Processing jobs: OR METRC update. Effective 4/14/23

Ok OR, who has their heads wrapped around OLCC’s latest foray into database design?

How you gonna make it work?
you’ve got three weeks…

https://wiki-or.metrc.com/processing-jobs

my first job is to have Steve (ChatGPT) get all our SOP’s up to snuff.

my next is to ask OLCC:

  • is spinning BHO in a centrifuge extraction or infusion?
  • why?
  • does it depend which centrifuge (flacktek)?

Processing Job Types – the OLCC has supplied pre-defined processing job type categories in Metrc as outlined in rule. Each processing job type can have a single job type category. These
categories are:

  • Extraction of cannabinoids” (when the outputs’ weights are less than the inputs weights).
    or
  • Incorporation of cannabinoids” (when the outputs’ weights are greater than or equal to the sum of the inputs’ weights).

hands up those of you who knew this was coming?
hands up those who are ready for it?

anyone think they got it right?
what did they get wrong?!?

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What am I missing? Seems pretty straight forward. Spinning bho in a centrifuge doesn’t add to the weight so it couldn’t be an incorporation of cannabinoids.

Also kind of confused why you would even bother logging the process. Seems like you’d have bho product A, spin it, decarb, add back terps. Weight is still less than what started with creating product b.

I know olcc does things weird so figure I gotta be missing some key info

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Because it has become (3 weeks hence) a requirement…are you playing in OR?

Agreed.

However, I would also argue that it is not well characterized as an “extraction”, as nothing is thrown away.

It’s a separation or fractionation. Not an extraction nor an incorporation imo.

Stirring two runs of the same strain together is also a “cannabinoid incorporation”, which again doesn’t read like anyone one talked to processors before deciding to implement.

Is it a better model than the package shuffling metrc has been offering for years?

Probably…but I’m not convinced it’s going to roll out smoothly, and I’m trying to get ahead of the curve ball I see the pitcher winding up to deliver.

Figured it was worth the heads up for folks at a min.

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Looks like we might get this same thing in Colorado and Michigan as well. Its been part of my METRC workgroup conversation stuff. How to cover WIP with fewer package tags and stuff.

Their training videos are kind of terrible… like low definition, when you need high definition to read things.

But the training guide has some additional clarity…

image

I think the key there is “Incorporation” only happens if there will be no further extraction, separation, of refinement processes. AKA you are making a cart, edible, tincture, whatever. -shrug-

Sure its always frustrating when regulators use words to define things that are different than how we use those same words. That’s why its important that we participate in the process (go to the workgroups, respond to the public comment periods, attend the public hearings, etc…)

I mean how many times have we argued about the simplest terms on F4200? Synthetic? Resin? Every category of dabs for all time? :stuck_out_tongue:

Anyway - I think it cool. Cool as in, I am not sure I would like to use it without actually having to use, but I’m not afraid that it will break the world when it comes to Michigan later this year or next year.

I really like that you can change what happened with the packages, including weights and adding/removing packages from your production batch package using this tool, without having to completely recreate new packages, discontinuing stuff, or calling METRC and begging them to change things. <3

I think its utterly stupid that you have to issue new fucking tags for each WIP step (which we could have done before…) and that this increases the total number of actual tags needed for each process, without adding any additional functionality (besides what I mentioned in the paragraph above) except for perhaps creating a really shitty electronic batch record. I say shitty, cause I will still want to record a FUCKTON of information that isn’t in METRC. So I’ll still have to have a third-party program or a piece of paper to get all of that stuff collected…

But it is NICE that I can potentially maybe… be able to capture and comingle the “cleaning residue” from all my activities that goes into the mother liquor and then get that back out… maybe by leaving a process job open until the very very end when it all gets combined, but I don’t see anything that allows you to combine processing job remnants into one bigger batch without first using additional TAGS, which again defeats the purpose. You could already have created a fucking tag for the 5 grams that is left in your cleaning ethanol…if you wanted and continue rolling that into a new tag for days or weeks… until you finished and came out with a missmash of crude.

I found how you can “reuse” “biomass”…

image

And that is kind of nice… but again, more TAGS. FFS - how many additional tags now, for no additional information. Its like they some how think that the physical tag really matters (does it, probably not…how many people use the actual tag function, I think no one, so really its just the unique number that is needed…)

And they have still fucked the “waste management” section - by forcing you to say that you created 100 good units, when you only created 96 good units and 4 of them were waste… and then saying you wasted 4 of the good units, which never existed. Which means you still have to keep fully separate books to monitor for process and operational efficiency.

I don’t expect much from METRC… they seem to think only in the context of tags… and that’s what OLCC is using, tags to tags to tags to tags - so that they can “track” our processes more, without actually capturing any of the actually useful information, streamlining costs, or creating more inherent quality.

SAD.

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I am only slightly annoyed by this since it means more METRC work. As far as the centrifuge thing, I’d guess it’d fall under “extraction,” but you could also just keep all of your raw material in your processing job until the rocks/sauce are separated and then tag them directly from the extraction as separate products.

I was frustrated the first time I read through it, but after sitting on it for awhile… it’s really not much different from the way I was tracking our processing jobs internally. So it’s a bit redundant, but at least I won’t have raw material tags sitting in METRC as the output moves through the lab.

I agree. I think unless you are adding something to product A, you don’t have to worry about it being considered anything except an “extraction“

For instance adding terps to distillate would be an extraction incorporation.

I think what cyclopsth is saying would be true if you viewed/logged the products as final products vs as in process.

For instance if you separated the hte using centrifuge and then decided you wanted to keep the thca as isolate, got it tested and packaged. Down the road you decide to take this completed product and add hte to it, you’d be incorporating cannabinoids.

But as far as the process goes I’d imagine (don’t know for sure) that you’d just go ahead and consider each step an extraction process unless you’re adding to the weight by putting another product in it.

But

Since these processes are being logged separately you may have to log it like this

Biomass extraction (extraction)
Post processing with oven (extraction)
Sieve terpenes (extraction)
Spin terpenes out (extraction)
Add terpenes back in (incorporation)

Product is ready for sale.

It’s very possible your record it that way as it seems metrc is just trying to get more information about how people are taking product A and reaching product B. After all, metrc is just a giant database of information compiling.

My disappointment is that we’ve gone from shuffling packages to two types of processing.

Sure, it’s closer to reality, but it (again) doesn’t seem like anybody wrapped their head all the way around the problem before hitting go.

How about “decarb”?
Clearly falls under “extraction”.

Except it’s NOT an “extraction” (nor an incorporation) by any rational definition

dude, wanna see me extract some thc from this pile of thca isolate?

Betting we still need to account for the weight loss as “moisture”!!

Terpene loss? Moisture!
Solvent loss? Moisture!

Were this year one of legalization I’d say they missed, but congratulate them for trying, but at year 10 it demonstrates an absolutely pitiful understanding of our work flow.

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Only problem with this being so awesome - is that in each processing step there is a package step, which means a process that was a piece of paper before and $0.25 is now a piece of paper and $1.25. I just hate that its all “use more tags” focused. As though there is not another way to issue unique numbers. Especially when you can print labels for way less than the RFID tags that most people don’t use. I mean - RFID cool. But fuck if you need it for everything all the time…

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Your extracting co2 :stuck_out_tongue_winking_eye:

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I agree. Something like centrifuging terpenes is clearly a “concentration” more than an extraction. But leave it to the man to regulate something he doesn’t understand

Centrifuging is definitely a separation method. Separation methods are extraction activities, like LLE, which is using insoluble liquids to separate things into different groups.

Sure your “concentrating” things of a higher weight from those of a lower weight. But you’re doing it to separate things - to extract them from lower weight materials.

And I’ll say again - there were so many opportunities for people to comment on these regulations. So why not participate in the process instead of just telling people they are dumb. x.X

Got flacktek?

Because refraining from calling them dumb during the process can be so #%*€£#¥ing difficult…

:shushing_face:

Fighting to get an actual location field into METRC took way too much effort…

The mission is to track the mother fucking cannabis, what do you mean you morons don’t have a way for me to tell you where the fuck I put it?

…seriously.

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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.

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…and they agree they need a sandbox, but are not clear franwell will get it operational before this goes live.

:man_shrugging:

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.

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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.

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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.

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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.

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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

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