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“If my dietary supplement is a hemp extract, I’m calling a lot less attention to myself than if I use the exact term that FDA’s already publicly stated doesn’t qualify as a dietary ingredient in a dietary supplement,” he said.

The idea is a plant’s various compounds “work synergistically together to deliver an outcome as nature has created them,” explained Grace, who no longer is employed with CW Hemp, “and that’s always going to outperform any Western medicine-derived specific compound that we may take out of nature and try to apply …. as a drug.”

According to Bluebird’s website, its “Classic Hemp CBD Oil” contains more than 80 different phytocannabinoids. Other substances naturally present in Bluebird’s hemp extracts include amino acids, carbohydrates, vitamins and fatty acids, the company says.

“Any misrepresentations about the content of a product is potentially going to be problematic,” Carvajal observed. “If you say, ‘Contains X, Y and Z,’ and it only contains X, that’s a problem, especially if the consumer would ascribe a lot of value to Y and Z, which happened to be missing.”

Bluebird, Harinen said, began to produce hemp extracts that were standardized for total cannabinoid content rather than just CBD.

Employers can maintain a drug-free workplace and implement policies prohibiting the possession, use, or other consumption of cannabis by an employee, subject to certain exceptions, including existing protections for qualified patients under the state’s medicinal marijuana law. Employers must put such policies in writing and make them available to employees and prospective employees.

Employers can take adverse employment actions based on positive marijuana drug test results when there is reasonable suspicion (as described above), or after a pre-employment drug test or random drug test (only as permitted by existing Connecticut law), when the employer has an established drug testing policy stating that a positive test result for marijuana may result in adverse employment action.

Provisions Affecting Employers

The employment-related provisions of the law do not apply to the privileges, qualifications, credentialing, review, or discipline of nonemployee, licensed healthcare professionals on the medical staff of a hospital or other medical organization.

Governor Ned Lamont signed the Act Concerning Responsible and Equitable Regulation of Adult-use Cannabis on June 22, 2021. Connecticut will permit individuals 21 years of age and older to possess and use recreational cannabis. Individuals cannot possess more than 1.5 ounces on their person or more than 5 ounces in a locked container in their home or in a locked glove box or trunk of a motor vehicle.

Provisions regarding lawful possession go into effect July 1, 2021, but the provisions affecting employers will take effect next year on July 1, 2022.