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USDA EXTENDS COMMENT PERIOD

Make your voice known! The USDA has extended their comment period on the interim regulations governing hemp cultivation and CBD production from Dec. 31st, 2019 to January 29th, 2020. If you’d like to learn more or submit your comments be sure to visit the second link below and share your thoughts! We know we have.

Personally I think these regulations are an amazing step forward, and although they do have some issues, they are a step in the right direction. Specifically I think they could be improved when addressing THC testing and registration of producers at the federal level (I can’t believe I even just advocated for increased oversight).

As it stands right now the proposed interim rule would essentially kill the CBD production that has fueled the rapid expansion of the hemp industry. The new rules make it nearly impossible to comply with the new testing standards which are arbitrarily strict from a scientific standpoint. With the new rules measuring both the non-psychoactive (THCa) and the psychoactive (Delta-9 THC) components as if they were one and the same. While we see and fully understand that there is a need a limit on total THC. The proposed (.3% THC) is not that limit and is so strict it is  impossible to be currently complied with when producing for high CBD content. It would be like requiring 110 out of 100 points in order to pass an assignment. Make it 1% total THC as is a reasonable level generally accepted industry wide and in some places is already the current level. This would help producers, consumers, and regulators to all be on the same page and create the framework for a legitimate industry that can thrive rather than being hamstrung before it even develops. These testing limits (.3%) are going to place a huge burden on producers and regulators alike as they scramble to test and comply with an impossible limit.

That being said there do need to be limits put in place. By not limiting total THC, and failing to implement some type of federal framework, we will just be adding to the general confusion and mistrust of the industry that currently exists. We need sensible regulations that help producers, consumers, and law enforcement to all be on the same page and aware of what is and what isn’t allowed. As producers we want to know that the rules we must comply with are actually attainable. As consumers we want to know that those rules are not so lax that anyone can try and produce CBD in manners that are unsafe. As law enforcement they probably just want to know what the rules actually are as they’ve changed more than basically any other over the last 4 years and it can definitely be confusing.

If you’re interested in learning more I’d suggest checking out Oregon CBD’s blog post on the proposed rules. They do a great job of summarizing the new rule changes specifically as they relate to testing and compliance with required THC levels.  https://oregoncbdseeds.com/blog/?post=new-usda-rules-pose-significant-challenges-to-hemp-industrybut-well-survive

Submit your comments! Or be a nerd like me and read the proposed changes in their legal form via the federal register at ​https://www.federalregister.gov/documents/2019/10/31/2019-23749/establishment-of-a-domestic-hemp-production-program#open-comment

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