Comment on the DEA IFR regarding synthetic THC analogues and WIP

https://www.regulations.gov/comment?D=DEA_FRDOC_0001-0291

Comment above

Here’s a template

DEA D8 Template .pdf (27.1 KB)

Thanks to @r33fermadness for compiling this

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“recent” is not an accurate term whatsoever. In the DEA’s opinion, it was scheduled long ago. Any reasonable person can expect they didn’t intend nor explicitly state that synthetically derived d8 thc was legal, and it remained on the CSA the whole time, now, if you could get THCA synthase to start spitting d8 instead of d9 you might have an argument, as its hemp derived, not synthesized from a hemp derived chemical. but, ianal

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Can someone fix the google drive link?

The previous template seems to be gone.

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Copied the original reposted as a pdf. We might want to modify it some

I made another here if people want it to have an assload of detail

EDIT: There is specific mention of states that are highlighted in red. just add your state in there and erase the red stuff unless you want to change the numbers for your state.

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Forum: Should Phils revision be. The primary one?

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To ensure proper handling of comments, you should reference “ RIN 1117- AB53/ Docket No. DEA-500 ” on all correspondence. (cited from Rod Knight below)

Also – Rod Knight’s arguments are far better, and directly supported; I would use Rod Knight arguments v those in this document which are thin and unsupported.

https://cannabusiness.law/dea-just-dropped-a-bomb-on-the-hemp-industry-part-1-hemp-extract/
https://cannabusiness.law/dea-just-dropped-a-bomb-on-the-hemp-industry-part-2-delta-8-thc/

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You contributed to the fall of d8 now you want to help lmfao.

Directed at Steve aka d8carkking

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How, by creating an open source forum or by organizing some of the leading scientists to do RnD on achieving compliant D8 while never selling a drop of it?

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Boss shit

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The DEA lays out plans…It appears as marihuana production increased 575% between 2017-2020 the DEA got cold feet.

DEA Hearing on Cannabis Policy for the New Decade CLEARED_0.pdf (223.3 KB)

We need many dif docs pdf in Google drop that helps uneducated understand some critical view points. Blast critical info to the masses

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@Briancollins is responding to user @D8CartKing

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Makes much more sense. Apologies @Briancollins

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Sorry that was directed to Steve aka d8cartking

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I’m not about hate I give people opportunities to be “Good and civil” I tried to communicate with D8cartking about sharing some proverde lab results to compare with his tests of 3chi natural D8 and I never received a response from him it’s been days…I also shared it with KCA.

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"The DEA has overstepped its bounds and misinterpreted the 2018 Farm Bill. Specifically, the 2018 Farm Bill includes hemp-derived “cannabinoids” and “derivatives” in its definition of “hemp”. In other words, cannabinoids and derivatives of hemp are themselves “hemp” under the statute. For this reason, a derivative of hemp-derived CBD is itself “hemp” under the statute.

Additionally, the DEA’s prohibition of “synthetic” THC is improper because the Farm Bill itself contemplates that synthetic cannabinoids will be exempt from the Controlled Substances Act (CSA). The Farm Bill expressly removes “derivatives” of hemp from the CSA. The Chemicool Dictionary defines a derivative as “ a compound that can be imagined to arise or actually be synthesized from a parent compound by replacement of one atom with another atom or group of atoms.Wikipedia defines a chemical derivative as “ a compound that is derived from a similar compound by a chemical reaction.” In this context, a “synthetic” cannabinoid from hemp is the same thing as a “derivative” of hemp. Thus, stating that all synthesized THC is illegal, including D8 and other forms of THC that do not contain more than 0.3% delta-9 THC, is a direct contradiction of the statutory language in the 2018 Farm Bill, which expressly removes hemp derivatives from the CSA." I like this explanation from his article. Is this appropriate to put in my comment??

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They wouldn’t let you win this. It’s THC. The alphabet boys HATE clever fucks.

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