“I am hopeful this is a first step towards Massachusetts someday being positioned as a global leader in cannabis research.”
At last Thursday’s meeting of the Massachusetts Cannabis Control Commission, members approved a final license for the state’s first Marijuana Research Facility. Such an operation is allowed to conduct studies involving cannabis products and plants, and can perform functions ranging from clinical investigations to agricultural and horticultural research.
“We are excited to move the state’s first-ever Research Facility license forward in the hopes that it will contribute to a safer regulated cannabis industry, rooted in science,” Acting CCC Chair Bruce Stebbins said in a media statement. “This licensee has worked diligently over the last two years to bring this facility to the Commonwealth, and we look forward to the work their team will accomplish after their receipt of a research permit.”
Curaleaf gets first research license in Massachusetts
The licensee is Curaleaf, a publicly-traded Canadian company which operates more than 150 dispensaries in 19 US states. In Massachusetts, it has adult-use dispensaries in Ware and Provincetown, a medical store in Hanover, and a shop serving the adult and medical markets in Oxford. Curaleaf also cultivates and manufactures the Select, Find, and Jams brands, and with the commissioners’ unanimous vote last week, it has a final license to operate a research facility in Newton.
The agency wrote that the approval marks “continued progress towards achieving greater understanding of the safety and applicability of regulated marijuana products through science.” The CCC noted: “In September, the Commission’s Investigations and Enforcement staff inspected the Marijuana Research Facility and found it to be in full compliance with the requirements under state law. Upon receiving administrative approval for any submitted Research Permit applications, Curaleaf Processing Inc. must then pass a final license inspection prior to being authorized to commence operations and begin research projects.”
Furthermore, “the final licensee will need to submit a Research Permit application for review by the agency’s Research Department.” In Massachusetts, “any research projects involving human subjects will require supplying necessary Institution Review Board details while any study involving animal subjects will require supplying necessary Institutional Animal Care and Use Committee (IACUC) details to the Commission.”
The “critical need” for research facilities
According to the CCC, “Since Massachusetts regulations first authorized the licensure and operation of Marijuana Research Facilities, seven applications have been submitted to the Commission.”
Beyond the realm of CCC licensing, Massachusetts is already the home to a number of long-running research entities, with some tied to universities and others that are fully independent. For example, the Institute of Cannabis Science in Cambridge has a mission to “educate and protect consumers of cannabis,” and has conducted shelf testing on products among other research, while the Cannabis Center of Excellence recently conducted a study on pot and harm reduction.
That’s in addition to the nonstop research at licensed grows and manufacturing facilities across the state, plus at labs with intersecting interests. Marijuana researchers in Massachusetts who we spoke with for this article were uncertain about what added benefits come with the designated CCC license; one person essentially said, I’m not sure what they will be able to do that we can’t. But there is a general agreement that it could make sense for a company like Curaleaf, which has other licenses with the commission, to conduct research in that framework. Judging by comments made by the commissioners, that’s part of the CCC’s calculation.
“While serving as the Commission’s public health appointee, I have emphasized time and again the critical need for more cannabis research to help Massachusetts residents better understand the potential risks and benefits of cannabis consumption,” Commissioner Kimberly Roy said in the statement. “As one of only fifteen cannabis research licenses of this type granted nationwide, the issuance of this Research Facility is a significant development for both the agency and industry. I am hopeful this is a first step towards Massachusetts someday being positioned as a global leader in cannabis research.”
Reached for comment, a spokesperson from Curaleaf wrote in an email to Talking Joints Memo that the company “is proud to have been granted the first Marijuana Research Facility license in the Commonwealth of Massachusetts. We thank the Massachusetts Cannabis Control Commission for establishing this industry-leading license type, and we are honored to receive it.”
The statement continued, “As a company, research and development is critically important to Curaleaf, and we’ll continue to prioritize it as we continue to build the world’s leading cannabis company. The company has actively participated in clinical research through partnerships with leading academic institutions, including Penn Medicine at the University of Pennsylvania Medical School as well as Imperial College in London. Our focus is on developing highly formulated products and form factors that are rooted in science and are specifically designed to address the health and wellness needs of our customers and patients.”
Curaleaf’s initial application
According to public documents, Curaleaf first filed its application with the CCC to build a “state-of-the art” “research and development facility” in 2022. “Curaleaf,” it reads, “is committed to making the world a better place by applying advancements in research and technology to the cannabis industry.”
The company proposed a six-point plan for the lab: Analytical Chemistry (“We will use advanced analytical chemistry tools to explore and develop consumer safety testing methodology”); Food Science and Formulations (“explore development of the next generation of cannabis products across a range of formats”); Process Development (“optimize existing manufacturing practices and develop novel processing technologies”); Biochemistry (“study the biochemistry and pharmacology of cannabinoids and other cannabis derived compounds using a range of in-vitro assays”); Chemistry (“study the chemical properties of cannabinoids and other natural components within the
cannabis plant”); Cannabinoid research (“support partnerships with external universities to conduct pre-clinical and clinical studies on cannabis-based dosage forms”).
The 2022 application noted, “As a research and development facility, Curaleaf Processing is not producing or distributing any marijuana or marijuana products. The direct effect of the facility and its operations on the health of the neighborhood and its residents will be non-existent. In fact, the research conducted at the facility may indirectly improve the health of the community by helping to better understand any link between marijuana use and substance abuse.”
Curaleaf’s recent enforcement action
Last month, the CCC announced an enforcement action against Curaleaf. According to the final order and agreement, “On April 6, 2020, [Curaleaf] hired a third-party contractor to treat the exterior of its Amesbury Facility for crawling insects in connection with general lawn maintenance. During that maintenance a third-party contractor applied Talstar Professional, a pesticide containing Bifenthrin, on the exterior of the Amesbury Facility on a monthly basis from May 2020 until September 2020.”
“The Amesbury Facility,” however, “was not properly sealed from outside contaminants. This failure led to the contamination of the Amesbury Facility and Marijuana cultivated therein, which risked the public health, safety, and welfare.” Furthermore, Curaleaf “did not take any additional precautions to prevent the contamination of Marijuana cultivated at said facility while application of pesticides to the exterior of the building was ongoing.”
We asked Curaleaf about the enforcement action, and how the company would respond to critics who argue revelations in those state investigations cast a cloud over a Curaleaf research facility. A spokesperson responded, “In October Curaleaf received a fine in Massachusetts principally due to an issue that occurred more than four years ago in a facility (in Amesbury, MA) that the company no longer operates. An additional issue concerning the presence of an unapproved cleaning solution was identified in Amesbury as well as in our existing facility in Webster, MA. Upon our investigation of the issue arising in Amesbury, it was discovered that a third-party lawn service was using a pesticide outside the building. Due to regular foot traffic around the facility, Curaleaf team members and other service providers tracked the chemical into the facility in very small amounts, which was then found on flower products, as identified in our routine testing process. All potentially impacted products were destroyed.”
The spokesperson continued, “Shortly after this issue was identified in Amesbury, Curaleaf retained an independent environmental firm to conduct a remediation of the facility to ensure no pesticide residue remained. We also added additional controls to prevent inadvertent cross-contamination on the premises, with updated procedures and training for team members. These practices have been applied to our facilities throughout the country, as the health and safety of our patients and customers remains our number one priority. We feel confident about the changes made to ensure this doesn’t happen again.”
The bigger picture of Marijuana Research Facility licenses in Massachusetts
In its statement about the Curaleaf vote, the CCC offered a broader view of what research license holders could do—not just at this first facility, but also in other ones moving forward. “Marijuana Research Facility licenses are available to any academic institution, nonprofit corporation, or domestic corporation or entity authorized to do business in the Commonwealth that is interested in either conducting research involving cannabis directly or permitting external researchers with an approved Research Permit to conduct research involving cannabis within approved facilities.”
“A Research Permit,” meanwhile, “is a certificate from the Commission to conduct a specified research study over a specified and finite period and identifies the type of research study to be performed at the licensed premises of the Marijuana Research Facility.”
Per the CCC: “By establishing the Marijuana Research Facility license type in 2018, the Commission aimed to build upon the Commonwealth’s status as a world-class hub for higher education, medical, and biotech advancements and ensure Massachusetts’ leadership in emerging cannabis research and science. To date, Massachusetts is one of five states in the nation with legalized cannabis that offer research licenses, including New York, Connecticut, Washington, and Colorado. Only fifteen cannabis research licenses have been granted nationwide, and just ten of those are active.”
“There is still so much to explore when it comes to cannabis policy—whether we are considering implications for public health and safety, medical uses, or the impacts of prohibition,” Commissioner Nurys Camargo said in a statement. “While this licensee may be the first Research Facility to reach this point in the Commonwealth, it is my hope that others push on through the process and continue expanding our cannabis knowledge.”
Commissioner Ava Callender Concepcion added, “As long as marijuana remains a Schedule I substance, it is important that states like ours continue to innovate and pursue opportunities for research despite the barriers that may exist. … I’m thrilled to see this licensee moving forward, and we are excited for the day when we can announce that their research efforts have officially begun.”