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DH, MMRegulations

_________________

From: Alexander Makar <info@ufcw1776.org> Wfti,2.SH W L

Sent: Wednesday, March 17, 2021 10:49 AMTo: DR MMRegulations; brodas@ufcw1776.org MAR 2 2 2021Subject [External] Public Comment in response to proposed Regulatiqn #10-219

1ndepcnd’nt RegulatoryReview Commission

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $i,ooo a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Alexander Makar

Mr. Alexander Makar6132 Noblestown RoadOakdale, PA 15071doclequack@gmail.com4128839146

2

DH, MMRegulations

From: Amanda Magerko <info@ufcw1776.org>Sent: Saturday. March 13, 2021 2:44 PMTo: Dft MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

lam submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Amanda m

Ms. Amanda Magerko10 cattelle ctwashington, Ni 07882a Imagerko@gmail.com9088352464

2

OH, MMRegulations

From: Amy Thomas <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 1:09 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and 5anctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Amy Thomas

Miss Amy Thomas50 orchard stcarbondale, PA 18407athomas34@hotmail.com5703961517

2

DH, MMRegulations

From: Attila Rigo <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 2:16 PMTo: OH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Attila Rico

Mr. Attila Rigo75 Hoffman AveCoatesville, PA 19320attila.rigo@ymail.com

2

DR, MMRegulations

From: Austin Chinnici <info@ufcwl76.org>Sent: Tuesday, March 16, 2021 11:31 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@Jpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation;

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Austin Chinnici

Mr. Austin Chinnici731 Jacques CircleChester Springs, PA 19425

Austin.chinnici@gmail.com4848811323

2

DR. MMRegutations

From: Barbara Wagner <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:44 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

I

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Babs wagner

Ms. Barbara wagner4141 Elmerton AveHbg, PA 17109wba h hers @yahoo. corn7174430100

2

DH, MMRegulations

From: Beau Schemery <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 4:40 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Beau Schemery

Mr. Beau Schemery941 Hepburn Streetwilliarnsport, PA 17701hed bonstu d los @ hotmail . corn5705067123

2

DH, MMRegulations

From: Billie Moyer <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 12:10 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Billie Moyer

Mrs. Billie Moyer30 nora stClark, PA 16113clarkboro2010@gmail.com7244560140

2

DH, MMRegulations

From: Bonnie Millard <info@ufcw1776.org>Sent Tuesday, March 16, 2021 10:35 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Bonnie Millard

Mrs. Bonnie Millard187 simpson rdMonroeton, PA 18832joe_ey@frontiernet.net6072595572

2

DH, MMRegulations

From: Bonnie Seiber <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:35 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message Is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forword the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial arlication.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Bonnie Seiber

Mrs. Bonnie Seiber477 Lumber StMiddletown, PA 17057-3236bkcbone@comcast.net

2

DR, MMRegutations

From: Brian Tibak <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:43 AMTa: OH, MMkegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from on external sender. Oo not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Brian TibakBrian Tibak

Mr. Brian Tibak806 hausman rdAllentown, PA 18104tibakb@gmail.com6103330521

2

DH, MMRegulations

From: Carl Trunk <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:59 AMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External) Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from on external sender. Do not open (inks or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@Ypa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation;

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change wfll permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,carl Trunk

Mr. Carl Trunk3031 Walton Rd.Plymouth Meeting, PA 19462

ctrunk@ufcw1776.org

2

DR, MMRegulations

From: Carla Dorsey <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:37 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Carla Dorsey

Miss Carla Dorsey6112 Locust StrPhy, PA 19139

carladorsey69@ iclo ud. corn215-7404215

2

OH, MM Regulations

From: Carload Mulvihill cinfo@ufcw1776.org>Sent: Wednesday, March 17, 2021 12:54 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links ar attachments from unknown sources. Toreport suspicious email, farward the message as an attachment to CWOPA_5PAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and 5anctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Carole Mulvihill

Mrs. Carload Mulvihill315 Poplar Rdwarminster, PA 18974

elorac3@verizon.net

2

DH, MMRegulations

From: Carlos Roman <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:10 AMTo: DH, MMRegulations; brodas@ufcwl 776orgSubject: [Externall Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health;

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Carlos Roman

Mr. Carlos Roman711 Randolph St, Apt 2Hanover, PA 17331

croman@ufcw1776.org4843627917

2

DH, MMRegulations

From: Cassandra Rosado <info@ufcw1776.org>Sent Wednesday, March 17, 2021 10:04 AMTo: DEl, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial apolication.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,cassandra rosado

Mrs. Cassandra Rosado22 elm ct.Cranberry township, PA 16066chulag9090@gmail.com7739001749

2

DH, MMRegulations

From: Charles Tyler <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:58 AMTo: DH, MMRegulations; brodas@ufcvi1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

4UENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Charles

Mr. Charles Tyler366 Parrish rdDuBois, PA 15801Cwtvler@gmail.com(814) 590-2300

2

OH, MMRegulations

From: Christina Bayer <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:19 AMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open (inks or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Since rely,christina Boyer

Mrs. Christina Boyer101 Lehman AvenueLancaster, PA 17502boyerclboyer@aol.com7173279183

2

DR, MMRegulations

From: Christopher Snyder <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 11:32AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation;

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Christopher Snyder

Mr. Christopher Snyder4640 Shuler StreetAllentown, PA 18103snyder1776@live.com

2

DR, MMRegulations

From: Cindy Kuliman <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:27 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or ottochments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,cynthia Kuliman

Ms. Cindy Kuilman7044 Birchwocd RdHARRISBURG, PA 17112ritzieturkey@hotmail.com

2

DH, MM Regulations

From: C Rider <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:10 AMTo: DH, MMRegulations; brodas@ufcwl776.orgSubject: [Externafl Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change willl permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Ci Rider

Mr. U Rider4120W Lincoln Hwy Apt 2WDowningtown, PA 19335

cj-rider@hotmail.com4846335226

2

OH, MMRegulations

From: Clifford Murray <info@ufcw1776.org>Sent: Saturday, March 13, 2021 1:28 PMTo: DEl, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Clifford Murray

Mr. Clifford Murray4738 main stWhitehall , PA 18052djpow610@icloud.com4845530446

2

DH, MMRegulations

From: Dana Copeland <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:35 AMTo: DH, MMRegulations; brodas@ufG’,l 776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkiorce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization tails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Dana Copeland

Ms. Dana Copeland627 Orchard Hill DrivePittsburgh ,PA 15238damacrcope@gmail.com

2

DH, MMRegulations

From: Daniel Volker <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:49 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Dan volker

Mr. Daniel Volker1942 crooked Oak DriveLANcASTER, PA 17601djvolker@comcast.net7179408946

2

DH, MMRegulations

From; Danielle Gumaer <info@ufcwi 776org>Sent Wednesday March 17, 2021 11:10AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Danielle Gumaer

Ms. Danielle Gumaer19 Union StPlains, PA 18705up2sumptin@hotmail.com

2

DH, MMRegulations

From: Danny Bauder <info@ufcw1776.org>Sent: Monday, March 15, 2021 4:42 PMTo: DH, MMRegulations; brodas@ufcn1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Danny Bauder

Mr. Danny Bauder633 west Rittenhouse St B1201PhiladelphIa, PA 19144dbauder@ufcw1776.org

2

DH, MMRegulations

From: David Michael <info@ulcw1776.org>Sent: Wednesday, March 17, 2021 12:15 PMTo: DH, MMRegulazions; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219; Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,David L Michael

Mr. David Michael104 maple Leaf driveBlandon, PA 19510blfrparrot@ ms n .com

2

DH, MMRegulations

From: Dennis Lesnikowski <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:50 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5P4M@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides Critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It iss critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Dennis lesnikowski

Mr. Dennis Lesnikowski315 5 broad stPhiladelphia, PA 19107den es k7 1@gma i I. corn2673203729

2

DH, MMRegulations

From: Dustin Krautter <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 2:26 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] UFCW Local 1776 Keystone State

ATrENTION: This email message Is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Thank you,Dustin

Mr. Dustin Krautter1425 S Colorado StPhiladelphia, PA 19146-4732Dustin.krautter@msn.com267-671-2926

2

DH, MMRegulations

From: Echo Gillespie <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:34 AMTo: OH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message os an ottachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Echo Gillespie

Ms. Echo Gillespie2535 Boyce PlazaPittsburgh,PA 15241echo201173@gmail.com7028825342

2

DH, MMRegulations

From: Ed Auer <info@u1cw1776org>Sent: Wednesday, March 17, 2021 9:19 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject; (Ekternal] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Ed Auer

Mr. Ed Auer214 lager drgibsonia, PA 15044ea ue r@ ufcwl776. org

2

OH, MMRegulations

From: Edward Cody Edward Cody <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:35 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely.Edward F. Cody

Mr. Edward Cody Edward Cody401 Grandview AvePerkasie, PA 19844Codyracing@hotmail.com267,315.0255

2

DR, MMRegulations

From: Fatima Baker <info@ufcwl776.org>Sent: Wednesday, March 17, 2021 9:27 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment n response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Fatima Baker

Ms. Fatima Baker129 Stratford avenuePittsburgh ,PA 15206bakerstarchick@aol.com

2

OH, MMRegulations

From: Felix Jimenez <info@ufcw1776.org>Sent: Wednesday March 17, 2021 9:25 AMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and 5anctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Felix Jimenez

Mr. Felixiimenez6128 Tackawanna StreetPhiladelphia, PA 19135

felixjimenez94@gmail.com2673337991

2

DH, MM Regulations

From: Floyd Adams <info@ufcw1776.org>Sent: Saturday, March 13, 2021 2:44 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Floyd Adams

Mr. Floyd Adams27 Walbert DrStroudshurg, PA 18360Hawthorn71@hotmail.com570-6293 624

2

PH, MMRegulations

From: George Lang <info@ufcw1776.org>Sent Wednesday, March 17, 2021 12:49 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about alt of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,George Lang

Mr. George Lang351 Academy Stcarnegie, PA 15106

georgelang1980@gmail.com4127580252

2

DH, MMRegulations

From: Gina Adams <info@ufcw1776.org>Sent Wednesday, March 17, zeal 11:06 AMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Pubhc Comment in response to proposed Regulation #10-219

AITEN77QN: This email message is from an external sender. Do not open links or ottachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Gins adams

Miss Gina Adams10190 Madison abeNorth huntingdon, PA 15642But54ch@aol.com4125543427

2

DR, MMRegulations

From: Glen Roetman <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:15 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Go not open (inks or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Eileen Roetman

Mrs. Glen Roetman144 Filly DriveNorth Wales, PA 19454

G@ufcwl77G.org2154122265

2

DR, MMRegulations

From: Gordon Murray <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 2:39 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open (inks or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Gordon Murray

Mr. Gordon Murray12 salem rdschwenksville, PA 19473gmu rrayO964@gm al .com2676805867

2

DH, MMRegulations

From: Heather Rack cinfo@ufcw1776.org>Sent Wednesday, March 17, 2021 10:22 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities tar employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Heather Rack

Ms. Heather Rack310 Shady Glen DriveCoraopolis, PA 15108Heatherlrack@gmail.com4128891985

2

OH, MMRegWations

From: Heike Lane <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:32 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATrFNTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Heike Lane

Mrs. Heike LaneP.O. Box 174Ardmore, PA 19003he i ke4da rrel@gmail. corn610-527-5085

2

OH, MMRegulations

From: Holly Bearley <info@ufcwl76.org>Sent Wednesday, March 17, 2021 3:42 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation;

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional paints for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Holly Bearley

Mrs. Holly Bearley1010 Milford St.Port Royal, PA 17082ka cies mo m98 @ya hoo. corn7173480629

2

DH, MMRegulations

From: Hope McKenzie <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 12:44 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

A7TENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Hope McKenzie

Ms. Hope McKenzie1217 Evans AveMcKeesport, PA 15132whopey15132@gmail.com4123521131

2

DH, MMRegulations

From: Howard Walker Sr <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:42 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions,

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Howard Walker Sr

Mr. Howard walker Sr2432 n. 16th StreetPhiladelphia, PA 19132qjchip@aol.com

2

OH, MMRegulations

From: Ingrid Chinnici <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 6:50 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Enforce Labor Peace Agreements Comment in response to proposed

Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Ingrid chinnici

Ms. Ingrid chinnici731 Jacques circleChester Springs, PA 19425Shortstuffs3kids@yahoo.com4844674838

2

DH, MM Regulations

From: James Bird <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:14 AMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do nat open links or ottachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,James Bird

Mr. James Bird412, Cedar AveMorton, PA 19070jimbird4l2 @gmaihcom6105514763

2

DH, MMRegulations

From: Janette Szapacs <info@ufcw1776.org>Sent: Saturday, March 13, 2021 10:07 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [Ekternalj Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Ca nat open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Janette Szapacs

Ms. Janette Szapacs615 King StStroudsburg, PA 18360

janzapl@verizon.net570-350-1462

2

DR MMRegulations

From: Janice Meeks <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:19 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [Externalj Public Comment in response to proposed Regulation #10-219

A7TENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attochment to CWQPASPAM@3pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Janice Meeks

Mrs. Janice Meeks6614 hegerman streetPhiladelphia, PA 19135janicejackson4621@gmail.com2672409335

2

DH, MMRegulations

From: Jean Gerard cinfo@ufcw1776.org>Sent: Wednesday, March 17, 2021 12:56 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the messoge as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Jean Edouard Gerard

Mr. Jean Gerard211 Academy stwilkes Barre, PA 18702Edddy35@yahoo.com901.484.2353

2

DR, MMRegulations

From: Jenine Virostek <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 12:41 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on externol sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message os an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing, Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Jenine virostek

Mrs. Jenine virostek2638 river roadVandergrift, PA 15690dolphin3805@yahoo.com7246027676

2

DH, MMRegulations

From: Jenna McDermot <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:39 AMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Since rely,Jenna mcdermot

Ms. Jenna McDermot706 evergreen avenue, Apt 1Milivale, PA 15209m cdermotjen na @gm all .com4128803952

2

DH, MMRegulations

From: Jenna Wagner <info@ufcwl76.org>Sent Wednesday, March 17, 2021 10:46 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [Externalj Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical reLief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Jenna wagner

Ms. Jenna wagner130 Willow St, 2nd floor aptDunmore, PA 18512Wagner.jenna@yahoo.coms702g01930

2

DH, MMRegulations

From: Jennifer Strong <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:33 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkiorce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Jennifer Strong

Miss Jennifer Strong1747 Eden Park BlvdMcKeesport, PA 15132JenStrong93@hotmail.com4126543713

2

DH, MMRegulations

From: Jill Weglarz <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 2:36 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [Ekternal] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the messoge as on attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Jill Weglarz

Ms. Jill Weglarz155 Conestoga RoadWayne, PA 19087sonnet25@msn.com6106870926

2

DH, MM Regulations

From: Jill Vounkin <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:27 AMTo: OH, MMRegulations; brodas@ufon1776.orgSubject: [Externall Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It iss critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Jill Vounkin

Ms. Jill Younkin10 Mowery AveJohnstown, PA 15905jillryounkin@gmail.com8145259023

2

DH, MMRegulations

From: Joanmarie Morgano <info@ufcw1776.org’Sent: Wednesday, March 17, 2021 9:25 AMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@ipa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable lobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

I

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Joanmarie Morgano

Mrs. Joanmarie Morgano322 Duff RdPittsburgh PA 15235mjgl57@comcast.net4125539403

2

DH, MMRegulations

From: John Dean <infoufcw1 776.org>Sent: Wednesday, March 17, 2021 1:43 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation;

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,John Dean

Mr. John Dean312 Bernard Dr

King of Prussia, PA 19406

De217an@yahoo.com2154317237

2

DH, MMRegulations

From: John DeLuca <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:19 AMTo: DH, MMRegulations; brodas@ufcwl 776orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_5PAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $i,ooo a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,John A DeLuca

Mr. John DeLuca248 East Main St, P0 Box 937Adamstown, PA 19501jdeluca248@gmail.com9173743642

2

DH, MM Regulations

From: John Dougherty <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:34 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,John dougherty

Mr. John Dougherty914 Tustin avePhila, PA 19111Jdougherty27@Verizon.net

2

OK, MMRegulations

From: John Tynan <info@ufcw1776.org>Sent: Saturday, March 13, 2021 7:48 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: fExtemal] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,john

Mr. John Tynan2017 Rhawn stPhila, PA 19152jtynan@ufcw1776.org215-725-0612

2

OH, MMRegulations

From: John Tynan <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:09 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gm’.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonweafth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,John Tynan

Mr. John Tynan2017 Rhawn stPhila, PA 19152jtynan@ufcw1776.org215-725-0612

2

DH, MMRegulations

From: Jon Lapinsky <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 12:00 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, ft is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and Card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,ion Lapinsky

Mr. ion Lapinsky145 clarks PikeCreighton, PA 15030jlapinsky@ufcw1776.org

2

OH, MMRegulations

From: Joseph Mielcarek <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 1:09 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or ottachments from unknown sources Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Joe mielcarek

Mr. Joseph Mielcarek224 west View AvePittsburgh, PA 15229Jvmm65@gmail.com412-760-7405

2

DH, MMRegulations

From: joseph shekmer cinfo@ufcw1776.org>Sent Wednesday, March 17, 2021 10:59 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

A7TENTION: This email message is from an external sender. Do not open links or attachments from unknown sources- Toreport suspicious email, forward the message as on attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and 5anctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation;

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Joseph M. Shekmer

Mr. Joseph shekmer156 palance avenuehazle township, PA 18202Jshekmer@gmail.com15704360862

2

DH, MMRegulations

From: Karen Reese <info@ufcw1776.org’Sent: Saturday, March 13, 2021 2:43 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Karen L Reese

Ms. Karen Reese132 Hammons LaneEast Stroudsburg, PA 18301buttercup62@msn.com57o476-1543

2

DH, MMRegulations

From: Karen Simpson <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:26 AMTo: DR MMRegulations; brodas@ufcwl76.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Karen Simpson

Ms. Karen Simpson250 Poplar Ave

Devon, PA 19333laydee414@gmail.com610-688-0506

2

DH, MM Regulations

From: Karen Somma <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 1:13 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/ar other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Karen Somma

Mrs. Karen Somma202 Rayburn LaneChalfont, PA 18914ksomma@ufcw1776.org4845350099

2

DH, MMRe9ulations

From: Katherine Salkowski <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:18 AMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Katherine Salkowski

Ms. Katherine Salkowski82 Quincy DrLevittown, PA 19057katiecharlton@comcast.net2674636599

2

DH, MMRegulations

From: Katie Sheridan <info@ufcw1776.org>Sent: Saturday, March 13, 2021 11:37 AMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do nat open links or attachments from unknawn sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gav.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Katie Sheridan

Miss Katie Sheridan2500 Swanson StEaston, PA 18045kesheridan1996@gmail.com4848960820

2

DH, MMRegulations

From: Kevin Boland <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 2:06 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Kevin Boland

Mr. Kevin Boland13 Acoma LaneCollegeville, PA 19426kevinbolandl@comcast.net6104099359

2

DH, MMRegulations

From: Keyshlanette Creamer cinfo@ufcw1776.org>Sent: Saturday, March 13, 2021 8:45 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [Externall Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief far thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Keyshlanette Creamer

Mrs. Keyshlanette creamer2045 Willow park rdBethlehem, PA 18020Creamer.keyshla@gmail.com4846357263

2

DH, MMRegulations

From: Lisa Cleary <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:51 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious emoil, forward the message os an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aflvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Lisa A Cleary

Ms. Lisa Cleary2068 E Main StDouglassville, PA 19518lac8226@gmail.com6103853966

2

DH, MMRegulations

From: Lorieanne Zoffel <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:04 AMTo: DH, MMRegulaUons: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the Way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Lorieanne Zoffel

Mrs. Lorleanne Zoffel374 Porte StreetOakmont, PA 15137loriezee@gmail.com724-393-2198

2

DH, MMRegulations

From: Lydia Malick <info@ufcw1776.org>Sent: Wednesday March 17, 2021 1:45 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links ar attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Lydia Malick

Miss Lydia Malick210 west view avepittsburgh, PA 15229Iydiamalick@yahoo.com8148811870

2

DI-!, MMRegulations

From: Macy Mcconnell <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:24 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public comment in response to proposed Regulation #10-219

A7TENTION: This email message is from an external sender. Do notopen links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Macy Mcconnell

Ms. Macy Mcconnell12 Zion church RdGrantville, PA 17028m cco n ne I lmacy@gma i I. corn8149334420

2

DH, MMRegulations

From: Margaret Smith <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:17 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWQPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a written

warning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do not

comply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Margaret Smith

Ms. Margaret Smith

417 w Wayne aveAldan, PA 19018

soxs@comcast.net2155707714

2

DH, MMRegulations

From: Margaret Smith <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:42 AMTo: DR MMRegulations; bradas@ufo.vl776.orgSubject; [Extemall Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Margaret Smith

Ms. Margaret Smith417 w wayne aveAldan, PA 19018soxs@comcast.net2155707714

2

DH, MMRegulations

From: Maria Gianoni <info@ufcw1776.org>Sent: Saturday, March 13, 2021 11:23 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AITENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Maria Gianoni

Miss Maria Gianoni9441 Perry HighwayWaterford, PA 16441mariagia169@gmail.com18148065627

2

DH, MMRegulations

From: Mark Wagner <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:18 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [Externall Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do not

comply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Mark wagner

Mr. Mark Wagner704 Sycamore RdMohnton, PA 19540msakw1003@yahoo.com6107779535

2

DH, MM Regulations

From: Markeda Cottle <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 9:53 AMTo: DR MMRegulations; brodas@ufcw1776.orgSubject [External) Public Comment in response to proposed Regulation #10-219

AITENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable lobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vil The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Markeda cattle

Ms. Markeda Cottle2004 E Huntingdon StPhiladelphia, PA 19125ma rkedacottle @gm a i I. cam2154329300

2

DH, MMRegulations

From: Mary Giordano <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 2:26 PMTo: DEl, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Mary Giordano

Mrs. Mary Giordano4345 Mitchell StreetPhiladelphia, PA 19128Charlesanthony516@gmail.com2672763955

2

DII, MMRegulations

From: Mary Owens <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:09 AMTo: DH, MMkegulations; brodas@uf1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or ottachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWQPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Mary Owens

Mrs. Mary Owens1546 windmill Rd

Warminster, PA 18974

mkowe@comcast.net2672531666

2

DH, MMRegulations

From: Matthew Ruffing <info@ufcwl76.org>Sent: Saturday, March 13, 2021 5:07 AMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aflvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change wilt permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Matthew Ruffing

Mr. Matthew Ruffing5, Heather LaneMckeesport, PA 15132matthewruffingS@icloud.com4126564102

2

DH, MM Regulations

From: Maureen Jones <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 2:37 PMTo: DR. MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWOPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements Which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Maureen Jones

Mrs. Maureen Jones73 E. Foothills Dr.Drums, PA 18222m au ree nj 12 14@ya hoo . corn5704973886

2

DH, MMRegulations

From: Maureen McAnena <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 1:47 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional paints on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Maureen McAnena

Mrs. Maureen McAnena2131 LardnerSt.Philadelphia, PA 19149

maureenmcanena@verizon.net215-715-7824

2

DH, MMRegulations

From: Maxwell Birnbaum <info@ufcwl76.org>Sent: Wednesday, March 17, 2021 9:17 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aflvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

sincerely,Max Birnbaum

Mr. Maxwell Birnbaum1928w Chew stAllentown, PA 18104

taskmaster1077@gmail.com6107304839

2

DH, MMRegulations

From: Michael Gleason <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:37 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

A1TENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Michael Gleason

Mr. Michael Gleason23 Fulton StHanover PA 17331

meg42105@gmail.com

2

DH, MMRegulations

From: Michael Walsh <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 12:17 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Michael walsh

Mr. Michael walsh2222 Sarahs LaneWarrington, PA 18976mwalsh1120@gmail.com215-343-0534

2

DH, MMRegulations

From: Michelle McNicholas <info@ufcw1776.org>Sent: Saturday, March 13, 2021 7:16 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Michelle McNicholas

Ms. Michelle McNicholas2311 Marquette driveBlakes lee, PA 18710Mcnic@atlanticbb.net

2

DH, MMRegulations

From: Mike Owens <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:10 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender, Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Mike Owens

Mr. Mike Owens1546 windmill Rdwarminster, PA 18974owes.21@3comcast.net2674413334

2

Dli, MMRegulations

From: Miyo Kamihira <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:30 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments fram unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aHvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,P7 M 72 Ki

Ms. Miyo Kamihira1727 N 4th StreetPhiladelphia, PA 19122rn.kamihira@gmail.com2158500910

2

DH, MMRegulations

From: Morgan Linn <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:12 AMTo: DH, MMRegulatons: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions), I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Morgan Linn

Ms. Morgan Linn8093 Peebles RdPittsburgh, PA 15237m rgn Iinn8@gmail.com

2

DH, MMRegulations

From: Msry Miller <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:33 AMTo: DR MMRegulations; brodas@ufov1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an ottochment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Mary Ann Miller

Miss Msry MillerS Market Street Apt 503Brownsville, PA 15417mamiller123@yahoo.com724-550-3458

2

DH, MMRegulation5

From: Nancy Mack <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:49 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10.219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Nancy Mack

Mrs. Nancy Mack52 Mahantongo StreetTremont, PA 17981nmack@psecu.com

2

DH, MMRegulations

From: Nick Chinnici <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 11:35 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails to,comply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincere Iv,Nick chinnici

Mr. Nick chinnici3865 Grandpine Way, Apt. 311Casselberry, FL 32707N ickChin n ici 15 @ G mail, corn6107197676

2

DH, MMRegulations

From: Patricia Perty <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:17 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aflvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Patricia Perry

Mrs. Patricia Pedy1220 N Broad St #1512Philadelphia PA 19121Pperry0613@gmail.com4016635612

2

DH, MMRegulations

From: PATRICK GREENING <info@ufcw1776.org>Sent: Wednesday March 17, 2021 12:22 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forword the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,PATRICK GREENING

Mr. PATRICK GREENING9921 DEERFIELD DRIVE

N. HUNTINGDON, PA 15642

pat_patx2@comcast.net7248633661

2

DH, MMRegulations

From: Prakul Pottapu <nfo@ufcw1 776.org>Sent: Monday, March 15, 2021 4:47 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Prakul Pottapu

Mr. Prakul Pottapu328s 17th streetPhiladelphia , PA 19103Prakul.reddv@gmail.com3023127873

2

OH, MMRegulations

From: Raymond Andrews <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:32 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation;

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Raymond T Andrews

Mr. Raymond Andrews157 S Main St.BIGLERvILLE, PA 17307rtandreas@hotmail.com7178090214

2

DH, MMRegulations

From: Renee Linn <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:34 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: (External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attochment to CWOPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and Sanction5. (aflvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Renee linn

Mrs. Renee Linn148 Ohare rdCanonsburg, PA 15317Reneelhnn2015@gmail.com7249862298

2

DH, MM Regulations

From: Rick Bobak <info@ufcw1776.org>Sent: Sunday, March 14, 2021 10:57 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health;

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation;

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Rick Bobak

Mr. Rick Bobak612 Southern avePittsburgh, PA 15211rick8976@verizon.net14123025878

2

DII, MMRegulations

From: Rob Matteson <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:48 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Co not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about alt of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Rob matteson

Mr. Rob Matteson1515 Putnam dr.Lancaster • PA 17602Rm atteson 17602 @ma ii. co m7172930524

2

DH, MMRegulations

From: Robert Burgeson <info@ufcw1776.org>Sent: Sunday, March 14, 2021 7:38 AMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

AITENTIQfQ: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peace

agreements which are included under “community impact” section of the application and

awarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Robert Burgeson

Mr. Robert Burgeson

1725 treasure lake

Dubois, PA 15801

Rburgeso@cswg.com6039032624

2

DH, MMRegulations

From: ROBERT derrick cinfo@ufcw1776.org>Sent Tuesday, March 16, 2021 7:32 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AITENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious emoil, forward the message as on attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,bob derrick

Mr. ROBERT derrick413 marsden aveessington, PA 19029rd2sponge2@yahoo.com6109316945

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DH, MM Regulations

From: Robert Landi <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:15 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAMpo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license,

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aHvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process, Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Robert Landi

Mr. Robert Landi3850 woodhaven rdPhiladelphia, PA 19154Roblandi@comcast.net2674084286

2

OH, MMRegulations

From: Robert Paczewski <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:18 AMTo: DH, MMRegulatons; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAM@Jpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Since rely,Bob paczewski

Mr. Robed Paczewski4728 Garden stPhiladelphia , PA 19137Bobbig66@msn.com2678180151

2

DH, MMRegulations

From: Robert Rice <info@ufcw1776.org>Sent: Wednesday March 17, 2021 10:36 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Bob Rice

Mr. Robert Rice7 Main Lin drCoatesville, PA 19320Supedresh377@yahoo.com

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DH, MMRegulations

From: Robin Troy <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:15 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment n response to proposed Regulation #10-219

AITENTIOPJ: This email message is from an external sender. Do not open links or attachments from unknawn sources. Tareport suspicious email, forward the message as an attachment to CWOPA_5PAM@pa.gai,.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.4] (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Robin Troy

Mrs. Robin Troy857 Lovitt WayPittsburgh, PA 15212-8023robintroy62@gmil.com4126289880

2

DH, MMRegulations

From: Ron Schoedler <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:44 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@Jpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more, Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Ron Schoedler

Mr. Ron Schoedler219 clarkdale LaneGilbertsville, PA 19525Ronschoedler@gmail.com2156314092

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DH, MMRegulations

From: Ryan Zarkesh <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:30 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@Jpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Ryan Zarkesh

Mr. Ryan Zarkesh424 Black Walnut Dr.Mountain Top, PA 18707r. zarkesh@gmail.com5705745425

2

OH, MMRegulations

From: Sally Judge <info@ufcw1776.org>Sent: Wednesday. March 17, 2021 11:10AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [Externall Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Sally Judge

Mrs. Sally Judge400 S Blakely StDunmore, PA 18512sally.judge@dunmorepa.gov5703437611

2

DH, MMRe9ulations

From: Sean McCaffrey <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 4:19 PMTo: DH, MMRegulations; brodas@ufcwl776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely.Sean McCaffrey Jr.

Mr. Sean McCaffrey55 Ash AveBristol, PA 19007Seanhimselfls@gmail.com2155016765

2

DH, MM Regulations

From: Sharon Purdy cinfo@ufcw1776.org>Sent: Tuesday, March 16, 2021 10:50 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Sharon Purdy

Mrs. Sharon Purdy53 centerstHughestown, PA 18640SharonpurdyO@gmail.com5703285341

2

DH, MMRegulations

From: sheryl messina <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:37 AMTo: DH, MMkegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links ar attochments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,s hery I

Miss sheryl messina2224 Mulberry Ct, Lansdale, PAlansdale, PA 19446sugarmag122@verizon.net12158537992

2

DH, MMRegulations

From: Shyann Grimm <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:15 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (alivi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Shyann grimni

Ms. Shyann Grimm45 Rostock stPittsburgh, PA 15212Shyann.Grimm098@gmail.com4128630623

2

DH, MMRegulations

From: Silvana Gortych <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:39 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message isfram an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@Pa.gOV.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Silvy

Ms. Silvana Gortych1750 Conestoga wayTohyhanna, PA 18466si Ivan agortych @gma ii. corn5705807645

2

DH, MMRegulations

From: Stanley Gonzalez <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 1:44 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application and

awarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Stanley Gonzalez

Mr. Stanley Gonzalez835 E 3rd StreetBerwick, PA 18603stanley_gonzalez@msn.com5702458566

2

OH, MMRegulations

From: Stephen Geary <info@ufcw1776.org>Sent Tuesday, March 16, 2021 1:59 PMTo: OH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWQPA_5PAMJpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Steve

Mr. Stephen Geary318 Sunnybrook RdSpringfield, PA 19064jgear318@aol.com6105445658

2

DH, MMRegulations

From: Steve Spicas <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 226 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Steve Spica

Mr. Steve Spicas2302 ferncroft circleUpper Chichester, PA 19061Sts47@comcast.net2679082095

2

DH, MMRegulations

From: Tasha Williamson <info@ufcwi776.org>Sent: Wednesday, March 17, 2021 12:45 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTIOIV: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Tasha Marie williamson

Ms. Tasha williamson62 Church StEDwARDSvILLE, PA 18704Tashamclean @ hotmail. corn6073488577

2

DH, MMRegulations

From: Theresa Webber cinfo@ufcwi776.org>Sent: Wednesday, March 17, 2021 8:16 AMTo: OH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aHvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Theresa webber

Ms. Theresa webber2826 narcissus rdPhiladelphia, PA 19154Termcw@aol.com2672315650

2

DH, MMRegulations

From: Thomasina moore <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:48 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Thomasina Harris moore

Ms. Thomasina moore2225 n Carlisle stPHILADELPHIA, PA 19132Thomasinamoore77@gmall.com12679029989

2

DH, MMRegulations

From: TIKISHA HOUSER <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:17 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Cornrnent in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Tikisha Houser

Ms. TIKISHA HOUSER352 VALLEY BROOK RD APT D9AMBLER, PA 19002

TIHOUSE04@GMAIL.COM21542139Q3

2

DH, MMRegulations

From: Timothy Arches <info@ufcw1776.org>Sent: Saturday, March 13, 2021 8:57 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AITENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWQPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Timothy James Arches

Mr. Timothy Arches2672 Fieldview diMacungie, PA 18062Ni kea i r17 92 @grn a ii. corn9082951603

2

DH, MMRegulations

From: TIMOTHY Mccarthy <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:28 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@ipo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Timothy Mccarthy

Mr. TIMOTHY McCarthy19 Fairview AvePittsburgh, PA 15229joanandtim@comcast.net4129319079

2

DH, MMRegulations

From: Tom Malick <info@ufcw1776.org>Sent: Tuesday, March 16, 2021 12:24 PMTo: DH, MMRegulations; brodas@ufo’jl 776.orgSubject: (External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Tom Malick

Mr. Tom Malick210 West View AvePgh, PA 15229tmlick@ufcw1776.org4124437869

2

DH, MMRegulations

From: Tom McDonnell <info@ufcw1776.org>Sent: Saturday, March 13, 2021 9:16 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an ottochment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional paints on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Tom McDonnell

Mr. Tom McDonnell1641 Pembrooke rdNorristown, PA 19403

Mcdonnelltom@hotmail.com6106308277

2

DH, MMRegulations

From: Tyreek Garrett <info@ufcw1776.org>Sent Wednesday, March 17, 2021 11:51 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

AITENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Tyreek garrett

Mr. Tyreek Garrett1806 bailie avenueMcKeesport, PA 15132tyreekarrett@ gma il.com4129238471

2

DH, MMRegulations

From: Valerie Morrison <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:28 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: (External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@Jpo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Valerie Morrison

Ms. Valerie Morrison2535 South Reese StreetPhiladelphia, PA 19148valmorrison80@gmail.com2674448990

2

DH, MMRegulations

From; Vernon Lee <info@uftw1776.org>Sent: Wednesday, March 17, 2021 10:08 AMTo; DH, MMRegulations; brodasufcw1 776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ArTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process, However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Vernon Michael Lee

Mr. Vernon Lee74 JENNIFER DRCHESTER SPRINGS, PA 19425

oatsie57@aol.com

2

DR MMRegulations

From: William DeStefano <info©ufcwl77G.org>Sent: Wednesday, March 17, 2021 12:47 PMTo: DR. MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the messoge as an attachment to CWQPASPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation;

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,William DeStefano

Mr. william DeStefano661 Christopher laneAston, PA 19014Sirthinksalot@comcast.net2152643452

2

DH, MMRegulations

From: Zachary Paschke <info©ufcwl776.org>Sent: Wednesday, March 17, 2021 9:44 AMTo: DH, MMRegulations; brodas@ufcn1776.orgSubject: (Externalj Public Comment in response to proposed Regutation 410-219

AUENTION: This email message is from an external sender. Do not open links ar attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Zachary Paschke

Ms. Zachary Paschke1000 Walkers Tn, Apt 3Greenshung, PA 15601Paschke02@gmail.com7245752376

2

DR MMRegulations

From: Anne Ickenroth <info@ufcw1776.org’Sent: Thursday, March 18, 2021 10:34 AMTo: OH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation t10-219

ATTENTION: This email message isfram an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAMJpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Anne Ickenroth

Ms. Anne Ickenroth1199 Lynn Street, #6Aliquippa, PA 15001annealiza@outlook.com5028887196

2

DH, MMRegulations

From: Anthony DeLacy <info@u1cw1776.org>Sent: Wednesday, March 17, 2021 5:36 PMTo: OH. MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links ar attachments from unknown sources. Toreport suspicious email, forword the message as on attochment to CWOPA_SPAMpo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Anthony DeLacy

Mr. Anthony DeLacy906 Greenwich StPhila, PA 19147ant ho ny.de Ia cy@gm all, corn

2

DH, MMRegulations

From: An Rosenberg <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:04 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Ca not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gm’.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,An Rosenberg

Mr. An Rosenberg203 Pottstown AvePennsburg, PA 18073arirosenberges@gmail.com2676648085

2

DR, MMRegulations

From: Ashley Malick <info@ufcw1776.org>Sent Wednesday, March 17, 2021 5:46 PMTo: DH, MMRegulations; brodas@uf1 776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forword the message as an attachment to CWQPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Ashley Malick

Ms. Ashley Malick160 East Station Square Drive,Pittsburgh, PA 15219ashleymalick@gmail.com4126080054

2

DH, MM Regulations

From: Beth Scarlatelli <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:39 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@Jpo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Beth Ann Scarlatelli

Mrs. Beth Scarlatelli704 Restan ctSeven fields , PA 16046Bama ick19@gmail.com4122164960

2

DH, MMRegulations

From: Brad Lytle <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:00 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [Bternal] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Brad Lytle

Mr. Brad Lytle142 Bertha avenueDonora, PA 15033

scorpio71@comcast.net724-379-4224

2

DH, MMRegulations

From: Brelan Skinner <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 6:22 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email) forward the message as an attachment to CWOPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Brelan Skinner

Mr. Brelan Skinner2436 Park Hill DrPittsburgh, PA 15221Breski Ian @ outlook, corn4128123836

2

DH, MMRegulations

From: Brenda Michael <info@ufcw1776.org>Sent: Thursday, March 18, 2021 7:34 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or ottachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Brenda

Mrs. Brenda Michael1300 Spang St ExtRoaring Spring, PA 16673b rend aottm ich@ya hoo corn8144145590

2

DH, MMRegulations

From: Carla Dorsey <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 4:15 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@ipa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under Ucommunity impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Carla Dorsey

Miss Carla Dorsey6112 Locust StrPhy, PA 19139

carladorsey69@icloud.com215-740-1215

2

DH, MMRegulations

From: Christa Greeno <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 5:26 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Christa Greene

Ms. Christa Greeno57 Bonnie Gellman CourtPhiladelphia, PA 19114Christaill@att.net215-687-9965

2

DH, MMRegulations

From: Christopher Barnes <info@ufcw1776.org>Sent: Wednesday. March 17, 2021 5:18 PMTo: DH, MMRegulations; brodas@uicw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aHvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Christopher Barnes

Mr. Christopher Barnes1457 Kelton AvenuePittsburgh, PA 15216barneschris357@gmail.com4127353391

2

DH, MMRegulations

From: Connor Mulvaney <info@ufcw1776.org>Sent: Thursday, March 18, 2021 1:59 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATrENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Connor Mulvaney

Mr. Connor Mulvaney523 clemesha AvenuePittsburgh, PA 15226mulvaneyc37@gmail.com4122660324

2

DH, MMRegulations

From: D Green <info@ufcw1776.org>Sent: Thursday, March 18, 2021 8:22 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@Jpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aflvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,D Green

Ms. D Green1532 Clearview StreetPhiladelphia NY 19141expressionsdeb@icloud.com

2

DH, MMRegulations

From: Dakota Potts-Krammes <info@u1cw1776.org>Sent: Thursday, March 18, 2021 1:18 AMTo: DH, MMRegulations; brodas@ufcvv1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Dakota Potts-Krammes

Mr. Dakota Potts-Krammes26 Mustang Dr.Pine Grove, PA 17963

dpkhm@hotmail.com5706404716

2

Dft MMRegulations

From: Dana Copeland <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 2:45 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAMpo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Dana Copeland

Ms. Dana Copeland627 Orchard Hill DrivePittsburgh , PA 15238damacrcope@gmail.com

2

DH, MM Regulations

From: Daniel Brozoski cinfo@ufcw1776.org>Sent: Thursday, March 18, 2021 1:22 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: fExternal] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attochment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely.Dan Brozoski

Mr. Daniel Brozoski2144 johnston AveBethlehem , PA 18015danbrozo215@gmil.com

2

DH, MMRegulations

From: David Byrd cinfo@uicw1776.org>Sent: Thursday, March 18, 2021 6:28 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: (External] Public Comment in response to proposed Regulation #10-219

AflENTION: This emaÜ message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attochment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,David G Byrd

Mr. David Byrd826, Wheatland drBridgeville, PA 15017dgbyrd 1966@grn ail. corn4123032262

2

OH, MMRegulations

From: David Pedano <info@ufcw1776.org>Sent: Thursday, March 18, 2021 1:18 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,David Pedano

Mr. David Pedano210 Stanley AveHavertown, PA 19083davidpedano@gmail.com4847166577

2

DH, MM Regulations

From: Debra Flinn <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:07 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message os an attachment to CWOPA_SPAMpo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Debra Flinn

Ms. Debra Flinn956 Meade Avenue, 1st FlScranton, PA 18508dflinnl3 @gmail.com5709864001

2

DR MMRegulations

From: Denice Sinclair <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 7:28 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject [Externall Public Comment in response to proposed Regulation #10-219

AITENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attochment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aHvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Denice Sonclair

Mrs. Denice Sinclair4749 rredonia p1Bensalem, PA 19020

djaiis@comcast.net2158501733

2

OH, MMRegulations

From: Donna Depasquale <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 2:47 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of theiroptions and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Donna Depasquale

Ms. Donna Depasquale527 Selma Street,Philadelphia, PA 19116ddepasquale27@gmail.com2154986697

2

DH, MMRegulations

From: Ed Smith <info@ufcw1776.org>Sent Wednesday, March 17, 2021 6:57 PMTo: OH. MMkegulations; brodas@ufcw1776.orgSubject: [Extemall Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Ed Smith

Mr. Ed Smith1512 4th AveArnold, PA 15068EdwardSmith5026@yahoo.com4125518729

2

DH, MMRegulations

From: Edward Erkel <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 5:11 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@PO.gOV.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Ed

Mr. Edward Erkel2435 Silver Oak PlacePITTSBuRGH, PA 15220

ederkei@verizon.net4123414820

2

DH, MMRegulations

From: Edward Lloyd <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 3:24 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as on attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Edward Lloyd

Mr. Edward Lloyd00214 E BRINGHURSTSTPhiladelphia, PA 19144eplloyd@usa.net12158446288

2

DH, MMRegulations

From: Fikerte Bekele <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 4:22 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender, Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It iss critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peace

agreements which are included under “community impact” section of the application and

awarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Fikerte Bekele

Ms. Fikerte Bekele7303 sanderling placePhiladelphia, PA 19153fikertebekele@yahoo.com2152602260

2

DH, MMRegulations

From: Fran Liebergott <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 6:11 PMTo: OH, MMRegulations; brodas@ufcw1776.orgSubject [Extemalj Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWOPA_SPAMpo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Fran Liebergott

Mrs. Fran Liebergott673OSylvester StreetPhila, PA 19149Frannie016@yahoo.com2256872273

2

DH, MMRegulations

From: Gabriel Caban <info@ufcw1776.org>Sent: Thursday, March 18, 2021 7:32 AMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Ga be

Mr. Gabriel Caban2060 WILMOT STPHILADELPHIA, PA 19124

gabec315@gmail.com2153490931

2

DH, MMRegulations

From: Gary Bromall <info@ufcw1776.org>Sent: Thursday, March 18, 2021 6:48 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely, garyGary v Bromall

Mr. Gary Bromall4721 Baltimore AvePhiladelphia, PA 19143-2014

nov0360@hotmail.com12672413836

2

DH, MMRegulations

From: Guy DAgostino into@ufcwl77S.org>Sent: Wednesday, March 17, 2021 9:48 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Ca not open links or attachments from unknown sources, Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,guy

Mr. Guy DAgostino314 Sharpless StWest Chester, PA 19382guydagostino@gmail.com610-732-4020

2

DH, MM Regulations

From: Heather Kline <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 2:52 PMTo: DR MMRegulations; brodas@ufcn1776.orgSubject [Extemalj Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWOPA_5PAMpo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails to

comply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application and

awarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Heather Kline

Ms. Heather KlineP0 Box 487Blakeslee, PA 18610heatherdkline@yahoo.com2679807321

2

DH, MMRegulations

From: Henry Zabala <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:02 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email messoge is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Henry Zabala

Mr. Henry Zabala922 n. 6th streetReadings PA 19604Henryjuly94@gmail.com6107909753

2

DR MMRegulations

From: Jade Wurst <info@ufcw1776.org>Sent: Thursday, March 18, 2021 2:29 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAM@Dpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Jade wurst

Mrs. Jade Wurst1212 Cambridge St.NATRONA HEIGHTS, PA 15065

jalamison@gmail.com17245256310

2

DH, MMRegulations

From: James Marutiak <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:16 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAMpo.qrni.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Jim Marutiak

Mr. James Marutiak24S Davies StreetLower Burrell, PA 15068

jmarutiak@hotmail.com7243347815

2

DH, MMRegulations

From: Janet polk <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:55 PMTo: OH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email mes5age is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Janet Polk

Mrs. Janet polk71 vilsack StPittsburgh, PA 15223polk.Janet@comcast.net14125833511

2

DH, MM Regulations

From: Joe Capone <info@ufcw1776.org>Sent; Wednesday, March 17, 2021 6:03 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do nat open links or attachments from unknown sources. Toreport suspicio us email, forward the message as an ottachment to CWQPASPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Joe Capone

Mr. Joe capone280 Coolidge St.Dupont, PA 18641

Jebro92@yahoo.com5709050836

2

DH, MMRegulations

From: Jordan snair <info@ufcwl76.org’Sent: Thursday, March 18, 2021 4:28 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Jordan Snair

Mr. Jordan snair209 Kirkpatrick aveLeechburg, PA 15656jordansnair@hotmail.com

2

DH, MMRegulations

From: Joseph Peters cinfo@ufcw1776.org>Sent: Wednesday, March 17, 2021 4:51 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Joseph Peters

Mr. Joseph Peter51020 Gypsy Hill RoadAmbler, PA 19002Josephrobedpeters@gmail.com2674380482

2

DH, MMRegulations

From: Katina Simmons cinfo@ufcw1776.org>Sent: Wednesday, March 17, 2021 6:35 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attochment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Katina Simmons

Ms. Katina Simmons923 East Durard streetPhiladelphia, PA 19150Katinamanda@gmail.com

2

DII, MMRegulations

From: Kayla Lee cinfo@ufcw1776.org>Sent: Wednesday, March 17, 2021 7:58 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [Extemall Public Comment in response to proposed Regu’ation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAMipa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licen5ees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Kayla

Ms. Kayla Lee10900 Bustleton Aye, B44Philadelphia, PA 19116kay.nicole. lee@gmail.com

2

OH, MMRegulations

From: Keenan Fields <info@ufcw1776.org>Sent: Wednesday March 17, 2021 2:55 PMTo: DH, MMRegulations; brodas@ufcwl 776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Keenan Fields

Mr. Keenan Fields1311 Tribbett AveSharon Hill, PR 19079

Dkdf@ comcast. net6105831245

2

DH, MMRegulations

From: Kelly McQuaid <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:46 PMTo: DH, MMRegulations; brodasufcw1 776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Kelly Mcouaid

Ms. Kelly McQuaid6425 Finley DriveMorrisville, PA 19067kellyyyanneee@gmail.com2674675404

2

DH, MM Regulations

From: Kimberly Freeman <info@ufcw1776.org>Sent: Thursday, March 18, 2021 4:39 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aHvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Kimberly Freeman

Ms. Kimberly Freeman3019 vensel wayPittsburgh, PA 15212mskimmy40@gmail.com7578790772

2

DH, MMRegulations

From: Kyle Hockensmith cinfo@ufcw1776.org>Sent: Wednesday, March 17, 2021 5:13 PMTo: OH, MMRegulations: brodas@ufcw1776.orgSubject [ExtemaU Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspiciaus email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariluana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Kyle Hockensmith

Mr. Kyle Hockensmith519 S Franklin StreetHanover, PA 17331kale402@gmail.com7178182409

2

DH, MMRegulations

From: Lawrence A Buckler <info©ufcwl77S.org>Sent: Wednesday, March 17, 2021 4:29 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [Extemalj Public Comment in response to proposed Regulation 1Q-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Lawrence A Buckler

Mr. Lawrence A Buckler931 Rose Ave.Morton, PA 19070larrybuckler@yahoo.com4848026231

2

OH, MM Regulations

From: Linda CALHOUN <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 6:53 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do nat open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aHvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,LINDA CALHOUNDE

Ms. Linda CALHOUN559 E Godfrey AvePhiladelphia, PA 19120lindacalhoun402@outlook.com12156887729

2

DH, MMRegulations

From: Lisa Gump <info@ufcw1776.org>Sent: Thursday, March 18, 2021 7:26 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: lExternal] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable lobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Lisa Gump

Mrs. Lisa Gump4136 battleridge rd.McDonald, PA 15057Lisagump@tahoo.com7246785572

2

DI-!, MMRegulations

From: Lisa McCoy <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:52 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and Cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Lisa McCoyLisa McCoy

Miss Lisa Mccoy568 Boggs diTionesta, PA 16353

windsormc@outlook.com8147588370

2

DH, MMRegulations

From: Lisa Napersky <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:04 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AITENTION: This emoil message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attochment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 114L47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Lisa Napersky

Ms. Lisa Napersky15 Elm St.Mountain Top, PA 18707In a pers ky@gm ail. corn5707091165

2

DR MMRegulations

From: Makenzie Riley <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:05PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do nat open links or attachments from unknown sources. Toreport suspicious email, forwardthemessageasanottochmenttaCWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses avai[able and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aHvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Makenzie Riley

Miss Makenzie Riley306 1/2 Hone AveOil city, PA 16301makenzieriley82@gmail.com8142083917

2

DH, MMRegulations

From: Mark Dernoga <info@ufcw1776.org>Sent: Thursday, March 18, 2021 3:47 AMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aHvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Mark Dernoga

Mr. Mark Dernoga933 Perry HwyPittsburgh, PA 15229mark.dernoga@gmail.com14125234508

2

DH, MMRegulations

From: Mark McCuch <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:24 PMTo: DR. MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Mark McCuch

Mr. Mark McCuch19 Paddington TerraceLIMERICK, PA 19468mccuchol@hotmail.com6104950776

2

DK, MMRegulations

From: Marshall Waddell <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 6:04 PMTo: DH, MMRegulations; brodas@ufcn1776.orgSubject: ExtemaI1 Public Comment in response to proposed Reguiation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Marshall Waddell

Mr. Marshall waddell1735 Theodan Dr,PITtSBURGH, PA 15216marshall2u@corncast.net4123274863

2

DH, MM Regulations

From: Martin Blankenbicker <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 5:44 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message isfram on external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Martin Blankenbicker

Mrs. Martin Blankenbicker909 California Avenue Apt 404Avalon, PA 15202iluv2play58@yahoo.com4128896826

2

DH, MMRegulations

From: Martin McSweeny <info@ufcw1776.org>Sent: Thursday, March 18, 2021 11:24 PMTo: OH, MMRegulations; brodas@ufcw1776.orgSubject: [Externalj Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still (earning how to best operate. Thank you for taking mycomments into consideration.

Since rely,Martini McSweeny

Mr. Martin McSweeny359 S Pacific AvePittsburgh, PA 15224sm a rtym arty1965@yahoo.com4124000988

2

DH, MMRegulations

From: Mary Eisley <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 7:11 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial apQlication.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application and

awarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Mary EisIey

Ms. Mary Eisley139 MorrisonPittsburgh, PA 15216maryeisley@yahoo.com412-889-6916

2

DH, MMRegulation5

From: Matthew Remer <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 10:45 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: lExternall Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Matthew Remer

Mr. Matthew Remer8701 Crispin DrivePhiladelphia, PA 19136hermitcell@gmail.com

2

DH, MMRegulations

From: Matthew Szczepanski <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 3:21 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvil The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Matthew Szczepanski

Mr. Matthew Szczepanski3013 Comly RdPhiladelphia, PA 19154Icemanmatt69@aol.com2159601526

2

DR. MMRegulations

From: Matthew Thomas info@u1cw1776.org’Sent: Wednesday, March 17, 2021 6:08 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This emoll message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely.Matthew thomas

Mr. Matthew Thomas54 bolin stPittston PA 18640Mrminer17@aol.com5707025134

2

DH, MMRegulations

From: Matthew Thomas <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:02 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.qm’.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and mare. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Matthew thomas

Mr. Matthew Thomas54 bolin stPittston, PA 18640Mrminer17@aol.com5707025134

2

_

--

__

DH, MMRegulations

From: pat Casee <info@ufcw1776.org’Sent: Thursday, March 18, 2021 5:45 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation ttlO-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peace

agreements which are included under “community impact” section of the application and

awarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Pat Cadee5pc2s

Ms. pat Casee2126 Berwyn StPhiladelphia , PA 19115Pcasee@gmail.com2159135496

2

DK, MMRegulations

From: Patricia Kean <info@ufcw1776.org>Sent: Thursday, March 18, 2021 11:23 AMTo: OH, MMRegulations; brodas@ufcw1776.orgSubject: [ExtemaI Public Comment in response to proposed Reguiation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jabs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions), I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Patricia Kean

Mrs. Patricia Kean1OS2S Modena terracePhiladelphia , PA 19154Pfkean@gmail.com2154109465

2

DH, MMRegulations

From: Patti Jones <info@ufcw1776.org>Sent: Thursday March 18, 2021 4:54 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Da not open links or attachments fram unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aflvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Patti Jones

Ms. Patti Jones3637 Cloverdale RdBensalern, PA 19020paddy]? @ co mcast. corn2152455388

2

OH, MMRegulations

From: Richard Hough <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 9:55 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do notopen links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

working for Jushi is horrendous. We need the unions helpL

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Departmentto suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Richard Hough

Mr. Richard Hough132 Fairview drDingmans ferry, PA 18328Rhough915@yahoo.com9732225861

2

DH, MMRegulations

From: Richard Romano <info@ufcwl76.org>Sent: Wednesday, March 17, 2021 5:14 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.4] (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aflvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Richard Romano

Mr. Richard Romano1630 Forrestal streetPhiladelphia, PA 19145rromano524@gmail.com2672498355

2

DH, MMRegulations

From: Rick Borne <info@ufcw1776.org>Sent: Thursday, March 18, 2021 7:58 AMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (ailvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peace

agreements which are included under “community impact” section of the application and

awarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,RICK BORNE

Mr. Rick BorneCottonwood ctCoraopolis, PA 15108rborne@pa.gov4122625701

2

DR MMRegulations

From: Rob Clarke <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 8:06 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@po.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (aflvi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Rob ClarkeRob clarke

Mr. Rob Clarke137 poplar st po boxl94Ellswarth, PA 15331Robclarke701@gmail.com7245318090

2

DH, MMRegulations

From: Robert Paczewski <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 4:19 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Bob paczewski

Mr. Robert Paczewski4728 Garden stPhiladelphia, PA 19137Bobbig66@msn.com2678180151

2

DR MMRegulations

From: Sherie Charles <in1o@ufcw1776.org>Sent: Wednesday, March 17, 2021 11:14 PMTo: OH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as on attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Sherie Charles

Ms. Sherie Charles1033 Oownlook StreetPittsburgh, PA 15201she ri e.tigerrose gmaiI.co m4126282129

2

OH, MMRegulations

From: Silvana Gortych <info@ufcw1776.org>Sent Wednesday, March 17, 2021 6:32 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject fExternal] Public Comment in response to proposed Regulation #10-219

AflENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Silvy

Ms. Silvana Godych1750 Conestoga wayTobyhanna, PA 18466si Ivanagodych @gma i I. corn5705807645

2

DH, MMRegulations

From: Steven rodriguez <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 5:54 PMTo: DH, MMReguations: brodas@ufcn1776.orgSubject [Externall PubLic Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAMpo.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It iss critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141,47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Steven rodriguez

Mr. Steven rodriguez112 tulpehocken aveWest Reading, PA 19611stevenrodrigi@yahoo.com4846652536

2

OH, MMRegulations

From: Susan Bubak <info@ufcw1776.org>Sent: Thursday, March 18, 2021 5:58 AMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more, Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and Sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Susan Bubak

Mrs. Susan Buhak1338 Route 940Pocono Lake, PA 18347hallman@ ptd.net5706431715

2

DH, MMRegulations

From: Susan Malone <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 6:59 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from on external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanction5. (ailvi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Susan Malone

Ms. Susan Malone#4-1004 vermont AvePITTSBURGH, PA 15234smalone0658@gmail.com4128868786

2

DII, MMRegulations

From: Sydney Doll <info@uicw1776.org>Sent: Wednesday, March 17, 2021 8:03 PMTo: DR MMRegulations; brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attochment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical marijuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Sydney Doll

Ms. Sydney Doll2810 Oarkridge CircleEagleville, PA 19403sdoll@ufcw1776.org2157206797

2

DH, MMRegulations

From: Tanya Shovlin <info@ufcw1776.org>Sent: Thursday, March 18, 2021 5:14 PMTo: DH, MMRegulations; brodas@ufcw1776.orgSubject (Extemalj Public Comment in response to proposed Regulation #10-219

AUENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWQPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana License submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to S additional points for signing. Specifically, this change will permit the Department

I

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Tanya shovlin

Mrs. Tanya Shovlin811 s market stNanticoke, PA 18634Pajeepgirl@msn.com5704177728

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DH, MMRegulations

From: Tom Malick <info@ufcwi776.org>Sent: Wednesday, March 17, 2021 4:04 PMTo: DH, MMRegulations; brodas@iufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

iUTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Tareport suspicious email, forward the message as an attachment to CWOPA_5PAMpa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Tom Malick

Mr. Tom Malick210 West view AvePgh, PA 15229tmalick@ufcw1776.org4124437869

2

DH, MMRegulations

From: Tracy Wieneke <info@ufcw1776.org>Sent: Wednesday, March 17, 2021 4:48 PMTo: DH, MMRegulations: brodas@ufcw1776.orgSubject: [External] Public Comment in response to proposed Regulation #10-219

ATTENTION: This email message is from an external sender. Do not open links or attachments from unknown sources. Toreport suspicious email, forward the message as an attachment to CWOPA_SPAM@pa.gov.

Members of the Independent Regulation Review Commission and Department of Health:

I am submitting public comment in response to proposed Regulation #10-219: Medical Marijuana.The Medical Marijuana Program provides critical relief for thousands of patients across theCommonwealth, sustainable jobs for growers, processors and distributors and an opportunity topave the way for a new industry in Pennsylvania. I believe it is imperative that employers in thisindustry are accountable and held to a standard consistent with other industries serving patientsin the Commonwealth. It is s critical that Pennsylvania get the process right in order to protect theworkforce and the future of this industry. As such, my comments are regarding section § 1141.47.General penalties and sanctions.

As you are aware, applicants seeking a medical marijuana license submit a comprehensiveapplication detailing their projected plans, financials, diversity plans, impact on the community,and more. Applicants have been able to receive additional points on their application by signinga neutrality and card check agreement with a labor organization, agreeing to stay neutral in theattempt to organize the workforce, bringing better wages, benefits and protection to employeesin this new industry. With a limited number of licenses available and therefore limitedopportunities for employment, it is critical that these employers are being held to such standardswhen receiving their license.

As such, I am requesting a change to subsection 1141.47 (General penalties and sanctions). I amrequesting that the Independent Regulation Review Commission and Department of Healthinclude the following language to ensure that employers comply with the neutrality and cardcheck agreements they submit with their application, giving the employees the opportunity tolearn about all of their options and penalize the employer should they be found in violation:

§ 1141.47. General penalties and sanctions. (a)(vi) The medical mariiuana organization fails tocomply with neutrality and card check agreements and/or other labor peace agreementssubmitted with the initial application.

This change will permit the Department of Health to enforce the submission of labor peaceagreements which are included under “community impact” section of the application andawarded up to 5 additional points for signing. Specifically, this change will permit the Department

1

to suspend or revoke a license, issue a civil penalty of up to $10,000 for the violation and anadditional penalty of up to $1,000 a day for each day the violation is not cured or issue a writtenwarning against the license, depending on the gravity of the situation. These are the samepenalties provided for all provisions under this section.

Under the current structure, medical marijuana licensees that do not comply with a labor peaceagreement are often taken through the lengthy arbitration process. However, even in instanceswhere unions have won in arbitration, little opportunity to organize is present because of variousreasons including turnover and termination of those agreeing to unionize, expiration of a laborpeace agreements and more. Employers lean into the lack of enforcement to extend the processwith the hopes of reaching the end of the contract before having to recognize a union. Theseemployers face no penalty for their failure to comply with the information submitted during theapplication process. Therefore, the suggested change would ensure that employers that do notcomply with labor peace agreements face a penalty, and the precedent is set that all informationsubmitted with an application must be complied with.

This additional language will permit the Department of Health to ensure that employers are notfalsifying their plans to stay neutral on applications in order to receive additional points andeliminate bad actors in this industry. This simple and necessary change will help protect theworkforce of an industry that we are still learning how to best operate. Thank you for taking mycomments into consideration.

Sincerely,Tracy wieneke

Ms. Tracy wieneke425 East 2nd AveTarentum, PA 15084Tin kyd in k30 @gmai I. corn7726341943

2