The United Food and Commercial Workers Union, Local 1000, our affiliated unions and International Union, stand in favor of Texas’ Compassionate Use Program to give patients with intractable epilepsy patients access to low-THC cannabis oil that is high in the non-psychoactive compound cannabidiol (CBD).

UFCW supports this law – and its fair implementation – for two reasons. Firstly, UFCW has had a more than three-decade commitment to the eradication of childhood cancers like leukemia. Our union members have donated tens of thousands of volunteer hours and raised millions of dollars on behalf of the Leukemia and Lymphoma Society. In every conceivable way, we stand by children of every class, social status, race, gender, and sickness. The alleviation of pain and suffering has been one of our union’s primary goals in terms of our commitment to improving the community and this Compassionate Use Program fits squarely within our goals.

Secondly, our union is a voice for workers in the medical marijuana industry. We are committed to raising standards and professional stature for all marijuana and hemp workers. Workers in the medical marijuana and cannabis fields are coming together to shape an industry that will provide good jobs while serving the needs of our patients. Through collective bargaining, workers are ensuring better training, less turn over, and better pay and benefits. The UFCW represents thousands of medical cannabis workers in six states and the District of Columbia.

It is for these reasons that we register our formal displeasure with proposed rules by the Texas Department of Public Safety governing the Compassionate Use Program. DPS proposed rules make it prohibitively difficult for businesses seeking to operate under this program. DPS proposed rules would, in effect, bar patients with intractable epilepsy from accessing a medical treatment that was approved for them by their representatives in Austin and signed into law. In particular we find three proposed rules particularly onerous:

  1. A proposed $1.3 million licensing fee
  2. Limiting licenses to 3 (from 12)
  3. Demanding a seven-day-a-week presence of DPS agents at dispensaries

The raising of fees, limiting of licenses, and demand for constant DPS surveillance and presence at facilities, puts an impossible burden on businesses who desire to operate in Texas and provide access to low-THC cannabis oil to patients with intractable epilepsy. If a business is even able to operate under these conditions, the imposition of these fees will likely raise the cost of the legal cannabis oil. The passing of extraneous and unjust costs onto patients is unfair and against the spirit of the Compassionate Use Program. The limitation of licenses puts an undue burden on socially responsible Texas small businesses interested in operating in this space, which in effect puts government’s thumb on the scale in favor of Big Cannabis conglomerates. Lastly, the requirement of a DPS staff presence at cannabis-growing facilities is both unnecessary and infringement of the rights of businesses to operate without the surveillance and intrusion of government into their proprietary methods and practices. There are no public safety concerns at similar facilities in other states.

These rules place undue burdens on small businesses in Texas and puts Texas patients at risk of not receiving medical treatment that could limit their pain and suffering. These rules should be revised and fairer rules promulgated that allow small businesses in Texas to operate under the Compassionate Use Program to provide low-THC cannabis oil to the patients who need it. Our union stands by these socially responsible businesses, long-suffering patients, and the Texas workers who will staff these facilities.


Anthony Elmo

Communications and Political Director

United Food and Commercial Workers Union Local 1000



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