In addition to the Class 1 and Class 2 licenses discussed in an earlier post, the University of Georgia and Fort Valley State University have been chosen as designated universities. This means they will have the option to be licensed as a production facility and contract with private companies to fulfill the terms of the license. The enabling legislation, HB 324, allows the aforementioned universities to “obtain cannabis through the National Institute on Drug Abuse [(NIDA)] or from any available legal source.” 

The bill defines “designated university licenses” as a “license issued by the commission … to a designated university to, separately or jointly, produce, manufacture, and purchase low THC oil.” Specifically, the Act states that (see 16-12-204, Sec. A) –

  1. The commission shall issue nontransferable designated university licenses for the production of low THC oil. The licenses granted to designated universities pursuant to this Code section shall be in addition to any licenses issued pursuant to Part 2 of this article. The designated universities shall have the option to be licensed as a production facility, either separately or jointly. The designated universities shall be authorized to contract with private entities to fulfill the terms of the license, including contracting for the production of low THC oil. All contracts shall be approved by the commission.

     (c)  The commission shall collect the following information from each University licensee: 

  • The amount of low THC oil produced by the licensee during each calendar year 
  • The details of all production costs, including but not limited to seed, fertilizer, labor, advisory services, construction, and irrigation 
  • The details of any items or services for which the licensee subcontracted and the costs of each subcontractor directly or indirectly working for the licensee 
  • The amount of therapeutic chemicals produced resulting from the low THC oil manufactured pursuant to this article 
  • The amounts paid each year to the licensee related to the licensee’s production of low THC oil manufactured pursuant to this article  
  • The amount of low THC oil distributed to each dispensing licensee to dispense low THC oil in this state during each calendar year 

Questions still abound as to how much viable data the level of low-THC required by the law will yield for researchers, as anecdotal patient data tends to reveal that higher levels of THC are often necessary for the ostensible “entourage effect” of whole-plant cannabis therapies to be most efficacious. However, the only American university with any history of supplying cannabis to NIDA has been the University of Mississippi, whose cannabis has been assailed by the cannabis research community for cultivating marijuana that is both so low in THC that it does not provide an adequate basis for measuring medically significant results in patients’ outcomes. Ole Miss has also been criticized for offering such a lack of diverse terpene profiles in the cannabis it cultivates for testing that medical benefits are also thwarted relative to what opportunities for healing and better quality of life richer plant profiles could provide if they were also cleared for participation in NIDA’s supply chain. Given this, despite the low THC level set for Georgia’s medical market, it will be interesting to see how the development of research is able to guide the state’s movement toward more and more expansive cannabis policies and regulatory structures over time.