Tag Archives: dispensaries

By Tegan Adams

Canada has been undergoing many changes in the cannabis marketplace, most notably in the last two years. Originally, the system began with increasing access to cannabis for those with medical conditions under a “grow your own” model, the Medical Marihuana Access Regulations (MMAR). After running for a while, our regulatory authority, Health Canada, decided that among other faults, the MMAR program could pose a security risk to individuals growing at home. Following the dissolve of the MMAR, later released was a set of regulations, called Marihuana for Medical Purposes Regulations (MMPR) to license commercial producers now called Licenced Producers (LPs). While some MMAR patients were grandfathered in, the MMPR began as the mainstream cannabis production platform. MMPR LPs are inspected with high security and quality standards to produce and distribute cannabis exclusively to medical patients with a doctor-prescribed medical document. Patients register with one LP exclusively and receive cannabis by a mail-order system, and mail order only.

Why mail order with a medical document? What about all the dispensaries selling cannabis across Vancouver and Toronto? Where is all this cannabis coming from, if the MMPR LPs can only distribute direct to a patient through mail order?

These are good questions. And they are questions you should be asking. There are a few different factors contributing to the vast array of consumer confusion across borders in the Canadian system. People are passionate about cannabis, as well as their own personal freedom to have it. Some are passionate for medical reasons, others for the pure punch of liberation. Either way these passions have resulted in an interesting series of court decisions including a more recent one that deemed the MMPR unsuitable to provide enough access to cannabis for those in need. Effective close to the end of August this year in 2016, the MMPR as it is currently written will cease to be in effect and require revisions or a new system entirely for the legislation to be accepted and continued with.

There are a few different critiques of the MMPR which include: not enough variety, no ability to “see and feel” products before purchase, limitations on supply sources, limitations on dosage formats (i.e. oil and dried flowers only) and some might try to argue the rise in cost. While cannabis remains illegal to traffic without adequate controls across Canada, it is low on the priority list for the RCMP to spend resources on. Depending on which town and situation you are caught carrying it in, you would be hard pressed to be charged for carrying cannabis unless you ask for it. So, Canada has seen a surge in retail dispensaries, licensed or not, at the municipal level to the point where hundreds of them now exist across the country, distributing hundreds of millions of dollars of cannabis products per year.

Dispensaries vary in degree of professionalism, prices and strains available. Some have over sixty strains while others hold only four or five. Because Health Canada does not require laboratory testing of these products, most do not know their cannabis’ potency or that it is safe from bacteria, moulds, pesticides and aflatoxins. If they wanted to know, they could not find out since those with Narcotics Licences for testing are unable to accept their products under any regulatory framework.

We have seen false and unaccredited labs pop up on street corners accepting the unregulated products, but what we have not seen is information on the methods these labs are using, how they are validated and whether or not they are accurate. Regardless, the general consumer base does not seem to mind. Many of these locations have been reportedly selling $20,000-$30,000 CAD per day per 5,000 square feet or less of an operation. That is on average $600,000 per month and if continued for a full year as some have done, around $7.2M per year. All unregulated, and all up until recently tolerated by our RCMP and local policy authorities.

Finally, given the industrial-scale distribution that was not just occurring in the black market anymore, different neighbourhoods that did not like cannabis complained. LPs complained. And other regulated product industry members complained. They all complained that the unregulated distribution of cannabis was negatively affecting them in one way or another. And so, Canada saw raids. Hundreds of dispensaries raided, and many people were arrested if only temporarily. Products were seized. However, these raids generally proved ineffective and we saw most of these dispensaries open the next day. While the daily amounts seized might have sounded like a lot, they were only about one day’s sales for most of these locations, providing the authorities with a better glimpse into just how much diversion of the supposedly controlled substance was going on.

Given that cannabis is promised for recreational legalization in the spring of 2017 in Canada, many are wondering about what sort of business opportunities there might be on the horizon. We know that while control of production will probably remain similar to how it is now, our distribution models will change. Here are a few points Health Canada is considering in their latest discussions:

A phased-in approach to distribution will probably be necessary. First, continuing with the mail-order system would be the easiest phase in approach.
Regulated storefronts as an alternative to the current dispensaries. It is doubtful that dispensaries operating as they are will continue. There are rumors floating around that Shopper’s Drug Mart and other pharmacies will be able to help with distribution. Time will tell if these rumors evolve.
Provincial and Territorial uniqueness. Distribution could be altered at regional levels and different models could be developed across the country, similar to liquor regulations in effect. Some of our provincial liquor distribution entities have inquired to become distributors.
Keep cannabis away from minors. Health Canada is considering a look at locations, hours of operation, density of retailers and producers and consumption of cannabis outside of personal dwellings all as factors in the new system.
Guarding against impaired driving. Our regulators want to make sure they have enough tools to monitor those who may have been driving after consumption of cannabis.
Sound product packaging and labeling. A focus on understanding THC & CBD potencies as well as appropriate health warning messages. Packaging and Labeling, and effectively sound testing, will all be necessary.

Want to know more, or see for yourself? Check out Health Canada’s latest discussion document.

Curious to know what this will mean for packaging and labeling? Get in touch with me to better understand what Eurofins-Experchem currently tests for with our Licensed Producers. Contact me at 416 665 2134 ext 252 or teganadams@eurofins.com

June 15, 2016

Documentation & Compliance: A Q&A with Michael Shea, ConformanceWare

By Aaron G. Biros

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Cannabis safety throughout the supply chain requires active documentation tools for business owners to keep up with standards and regulations on the local and state level. Michael Shea, founder and president of AccessQMS and chief executive officer of Upshot’s ConformanceWare, provides consulting support across multiple industries with independent referral services to compliance professionals. With quality, safety and efficiency at top of mind, ConformanceWare’s design team developed the Medical Cannabis Series (MC Series™) to help cannabis business owners make the task of compliance easier. The documentation tools in the program are individually tailored to address needs in cultivation, processing, analyzing and dispensing.

The MC Series-Analyze Edition is currently in use at Canalysis Laboratories and NV Cann Labs, both operating in Nevada. According to Tara Lynn, chief executive officer at NV Cann Labs, the product helps them meet all of their documentation needs. “I appreciate all of the development using the MC Series- Analyze Edition and look forward to developing even more of a relationship through the years to come,” says Lynn. We sit down with Michael Shea to learn more about his product and how cannabis business owners can stay on top of regulatory compliance.

CannabisIndustryJournal: How will the MC Series help cannabis laboratories, cultivators, processors and dispensaries navigate regulatory compliance?

Michael Shea: To open a sustainable business involving cannabis goes beyond submitting applications, paying fees and focusing on profit alone. As laws adjust and tighter controls are put in place, more and more business owners are realizing what preserves and sustains their business is, in fact, compliance.

True sustainability is driven by forward thinking that values documenting and following best practices to ensure quality, safety and efficiency. Ambiguity concerning where to turn or how to correctly produce this documentation not only poses a difficult dilemma, it can put one’s investment at risk as well.

Finding a remedy for the situation begins with an expansion of perspective. Businesses will benefit most by actively working toward compliance from the onset. This approach eliminates having to face non-compliance and the enforcement that goes along with it.

MC Series™ is designed for this purpose and will greatly help businesses precisely document how their method of operation demonstrates full compliance with applicable laws and standards. Each MC Series™ edition is developed using Microsoft Word and Excel, which is then customized to mirror each organization’s processes, procedures and instructions.

Being user friendly, we have built in numerous hyperlinks for navigating and managing files and documents so that the documentation behaves like a website. This enables each user to access, edit, save and retrieve information instantly.

CIJ: How does your product utilize CMC’s, FDA, ISO, FOCUS, AHPA and EPA standards to help business owners?

Michael: Businesses handling cannabis are subject to strict regulations and are expected to show full compliance with regulatory protocols. Setting up your business correctly means playing by the rules and operating with the proper documentation and structural foundation.

By applying established best practices from the start, business owners will be able to minimize risk for investors, tighten efficiencies and quickly adapt to regulatory changes with minor adjustments. This serves two primary functions: Business owners will now have the protection they need and the means to promote their brand as a world-class operation.

Because laws surrounding cannabis are in such a state of flux and revision, what is most valuable to know is what technical documents lawmakers select for the purpose of writing regulations. Putting this knowledge to work, the MC series uses a variety of guidance documents designated by regulatory and standards bodies for best establishing compliance.

Developed with regulations in mind, each series edition accurately defines the scope of applicability required for your business model. Whether you’re a grower, processor, cannabis testing service or dispensary the MC series has a solution. It significantly helps business owners to achieve compliance by providing the required documentation with an operations framework.

MC series merges regulatory best practices with internationally accepted standards to deliver a complete solution with a very quick turnaround time. Designed to ensure public safety and protect human health, the MC series provides a much-needed tool that bridges the gap between compliance and profitability.

CIJ: How might you be ahead of the curve in looking toward a rescheduling or a schedule 2 cannabis framework?

Michael: Being ahead of the curve simply translates to knowing the regulatory landscape and what’s involved moving forward. When the goal is to legalize cannabis for its great many uses and benefits, public health and safety must come first. Now is the time for business owners to get serious and effectively address the process of legitimizing it.

As with anything available for consumption, standardization is the method and regulators have a long established process for putting controls in place to ensure the health and safety of consumers. We have a lot of experience in this area, and our MC Series™ is an exceptionally useful tool for people who don’t. It is our way of contributing to assisting and accelerating the process.

Essentially, we are saying to business owners, operate your business as if cannabis is already legal. Managing your operations in compliance to existing regulatory best practices will speak volumes to lawmakers. You will be effectively demonstrating to Federal and State governments that you understand the importance of regulations to ensure public health and safety and are making compliance top priority.

This will make your business fluid in relation to regulatory changes and prepare you for Schedule II and beyond.

CIJ: Why should business owners be proactive in navigating regulatory compliance with a documentation management system?

Michael: With so many regulations targeting the cannabis industry, it is hard to keep track of and adjust accordingly. Many business owners are getting excited about being involved and making a difference. Amidst all this enthusiasm, the importance of best practices is often times overlooked and prioritized for when business is good and finances improve.

At this point, business owners can no longer afford to position best practices for future use.

For businesses handling cannabis, taking a future stance will always increase risk.. This leaves you legally exposed to unforeseen costs and complications. More importantly, it will exponentially increase the potential for watching your investment, hard work and business be out paced by the competition, or even worse, closed down permanently.

Alternatively, being proactive will yield different results. Great benefits will come by adopting and following best practices to operate your business. In doing so, you now have an effective method to ensure quality, health and safety, environmental stewardship and sustainability. As a rapidly growing industry, these areas of discipline are absolutely critical for cannabis to reach its full potential and be fully accepted.

In many industries, legitimate and successful companies see best practices as simply part of doing business. Many see it as a tool that provides a useful roadmap for continually improving their operations and strengthening their position in the market.

When the legal obligations have been taken care of, success becomes a matter of setting realistic goals, planning well and delivering with impeccable timing. Operational performance can now be measured and improved for unhindered growth. Everyone involved or tied to your business is now on the same page and in areas of supervision, micromanagement is replaced with a documented system. Documentation should clearly define everyone’s roles and responsibilities, so that when errors occur, there are corrective action procedures available to fix them.

Editor’s note: For more information you may reach out directly to Michael Shea at 313-303-6763 or info@conformanceware.com

April 12, 2016

Soapbox

Bridging the Gap: Doctors, Education and Compliance

By Aaron G. Biros

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Doctors are still very hesitant to recommend cannabis in medical treatment of their patients. A key aspect missing from the medical cannabis industry is participation from physicians and the medical community. Cannabis’ Schedule I drug status blocks medical research and leaves a stigma in the medical community. Doctors are concerned with the implications of recommending cannabis, the possibility of losing their license to practice and most lack any formal education in prescribing cannabis. The DEA’s recent announcement to consider rescheduling cannabis this year could dramatically impact doctor’s willingness to work with the drug.

The DEA’s plan to release a decision on the matter represents a major shift in attitude toward treating patients with medical cannabis. This could very possibly culminate in the rescheduling of cannabis, which would allow for more medical research, including clinical trials. Dr. Scott Gottlieb, board-certified anesthesiologist and pain management specialist from Pearl River, New York, believes the bigger obstacles for doctors prescribing cannabis include the stigma associated with it, legal concerns and physicians’ lack of education. Dr. Gottlieb has practices in both New York and New Jersey where he recommends patients cannabis. He believes there should be some type of recourse to help physicians circumvent legal issues. “Some of the bigger legal concerns regarding cannabis surround complying with state regulations,” says Gottlieb. “That sort of compliance includes confirming the diagnosis of the patient with thorough documentation, making sure it is an approved condition to treat with cannabis, documenting continued treatment of the illness and clearing the patient of any contraindications.”

Dr. Gottlieb believes it should be a collaborative effort on behalf of states, dispensaries and patients working to help educate doctors on the legal concerns surrounding the recommendation of cannabis. “Physicians are not taught anything in medical school about dosing or the medical effects of cannabis,” says Gottlieb. “With more education we can get rid of the stigma and get physicians aware of the potential benefits for their patients and the ability to control dosage in medication.”

Currently, there is very little communication between doctors and dispensaries in New York. A collaborative effort to educate all stakeholders involved could help get more doctors involved and streamline the entire process. “Doctors want patients to feel comfortable and know what to expect in receiving treatment with cannabis,” continues Gottlieb. “Which will come with a more transparent system, involving patients, doctors and dispensaries in a conversation about education.”

Pointing to the success of doctors actively recommending cannabis could also facilitate doctor participation. “The number one reason why I recommend cannabis is that I have a number of patients that use it to successfully treat their conditions and completely eliminate their opioid regiment,” says Gottlieb. That kind of success in a treatment should grab the attention of physicians as what could possibly be best for their patients. With more education and research, doctors will gradually feel more comfortable recommending cannabis to their patients.

April 6, 2016

Colorado Distributes Consumer Education ‘Good To Know’ Kits

By Aaron G. Biros

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The Colorado Department of Public Health and Environment (CDPHE) launched the Good to Know program in January of 2015, aimed at educating the public on consuming cannabis responsibly. The CDPHE developed a free kit for retailers that will be distributed this week, hoping to reinforce safe and responsible experiences with cannabis at the consumer level. Intended specifically for recreational cannabis retailers, the educational materials will be distributed at the point of sale.

According to the CDPHE, last year between April and August, Colorado saw a 28 percent increase in retail cannabis sales. In anticipation of a period of high demand this summer, the ‘Good to Know’ retailer kits are being distributed this week. According to Ali Maffey, CDPHE policy and communication unit supervisor, the state is mailing 100 kits to additional retailers ahead of cannabis-related events, such as April 20^th, which are expected to bring an influx of tourists.

The takeaway information cards in the kits display frequently asked questions regarding edibles and secondhand smoke, as well as advice for appropriate legal usage of cannabis. “The educational materials can help guide bud tenders through a conversation with a consumer to prepare them for the effects of cannabis, dosage considerations, using caution with edibles, driving impairment and the risks of second hand smoke,” says Maffey. “Voters passed the legalization of cannabis, and as the state health department our role is to educate on the safe and responsible use of cannabis, while safeguarding public health.”

The continued efforts by the state for consumer education could highlight an important push for safety. “We have been talking with other states about what works in our messaging and they are all looking at public education campaigns as well,” says Maffey. In this respect, Colorado is leading the country in educating consumers on safe, responsible and legal cannabis use.

February 2, 2016

A Q&A With Christian Hageseth: Innovate or Die

By Aaron G. Biros

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Christian Hageseth, founder of American Cannabis Partners, Green Man Cannabis and the Colorado Cannabis Ranch and author of “Big Weed,” gave a presentation at the recent High Times Business Summit titled “Innovate or Die.” During the session, he discussed at length why industry leadership in innovation is key in determining the progress and growth of the cannabis industry.

His company, Green Man Cannabis, has won the Cannabis Cup four times and he has been a partner at five dispensaries and six grow operations. He is currently a partner at two dispensaries and two grow operations and he is a founding partner of a medical research group in Israel. Christian Hageseth has years of experience working with cannabis in a number of capacities that has culminated in a keen eye for understanding the cannabis industry. We sat down with Hageseth to learn more about some of his expectations for the industry’s future.

Cannabis Industry Journal: Can you discuss why you decided to take your research group to Israel?

Christian Hageseth: Obviously the United States has barriers to medical research on the plant, so it is seriously lacking the ability to discover more about the plant. We know the NIH [National Institutes of Health] has been helping Dr. Raphael Mechoulam in Israel to study cannabis and THC for the past 35 years, even though this is not permitted in the United States. Israel is willing to allow the research in an open format. We will be able to get an independent review board and the ability to work with institutions in Israel.

Christian Hageseth, founder of American Cannabis Partners, Green Man Cannabis and the Colorado Cannabis Ranch and author of "Big Weed" — Christian Hageseth, founder of American Cannabis Partners, Green Man Cannabis and the Colorado Cannabis Ranch and author of “Big Weed”

CIJ: What kind of research are you looking to accomplish?

Christian: We are researching what cannabis formulation and delivery mechanism would work better than what is available for certain ailments. The research should initiate in March with the goal of reaching clinical trials in the future. We are looking to study the treatment of five ailments with cannabis: migraines, joint pain, insomnia, irritable bowel syndrome and psoriasis.

CIJ: How do you think your research will help people?

Christian: I own dispensaries, and I see people come in and ask for advice on how to treat their insomnia or migraines all the time. We want to be able to recommend something that will accurately treat them. Simply recommending an indica or sativa strain is such a hollow answer for people that are actually in physical pain and need precise treatment. We want to be able to provide the real answers to people seeking help.

The Colorado Cannabis Ranch will be the first cultivation center in Colorado to offer educational tours, similar to a brewery or winery

CIJ: Switching gears a little, how is progress on the Colorado Cannabis Ranch?

Christian: We are ready to break ground on the Colorado Cannabis Ranch (the Weedery) in the beginning of March this year. We expect greenhouses at the Ranch to be operational by July along with a summer concert series a little later.

CIJ: Looking at the cannabis industry as a whole, where do you think innovation will come from in the near future?

Christian: Emerging medical technologies will have the greatest impact on the industry. Nanoparticle delivery systems for sublingual drug delivery are one example of biotechnology that I foresee having a major impact. I can expect some major innovations in some of the process technology around extraction. The technology around extracting specific and separate cannabinoids in particular will get refined more and more. The industry as a whole and market expansion will be driven by product development.

December 3, 2015

Consumer Trends: Analyzing Oregon’s Dynamic Markets

By Aaron G. Biros

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Oregon was the second state to legalize medical marijuana in 1998 behind California that introduced legislation measures two years earlier in 1996. In the past two decades, Oregon has grown its medical market, treating more patients and producing exponentially more cannabis. Since October 1^st of 2015, Oregon’s recreational sales have been made legal, creating potential opportunities for dispensaries to target this emerging market.

In that first week of recreational sales alone, dispensaries in Oregon made over $11 million in revenue. That figure is more than double what Colorado made in its first week and significantly larger than Washington’s figures posted.

puregreenpdx — The exterior storefront of PureGreen in Northeast Portland, Oregon

Matt Walstatter, president and founder of PureGreen, a dispensary located in Northeast Portland, Oregon, says that while recreational customers are limited to seven grams of flower per day (no concentrates or edibles yet), they have noticed an uptick in sales of certain strains.

“Up until October 1^st of this year, our sales percentages have been very consistent with about 66% to 72% flower sales since we opened and around 20% concentrates and 10% edibles, with the remainder consisting of topicals and non-medicated products,” says Walstatter. “Now we have an influx of a new type of customer so we do around 80% of sales in flower since the introduction of recreational sales on October 1^st.”

When analyzing the top-selling strains, Walstatter’s figures show an inclination of customers and patients to prefer high-THC strains when buying flower. Girl Scout Cookies, a very high THC, low CBD strain, consistently sells the most at over 2000 grams per month. “People that smoke flower generally want high-THC strains, while people that seek CBD overwhelmingly do not smoke as much and prefer ingesting edibles, tinctures, capsules or other products with low THC content,” adds Walstatter.

PureGreen keeps a select few high-CBD strains on their shelves, including Cannatonic, which is known for its approximate 1:1 ratio of THC to CBD. “Out of twenty five strains on my shelves, I usually keep two or three high-CBD strains because they have their niche, even if they are less sought after, it is certainly worthwhile to carry them,” says Walstatter.

“Because Oregon has such a well established cannabis culture with less novice customers than other markets, our more popular strains are consistent over multiple months so we built a brand around knowledge and education,” Walstatter says. “Our budtenders usually come from a background involving the plant whether they were involved in cultivation, trimming or processing, and then they go through extensive training to be able to recommend certain strains for different ailments or preferences.”

Walstatter offered some tips for dispensary owners and employees at the Las Vegas Marijuana Business Conference in November where he sat on a panel with other industry experts called What Patients and Consumers Want: Strain Trends, Product Mix & CBD vs. THC. “Understanding your customer’s needs and their buying habits plus properly managing your inventory is the key to success,” says Walstatter. “We have a couple of exclusive growers that went through an extensive review process, they tend to rotate through different strains while we have some grower-specialists that grow only one strain very consistently.”

Walstatter prides himself in his team’s exceptional customer service. “People do business with people they know, like and trust, so authenticity is very important to us,” he adds. “Over delivering on value in the form of knowledge, expertise and service is crucial to growing your brand and business.” Having a high quality product mix, knowledgeable staff and inviting atmosphere are a few of the ingredients to running a successful dispensary.

“It can take up to six months or longer to bring a new strain from seed to sale, so if it is a popular strain, it is very important to have a backup grower,” Walstatter adds. He likens his dispensary to a farm-to-table restaurant where the menu is constantly changing: “This time of year, there are some greenhouse and outdoor crops that do well on the shelves but strains can go in and out of season.”

While edibles and concentrates are not yet available for recreational sales, state regulators are closely monitoring other state’s rules and progress to map out a timeline for their introduction. This would effectively create another new emerging market, opening up potential opportunities for dispensaries in Oregon to diversify.

October 19, 2015

A Dispensary’s Road to Success

By Aaron G. Biros

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The Herbery, a dispensary with two locations in Vancouver, Washington, is currently awaiting medical endorsements from the state for both locations. The two co-founders, Jim Mullen and Rick Zahler, found a credit union to work with them, Salal Credit Union in Seattle. “There are five dispensaries in the Western part of Vancouver, so it is quite a saturated market,” says Jim Mullen. “But we have drawn considerable business and are very happy with the success of our two locations.”

It has not always been like that, says Mullen. There are several key ingredients that go into launching and operating a successful dispensary, all of which pose significant barriers to entry in an extremely competitive retail market. Rick Zahler won the second and third positions in Vancouver for the state i502 retail licensing lottery. Zahler has more than 40 years of experience in franchising restaurants, a background that gives him a competitive advantage in scaling up his business.

Mullen and Zahler formed a partnership in early 2014 and by that summer they had finalized their lease agreement, converting an old restaurant into their flagship store. They hired local architects, contractors, and CPA’s and began looking for staff. “We set out to find the best people who could provide a level of customer service that this industry needs to be recognized as a mainstream business,” adds Mullen.

“We are changing the perception that you have to go into some back alley store to buy your pot,” he says. “We have a very attractive, well-lit storefront; we get complimented on the look of our stores all the time, one woman called us the Nordstrom’s of dispensaries.”

Before the doors opened, Mullen and Zahler worked long and hard to find growers, manufacturers and processors that met their standards. “We wanted to fill our display cases and shelves with premium cannabis, so we found really high-quality indoor, outdoor and greenhouse grows across the state,” says Mullen. “We go out and do site visits to see firsthand what nutrients they use, along with their standards and practices, to really size up our suppliers and verify they are giving us safe and high-quality products.”

budtenderpic — A bud tender helping customers at the dispensary

The Herbery hit some early obstacles as the market in Vancouver became highly saturated with dispensaries like New Vansterdam and Main Street Marijuana grossing well over $1 million each in revenue in May 2015.

“Our competition received a lot of media coverage and brand recognition early on. We had to side-step that with heavy guerilla marketing including handing out cards and flyers on street corners,” says Mullen. “We continued to push our social media marketing campaigns, slowly building a clientele with quality products, affordable prices and good customer service.”

Of all the roadblocks they hit, Mullen said the toughest aspect of getting started has been simply “letting people know that we opened and where we are.”

“There are fairly strict marketing rules, and staying compliant is difficult when you are trying to get your name out there,” Mullen adds. “We have been doing what we can with billboards and ads in magazines, but really word of mouth has gotten us far.”

budtenderpicdispensary — A bud tender can give recommendations on different strains or advice on consuming edibles

Looking forward, Mullen wants the ability to market in a manner that is similar to other mainstream businesses. He is also excited to get endorsed to sell medical cannabis. “With so many people seeking high-CBD products for a variety of conditions like fibromyalgia, chronic pain, anxiety, and more, we want to help patients get access to the medicine they need.”

As cannabis continues to be studied for its true benefits, Mullen anticipates significant advances in knowledge to occur within a very short timeframe.