Okay, I'm going to start us off, it's 103 I will just start so that you understand the timeline as far as expectations of how we'll go about today, I'm gonna start by just admitting people. Um, I'm going to start by talking about just the cannabis programs, what that means and where we all sit in the division. We've had some reorganization. So I want to talk to you about that. Then we're going to talk about accreditation, the cannabis labs standard and the accreditation, so the cannabis lab analysis Standards Program, the transition plan, I'm going to go through that, then we're going to take questions on it, if people have any, and then we are going to move into her program updates in that order. So at each interval, I will provide an opportunity to pose questions, it's a lot of me talking, I'm sorry. Try to make it as entertaining as possible. And then feel free to type questions into the chat box. My team at AG if you happen to see people like waiting to be admitted, feel free to admit them into the meeting room.
So I will just start by talking about the division. So the way this all started, the Department of Agriculture has been interacting with cannabis for a very long time. We have a pesticide team. They make the pesticide list. We have a laboratory in Yakima, that it's it's considered our hop laboratory, but they do some compliance testing for cannabis. And so, there have always been kind of a variety of ways in which we interact, have interacted with cannabis. In 2014. There was a hemp industrial hemp research program that got started. And I think there were like between nine and 14 members of it, it was very small because all you could do was research hemp, you could not sell it. But in 2018 when that farm bill passed, the hemp program became a commercial program. And we started off with around 200 ish licensees. We increased to around 220 to 30, probably at the peak. And so the hemp program was a part of our commodity Inspection Division, commodity inspection, inspects grain facilities. We have a seed program and our commodity inspection. And it was just different entities that that get inspected, hemp was something that needed to get inspected based on federal laws. So we did that. That fast forward to last year and we only had about 47 licensees down from 220. So the hemp program was getting much smaller. And at the same time we were we were kind of increasing our involvement in other cannabis activities. We received we were the lead agency to create a cannabis lab standard. And then from there ended up writing an agency request legislation to take on Laboratory Accreditation. And so it made sense for the cannabis program because hemp and cannabis are so similar in so many ways. And so many of the products interact at least it made sense to house them all in under one program, the cannabis programs. And so I'm the program manager for the cannabis programs. Under that directly is the hemp program and the cannabis laboratory analysis program. And then indirectly I oversee the budgetary components of all of the ways in which cannabis interacts with the USDA. So there is some funding that goes to our hops lab that does cannabis compliance in Yakima. There is some funding that goes through our pesticide registration and compliance teams. And so I check in on those budgets and work with Kelly to make sure that the agency has what it needs for cannabis and that we're spending it appropriately. So hopefully that gives you some scope. Now until March, the cannabis programs were all underneath commodity But there was a big change that started around April 1. And the canvas programs have now moved into what is actually a new division. It's called the Agricultural and Environmental Services Division. So Kelly McLean, who many of you know, through her policy work, she might get the chance to join us, we'll see. But Kelly McLean had been our legislative liaison for many years, she worked in policy and specifically maintained the cannabis portfolio for W. SDA for many years. So many of you have actually gotten the opportunity to connect with her already. And she has taken on the position of assistant director of the agricultural and environmental services division. So kudos to Kelly congratulations. And just so you all know, because I'm sure you're nervous. I'm sure many of you have gotten a chance to enjoy working policy with Kelly and Kelly is going to continue to have cannabis and hemp in her policy portfolio. So she will be the assistant director of the Agricultural and Environmental Services Division, but she will also still you will still see her at hearings, testifying on cannabis bills, and and current I work together on cannabis policy, we have been doing so for almost four years now. So that just adds, you know, gives us more time to connect on policy issues hopefully makes things more streamlined and easier for you. So that is the the big change. The other component that I think is really ideal is that like the Agricultural and Environmental Services division includes our pesticide management division, so compliance and registration. It also includes N RAs, our natural resources program. So Ed Ras was actually somewhat involved when the whole DD D D D E. issue came up last year, I worked with n RAS to connect with Department of Ecology and different folks on that issue. So by now having us all in one division together, we just get to interface more. It was great to be a part of commodities, but there wasn't necessarily that like connection and relevance to the other programs within commodities. Whereas now I think there's going to be a lot of great synchronicity and like the fact that all of our scientists and experts on environmental issues and pesticide issues are going to be in one place, I think it'll hopefully streamline your experience as stakeholders. So that is the primary divisional update. The other I guess update that I will provide while in this mode is that I will be leaving on maternity leave in approximately eight weeks for an undetermined period of time. I will be back in the fall. But I do want to communicate to folks, if you do have any like seedlings or sprouts of policy ideas that you want to talk about a strongly urge you to get some time on my calendar in the next eight weeks. Kelly, of course will be here and we'll be taking over the policy component of my role in my absence. However, she's also going to be an ad so she'll be pretty busy. And anything that we can discuss early on is going to be beneficial. So if you have policy considerations, questions, seedlings of ideas, Bill proposals, drafts, just try to get those in front of me in the next eight weeks or so. And so from there, I guess that's the division reorg component. I'm going to move through accreditation and lab standards. But first, are there any questions related to the division reorg?
No, seeing none, I will move on.
So I'm going to talk about our cannabis lab analysis program. And what I'm going to do is I'm going to put the links for like this is the program site and putting that into the chat. We also just kind of did two different wall processes. So I'm gonna send you to our rulemaking page both for the analysis d&d, IRD and which is 16 309. And the accreditation standard, which is 16th return in that way, you can read all the documents, if you haven't gotten to read through the updated rules. They are on our rulemaking pages.
So we filed a 103 on 16 309, the cannabis lab analysis standard, so that was published, which is great news. And let me just look at the deets. On all of that. It looks like the completed rulemaking we filed on 417. So it was or it was adopted on 417. So 16 Three, and I'm updated lab standard is now adopted as a 417. But there, we also filed a policy statement. So there are two sets of rules and a policy statement, it's a little confusing. The first set was writing the standard. So that's 16 309, we wrote the standard that cannabis labs will be held to the second set of rules is 16 310. That's the accreditation standard, standard. So we are accrediting labs, and 16 310, to the standard set in 16 309. And the third thing we did was issue a policy statement, because in 16 310, we describe our transition period. And the reason why we have a transition period is because the new lab standard and 16 309, it's going to take labs some time to get up to standard. And so we want to give them that time so that they can get up to standard, it will also increase their costs in some arenas. And so they need a little bit of time to do that we wanted to provide six months. And so we describe that six months and the transition period and 16 310. However, 16 310 will be adopted after 16 309. So to bridge the gap, we issued a policy statement. And the policy statement just basically tells you that there is a delay in enforcement and implementation of 16 309. So laboratories will need to be up to date with 16 309 by December 31 of 2024. They also will have to submit their methods to us. So you can either use a pre approved method that has been approved by ws da, and can be found on our class website, which is in the chat box. Or you can submit your own method approval. And as of approximately one hour ago, we now have our method Approval Form available for you on the website. So if you want to submit a method for approval, you can do that starting today. And the method approval form is now available. For those of you who don't know, we actually do have a cannabis inbox. We have a hemp inbox, and we have a cannabis inbox. So if you like say do a method approval form, you can send that to our cannabis inbox, which I just put into the chat box cannabis@agr.wa dot gob. And if you have a hemp related question, we also have him in box. And so I have both of our email addresses there for you available.
So to talk a little bit about the transition, and about the accreditation rules for those of you who don't know, we wrote an agency requests bill to take on accreditation and do take on that role of auditing and accrediting labs in place of the Department of Ecology. The things that are different from about our accreditation rule relative to the Department of Ecology role. The big thing you'll notice is fees. Our fees have stayed in alignment with the current fees of RJ Li, the third party contractor so the lab should not be experiencing any major difference in how much it costs for them to get audited. I think probably the biggest change is that because we are a publicly funded group. In the RJ Lee contract if a laboratory wanted to like have a meeting with RJ li group they had they were charged for that time because we are going to have state employees doing the audits and the accreditation. If you want to have a meeting with us. You can do that and we won't charge you. We are hoping that by not being charged for our time and not having you know third party contractor in the middle of that there will be more opportunities for education and to compliance and to work with labs to move them into compliance or talk to them through issues in a way that is not expensive for them. So we're very excited about that. And then the other component is just that we'll have a method approval process which ecology didn't have, I don't think they had kind of clarified the method approval process is more a part of the standard, but that is something to expect. The other difference between our rules and ecologies rules is that ecology intended to a credit by matrix, and they had defined three different matrixes matrices. I think it was like flour, edibles, and oils. Feel free to correct me if I'm wrong, someone. But we have decided that we will not accredit labs to matrices right away. It's not something that we're against in any way, it was more that we weren't sure that the the three matrix types provided were the best way to divide them. People are making a lot of unique products. And so we felt like it was important to provide stakeholders the opportunity. And for us to also work in tandem with the LCB to kind of define together what what different matrices might look like. You can anticipate some more stakeholder engagement on that. Starting probably in January, we'll start chatting with people about you know, what different matrices might look like what it would look like to credit or audit labs based on different matrix types. And then the third arena, so it's fees, if lower fees Wahoo. We're not going to a credit to matrix. And then the the big challenge in and the change it from ecology to AG is that apology said that you had to do pts and matrix like folks needed to use cannabis flour for their high THC cannabis flower for their proficiency testing. However high THC cannabis flower is not available. And so we are allowing him to be used for proficiency testing until cannabis is available. And we may do some stakeholder engagement on what it might look like to to to utilize high THC cannabis and proficiency testing and what our options are. And if that's something that can make sense. The other kind of added component that was a part of our accreditation rules that was not a part of the Department of ecologies was interlaboratory comparison studies. And so we do have the option of creating an inter laboratory comparison store that study so that multiple laboratories could test the same sample. And so we that is something that I'm not sure we'll be able to do in the first year. We're going to have to talk about exactly what that looks like. But we have already started conversations with different PT providers about how we can make that happen.
And so the big thing coming up is really just the transition. So regulatory authority transitions to us on July 1, we are going to continue to use the RJ li group to audit and accredit labs through December 31 of 2020. For what does that look like that basically, labs will continue to be accredited and audited 2314 Dash five five just like they have been in years past. Their accreditations will last for one year. Assuming that they come up to standard. We will have staff from ws da attending all of the audits this year. So they will be there with RJ Lee. But RJ we basically had a contract with the LCB through December 31 of 2024. So what we are doing is on July 1, we will start a pretty much identical contract with RJ Lee. That will go from July 1 to December 31 of 2024 and they will be doing the same work. And it is my understanding that the LCB will terminate their contract with RJ Lee on June 30. That is the plan as discussed mostly Recently, we are also doing what we call a direct buy a short and small contract with RJ Lee, that I believe is being executed, perhaps today. And so that is just from right now until June 30. So that we can call RJ Lee talk to them, have meetings with them, discuss scheduling with them, discuss the transition with them, and they can bill us for their time. So we are contracting with them immediately just so that we can have those conversations and and talk about the plan. And then from July 1, we will have the contract ourselves directly with them is the plan. And then after December 31 2020, for RJ we will exit and it will be our team conducting audits and accrediting laboratories in full. As you know, in the accreditation rules, we do ask that all methods are validated and that we received validations. I think it's November 1. My team can correct me if I'm wrong. But we basically want to be able to see that laboratories are coming into compliance and are preparing for that January 1 date, we will go into laboratories, especially if we're seeing data that is concerning to make sure that they have come into compliance with the updated standard after January 1 of 2025. Because then it is go time. But as I said, the great thing about you know having this service within the state agency is that we are here, we don't charge you for our time on an average at an hourly rate. So if you have questions or concerns about coming into compliance with the updated standard, I encourage you to please start reaching out now. We are here to help you. It is a big change. And so you have a little over six months, please reach out to us. Now, if you are needing help with coming into compliance. We are happy to have meetings with you talk to you about it. And we will be present at all of the audits over the next six months. Any questions about the second part that I shared? Anyone?
None. Really? I mean, that's great. Yes,
Trisha, first of all, thank you guys for taking this over. Like you guys have done the industry like, you know, a lot, a very good deed. And then in the context of the required cannabinoids, I was looking through the paperwork is da da, it's required by the labs to be tested for Is that accurate? I just in the context of some of the discussions with LCB. I just didn't know if that's a reported required. It looks like it is on the list.
Where are you looking?
I'm looking at the link that you sent out or the link you put in the chat. The first document I believe it is underneath the first link see here. And there was required cannabinoids, it looks like D nine D eight, CBD and CBN.
Is any of my scientific team here that can confirm or deny that my brain space is not on that document? Mix.
So right now LCB has not added delta eight. I know there's some discussions but department agriculture does not choose which m lights are to be tested that will come from the LCD rules.
Totally fair. I just am asking because on the cannabinoid concentration analysis doc under one two it listed as a required which is why I had questions
under 102?
On the under the one two, so the cannabinoid concentration analysis document.
The method?
Yep, the method.
Yes. Under the method Yeah, you're you're reading that I believe correctly, although I think there should be asterisks next to Delta eight and CBN. They're in the method for quality control and quality assurance reasons are not required to be reported. There used to be Understand specificity of like delta nine versus delta A because they can easily co Aleut during the method. So it's been added in there at least right now in that method for specificity. It is not required to be reported only the Big Four Delta nine THC, high CBD and CBDa. Under lcbs Rules are required to be reported.
Excellent, thanks, Nick.
Yep.
Here we go. I was like, What document so thank you. Any other questions on the accreditation component, the transition we have gone through division reorg and accreditation.
Okay, I will move forward to the hemp program if the hemp program is ready. So, the biggest well there are a couple of things happening with the hemp program. What day is today is the 25th. So if you are a current complacency and you will have not yet renewed your license, your license will expire on the 30th. In five days, I will say if you have not sent a check in the mail, then your license will be expiring with a lapse. So because it takes us a while to process our checks. And then you have to do the renewal application as well. So if you have not yet sent your check in the mail, you will see probably a small lapse in your license. We were looking at licensure so far from where I'm sitting. I think we're going to be pretty similar to last year in the like 40 to 50 licensees max range. We continue to see drop offs. You in hemp licensing. For those of you who are have questions about the impacts of 5367 they don't have a ton of information for you. I can tell you this 5367 didn't actually change so much for hemp in Washington State in the sense that hemp infused edibles like CBD edibles have never been legal in this state. Yes, I know they are extremely present, but they are not legal. So while you see CBD beverages and gummies even in like large pharmacy chains, they are not technically legal in this state. So 5367 did not change that. The only product that did have a legal marketplace prior to 5367. And no longer has a legal marketplace is hemp smokeable. So rolled hemp joint smokable hemp, that was something that we did have some licensees producing in the past, that is now considered consumable. And so there is not a market for that in Washington state right now. We will be hosting a webinar on hemp harvests in probably in early June. Remember that you do need to reach out to us 45 days prior to your anticipated harvest date to schedule an inspection. It is mandatory, you cannot take your own sample and send it to a lab you must have a Washington State Department of Agriculture and inspector come to your property and take a sample. The closer the USDA requires that we take that sample within 30 days of your anticipated harvest date. If you like think you're gonna harvest on Wednesday and like oops, you harvest on Thursday. That is not a big deal. That's fine. But if you think you're going to harvest on Wednesday, and then we see plants that you haven't harvested a month later, that's a problem. So if your anticipated harvest date changes you need to let us know we also get lots of calls every year from people who are like I'm 30 days out from harvest or and 20 days out from harvest or I'm five days out from harvest. I need you to come now. We can't do that. We need 45 days notice of your anticipated harvest date so that we have time to get to your farm and take a sample and schedule will that bring it to the lab, we are still seeing about 25% of inspections as hot inspections. So typically what we see is about 60% of licensees are actually harvesting, some people are just doing r&d and destroying some people their crop fails, some people end up not producing, but about 60% of licensees are harvesting material for sale. And of those about 25% of those inspections end up with hot hand. And on top of that 25%, I would say I'm seeing another 10 to 15% of people who are getting point two 8.29, where like if we were just a day or two later, who knows if you would be making that point three or not. So I'm really encouraging folks to give plenty of early notice. And just like to really do due diligence on your strains, there's nothing stopping you from taking your own private samples early in addition to the compliance samples that we take, so that you know where you stand. I've had so many people tell me about their excellent seed, and their excellent seed unfortunately fails. We have so I just really encourage you, you know, you can test for yourself, call us out early. There is a harvest inspection form and a part of our Licensing Portal. If you're having trouble with it, send an email to our hump address Hamba AGR dot why CIO v. And just make sure we know that you want to get inspected as soon as you have an idea of it.
And I am trying to think about if there are any other Oh, so I do want to Lauren, are you with us?
Yeah, I'm here.
I would like everyone to say hello to our microbiologist Lauren Christiansen. Laurie Lauren, comes to us. She actually worked as a microbiologist at Madison Creek, she helped us write our laboratory standard. And she will be a part of our accreditation team. However. This summer, she will also be overseeing our hemp program, which is very awesome. I will be on leave and Lauren will be here overseeing our hemp program. This is also going to give her like a really interesting set of experiences. Because when this is done, she will have worked at a cannabis laboratory. She will have written cannabis laboratory standard and gone on audits for it. And she will also be in charge of a federal sampling program for a cannabis plant. So I think she's going to come away with a really unique perspective to add to the industry. I'm really excited for her. And she is also finishing her master's degree in a matter of weeks. From evergreen, everyone's local faith. Lauren, can you say hello, maybe a few things about yourself? Yeah, hey, Ron.
Like Trisha said, I've had a very interesting, varied work experience. I was a microbiologist a long time and Canada's testing laboratory, one of our own. And I joined to the USDA, last year last February 2023. And yes, I am a graduate student. I'm in evergreens, Master of Public Administration program, and I'm on track to graduate in June. So just while I get that shiny new degree is when I will probably need to be taking on the reins and acting as head manager for the next few months. And I'm really excited for the opportunity. And I'm also very excited to see this industry from a different dimension, basically like a different side of things. Really looking forward to it. And we're looking looking forward to working with you. All
right. Yes, I am leaving you in excellent hands. Thank you, Lauren. I think it's gonna be a really neat opportunity for everyone, and they're all probably sick of me. So good news. I see a question. Does the WS da maintain a C being farmers can use that includes strains that meet the requirement? The answer is no. And I'm going to explain why. There are there are I believe Kentucky might and I believe that there are some provinces in Canada that do. The reason that we do not is because I would say we have a very NAB annoyed centric culture here in Washington State. So like in a state like Kentucky, where almost everyone is going for grain, they have a couple, they have some strains that are tried and true. And they're mostly grain and fiber strains. For us, as I stated, we're still seeing about 25% of stuff go hot. And so we don't want to steer people in the wrong direction. Because we just see too much good stuff go bad. I, you know, for folks who are interested in you know, I encourage you to look up other states lists, but you are going to probably be getting grain and fiber strains. From those lists, we are not seeing you know, what I will say is if a C Company is boasting, eight or nine or 10% CBD, don't expect to get under point 3% THC, when we start seeing CBD at those levels. The THC is failing every time. So we don't want to put ourselves in the awful position of recommending a bad strain to a farmer. That would be literally my least favorite thing next to telling a farmer they have to destroy their crop. So those are the major components of my updates for y'all today. I just talked a real lot. Does anyone have questions? We went through division reorg. We went through lab standards and accreditation transition plan and have any thoughts on why so many farmers who have stopped? Oh, yeah, actually, I did forget part of my update. Okay. So huge part of my update. I have a lot of thoughts on why farmers have stopped applying for industrial hemp licenses. It's multifold. One is that the continued like illegality in our state of consumables, the lack of a marketplace for certain product types. And the general confusion about what products are or are not legal or where has definitely led some people to be less interested because they just they're sitting on crops they don't know what to do with that are oversaturated. There is so that that's a huge issue. The other issue is manufacturing, the manufacturing of hemp is unregulated, and the processing of hemp is unregulated. A lot of people are not sure where to send their plant next. Because there is a legal cannabis marketplace. In Washington State, we see that like some states that don't have a legal cannabis marketplace at all are able to have a more prominent CBD marketplace in replacement. So that also changes the dynamic is that people do have access to cannabinoid products, different types of cannabinoid products through the i 502. So there might be less incentive to make them here. The one opportunity that we are exploring, we are contracting with a consulting an environmental consulting firm, who is going to conduct a study on utilizing hemp for building materials and other sustainable reasons. We do have like a very small number of farmers in Washington state who is interested in like using hemp for insulation, using it for dry walling. There have been some really successful hemp flooring companies and other states. And so the contractor is going to work at both like a local level of like, what are people interested in Washington State and what are the barriers? This was actually a budget proviso that we wrote last session that went through so we have money we're working to execute contract with a with consulting firm, and they're going to spend a year studying this they're probably going to reach out to many of you, hemp farmers, licensees advocates, especially any of you who are interested in in utilizing hemp for building materials to see where are the opportunities, where are the challenges, what opportunities are considered regulatory, what are a part of the marketplace or both and And I think we'll also have them do some research at the international level to make sure you know, because there are places that do have some pretty successful marketplaces. And so we'd like to see, what are the barriers here? What are the opportunities? What can we do from a regulatory perspective to improve things? And then finally, the third? I think, challenge is, is the Farm Bill, we're well, being maybe there's some hope for the farm bill next September, but we are, we are still in a delay mode. And the Farm Bill does have some, you know, pretty costly restrictions, we have to report a lot of data to the USDA, we have to go take samples, you know, even when we go to a fiber farm where there are like, essentially no flowering plants, we still have to go take a sample. And that is an expensive process. And so I think part of why we're seeing a reduction in licensing is because it's expensive to have a hemp license, you have to pay for licensing and you have to pay for testing. And a lot of that is due to USDA requirements with the data that they expect us to collect. And so that that definitely adds to the cost which is going to take some farmers away from the project. Absolutely. Any other questions.
And the contractor we have not executed yet, but we are in the process of drafting a contract with green economics. They are a woman owned environmental consulting firm based here in Washington. And so hopefully we'll get that contract through and we'll work we'll start around July 1. Any other questions, answers feelings, give space for all of it. Nothing the people are feeling informed.
Is there a processing plant in Washington a hemp processing plant or when there are many hemp processors, we do actually have a list of registered processors on our website. So if you go to the hemp Program website, let me put in the hemp Program website.
Then you will find at the bottom that there is a list. We do not license have processors, we just have an opportunity for them to register with us they get a registration certificate, some of them utilize it so that it makes it easier for them to export because they have like a certificate from a state agency that I guess helps legitimize them in some sense. So that list is not exhaustive. It is not all of the hemp processors in Washington state is just the ones that have chosen to register with us. But yeah, I think, you know, part of the challenge is connecting hemp farmers with him processors. So and again because there's no formal regulatory authority, overhand processing, that connection becomes challenging. Any other questions?
None. If there are none, I thank you all for coming today. Feel free to follow up with me again, if you have policy ideas, seedlings, questions, please shoot me an email. Get some time on my calendar. That's the most efficient way to do it. If you are a laboratory Who is having questions about the new standard that has been adopted about the method approval process? Please reach out to us. We are here for you. We are here to work with you and help you. You have about seven months so like utilize every single one of them. We are here to help. That is our job, your public servants. Well, thank you so, so much for coming. And I really look forward to working with you all in continuation. Thanks so much.
