It does.
I suggested a couple of minor changes.
Suggested changes are in italics
I again encourage the more articulate stakeholders among us let OLCC know what’s up with CRC vs isomerization
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they run the miscella thru dual slurries one of a bleaching clay and one silica before solvent recovery and then into final distillation before sale. most cooking oils are room temp hexane extracted.
You are the MAN!! Not even a half day goes by and people freak assuming the worst then you do the logical step and get clarification and now everyone can relax cause CRC is staying.
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Yes…I take it you have had previous experience trying to talk sense to them…and have found your efforts rewarded.
Give them a direct call…set up a meeting with whoever is in charge.
Go for it.
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Didn’t you mention something at bizzcon about acid activated bleaching clay isomerizing the terpenes?
Wait till Oregon catches on to crc modifying the terpenes, I bet this happens again…
Based on this response @cyclopath received I’d say terpenes count too
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Let’s just say I pushed hard to make sure in house QC was a thing.
I stopped attending the rule making sessions because showing up with a ball-gag installed was (also) deemed disruptive
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If I remember correctly, “water clear” distillate was made by adding clays and the like to the still pot in an attempt to decolorize the distillate. Some components in the distilland were retained, decomposed, rearranged, but d9 also isomerized to the more colorless d8.
Maybe language along the lines “that no additives are to be used above a certain temperature, and never in distillation type manufacturing” could be added?
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I was under the impression that d9 had no pigment as well when truly pure.
D8 is usually easier to maker water clear because you are starting with much less pigment (if using isolate) also the acids and water washes help get d8 clear easier.
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They are just trying to protect their market from isomers… Make sure your procedures don’t make isomers and you are good. Call it filtration media and stop saying it’s a reaction. Vacuum filtration through bentonite is not on their list… Just don’t let it get in the distillation flask and convert.
Agreed that the wording is like a toddler wrote it through.
If you are a hemp licensee in OR, stop fucking making isomers/HHC for fucksake
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What a debate!!!
Well what if i told u that i was hard at work developing a WET CRC process
No powders!
Just liquid liquid extraction
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That is true; starting from crystalline CBD to get to d8, you’re at an advantage in getting to absolutely colorless d8.
But d9 isn’t completely colorless; The human eye can pick out an ever so slight visible spectrum absorption and the molecule when very very pure is still characterized as “almost colorless” wherever I’ve seen it.
Actually, the wording is “nearly colorless”. This excerpt from Duchek’s 2006 tosylTHC patent:
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I suggest not doing this, pesticides, antibiotics, microbes love chicken feathers. I read something years ago in not even using them for compost
I attended all those meetings as well.
and attended meeting with staff at later time as well.
The assumption is you can call in and someone will understand what your are saying. And who ever you do meet…most likely has absolutely
no power to make a decision, concerning detailed chemical nuance ,
and absolutely no control over a policy decision. It is a bureaucracy.
I am sure Mr. Crowley is doing his best.
How many Dept of Ag. licensed Hemp processors in Oregon actually have a dual license from OLCC to distribute? How many are even affected by these rule changes.
From a legal point of view, Hemp is a food that can be processed as a food product to eat…or other wise for non consumption.
Using Hemp based feed stock to produce “artificially derived cannabinoids” is a legal nightmare in the arena of human consumption.
There is no doubt in my mind the lawyer’s advice to OLCC is
“outlaw all artificially derived cannabinoids”…and the wording
as stated is cleverly arranged to cover this problem.
Because the Federal Farm Bill may allow you to make or possess
any chemical derivative of cannabinoid you may dream up,
selling that product for human consumption in an Oregon Licensed Dispensary is absurd. Who is libel for the tort? Have Pfizer come out and give us a talk on that subject. It is only matter of time before a serious lawsuit arises…and I mean one that will destroy the business.
So will regulation destroy the business on the Front end or will it be
a law suit on the back end?
Claiming that such chemical conversions are the result of
CRC “Bleaching Clay” is equally absurd (yes all dirt has some zeolite somewhere)…and needs revision.
CBDA to CBD to THC …natural???
THCA to THC …natural???
“bleaching clays”
Weedo top down
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Seems like he’s trying….
We’ve updated the bulletin on our website, changes in bold italics:
Concentrates or Extracts processed with Color Remediation Column (CRC):OLCC is aware that some Processors treat concentrates or extracts with reactive materials like bleaching clay. Under certain conditions, bleaching clay and other materials may react with the cannabinoids in a concentrate or extract to generate artificially derived cannabinoids. Concentrates or extracts processed in this manner prior to January 1, 2022 can continue to be sold until July 1, 2022. Concentrates or extracts processed in this manner on or after January 1, 2022 are not eligible for transfer to other licensees if they contain any artificially derived cannabinoids.
Seems like clarification to me…
He also stated that this clarification will go out via email
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So this pretty much bans spd >2l it would seem, if the presence of artificial cannabinoids as manufacturing artifacts is the disqualifier
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The elephant in the room, as far as I am concerned, is CBN.
What about the January 1st 2023 date? It seems like they expect updated Federal language at that point.
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it might…but only once the labs are actually required to test for these things. which they’re currently not.
look at this “HHC COA” as a for instance: No oil is currely available
nothing to see here…certainly no artificial cannabinoids detected.
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So basically they are banning crc to raise prices on extracts and just flat out lying about what a crc does in order to do so? Amurica
Without fucking up the terps?
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What terps?
The terps are long gone, i pull those out before i extract.
Like a normal fucking human being.
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