February 24, 2020 | By NACE Staff
TAGS: best practices, internships, policy, spotlight, career development
Spotlight for Career Services Professionals
An inquiry by a student challenged Bryant University’s marijuana policy and prompted the career center to spearhead a push to make an exception for the hemp industry.
“Medical marijuana is legal in Rhode Island through licensed facilities, but is not yet legalized federally,” says Kevin Gaw, executive director of Bryant University’s Amica Center for Career Education.
“Thus, we have been advised to not post medical marijuana-related opportunities.”
Bryant’s policy regarding the marijuana/cannabis industry reads:
The Bryant University's Amica Center for Career Education will not accept or post positions related to the use or distribution of recreational or medical marijuana. This includes tertiary positions not directly related to the sale or distribution of marijuana/cannabis but are designed to support or advance the industries. Employers seeking to recruit for such positions at any on-campus recruiting event or through any campus means will be asked to cease and desist, and withdraw from the campus immediately. As the use of marijuana is illegal at the federal level and Bryant University receives federal funds, we must comply with federal law. In addition, the possession and use of marijuana violates the Drug-Free Schools and Campuses Act, is illegal in the State of Rhode Island and Providence Plantations, and is banned on the Bryant University campus.
“It is definitely a growing request as the industry is burgeoning and it is presenting definite challenges because these are legitimate, licensed businesses,” Gaw says.
“Rhode Island law approves the cultivation, sale, and use of medical marijuana, and the industry is tightly controlled and regulated. In fact, some 18 states have legalized medical marijuana. The superseding element always has been that most universities draw a line by saying if they receive federal funding, they don't want to compromise or risk that funding by doing something that is not in alignment with federal law.”
However, as Gaw found out, there can be exceptions. Last spring, a student came to the Amica Center and said he wanted to do an internship at a hemp production facility. Staff initially told the student that there’s a policy against approving such an internship posting.
“The student was prepared and had research and documents, so we listened to him and saw validity in his argument,” Gaw says.
“I told him that we are not going to say no, but we have to get others to say yes.”
Part of the problem that hampers hemp’s acceptance, Gaw notes, is a misperception about what hemp is and how it can be used.
“Some people think that hemp is pot, but it's not,” Gaw explains.
“It is not psychoactive. It is regulated by law by the percentage of THC, which means it cannot have a level that can get you high. When you understand it from that perspective, you realize that it is essentially rope and fiber.”
Gaw read up on regulations regarding hemp and drafted a policy. He also called the state licensing board and explained his work.
“[The state licensing board was] intrigued and thought it was great for someone to ask about internships and industry regulations,” Gaw recalls.
“It helped them tease out their own policies and procedures. They reviewed our hemp exception and said that it looks good.”
Gaw submitted the hemp exception to the university. On August 27, 2019—about four months after the student first inquired about interning at a hemp-production facility—Bryant’s hemp exception to its marijuana/cannabis industries policy was approved and implemented.
“If it's a hemp business in another state, we will still ask for their certification,” Gaw reports.
“It is our job to do our due diligence to make sure that if a student is going to work in that business as an intern, they're going into a facility or a work environment that has been licensed by the state. If it is approved, there's nothing dubious about it. We are very happy and proud of the fact that we are able to support a new industry that is considered a viable and appropriate industry in our state.”
The Bryant University’s Amica Center for Career Education will not accept or post positions related to the use or distribution of recreational or medical marijuana. This includes tertiary positions not directly related to the sale or distribution of marijuana/cannabis but are designed to support or advance the industries. Employers seeking to recruit for such positions at any on-campus recruiting event or through any campus means will be asked to cease and desist, and withdraw from the campus immediately. As the use of marijuana is illegal at the federal level and Bryant University receives federal funds, we must comply with federal law. In addition, the possession and use of marijuana violates the Drug-Free Schools and Campuses Act, is illegal (except where medically prescribed) in the State of Rhode Island and Providence Plantations, and is (except where in conflict with Rhode Island law) banned on the Bryant University campus.
If an employer is a licensed agricultural grower or handler of “hemp” or “industrial hemp” under the Rhode Island “Hemp Growth Act,” R.I. Gen. Laws § 2-26-1 et seq., and the internship or work experience is solely within that specific hemp-based industry, the posting and recruitment can be permitted. The employer must provide the Amica Center for Career Education formal evidence of state licensure prior to posting.
For students seeking a hemp industry internship/employment experience, the State of Rhode Island requires such individuals to be 21 years of age or older and that they obtain a registry ID card issued by Rhode Island Department of Business Regulation. Further, such internship/employment activities must be associated with a Rhode Island Licensed Hemp Farm. It is the student’s responsibility to obtain this registry ID.
Students who are seeking to obtain Bryant University academic internship credit must present formal evidence of their registry ID to the Amica Center for Career Education before starting the academic internship; failure to do so will result in the academic internship being administratively cancelled and any and all Bryant-related fees/costs incurred by the student (e.g., tuition) for this internship will be forfeited to Bryant University. Bryant University shall not be held liable for a student’s failure to follow state law and to obtain and provide evidence of the required documentation. It is the student’s responsibility to obtain and provide their necessary registry documentation.
Outside of Rhode Island
If the employer is located in a state other than the State of Rhode Island, they must provide 1) formal evidence of that state’s licensure, and 2) the relevant state/territory statutes that permit the agricultural production/handling/research of hemp. If the student intern who is seeking academic credit requires licensure or registration in that state, this must be done (and formal evidence submitted to the Amica Center for Career Education) before the internship can be approved for academic credit. Failure to present formal evidence of licensure/registration will result in the academic internship being administratively cancelled and any and all Bryant-related fees/costs incurred by the student (e.g., tuition) will be forfeited to Bryant University. Bryant University shall not be held liable for a student’s failure to follow state law and to obtain and provide evidence the required documentation. It is the student’s responsibility to obtain and provide their necessary registry documentation.Rhode Island Statute References:
§ 2-26-3 - Definitions
(4) "Grower" means a person or entity who or that produces hemp for commercial purposes.
(5) "Handler" means a person or entity who or that produces hemp for processing into commodities, products, or agricultural hemp seed.
(6) "Hemp" means the plant of the genus cannabis and any part of such plant, whether growing or not, with a delta-9 tetrahydrocannabinol concentration that does not exceed three-tenths percent (0.3%) on a dry-weight basis of any part of the plant cannabis, or per volume or weight of marijuana product or the combined percent of delta-9 tetrahydrocannabinol and tetrahydrocannabinolic acid in any part of the plant cannabis regardless of the moisture content. Hemp is also commonly referred to in this context as "industrial hemp."
§ 2-26-4. Hemp an agricultural product.
Hemp is an agricultural product that may be grown as a crop, produced, possessed, distributed, and commercially traded pursuant to the provisions of this chapter. Hemp is subject to primary regulation by the department. The division may assist the department in the regulation of hemp growth and production.
§ 2-26-5. Authority over licensing and sales.
(b) All growers and handlers must have a hemp license issued by the department.
230-RICR-80-10-1 (Rhode Island Industrial Hemp Agricultural Program)
1.9(C) (Registry Identification Card Requirement, Eligibility, Annual Fee and Application)
1. All officers, directors, owners, shareholders, managers, members, employees, and agents of the licensee must apply for Agricultural Pilot Program registry identification cards.
2. Each licensee shall maintain a current list of all licensed cardholders associated with the licensee.
3. Licensed cardholders shall be at least twenty-one (21) years old.
4. There shall be a fifty-dollar ($50.00) non-returnable, non-refundable biennial fee for an Agricultural Pilot Program registry identification card, including each initial application and subsequent annual renewal.
5. Applications pursuant to this section shall be on such forms and through such submission mechanisms as directed by DBR.
Policy Development Resources:
Formal email communication with the Department of Business Regulation, 6/17/19
[HempCompliance, DBR (DBR) DBR.HempCompliance@dbr.ri.gov]
“An intern would need a registry ID card issued by R.I. Dept. of Business Regulation and is associated with a Licensed Hemp Farm and be over 21 years old.”
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