2024_04_25-wsda-webinar-cannabis_programs-00-complete

Gregory Foster45min

Trecia Ehrlich

00:00

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.

Trecia Ehrlich

01:25

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?

Trecia Ehrlich

09:20

No, seeing none, I will move on.

Trecia Ehrlich

09:25

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.

Trecia Ehrlich

10:16

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.

Trecia Ehrlich

09:25

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.

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