collect taxes on sales or its all going to fail. Let anybody and everybody legally sell cannabis. Any amount over 3grams can be taxed. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 1:07 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Cannabis lounges and cafes would promote lung disease and other illnesses among patrons and establishment staff. This will increase health costs and may give rise to law suits against the EOntario government. We have reduced lung cancer in the workplace for smokers and non smokers from tobacco through legislation. We do not want to increase tobacco consumption. Why should we encourage cannabis consumption. ESpecial purpose events would also put us at risk from second hand smoke. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 12:49 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 12:29 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI don?t believe cannabis should be allowed in any indoor facility or outdoor festivals/concerts. Cannabis smoke contains many of the same cancer-causing substances as tobacco smoke. EAnywhere tobacco is not allowed, cannabis should not be allowed. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 12:08 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashlex (MAG) From: 521(1) Sent: February 11, 2020 11:48 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Feedback re cannabis cafe and festival Categories: Anti Smoking/Vaping Lounges, Individual submission I strongly believe no one should be placed in a position to be exposed to second hand smoke of any kind in any public location. Cannabis should not be an exception. When people smoke cannabis or affects everyone around them. If you feel strongly about cannabis in public locations, it should be edible to protect the rights of others around them. It took a long time to ban smoking in public spaces, don't reverse our health progress with cannabis smoke. Sent from my Bell Samsung device over Canada's largest network. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 12:00 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 11:54 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI propose that a system of cannabis clubs similar to Spain in some ways is put into place. These Eclubs set up in spaces with ventilation and sell yearly or daily passes to be a club member for a reasonable fee to help cover expenses. The Cubs also allow smoking and vaping in them which provides a venue and also a community for those interested in cannabis culture not just consumption. The clubs could sell cannabis products ideally but can run selling accessories and Esnack products to. EThank you for considering my proposal and have a wonderful day. Benjamin Jennings Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 11:36 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Anti Licensed Est, Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: Andrea Fechner 521(1) Email: andreafechner@roqers.com Private cafes? Yes. Public festivals? No. Just like I don't want to smell cigarette smoke in public places, I don't want to smell cannabis either. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 11:31 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Unless it's a pot festival, there should be no change to our current laws on smoking. EShame on you for even considering this! Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 10:22 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) establishment of Cannabis Caf?s. As recreational and medical marijuana become more propagated Ethroughout canadian cities and small towns, I think social settings should adapt to this, as Cannabis ECaf?s are already a legal operation in places like Portland, OR. In my experience I have been to a Efestival-type setting recently and having legal permission to bring marijuana onto the festival Egrounds was easily respectable and enhanced my experience. Controlled smoking spaces and respect of others and the drug itself should be taken as a high priority. Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 10:10 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Pro Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like 5, your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 8:57 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis SpeCIal Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI?ve seen the affects marijuana has on families. Kids are being exposed at too young of an age. Please keep drugs out of the public. Drugs are trashy, and can be dangerous or fatal. I don?t want my kids to see people enjoying being stoned. Which parent dreams of their kids growing up to be Estoners? Like it or not, you?re paving the way for a screwed up, and unhealthy future. Cafes, and event permits, etc are a horrible idea. Stop now before it becomes uncontrollable. Canada is capitalizing on addictions. Sickening. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 8:21 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI am against any changes that would subject the general pubic to health risks. It has taken decades to eliminate smoking in public areas, restaurants, music venues, etc why would the Government reverse that. It is a health issue. I have COPD and do not want to be a burden to the health care system by being exposed to harmful pot smoke. EAs long as cheap 'smokes' can be purchased on reserves, the Gov't will never curtail the black market. Retain the present 'Smoke-Free Ontario Act, 2017'. ESmoking and vaping cannabis are prohibited in indoor public places and other designated areas under the Smoke-Free Ontario Act, 2017. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 8:18 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Categories: Anti Smoking/Vaping Lounges, Anti Licensed Est, Individual submission ETitle' Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI disagree with this proposal. I was a teenager in the '60's. My generation is no stranger to drugs. But many I know are against this proposal. Iwish pot had not been legalized. Trudeau did this strictly for votes. The pot of today stinks. I walk at night with my wife and if someone is growing it in their yards or smoking it in their yards you can smell the stink in the street. It is offensive. It's Enot like drinking a beer. If you go fir lunch and drink a beer you can be productive in the afternoon Eat work. If you smoke pot at lunch you are not much good in the afternoon. I see people smoking everywhere in public. You can't do this with alcohol. Trudeau did not think this through. He has Ecreated a monster. It needs to be controlled like it is in Amsterdam. Only sections if the city are .. Eapproved for smoking. If you don't like it then you avoid that section of the city. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 8:02 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ii your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EI have always thought that a nice cigar lounge would be a good idea. Cigar smoking is completely Edifferent from smoking cigarettes but the anti smokers have chosen to lump them together in the Esmoking venue ban. Now you want to set up venues for smoking marijuana. Works for me if I can Ego there and smoke my cigar. Other wise this is utter nonsense. What idiot is pushing for this? . Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 8:01 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 7:43 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Anti Smoking/Vaping Lounges, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) How can we allow people to smoke marijuana in these establishments but not allow cigarette Esmoking in the same facility? I am not a cigarette smoker but I think we are moving backwards in Eour attempts to reduce ?smoking? related illnesses. If you move forward only allow edibles and ??drinks no smoking. . Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: February 11, 2020 7:08 AM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Follow Up Flag: Follow up Flag Status: Completed Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like 5; your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for 5 consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Cannabis lounges and cafe is great idea. About time. Ontario Legalization of Cannabis Secretariat Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Oocasion Permits Date: February 10, 2020 12:28: 13 PM Attachments: Requlatorv Registry Feedback Fonn.docx Potential for Cannabis Consumption Establishments and/0r Cannabis Special Occasion Permits As part of Ontario's transition to an open market, the government . would like your feedback on the potential implementation of . . additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) Excellent idea. I believe Cannabis is a wonderful alternative to alcohol with less health and societal risks. Allowing for legal adult use at Lounges and similar locations provides an alternative Et0 bars for those looking to socialize and unwind. With less risk of aggressive/ Eviolent behaviour. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization Citizen of Ontario Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region 3. Greater Toronto rea . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEECEI: (insert comments if necessary the box will expand as you type) Yes, this provides a wonderful adult recreational alternative to bars and alcohol. With less risk of aggressive/ violent behaviour. Cannabis lounges have been and continue to operate illegally in this province. With cannabis now legal for recreational consumption see no reason why lounges should not be legitimized, regulated and taxed as bars are. (insert comments if necessary the box will expand as you type) accessories, merchandise (clothing, etc.), cannabis accessories food beverage. No alcohol. (insert comments if necessary the box will expand as you type) Yes, smoking, vaping, edibles Cannabis Consumption Establishments: no SOPs: no None. Just set rules at the provincial level and allow for free enterpn'se/ entrepreneurialism. (insert comments if necessary the box will expand as you type) Martin, Ashlex (MAG) From: Reg back, (MEDJCT) Sent: March 5, 2020 10:51 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Attachments: Regulatory Registry Feedback Form.docx Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like :3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) EThe people need access to legal, safe cannabis that has been grown according to Health Canada's strict regulations. Can we please eradicate the black market once and for all REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other Citizen_ Region (please refer to map and check appropriate box) 1. Central Ontario 2. Eastern Ontario 3. Greater Toronto Area 4. Northern Ontario 5. Southeastern Ontario 6. Southwestern Ontario 7. Western Ontario 8. Provincial be treated as such. 100% yes it is time cannabis be treated like alcohol and not demonized. lt is legal and sgoukd desserts etc. Whatever the owner Wishes to sell and the customers are Willing to buy. Food, drinks, cannabis Yes 19+ event and treat it like alcohol let adults be adults. Cannabis Consumption Establishments The same risks associated with alcohol and when done properly there are no issues. 19+ and responsible consumption and responsible owners dispensing and selling the product SOPs: I do not believe there are alcohol has been treated like this for years and its time cannabis be treated the same The exact same involvement they have With alcohol consumption Give people the freedom to enjoy a legal substance in a nice atmosphere with other responsible people. Give the legal market a fighting chance to survive and finally eradicate the black market once and for all. More locations and more ways to consume quality safe legal cannabis that?s grown according to health Canada?s rules and regulations. People have been smoking cannabis forever whether it was legal or not give people access to safe quality cannabis and the only way to do that is to treat it like alcohol, have legal cannabis available in way more locations and establishments. Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 13, 2020 10:39 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Attachments: Regulatory Registry Feedback Form _Mike_DeHaan_20200211_.doc Follow Up Flag: Follow up Flag Status: Flagged Categories: Unclear, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like is your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: 521(1) My concerns regard the effects of smoke or vapour on the staff at such lounges. Although the form .. Estates that it "is not considering changes to the SFOA regime as part of this consultation", I want to register my concerns in case that changes. My premise is that a work shift could be 8 hours or so. 1/ Smoking or vaping may release carcinogens into the air in the lounge. Staff would be exposed for several hours/day and several days/week. This may lead to cancer. 2/ Smoking or vaping may release THC into the air in the lounge. Staff would be exposed for several hours/day. Staff may get a "contact high", posing a health and safety risk, especially in the case of an emergency such as a fire. l5 EA quick web search found an article (US gov't, so it may be biased against cannabis) Ewhich speaks directly to my concerns about second-hand marijuana smoke. More details are in the attached Word document. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 20annabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. PAGE DBD For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: ocannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) ocannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) ocannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) IDAbout You or Your Organization DAbout You or Your Organization About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other Private individual 521(1) PAGE DBD IURegion URegion Region (please refer to map and check appropriate box) U1. Central Ontario U2. Eastern Ontario U3. Greater Toronto Area U4. Northern Ontario U5. Southeastern Ontario U6. Southwestern Ontario U7. Western Ontario U8. ProvinciaID DIUCannabis Consumption Establishments/Special Occasion PermitsU UTaking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not?U DIUCannabis Consumption Establishments/Special Occasion PermitsU UTaking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not?U IUCannabis Consumption Establishments/Special Occasion PermitsUUTaking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not?U UCannabis Consumption Establishments/Special Occasion PermitsUUTaking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not?D Cannabis Consumption Establishments/Special Occasion into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not?D DTaking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not?D 1 .Taking into consideration the places of use rules for cannabis under the SFOA, 2017 (as outlined on page 1), should the government consider facilitating the sale of cannabis for consumption in establishments like lounges and cafes in Ontario? Why or why not?D (insert comments if necessary the box will expand as you type) have no particular concern with edibles or potables. have 2 concerns with smoking or vaping which page 1 says is not under consideration. Regardless, ifsmoking or vaping were permitted: 1/ Concern for the staff. "Second-hand smoke from any source may be a carcinogen". Staff are in the confined space for their whole shift. 2/ Concern for staff and customers. Staff would be exposed to some level of airborne THC throughout their shift. This may lead to some degree of impairment. A somewhat-impaired staff person might not recognize a problem, such as a client's heart attack; or might not respond quickly and effectively to, say, a fire. PAGE DBD A quick web search found an article (US gov't, so it may be biased against cannabis) which speaks directly to my concerns about second-hand marijuana smoke. DD 1.lf cannabis consumption establishments were considered in Ontario, what other products should be permitted for sale in those establishments cannabis accessories, food/beverage products that do not contain cannabis)? DD (insert comments if necessary the box will expand as you type) I express no opinion other than on smoking or vaping. Din Ontario, the Alcohol and Gaming Commission of Ontario (AGCO) oversees the administration of an alcohol SOP program, which allows for the sale and service of alcohol at special occasions, including large scale events that are open to the public, such as festivals. Din Ontario, the Alcohol and Gaming Commission of Ontario (AGCO) oversees the administration of an alcohol SOP program, which allows for the sale and service of alcohol at special occasions, including large scale events that are open to the public, such as festivals. 1.ln Ontario, the Alcohol and Gaming Commission of Ontario (AGCO) oversees the administration of an alcohol SOP program, which allows for the sale and service of alcohol at special occasions, including large scale events that are open to the public, such as festivals. Should the government consider establishing a similar SOP program for cannabis to be sold and consumed at festivals and events? Why or why not? If yes, what conditions should be included should alcohol consumption at the same event be restricted, should the event be age-restricted to 19+, what methods of cannabis consumption should be permitted)? For more information on the current alcohol SOP program, please visit: (insert comments if necessary the box will expand as you type) I express no opinion other than on smoking or vaping. DAre there any additional risks I opportunities created by cannabis consumption establishments or SOPs when compared to authorized cannabis retail stores? DCannabis Consumption Establishments: PAGE DBD DAre there any additional risks I opportunities created by cannabis consumption establishments or SOPs when compared to authorized cannabis retail stores? DCannabis Consumption Establishments: 1 .Are there any additional risks I opportunities created by cannabis consumption establishments or SOPs when compared to authorized cannabis retail stores? DCannabis Consumption Establishments: DCannabis Consumption Establishments: Cannabis Consumption Establishments: (insert comments if necessary the box will expand as you type) I express no opinion other than on smoking or vaping. SOPs: (insert comments if necessary the box will expand as you type) I express no opinion other than on smoking or vaping. 1.What should be a municipality?s involvement, if any, in a potential framework for cannabis consumption establishments or (insert comments if necessary the box will expand as you type) I express no opinion other than on smoking or vaping. are interested in any other comments or suggestions you wish to make about cannabis consumption establishments and/or are interested in any other comments or suggestions you wish to make about cannabis consumption establishments and/or We are interested in any other comments or suggestions you wish to make about cannabis consumption establishments and/or (insert comments if necessary the box will expand as you type) I express no opinion other than on smoking or vaping. Please submit your feedback on the Regulatory Registry by March 10, 2020 Privacy Statement Please note that unless requested and agreed othenivise by the Ministry of the Attorney General, all materials or comments received from organizations in response to this consultation will be considered public information and may be used and disclosed by the ministry to assist the ministry in developing potential amendments to the cannabis framework. This may involve disclosing materials or comments, or summaries of them, to other interested parties during and after the request for public comment process. An individual who provides materials or comments and who indicates an af?liation with an organization will be considered to have submitted those comments or materials on behalf of the organization so identi?ed. Materials or comments received from individuals who do not indicate an af?liation with an organization will not be considered public information unless expressly stated othenivise by the individual. However, materials or comments from individuals may be used and disclosed by the ministry to assist in developing potential amendments. PAGE DBD Personal information of those who do not specify an organizational af?liation, such as an individual's name and contact details, will not be disclosed by the ministry without the individual's consent unless required by law. If you have any questions about the collection of this information, please contact the Legalization of Cannabis Branch at ID Martin, Ashley (MAG) From: Reg back, (MEDJCT) Sent: February 12, 2020 4:57 PM To: Ontario Legalization of Cannabis Secretariat (MAG) Subject: Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Attachments: Regulatory Registry Feedback Form.docx Follow Up Flag: Follow up Flag Status: Flagged Categories: Pro Licensed Est, Individual submission Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits Title: As part of Ontario's transition to an open market, the government would like ,3 your feedback on the potential implementation of additional cannabis business Description: opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and caf?s (cannabis consumption establishments); and, 2. cannabis special occasion permits. Comments Due: 10/03/20 Contact: EI believe that with Public Health as part of the mandate for legalization, cannabis consumption Espaces would help provide a space for safe consumption, overdose prevention, an extra checkpoint for driving under the influence, and consumer education. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other Region (please refer to map and check appropriate box) . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial CECEECEI: If the mandate for legalization is public health, then I believe that allowing consumption lounges or cafes gives consumers a safe place to experience cannabis. I believe there are multiple reasons why a person would need a space like this: 1. If they don't feel comfortable consuming at home, whether they have children they don't want to consume in front of, or other people who are uncomfortable with it in their home 2. If a person is new to cannabis, consuming in a space where you know someone can watch over you while you are intoxicated or experiencing something new. In the case of edibles, many people have had bad experiences because it is new or they've had too much. A place where staff are able to manage minor overdoses or simply allow someone to feel safe is in the best interest of the public. 3. Since you cannot open a cannabis package in the store, consumers who are having difficulty with the child proof packaging or not sure what to do with a product can come to a place to learn about consumption and usage 4. If users are consuming, consumption sites would also provide an extra level of security against driving under the influence Cannabis accessories Infused food/beverage, topicals, oils Non-infused food and beverage Cannabis flower Yes with the restriction of 19+ events, separated alcohol and cannabis locations with identification for each SOP site. Consumption sites should be open to smoking, vaping, edibles, unless it violates the SFOA. Cannabis Consumption Establishments: I think there is an additional opportunity for service education and overdose prevention through education. Similar to Cansell for budtenders, I think a SmartServe equivalent for cannabis consumption would be necessary. SOPs: Provide a better smoke free experience at events. (insert comments if necessary the box will expand as you type) The same level of involvement that they have for alcohol consumption sites (bars, restaurants etc) and SOPs. I believe that with Public Health as part of the mandate for legalization, cannabis consumption spaces would help provide a space for safe consumption, overdose prevention, an extra checkpoint for driving under the influence, and consumer education. 2 n. . ?Mr. 3/{"5137 SOP-S If}? We {arr -JE ?in 5532? 4.). ,5 ?1 J. 5? . l. .?:251.?25. :Ij'i 32' 153.5- L5 .. 5'51-55:! '17 I . '55- i? C5 459?(fo 41.42.. 4 u. .-. 'ni.rvuz I k! x, .5 5'5. a n5}! 5. - 5 v.41). 4255.5 "a .uw 553:54: +55% 5: .k OFF?P?w . :33If? .17 ?fth;- 5 Li?. ., 5? 1. 2 Cannabis Consumptioni establishments andxor Cannabis establishments or We are interested in 555m make-3mm Wh?t??duld'??a municipality invalvement,? ?aw, in uu - 52": I .I. I. . 5 5?5} 1/593" 57?- ..-. 1 :4 574555 51.. .- . . a: Qannabis Con-isumption Establishments I REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). (please insert contact information) 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Educator Law enforcement Municipality Indigenous organization/community Other: Citizen, parent, person who cares about Ontario box) Region (please refer to map and check appropriate . Central Ontario . Eastern Ontario . Greater Toronto Area . Northern Ontario . Southeastern Ontario . Southwestern Ontario . Western Ontario . Provincial I am concerned for the health of the staff. While a smoking caf? might attract some tourists and residents, the health of the employees will be compromised. There's no getting around that. And, its tax payer dollars that will be spent on their lung cancer treatments. (insert comments if necessary the box will expand as you type) Absolutely! It provides revenue for the province and enable a consistent standard for health and safety. The rules should be similar to those for alcohol, and the age should be restricted. Cannabis Consumption Establishments: (insert comments if necessary the box will expand as you type) SOPs: (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) (insert comments if necessary the box will expand as you type) REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. 521(1) Looking for a way to setup this business. Imagine like ubrew for beer and wine but for Cannabis Concentrates Customers bring in their Sealed Legal Marijuana Flower 2. Customer Use Non Solvent based extraction with the assistance of staff( rosin,c02, dry ice hash) Classes andlor appointments andlor drop in 3. Customer leave establishment with concentrate from legal purchased flower 4. Ideally the customers could also be able to consume said concentrate is a lounge like setting. Only legal product would be allowed on premises strictly enforced) 5. This will also bring the price of concentrates lower to below cost of the black market. Thus helping eliminate the Black market sales. About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other - Business start-up Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario 3. Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial Yes, in vape form, not smoking. Marijuana is a social activity, it does not make you reckless but rather changes your perspective. Having the ability to vape in a controlled area would be nice. Edibles are not advisable as the effects are not set in for hours therefore you don?t have the ability to see if individual is overserved. look again to my upress rosin press establishment Being able to use expensive equipment to press ?ower into concentrate and use simple lab equipment to filter out contaminants( waxes, lipids) would be advisable. The ability to sell simple non solvent based extraction machine would also be available. On site testing and the ability to consume would also be a bonus. lf lounge is available. Snacks and drinks healthy and junk food) too Outdoor venues should have consumption areas like beer gardens. Cannabis Consumption Establishments. Serving it right - edilbles should not be sold as the risk of a server not knowing how much is consumed adds to liability. Self sobriety testing should also be available. SOPs: (insert comments if necessary the box will expand as you type) No, look at Oakville, our residents are held hostage due to a antiquated mayor and council. This has a negative impact on the community as people now have to drive to Burlington to purchase product. We would have more drug impaired driving. Best to have local consumption venues that have good walkable scores to high population hubs. wish to have a way for the average person to enjoy concentrates without the heavy burden of setting up and storing expensive processing equipment The lure of using cheap BHO solutions at of is dangerous. And illegal in Canada at home as this is flammable and highly dangerous. There is a safer way through heat and pressure to make concentrates called Rosin Press. This is done in roughly 90 seconds with flower squished between 2 plates at 190 at 4-5 tonnes of pressure. The process is simple, but the gear is large, hard to ship, and takes up a lot of room. Not to mention there is good technique to get a good product.. would like to setup a store front where people citizens/tourists can come and press their legally purchased flower into concentrate having the ability to consume would be a bonus lt would be setup as drop in and appointment based business. Also we would have the ability to have classes like where groups can learn this safe process and potentially buy equipment for home use. This is going on already with black market classes in the back of hydro shops and black market sellers of marijuana. want this to stop. want to promote the legal market personallyl have never purchased black market Marijuana ever and feel legalization is a gift to legitimize this business) am a business major work in Tech Sector and have never been involved in any criminal activity. can ensure that safe methods are used to make concentrate no Flammable BHO extraction can ensure people are of legal age to make concentrates can ensure no one person has over 30g of legal Manjuana Flower can ensure only sealed legal Marijuana is used and record excise tax stamp numbers. can ensure no product is stored on premises People are doing this already but in violation of the law. want to legitimize this business. Please help me make upress. ca a reality REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. REGULATORY REGISTRY FEEDBACK FORM Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits On December 12, 2019, the government announced that it is taking steps to move to an open market for retail cannabis sales in Ontario, as it originally intended. This will provide consumers with more choice and convenience and a safe and reliable supply of cannabis. For more information, please visit retail-market.html. As part of Ontario's transition to an open market, the government would like your feedback on the potential implementation of additional cannabis business opportunities in the future, including: 1. facilitating the sale of cannabis for consumption in establishments like lounges and cafes (cannabis consumption establishments); and, 2. cannabis special occasion permits (SOPs). The government is collecting feedback at this time to inform potential decisions about opportunities in an open cannabis market in the future. No changes to the cannabis framework are expected at this time nor is there a current timeframe for any additional changes that may be informed by this feedback. Cannabis Consumption Establishments and Special Occasion Permits Cannabis consumption establishments and SOPs, if brought forward, could facilitate the purchase and consumption of cannabis in specified social settings (eg. caf?s, entertainment venues, festivals and events). Cannabis Consumption Rules Cannabis can be smoked or vaped in many outdoor public places and in private residences. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) and the regulations under that Act prohibit the smoking of cannabis and the use of electronic cigarettes (e-cigarettes) to vape any substance (including cannabis) in enclosed workplaces and enclosed public places, as well as other prescribed places restaurant and bar patios or within nine metres of these patios). The SFOA, 2017 also prohibits drivers and passengers from consuming any form of cannabis (smoking, vaping, eating) in vehicles and boats that are being driven or will be driven, subject to certain exceptions. The SFOA, 2017 is not the only source of smoking and vaping restrictions in Ontario. Additional restrictions on cannabis consumption may be found in municipal bylaws and the policies of employers and property owners. The government is not considering changes to the SFOA regime as part of this consultation. For more information on Ontario's cannabis consumption rules, please visit Other Forms of Cannabis Products On June 26, 2019, Health Canada published regulations for the production and sale of three new classes of cannabis products: 0 cannabis edibles cannabis products that can be consumed in the same manner as food food or beverage) cannabis extracts cannabis products that are produced using extraction processing methods or by phytocannabinoids oils, capsules, hash, wax) cannabis topicals cannabis products that can be used on a body surface lotion) These new federal regulations came into force on October 17, 2019 and the new classes of cannabis products became available for sale in Ontario on January 6, 2020. For more information on Health Canada's rules for edibles, extracts and topicals, please visit: Other Jurisdictions At this time, no other Canadian jurisdiction has implemented a framework for cannabis consumption establishments, like lounges or cafes, or SOPs. Some jurisdictions in the United States that have legalized recreational cannabis have allowed regulated cannabis consumption establishments and SOPs where individuals are permitted to consume recreational cannabis. However, it should be noted that in those states, the consumption of recreational cannabis is restricted to private residences only cannabis consumption is not permitted in any public place). In these jurisdictions, cannabis consumption establishments/SOPs might assist in mitigating certain equity issues in a more restrictive consumption rules framework tourism, individuals who are not permitted to consume cannabis in their private residence per condominium/building policies). Instructions Please provide your feedback to the questions below on this form and submit to cannabis@ontario.ca. The closing date for providing feedback is March 10, 2020. Contact Information Please provide your name, title and the full name and address of your organization (if you are submitting comments on behalf of an organization). 521(1) About You or Your Organization (please check the appropriate box/boxes) Health organization Municipality Educator Indigenous organization/community Law enforcement Other _retired scientist_ Region (please refer to map and check appropriate box) LI 1. Central Ontario LI 2. Eastern Ontario 3. Greater Toronto Area LI 4. Northern Ontario LI 5. Southeastern Ontario LI 6. Southwestern Ontario LI 7. Western Ontario LI 8. Provincial NO. Most of us do NOT consume cannabis, or if we do, this is done privately where it will not affect others in the environment. Second hand smoke is not only harmful but also very unpleasant, especially if one is trying to enjoy a meal. Permitting open consumption in lounges and cafes sets an example to children and youth, as being the ?norm? i. e. self medication is acceptable and easily accessible. have been involved first hand with the devastating results of addiction and cannot support a government that openly allows and indeed profits from sales of these products. We have enough on our hand with the massive costs of alcohol and tobacco addiction, without adding more substances. Where do we stop are we to allow all ?recreational? drugs to allow ?safe users?? There is no question that alcohol consumption, also allowed in licensed premises, can also have extremely harmful effects; however, consumption of a glass of wine at a table has no direct ?second hand? effect? on the neighbouring people and the bar/restaurant has the right to refuse to serve inebriated customer. Alcohol, however, is not being debated here as the question relates to cannabis. lt is impossible to separate smoke-free vs smoke-permitted areas both tobacco and cannabis fumes permeate establishments and result in a low-level odour and irritant to all of us. do not support the sale of any cannabis related products in these establishments. We have enough problems as it is With the legacy drugs (tobacco and alcohol). lt is ironic that the government openly allows and indeed profits from sales of these products (and cannabis) and at the same time, is involved in addiction treatment. No, for the reasons stated above Cannabis Consumption Establishments. really cannot comment the government is anxious to promote this usage to please a small percentage of the population and garner their votes); the long term effects of this Will take a While to manifest SOPs: (insert comments if necessary the box will expand as you type) They should be allowed autonomy in this decision. 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