The Oklahoma Bar Journal May 2025

THE OKLAHOMA BAR JOURNAL 14 | MAY 2025 terpenes. Hash can be produced through various methods, including dry sieving, hand-rubbing or ice water extraction (bubble hash), resulting in a dense, resinous product. It is one of the oldest and most widely used cannabis concentrates. See Aitor Sainz Martinez, supra note at 13. 16. Dry-cured cannabis refers to harvested cannabis plants that have undergone a drying and curing process to remove moisture and enhance flavor and aroma. This involves hanging the plants in a controlled environment to dry, followed by storing the dried buds in airtight containers to cure, allowing for the breakdown of chlorophyll and the development of desired flavors. See “The Ultimate Guide to Drying and Curing Cannabis for the Best Results,” Leafly, https://bit.ly/428p3Hz (last visited Feb. 10, 2025). 17. Fresh-frozen cannabis refers to cannabis plants that are harvested and immediately frozen to preserve their cannabinoid and terpene profiles. This method skips the traditional drying and curing stages, maintaining the plant’s freshness, and is often used in the production of high-quality concentrates like live resin. See “What Is Fresh Frozen?” Leafly, https://bit.ly/3G1Jux4 (last visited Feb. 10, 2025). 18. Modern Canna Labs, “Residual Solvent Testing in Cannabis,” https://bit.ly/3R9TKWz (last visited Feb. 8, 2025); Drexel University Cannabis Research Center, “OSHA and Cannabis Workplace Safety,” https://bit.ly/3RcAgRa (last visited Feb. 8, 2025). 19. International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH), “Guideline for Residual Solvents” Q3C (R8), (May 2021), https://bit.ly/3GiiWrI (last visited Feb. 8, 2025). United States Pharmacopeia (USP), USP General Chapter <467> “Residual Solvents,” (2021), https://bit.ly/3ExAUWA (last visited Feb. 8, 2025). 20. Id. 21. Id. 22. Id. 23. Okla. Admin Code supra note 3, at 2. 24. Id. 25. The Oklahoma Medical Marijuana Authority does not provide a specific definition for cannabidiol (CBD) in its regulations. However, under Oklahoma law, a “cannabinoid” is defined as “any of the chemical compounds that are active principles of marijuana,” which includes CBD. See 63 Okla. Stat. §427.2(4). 26. Ethan B. Russo, “Taming THC: Potential Cannabis Synergy and Phytocannabinoid-Terpenoid Entourage Effects,” 163 Brit. J. Pharmacol. 1344, 1348-49 (2011), https://bit.ly/3GfGf5e (last visited Feb. 10, 2025). 27. Cannabigerol (CBG) is a nonpsychoactive cannabinoid found in the cannabis sativa plant. It is synthesized from its precursor, cannabigerolic acid (CBGA), which also serves as a biosynthetic precursor to other cannabinoids, including cannabidiol (CBD) and Δ9-tetrahydrocannabinol (THC). CBG is typically present in low concentrations within the plant. See Benedikt B. Wenzel et al., “Pharmacological Aspects and Biological Effects of Cannabigerol and Its Synthetic Derivatives,” 13 Biomolecules 1841, 1843-45 (2023), available at https://bit.ly/3GfGjlu (last visited Feb. 10, 2025). 28. “Full Spectrum CBD vs Isolate CBD – What’s the Difference?” Cannabis Clinic, https://bit.ly/4jqVeYs (last visited Feb. 10, 2025); “Full Spectrum, Broad Spectrum, and Isolate: What’s the Difference?” SōRSE Technology, https://bit.ly/43SR9I8 (last visited Feb. 10, 2025); “What’s the difference between CBD isolate and full-spectrum CBD?” Medical News Today, https://bit.ly/4jzWfh6 (last visited Feb. 10, 2025). 29. Russo, supra note 26. 30. Id. 31. Id. 32. Delta-8 THC (Δ8-tetrahydrocannabinol) is a naturally occurring minor cannabinoid in cannabis, structurally similar to delta-9 THC but with milder psychoactive effects. It is often produced synthetically through the isomerization of CBD due to its low natural concentration in cannabis plants. Delta-8 THC interacts with the CB1 receptors in the endocannabinoid system, producing euphoric and relaxing effects, though it is generally considered less potent than delta-9 THC. See Daniel J. Kruger and Jessica S. Kruger, “Delta-8-THC: Delta-9-THC’s Nicer Younger Sibling?” 46 J. Med. Toxicol. 1, 2 (2021), available at https://bit.ly/4ii82Q6 (last visited Feb. 10, 2025). 33. Okla. Admin. Code §442:10-1-5(c) (2024). 34. Okla. Admin. Code §420:10-1-5(b)(9)(2024). 35. “Oklahoma Department of Agriculture, Food and Forestry, Nursery Program FAQs,” https://bit.ly/44cq7vB (last visited Feb. 8, 2025). 36. “Oklahoma Department of Agriculture, Food and Forestry, Agricultural Licenses Needed,” https://bit.ly/4jwlsJ0 (last visited Feb. 8, 2025). 37. Okla. Admin. Code §§442:10-5-8, 310:257, 310:260 (2024). 38. 74 Okla. Stat. §324.11 (2024). 39. C1D1 certification for hazardous processing safety protocols: supra note 7, at 2. 40. Okla. Dep’t of Envtl. Quality, “About DEQ,” www.deq.ok.gov/asd/about-deq (last visited Feb. 10, 2025). 41. Id. 42. Okla. Dep’t of Envtl. Quality, “Air Permits,” https://bit.ly/3GbRMCU (last visited Feb. 10, 2025). 43. Okla. Dep’t of Envtl. Quality, “Water Quality Division,” www.deq.ok.gov/divisions/wqd (last visited Feb. 10, 2025); Okla. Dep’t of Envtl. Quality, “Waste Management,” https://bit.ly/4juWHgn (last visited Feb. 10, 2025). 44. Okla. Admin. Code §252:656-1-3 (2024). 45. Id. 46. Okla. Admin. Code §442:10-9-9 (2024). 47. Purcell, Okla., Mun. Code §123-10 (2022). 48. James J. Black and Marc-Alain Galeazzi, “Cannabis Banking: Proceed with Caution.” Bus. L Today. (Feb. 6, 2020), https://bit.ly/4cEq0uB.​ 49. Id. 50. 26 U.S.C. §280E (2018); Nat’l Cannabis Indus. Ass’n, The Impact of IRS 280E on the Cannabis Industry (2022). 51. Andrew Larson, “Effective Tax Rate on Cannabis Companies ‘Can Be Fatal’; Proposed Bill Would Offer Relief,” Hartford Bus. J., Feb. 6, 2022, https://bit.ly/3Y5Rbsy. (last visited April. 18, 2025). Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff.

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