If you’re a hemp industry professional, you are hopefully aware of the draft Interim Final Rule that was released October 29, 2019. If not, you can read it in full and comment here.
If you’re in the hemp industry and the USDA is able to finalize these draft rules, it could be really detrimental to the entire hemp ecosystem. Phytonyx summarized their concerns with the USDA’s Interim Final Rule, so highly recommend you familiarize with these potential changes and the affect it could have on your business. You only have until Jan 29, 2020 to comment on this rule to reserve your right to challenge it later, so highly recommend you do so if you haven’t already.
I’ll summarize the main issues I’m seeing:
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Pre-harvest sampling by DEA labs only. This is going to create costly bottlenecks.
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Pre-harvest sampling limited to the top two inches of the hemp flower, so sampling is not an accurate representation of the total THC level.
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A 15 day harvest rule is not realistic. Especially if you are limiting hemp farmers to DEA labs, it could easily take two weeks to get your results back alone. Even with mechanized harvesters, it could take a month or longer to harvest.
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Strict 0.3% THC level is based on arcane 1990s era Canadian hemp standards. Nobody is getting high off hemp, we would be better served making this limit 1%.
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3-strike system where hemp farmers that go inadvertently hot (0.5% THC or over) will be given a strike. A hemp farmer who receives 3 strikes within 5 years would be barred from growing or processing hemp for 5 years.
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Thanks Alex, much appreciated summary!
How can we get more involved? This is going full absurdity! As an industrial hemp processing company we look beyond just the cbd and towards the whole plant which can make the raw materials of the new modern civilization. https://jv.gravitaskannavis.com/index.php/hemp-uses/#3history
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Our comment on the proposed rules filed a few minutes ago:
We are building a continuous hemp harvest farm. 100% of the plant is processed green, including roots, stalks, flowers, we separate that into solids, water, and oils. The oils we call an extrication liquor. We do not dry the biomass ever.
We are processing 24 plants every minute, 7x24x365, we do not have seasonal harvests. We also have the ability to isolate and extract the THC from the extrication liquor post processing.
What protocol do you have for continuous harvest operations of green plants for testing? We can easily test the extrication liquor post processing.
If you would like a suggested protocol we can supply one for this use case.
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Thank you so much for commenting, that’s great! We are up to 1,873 comments now, which is fantastic to see. Hoping we can reach the 2,000 comment mark before the January 29, 2020 deadline.
If you’d like to get more involved, please make sure your hemp industry network is aware of the draft Interim Final Rule, the Jan 29 deadline, and the need for their comment to reserve their right to challenge these bogus rules. We are strength in numbers, so hoping we can drive enough outrage that we can influence these rules before they are finalized and do some real damage to the industry.
Thanks for your help!
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Thanks Alex,
I spread the word to our team!
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