I appreciate your time and effort on this situation and will definitely co-sign and help out any way I can with your document. I am just not sure this forum is the best avenue to reach farmers, which are the ones the USDA interim rules affect most directly. Wondering what avenue there might be to reach more farmers in-order to inform and get them to take coordinated action.
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There are countless associations aligning with us but how do we vet them? How do we know they are genuine?
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It’s garbage if it did not originate here at 4200
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Now this is how you comment to USDA
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Still working on formulating my comments, I will definitely post here when I do, along with submitting directly to the USDA and my local State and Federal Reps. I found this post very helpful in considering what to focus on.
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All - I’m sure we are echoing thoughts and commentary out there. Just want to cover as many dissent bases as possible.
- The costs for third-party labs to gain registration with the DEA are not limited to the $244.00 registration fee. Labs will have to absorb additional costs for DEA audits. Obviously, these costs will be passed on to the consumer in the form of increased costs per lab analyses. Is that a desired goal of the USDA?
- According to FCIC rules, no insurance can be used if the grower’s harvest exceeds the generally accepted, but completely arbitrary, level of Delta9 THC at 0.3% dry weight. Using “Total THC” numbers will cause many farmers to lose their investment and the small farmers in our area (eastern TN), who’ve farmed tobacco most of the time, cannot tolerate those losses without access to WFRP funds (see attached FCIC Policy and Hemp.pdf).
- “Total THC” is not a legitimate means of determining the legality of industrial hemp. Differing amounts of THCa is converted to Delta9 THC depending upon temperature and time. Inconsistencies in decarboxylation of hemp leads to inconsistencies in “Total THC” values. Many labs use Gas Chromatography (GC) as measurement devices determining cannabinoid content in samples. Operating parameters for GCs will impact the accuracy of “Total THC” conclusions, Additionally, THCa and Delta9 THC are two ENTIRELY different molecules, therefore require distinctly different allowable amounts. In some cases, researchers include unknown cannabinoids in the “Total THC” calculations (See attached .pdf doc #1, Chemometric Analysis of Cannabinoids: Chemotaxonomy and Domestication Syndrome | Scientific Reports). Without a standard that is NOT supplied by the proposed rules, how can consistent measurements be achieved industry wide? How can disputable test results be used to decide the future of farmers attempting to diversify their crop investments?
- While we in the industry have invested a great deal of time and effort in educating ourselves about cannabis, legal practices are very short on knowledge. It will cost enormous amounts of money for the small farmer and small processors to engage legal counsel to argue before a court the consequences of being outside compliance with the proposed regulations. Yet again, this situation incurs higher costs that are ultimately passed onto the consumer.
- There is a fairly obvious, in our opinion, conclusion regarding this regulatory policy - very specific, wealthy, and likely, racially mono-chromatic individuals are the only groups able to partake in this industry. This regulatory policy will cause divisiveness and further economic stratification.
- Given the secrecy under which this Interim Rule was drafted, we are very disappointed in the USDA for not seeking input by hemp industry participants regarding these proposed policies; this erodes our belief the USDA will take our public commentary into account.
FCIC Policy and Hemp.pdf (80.7 KB) Reference Doc No 1 for USDA 11-12-2019.pdf (1.5 MB)
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So far, the site cataloging commentary on this rule has 570 postings. (Regulations.gov).
We, as a self-proclaimed group of advocates for this industry, need to do a better job of countering the USDA’s overreach. Please add your thoughtful comments ASAP.
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Credit where it’s due: I used these 6 points as the general basis for what I commented yesterday. Thank you for doing the legwork on this, you’re a legend.
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What does “except for tetrahydrocannabinol in hemp mean?”
This is the bill that passed the house committee, right?
Unsure because I can’t find that specific section in the CSA…
Yes from the MORE act, that’s what they are calling it
Someone correct me if I’m wrong but it’s it’s just a list of drugs and their groups of scheduling.
Seems to me it’s being removed except for thc from hemp. Which is dumb but I see the legal reasoning.
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112019 Wyden Merkley USDA Hemp Rule Feedback.pdf (207.5 KB)
I think we should all just upload this letter to the comments section. Consistency is key.
In case y’all forgot that the FDA and USDA are data driven organizations… Want to make a difference with this letter? Bring out the data.
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Cutoff to submit comments for this letter will be
Wednesday night, 12/18 at 11:59pm pacific. Gives me enough time to compile and turn things around for a consensus process the following week.
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