Washington Cannabis Institute | I 502 Training for Washington
I 502 Draft Rules

Here are some of the highlights of the I 502 draft rules:

I 502 implementation

LCB Marijuana Licensing and Regulation Manager, Becky Smith and Washington Cannabis Institute president, George Boyadjian

The Washington Liquor Control Board released I 502 draft rules on May 16, 2013.  As LCB licensing director Alan Rathburn noted in our last seminar, we will have 30 days to submit any ideas for changes to rules@liq.wa.gov.   In mid June, they are expected to formally file the guidelines for I 502.  The regulatory timeline will would end by later in August. LCB hopes that the rules will start being implemented at that time. LCB told us that this trial period is the time to make any changes and they are urging the public to submit ideas for any changes. They want to hear about the solutions that we can come up with for the problems that we might be facing.

Here are only some basic areas of importance, as we see it, in the draft rules:

I 502 Draft Rules License Requirements Highlights

Background Checks

  • Personal criminal history form with license forfeiture if incomplete or incorrect
  • Fingerprinting of all potential licensees
  • WSP and FBI background checks of licensees and financiers

Point System

  • The LCB will apply a disqualifying point system similar to liquor
  • Draft rules allow exceptions for two misdemeanor convictions of possession w/in three years

Property Leases

  • License applicants must submit an affidavit signed by a potential landlord that he/she knows their property will be used for the cultivation, processing or retailing marijuana


  • License applicants must submit a signed attestation that they are current on taxes owed

I 502 Producer Structures

  • Draft rules allow producer operations in secure indoor grows or greenhouses


  • LCB will employ a robust and comprehensive traceability system (software) that will trace product from seedling to sale
  • LCB enforcement can match records to actual product on hand
  • One person or entity CANNOT own all three licenses

Point System

  • LCB will apply a disqualifying point system similar to liquor (with exceptions).

Violation Guidelines

  • $1,000 criminal penalty for sales to a minor
  • Sets strict tiered system of violation record over a three year period.


  • Group 1 public safety:
  • First violation: 10 day suspension or $2,500
  • Second violation: 30 day suspension
  • Third violation: license cancellation


  • Similar to Colorado: video camera requirements, no third party

Advertising Restrictions

  • Law restricts advertising within 1,000 feet of schools, public parks, transit centers, arcades, and other areas where children are present

Location Restrictions of Retail Stores

  • 1,000 feet from perimeter; 8 entities listed in statute
  • Advance notice to local authority
  • Board to determine number of retail outlets
  • If the number of applicants in a county exceeds the limit, the LCB will hold a lottery.
  • BOTEC determining county consumption levels. Consumption will drive retail outlets.

Consumer safety

  • Behind the counter storage
  • No containers

Strict packaging and labeling requirements

  • Serving size
  • Lot number
  • Net weight
  • Concentration of THC and five other cannabinoids
  • Usage warnings (specific warning for indigestible foods/liquids about effect delays)
  • Out of state removal warning (produced in Washington icon)

Upon request

  • Third party lab that tested lot
  • All pesticides, herbicides, fungicides found in product

Serving size

  • Defined serving sizes on label
  • 10mg of THC per serving
  • 100mg of THC per product

Store signage and product warnings

  • No minors allowed in stores
  • Required product and usage signs within stores

Potential Issues and Challenges

  • Federal uncertainty
  • Illegal at the federal level.
  • No clarity about DOJ reaction
  • Concerns expressed about controlling diversion
  • Minimizing illicit market
  • Balancing product demand with production and over-production
  • Medical marijuana competing system that is largely untaxed and unregulated
  • Banking
  • Federal banking laws prevent marijuana-related businesses
  • Taxation and pricing
  • Will it be competitive?

Remember we only have 30 days from draft issuance dates to submit any ideas. Email the LCB with your ideas for changes to rules@liq.wa.gov.

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