Bump.
Because I doubt everyone in the OR rec market is actually ready for this roll out.
I know I’m not…
Edit: on the bright side, OLCC claims they’re (or will be) good with putting 10kg into decarb, and getting 8.7kg out with no need for “waste” or “moisture loss”…so long as you’ve got that documented in your SOP.
…and they agree they need a sandbox, but are not clear franwell will get it operational before this goes live.
It seems like they’re doing their best to stop people from “wasting” product out the back door, which I support. The problem lies in the absolutely clunky way they’re proposing to do it.
Seems simple enough for a regulator to go into a lab, develop a fundamental understanding of workflow and processes, and develop a framework that’s conducive to their goals.
Not sure why they’re not doing that. Money if I had to guess.
To me it seems there’s more confusion in the wording than the actual intent and purpose.
Looking at the training videos that were posted in this thread you’d simply log your process and each process would fall under
A process that removes weight (extraction)
A process that adds weight (incorporation)
The final product would still be whatever product you choose to call it. Just for metrc data collecting you’d be logging each individual step.
Doesn’t seem too complex and ultimately will drive better understanding for regulators.
Nomenclature and redundancy mitigation training for regulators sounds awfully nice all of a sudden.
Having to use 4 or 5 METRC tags to go from biomass > cart seems a bit excessive and causes more confusion than efficiency imo.
In MI we have to weigh crude extracts straight out of the machine, by end of day. Regardless of the fact the crude still has some amount of solvent in it, and will inevitably lose weight. As opposed to, weigh it when it’s done purging so you have an accurate assessment of the true weight of the extract.
Well, now I have to either adjust the tag or I’m out of compliance. Redundant.
Also, these tags are just more plastic trash that we as an industry already produce, those 2-3 tags between extraction and final product just end up in the trash.
Yep. Franwell has had 10years to get this right, and this change is coming from OLCC not metrc.
Listening to stakeholders to figure out how best to track what’s actually going on would mean hiring programmers… so I suspect you’re dead on. It’s all about $$
Totally agree…I was vehement that we needed Organoleptics: In House QC? during OR’s original rule making. Not sure if others have that. Hope so, but ?!?
I gave up on the metrc user group because the push back from franwell on the “location” field had me incensed enough that I told the then CEO in a phone conference that taking thousands of dollars to “track the cannabis”, without a location field, amounted to interstate fraud as far as I was concerned.
I think it was year five they finally added it.
I don’t see where they are saying you’ll have to create multiple tags for each product.
My understanding is you log the processing job in the metrc program. Metrc tags are only used for finished products.
You may come into a scenario where you take a strain and split it into two different types of extracts from the same batch. Say you turn half into shatter, half into sugar
You may need two tags in that scenario but I don’t think you’ll need a tag for biomass, crude oil, finished product.
Sorry, I’m working under some presumptions that our METRC timelines are the same.
Here, it goes crude tag > HTE tag > cannabinoid/sugar tag > decarbed oil tag > recombined HTE & cannabinoid tag > filled cart tag
I’d much rather just go crude tag > filled cart tag
How would you rate those trading videos?
It may be the case, I would agree that it’s stupid if it is. The process job logging makes sense, multiple tags not so much.
The training videos were meh. Not great but not terrible I guess.
I may be going overboard with the tags, but I don’t think so. Last bit of info I was told by regulators was that if anything was done to change something from one form to another, that a tag must be made to dictate that change by end of day.
Really annoying when there’s a 300lb batch I want to extract over the course of multiple days, and I have to make multiple crude tags just to eventually recombine them when the whole batch is done.
Makes doing different strains on different machines a headache.
I understand. It’s hard to know for certain what they want until they want it. So long as you’re trying to understand the compliance, there’s usually some flexibility from their side. Obviously their intention isn’t to shut people out with complex regulations so there may be a learning curve for all of us.
Luckily I’m in the process of leasing a shop for a license transfer and by the time this rolls out, I will have to do metrc training anyways.
Hopefully it will be ironed out for you guys by then but if not I’ll be glad to share my training experience on the matter when that time comes.
What’s more concerning to me is that metrc gets to have all the trade secret information that we’ve been protecting for years to have an edge on the market and secure our importance. Hopefully this isn’t a step towards a widespread compliance masterclass in the future but for now I’d say their intention is to simply understand how we get from A to B and as always, metrc will compile that information to seek abnormalities and issue violations. At least that’s my take but I’m a paranoid stoner
Every time you make something - meaning you have a WIP from a processing step, you are creating a tag. Its right there in their guidance document and presentation on how to make this stuff.
So you have Crude - you have a tag. Just decarbed, you have a tag. You have Distillate now, you have a tag. Oh and you have a tag for your residue. And you have a tag for your batch of homogenized disty with terpenes. And you have a tag for the carts you put that flavored disty into.
You already had to have a tag for the biomass… so yeah. Could be a lot more tags. Especially if you are having a lot of different process steps.
Just remember - you don’t have to put your trade secret stuff in. You literally just reference your own documents - your SOPs in the process step, without actually saying how you are doing it. 
I just re read the guide and didn’t see the need to draw new tags for every processing job. Seems like only packaged goods need tags but I could be wrong
Can you show me where it says that? Not being condescending, just curious and i have to do tags eventually
Sure. Page 9, 10, and 11 talk about the process for creating packages from Processing Jobs. This is necessary to get material back out of the processing job. Material in the processing job is locked down, you cannot use it anywhere else until you pull it back out either as a package or as waste.
Here’s the section that says you have to get everything out using packages OR waste. 
Does that imply to you that “vanished into the atmosphere” will suffice for decarb?
we puts 10kg in
We gots 8.7kg out
Transfer losses account for 67g
My bet is METRC will barf unless I somehow “adjust” for that mass (as they should)…I will be truly amazed if I can specify it as other than “waste” or “moisture”.
Despite being told otherwise by OLCC yesterday…
I hoping they show some comprehension of “solvent loss”, as they explicitly ask “is solvent in this step?!?”
…and they’re trying to get a sandbox up before this goes live?!?
Maybes we can “package” the CO2?
Sell it as “cannabis derived” to the folks claiming CO2 extraction is solventless…”no non-cannabis derived solvents”.
You don’t package the CO2. But the weight is gone and its not in a package which makes it waste. And CO2 is a waste product of the processing step. There is a process for this, and its covered in the guide (how to handle wastes). This could be biomass waste, solvent waste, residue waste (that you are then handling as waste with your waste SOP), Co2 waste, etc.
Its in your PROCESS JOB, which you are defining. There are plenty of ways to define it, including a very elaborate (other) if you wanted. And you just drop in your SOP number and call it good for those process steps for those that are worried about IP being stolen by METRC or something like that…
There’s no reason METRC should barf for this - that’s what this new processing tool is supposed to be about. Increasing/decreasing weights from process steps.
If we don’t assume that everyone else are idiots… then we can use the tool they have given us to do these things. They don’t need to be rocket scientists, and hell we don’t want them to be. The more they know, they more they will regulate. The more they will regulate, the harder it will be to maintain the status quo - AKA them not knowing enough to come in and tell you that you can’t do something because reasons.
I have my next METRC work group in about 2 weeks. I’ll ask some clarifying questions, but really other than the system requiring a fuckton of additional tags, without really having any additional tools that streamline my work, seems like it covers all the important database bases… And its flexible (similar to adding plants and items…) which is also nice.
Wow, I didn’t realize that they wanted you to assign a package for an unfinished product. That’s where the disconnect for me was. I figured they referred to package as an end product.
What do tags cost for processors these days? Or did Oregon opt out of tag fees?
How much do the tags cost? Plant tags are . 45 cents each and package tags are . 25 cents each .
That’s from METRCs website for Oregon.
