 Five, we were given minutes from the last meeting, which are probably available online as well. They should be. And I didn't have any particular changes that needed to be made. I carry to you. No, no, no. I haven't got, since the two of us, I'll make the motion to approve the minutes. Second. All in favor. Yeah, how do we do that? Aye. Aye. You're taking minutes this time. I'm taking minutes this time. Okay. I think either Brenner, Julie did that last time, but we're kind of providing you with concrete. Yeah, that would be great. Kyle Harris became of a control board for the record. Yeah, we might as well go around and introduce ourselves for the record to see who's here. And you can start over there. Sure. Hi. I am the quality manager at series med. What's the name of it? Uh, series med, formerly shifting value dispensary in southern valley wellness. Yeah. Kyle Harris with the cannabis control board. Kerry to here. Yep. Sorry. I'm Roy Rose. Not with any cannabis company right now. I'm just trying to see what you guys are doing right now. Okay. Hi, I'm Ashley Moore with AMO strategies. Okay. Kim Watson, private consultant with myself. Well, welcome everybody to the new space. This is where the meetings are going to, I think, start moving over to between here and the department of financial regulations office. They've been kind enough to let us use their conference room, but we're going to see what we can do with, as you said, our large conference room that is not so large, but the plan is to have a bigger conference table and open space in the back of the building. Nice. So we've picked up first agenda. I don't know. I sent you something pretty late in regards to. I have it open right now. Okay. So do you want to switch to that comment that first and then we can go to standard operating procedures just because. Yeah. So one of my action items was to find out what it was costing for a full set of tests throughout different, you know, states and requirements. And I actually had a conversation with another woman who has been involved with the Oregon as well as California, Michigan, and let's see Michigan Oregon, California and Michigan. And her comments were that the pricing was around feet 450 to 650 for the full suite of tests. But then of course, as you can see, I sent an email with regards to Robert from reassure labs, which is I think is out of California. I think they have other ones around as well. I haven't had an opportunity to talk with him yet, but he's more than happy to talk with us. And actually I even mentioned that if we wanted him to come talk to all of us, he could do that. Yeah. And he may be interested in doing that. So then he wrote to my friend Shannon, who is a consultant as well in the lab audits and for different cannabis labs and things like that. And she had told me those prices, but he says they're really down a lot lower now for 400 to 600. And let me see. I don't know if I can open because I'm not on the internet. So you may want to just comment on what you thought. Yeah. No, that seems reasonable. And trying to balance it. I mean, we can put together a report for the control board for the commission that we believe is the best passport. Now we can either do how we want to sort of state or do this document. I think we either give the Cadillac model all the way down to a bare minimum and let the control board pick before we make a recommendation about where on that spectrum we believe Vermont should be. Right. Right. You know, every state, like we were talking about, every state is different. I mean, nobody has joined the, and it is, whether you have your requirements of torpedoes and because then they have to do in different tests because it's GC, FID, things like that. So it's really comes down to what the full suite, what you are considering the full suite and how you're going to, you know, what is your batch? Yeah. You know, because I think he defined it there. I had, you know, let's, maybe we can read that for the record. Okay. This is an email from Robert. I'll just forward it to you, Kyle. Okay. But I'll read it. It's an email from Robert Goldman. We can. And it says prices are not generally, generally around $400 to $600 for a full compliance suite of tests in those states. States that have fewer required tests will be a little lower states, more tests a little higher. Have also seen the lab in California that were mostly automated with liquid handling robots. I know. Tempt to come down to 300 or so for full compliance. So in California, this is potency, pesticides, solvents, micro, oh, so micro biological contaminants, metals, water activity and moisture, foreign matter, terpenes are optional. So that's a, that's a full panel right there. Yeah. I haven't heard of people flocking to them despite their lower price. Where labs have listed prices on their website, you consider should consider these exploited. No one advertises true prices. Generally negotiate with clients based on volume or other considerations. Labs also secret shop one another all the time. So I think this tends to keep prices in the same ballpark since everyone eventually finds out the sort of discounts other labs are offering. And this leads to price stabilization. Let me know if you have any more specific questions. And I like the full suite. And I think most of the folks who, who envision a Vermont market envision an envision of almost organic, high standard branded, Vermont branded product. And I don't think we can get there without all these tests. Well, not for product safety. Correct. Yeah. The question is how do we make that sustainable. So, so if a license is 1500 to 2000 and then for every batch or, you know, and I'm using a number that's been sort of bad around and we can look to Kyle who's been in on the discussions for whether or not we're in the ballpark for a small scale. It's hard to comment with any degree of certainty right now. No, no problem. But you can use numbers as placeholders. Yeah. Just, you know, figure it out. Yeah. So the what had been discussed I guess is potentially around a dollar per square foot. So if it's a 2000 square foot operation. Oh, I see. Right. All the way up to the 50,000 square foot. So if you've got a $2000 annual license fee and then 400 to 600 or potentially another 1000 in just testing fees every two months. Are we going to be overpriced? Are we going to encourage black market? Right. Right. Can I ask you a question? You're here based on your role with the agency of agriculture. You know, I know and in board meetings when we talked about the Hem program and this issue, specifically we've kind of batted around ideas on is there anything that could be done at the farm field level to alleviate some of the testing requirements in a laboratory. So you can soil testing for, you know, and then testing, you know, your usage on farm as opposed to in the lab. I don't know if that's more cost effective or not. It's just so I the largest issue in most states has been pesticides. Right. And we can do inspections to ensure that nobody's misusing pesticides at the facilities because I have a suite of pesticide inspectors or if they were third party certified. What we did in the Hem program, if you were clean green certified or NOFA certified, the requirement for testing pesticides isn't there. Right, because I mean. You've got third party certifying that you're not using any of these products. Right. And then there's also the trust by verify piece where we'll test 20% of the product in the market at the agency's lab for pesticides. Say that again. You'll do what? We'll, we'll shelf sample. Oh. 20% of the product. So shelf sample. What does that mean? You'll like. Purchase. Ask them to send you. No, we'll just go to the marketplace and buy it. Oh, I see. Or just random. Random. Yeah, right, right. Random. Or if we're at a farm that's got some prepackaged stuff, we'll just take it out of the sample. Right, right, right. And test that for pesticides. Because this number drops in half if you, if you pull the pesticides out. Right. That was going to be my next question. Yes. It's the hard, it's the hardest thing. That's the most cost prohibitive part of the testing. Yeah. The instrumentation is probably the. Yeah, we're running a brand new Q-top that the pesticide program just bought. So. Yeah. Yeah. Yeah. Thank you. What are they? 300,000? Yes. Yeah. As bad as a, you know, a farm crop or a cloth chopper. Yeah, yeah. So if we, if we were to. So, so let me envision what you're thinking. That if the pesticide piece doesn't have to be done because you have organic, the OF organic certification, being one of them, or they have, can they do self attestation? Are you, are you looking at that? Like, you know, they have the signed documents that say we don't. We can do that. We have it just because of the third party piece. Right. And then. And they're doing it for, they're doing it for. Right. So only those facilities that would be required to do pesticides. Only certain. Right. Right. Yeah. Do you like that model? That isn't a bad idea. I mean, I know how much it costs to get your VOF certification. Yeah. Yeah, but. And they do do a pretty good job, but I don't know what they're doing for producers or processors. I mean, I don't know. But the only concern I would have is that it leaves it up to you guys to test for it rather than the producer itself being, having their responsibility. Yeah. You know, because so it's like the batch is already gone and it's out there. And if you found out there was any pesticide, it's a little late. And I mean, you got to do more to make them that they lose a batch. Yeah. You know, you lose a batch early on. You've already made your money. Yeah. So if you're going to cheat on that aspect, it's going to happen at the farm level or the producer level versus. And I would think your sort of lessons would be at stake. Yeah. Yeah. That would be my only concern. A big regulatory hook there. Like if you cheat, you're done. There's one strike. Yeah. I mean, that's, yeah, if you get caught. Yeah. I mean, maybe that's a way to start it. And of course you can always change it, but you're not. Yeah. Is there any other states that have tried to approach at least pesticide testing in this? I don't know. That would be a good question for this guy that, you know, if he's willing to talk to us at our next meeting, he's definitely, he's very interested or even Shannon, if she was Swan Tech, she used to work for the Department of Health in Oregon. She was a certifying, you know, accreditation body person. And she's been involved in the cannabis part there for a long time. I also. But now she consults for California and Michigan and Colorado. I think so the other pesticide program managers that have spoken with it all, they all do different. Every cannabis program does a different. And sometimes it isn't the cannabis program at all who's dealing with the pesticides. It's the other folks. In Colorado, I think it's the, it is the AG agency doing the testing and then they refer to the individual boards of health in the county that they're in. Is that a product of just the way that they structure local government? It is. And everything's kind of at the county level out there. There's some states that they don't do much at all. Well, I don't think Mass is doing anything currently. Yeah. Yeah. So. Well, my question, another question that I have for you, Carrie, is when we look at, so timing or like if we're going to look at various steps to getting a product to be tested in a lab, at what point would it make sense for inspectors to go and test soil and depending on how many licenses we start with, is there going to be a bottleneck there? And at what point does the timing and somebody waiting for their product to be tested in the field or their soil to be tested become so prohibitive that it might even make more sense to just pay a little bit more money at a lab to have pesticides tested there? Oh, you know what I mean? Yeah, I know. Okay. I didn't know if it was a concern at all, you know, getting that inspector to come and check that box for your product, especially for, you know, outdoor grows. Is that making sense at all? What's more, see outdoor grows, it's hard to know. It's actually indoor grows that actually may use more pesticides, which is unusual. I mean you'd think it the other way around. Yeah. I was thinking in the context of there's more of a defined season. So there's a bottleneck at one point in the process throughout that outdoor grows season. It might create some consternation that there's... Well, so the soil test can happen anytime, anytime. And you're going to test the soil before you put plants in the ground. Okay. And that test is $15 for nutrients and $25 for heavy metals through UVO. And you can test that, run that test anytime throughout the year. And you're looking at three to five hundred for just pesticides. Okay. So yeah, I was thinking, okay, the soil test before plants, but if there was going to be an understanding of what farm applicators were used by somebody growing, what would the timing of that look like? Or what would you propose that we just, you know, as you said earlier, your license is on the line if your soil has been tested. We assume. Well, pesticides would not be tested on the soil per se. You would be testing it on the flower itself. Right. So I'm trying to get to my point of when would that actually occur in the life cycle of the operation? At harvest. At harvest. Right. So if Carrie's team is going to be doing that and there's only a number, a certain number of inspectors and there's a certain number of license holders at the time of harvest, is it going to create consternation that there's a bottleneck that not everybody can get their product tested expeditiously? Well, it depends on how we request the sampling side to happen. I'm just raising the question. So it will be harvest and then either whether the samplers come from the Department of Ag, whether they come from the lab, whether the producers themselves have trained samplers. So and then that actual sample has a holding time associated with it. I may be able to freeze it. I'm not sure whether they, yeah. Yeah, I was trying to tease out at what point does that become burdensome to the point where it might make more sense to just spend three to five hundred dollars on a pesticide test at the lab level. Right. If it was held up due to product wanting to get to the store or to the facility, yeah, it might be a month's time if you had a lot of samples. And that's your drying time anyways. Yeah. Right? Your drying and curing is on month. Right. I'm just asking questions to make sure. Yeah, no, it makes a lot of sense because if, you know, if everyone's harvesting in September or October and all of a sudden there's, but thinking, you know, there's hundreds of tests to be done in that short period of time. That's why I use the aqua grower as a model just because there's more timing bottlenecks, I would imagine that would happen, you know. Right. But it shouldn't be. I mean, most of these labs can, it depends on the size of the lab, but they batch them and they can do, you know, 20 to 30 to 40 samples a day. Yeah, your diagnostics, they're up in Colchester. They've got a brand new cannabis lab and it was, it can run around the clock. Yeah. Yeah, I mean, this is not a bad model. I'm just wondering, and it does allow for the self, the smaller facilities to prove themselves in that, you know, they're not using pesticides. They're more attentive to the plant on a case by case basis and they're able to monitor things that way. And pesticides are not cheap. So, I mean, you've got that, you know, what do you want to, if you're using pesticides, what do you want to spend your money on the tests or just say, I'm not going to have that expense and I'm going to pamper my plants. In the smaller, even on the indoor grows on the smaller facilities, the pest pressure is less. Yeah. It's when you have a warehouse foam that you ran into those issues. So, I mean, on the HEM program now, is that how it's working? Yes. Okay. Yeah. Totally. So, you guys go out and... We spot check. Spot check. And other than that, people do tests and keep records. Yeah. And what's your data showing? Not a lot of, like, that we can't really grow half in a state. But nobody's really using pesticides either. Yeah. Yeah. If they are, they're using stuff off the list. The biologicals, there's a lot of investment in also biological controls, ladybugs, lace wings. Yeah, yeah, yeah. And then the fungicide that folks are using towards the end of the season are generally OMRI certified. You can see there that oxidate, cyanidate, cease, actinidate. So you're... a lot of potassium bicarbonate as well. But all very gentle chemistry. Yeah. Nobody's, we haven't seen, we haven't looked, nobody's using Eagle 20, but my computer's no product or... Or a roundup. Right. Yeah. I mean, it's not a, it's not a, with such a small state and cost being, and can be an issue. It's, it looks like a good model to me. Yeah. I don't want to make it, I do want to perpetuate a culture around a Vermont brand that's mostly organic, mostly high quality, without the burden of thousands of dollars in testing per lot because your lot size on a small girl won't be that big. Right, right. And I guess, you know, it depends on the batch size. It does. You know, if you're only doing 20 pound batches at a time. Yeah. That's one thing versus 50 pound. Yeah. Yeah. Yeah. The producers here for the hemp right now, you know, they, who's doing, so, if we agree on that, that's not a bad thing. So let's move to sampling. Mm-hmm. Yeah. So, next conversation to have or to be had. And, yeah. Yeah. I have six inspectors statewide that I could devote to this. So we could have state samplers that sampled either pre or post harvest and, you know, delivered to the lab with their choice. Or, we modify the current laboratory certification process to include trained third party samplers. And either option works. One is free for the producer and the other gets rolled into the lab testing cost. So, the six inspectors samplers, how are they going to be trained? By you. No, I read it. No, no. Okay. They are currently trained samplers for pesticide feed seed fertilizer, mycotoxin, you know, you're not starting at ground zero on how to take a representative sample. Yeah. But it's a new product, a new crop. Yeah. And we're looking so low for pesticide, but they already know how to sample for pesticides. Right, right. And they, so that would be one and two is the producers, you say that again, that we could have lab- Trained third party samplers associated with full laboratories. Or even not, I suppose. They could be in their own. They could do, they could have their own person on site, but you, and if you're inspecting that kind of data, you know, they have to keep their training records and things like that if they're going to choose that route. Third party via the labs or third party. One of the sort of sign businesses that I've sort of heard talk of is these mobile trim teams. Like if you're a 2000 square foot thrower, you don't need to hire a full-time team to trim. I see. So there would be these potential third party mobile trim teams that would go wherever they were, you know, contracted to go. And the sample piece would be something that's getting nice with that business model. Yeah. I mean, as long as someone you had the ability, I mean to keep an eye on them, yeah. It's pretty easy to cheat. It is. When you're on that road. That's why. California had trim teams for years and nobody kept an eye on them. Correct. So. Yeah, no, I mean in that, I sort of favor the model of having my inspectors do it, but that's only because I've been working in regulatory programs for my career and chain capacity is of utmost. Yeah. Like. Yeah. Of utmost importance. Yeah. It's on the top of my mind. Documentation, documentation. If you didn't write it down, it didn't happen. Didn't happen. Yeah. Yeah. That's the good laboratory practice model. Yeah. Yeah. So. Oh, now I'm just scratching. Yeah. Yeah. That works for me. All right. Yeah. That's worth proposing then. We'll figure out how we're going to get this all written down. Yeah. I don't know if that was something that. Are we writing a report for you guys? Yeah. So the way I understand it and brand might be a better point of contact for this question, because we've heard this from multiple subcommittee members and consultants that are helping us out in other subcommittees. So each subcommittee is going to give, and I don't necessarily know the exact structure with which the report will look. We've heard bullet points. A couple, not a one pager, but a couple pagers. Synopsis of recommendations that the subcommittee is going to recommend to the board. And so then the board will review that vote on it if we decided something we want to move forward on. It'll get presented to the legislature. If everybody's on board, then Brandon team here will start using that as the launch pattern, the foundation, the vision for role-making. Okay. Is that how you understand it, Carrie? It's a moving card. I haven't been paying so much attention. This is going to form. But I think our report will be much longer than a one pager. I hope so, but something that's scary. Yeah, yeah, yeah. With the fees attached. Yeah, yeah. Well, this might be a little bit different than some of the other subcommittees where it's a little bit more topical at first. But, you know, we've, the last couple or a couple meetings ago, we laid out our vision and our mission statement. And so we're going to make sure that the report of each subcommittee reflects what we've decided on as a vision statement in our mission. And if they line up and we get all the approvals that we need, those will form the rule-making process. Okay. That's how, that's my understanding of how this is going to be moving over the next couple months. So one of the things I missed out when we were talking about the pesticides is who will do the other, the potency and all of that. There's six inspectors as well. Or are you looking at that going in a different way? Because that has to be by batch. They can certainly take the sample, but we have in the HEP program now the Canvas Quality Control Program where we're currently certifying labs to do all of the, all of this work. Yeah. Yeah. And I think we, you know, knight those labs or bless those labs under an MOU to also do high THC cannabis. So their review happens by Bob Shipman who's an employee of ours who's certifying these labs. Those labs that are certified to do HEP are just then certified to do cannabis. And it's the same fee. Like we charge a fee right now. Right. We would sort of turn that over to the board. So one fee to do HEP and high THC and medicinal. So we would roll those programs into one. So there would be these third party labs and we can just run all the pesticides at our lab or we can use the third party labs. But we can also I think the pesticides are really and well, Poe's Yeah, it's pretty critical. It is. Plus, for the label anyway. Yeah. And for, you know, it's use. Yeah. I mean, whether you use it to scale. Yeah. And it better be clearly identified on the label. Yeah. So you're going to need that right up front before they can even start packaging. Yeah. And the cartridges or other. Yeah. Well, I'm more concerned about residual solvents than some of the other. So yeah, it's all under chain of custody. Well, no, but how are you going to do who's going to start this thing? I mean, you're going to have to do it. Yeah. They're going to be busy full-time when it comes to harvesting. Yeah. I think we can because that's right. That's other piece can happen year round. Right. Right. It's not just the September, October harvest. Right, right. The problem is your September October harvest isn't going to make it to a shelf very quickly. So yeah. Well, that's if it goes into something else. Product or into a product like semi-bears or oils, butter. Okay. Yeah, no, they can. Yeah, because that's going to be a little more critical in terms of timeline because they're going to want to know because the quicker they get their stuff on the shelf or into the dispensary, the quicker they can sell it and the quicker they can. Mm-hmm. Yeah. So that's going to be, yeah. So if you, the way it's written right now for the hemp program, how does that work for product safety before it goes out to the. Yeah, it's not a before. Where, like I said, pulling products off a shelf and sampling and verifying that they did everything correctly. So it isn't a pre, it isn't before you market it. Right. It's a check while it's still in the marketplace. They think that's going to be, I mean, is that for, for THC too? No, they have to have that before. We, like I said, make a recommendation, but I would assume prior. Yeah, yeah. Yeah. You know, like, like I said, we modeled the hemp program on all the other consumer protection programs that we have where we trust and believe that you're doing the writing, but we have a lab to verify that you are. So it, like I said before, it's sort of a trust to verify and that's what your records are available for us to check at any time. And we're also verifying your product when we find it out in the marketplace. Right. Right. And what's the, what's the rate at which that happens? Which? How often are you verifying what it's in the marketplace? Um, often. I can't, I don't know what the rate is. One in ten pieces on the shelf, one in twenty. So we'll stop here and take a bunch of samples. And our market for CBB products was very large. It's contracted a bit in the last year. Right, right. So I don't know what their rate would be but we know who's, we know where the market is. Right. And you know who's putting the products on the shelf. Yes. And how often do you go to their actual grocery sites? Um, the grocery sites, we haven't been to all of them. But we have one person doing the Hemp Program right now. And, you know, when we had a, when we had, that's where that twenty percent number came from. Okay. So he was hitting twenty percent of the registered growers randomly. And if we went to those twenty percent last year, he would go to a different twenty percent. And then he would go to Spain and five years we would have visited all the growers once. But the products are being checked at a more frequent basis. Right. Because, you know, there might be Do you ever have to send out yourself? Send out samples. Yeah. We have. Yeah. We have. Okay. Um, for the you know, there's tests, there's all different ways to do that. Um, yeah. And we wanted to see if it was happening correctly. Yeah. You're QC'ing yourself as well as QC and other facilities. Yeah. Okay. Okay. And the same is true with right now, um, we're running a lab survey on, um, sample that we blend and blend and, you know, we're running. So just to check us, check them, just so everybody's on it. Right. Right. It is blind. You get your result and see everybody's, you know, how it is. Yeah. Yeah. So you're doing some proficiency testing yourself. Yeah. And I mean, that you will, if you need to do that for your own certification. Yeah. And maybe that's something that we, you know. Yeah. When you think about it. Yeah. And I liked the check sample piece because it tells you a lot more than looking at records. And I don't know if you're aware of that sort of emerald, emerald program. So it's a check sample program, but basically this company sells standards, calibration standards, as well as runs a check sample program. And the check sample comes already extracted. So you get a vial that you stick in your auto-sampler. So it's checking the instrument of the analyst. And I think we need more than that. Extraction is the most difficult part. Agreed. Agreed. That's why we worked in the extraction lab for a few years. Yeah. And that's the only thing that was available nationally because once it was in a solid and extracted, they could send it through the lab. Right, right, right. They couldn't actually send products. Yeah. I understand why they did that and they needed something, but I don't if you got a gold badge from emerald it doesn't mean you're a good lab. Yeah, yeah. But it's a good check on the instrument and calibration standards. Well, even if you could do it as a not let the panelists know that he's getting that sample somehow just put it in one of your own vials. It actually works pretty well. Yeah. Makes sense. Make it a double blind. Yeah. But, okay. So, so that, so when I look at this list, let me just go back to what we were looking at the other day, last meeting. So that's all, oh, it happens randomly. As the season goes on. Yeah. Right. And then, so you don't require any hemp producers at this time to actually send a sample and before they can put it on the shelf. It doesn't have to pass anything before they can put it on the shelf. So the potency test, like if it's an It just, right. It just has the potency. That's the only one. At this point, yeah. Okay. What are your thoughts on, so. No, so the, they are, the potency is the only one that's done really under chain of custody. Because that's what the program is based on. The rest of it, they are doing those tests, keeping records and make them available to us. Okay. And, you know, we, if somebody's outside of the parameters that we post on the website, they call us and say, well, they, and then they have the option to do what you guys were talking about. Mm-hmm. Um, you know, some kind of extraction of the THC and whatever. Yeah. Yeah. And like, deep bath coffee. Yeah. Yeah. Hopefully, they don't use methylene chloride. No, no, they don't know that. But, Okay. The hard one on that list is the mycotoxins and and like, we're using other people's numbers and I'm not, we're not sure. Is this pre-quiet pre? Yes. Okay. Yeah. So, this is pre and this is pre. Any of the others? Water? Yeah. It kind of makes it look like. So, you need a moisture. You need a moisture reading anyway, period. And they can do that. Are they doing themselves on site? Or are you guys doing it? So, the lab is doing it. It's done at the lab. And you need the moisture to calculate here. Percent anyways. Yeah. And that's like, on here, they listed water activity. That's just a, that's just a calculation. And the residual solvents are only after. On extracts. On extracts. Yeah. And they, the only other thing I see here is foreign matter. Oh, from that, from Robert. Yeah. Yeah. Yeah. That, I, yeah. To me, in the feed world, that means filth, which means, or rat shit. Right? Or, mouse poop. Yeah. Or, potentially bugs. Yeah. Bugs that got in it. Yeah. And that, like he said, it's optional for most. Yeah. You're going to see it. Yeah. That's why foreign matter and terpenes are optional. Yeah. Okay. Yeah. So that makes all sense. I mean, the only other thing is, do, do you want to prepare some sampling SOPs like we did for, to give people the option to. I think we start with, yeah, the ones that you've written. Yeah. Those are very detailed, very good. Totally. Yeah. I mean, they, and, Oregon has no problem if we model Okay. of various, the same thing. I mean, they, those were all public. I mean, you can still get them on their website today. Perfect. Yeah. Yeah. So I think, well, we'll write up a pro called based on, based on a hemp, but, more required. I mean, Well, you, you already have some descriptions and stuff in there. Mm-hmm. But we'll make it more required for the THC market. And then, then a way to, if you have a third party certifying your organic status, then the requirement for testing pesticides isn't on the producer. But we'll still sample random. Right. Just, and having that there, like, not only would they lose their organic certification if we found it, the potential that your license exists as well. Right. Okay. That sounds good. That's your action. You want to review the action items at the meeting minutes? Sure. We have, Yeah. The question, we have public comment. Yeah. Okay. Okay. So action items. Who's going to write up the SOPs? Uh-oh. You have them already done, right? Also? Yeah. Well, I'll take a crack and attach your, your stuff as a pendant. Leaving them as they are with the organ headings on them. Yeah, yeah, yeah. Just, we can take that off later, but just so. Yeah, yeah. So we see how they were located in there. Yeah. Okay. I'll leave that pretty, I'll just in the cell committee we'll write up SOPs. Yeah. Yeah. And he's going to, and then we'll review them at the next meeting. To be reviewed by the next meeting. Yeah. And then the question is, do you want either Shannon or Robert to talk to us at the next meeting? Yeah. Let's, let's, And see what they think of that model. I think it's worth Yeah. And other than, I mean, yours is pretty high up there. Well, no, not really. These guys, I mean, I, I, yeah, I'm learning new stuff every day is like. Yeah. Same. Yes. They said, I'm old school now. Yeah. Same. I know. So I was at the last meeting. Did you look to set the next meeting at the last meeting or would it make sense to talk to Robert, see what availability they might have and structure this meeting around his schedule? Right. My availability comes less in the, the, the week of the 20th and the week of the 27th till after and the week of October 4th. Yeah. So, and so we could either give you that timeline to do it or let's look at it. Let me look at a calendar and then we can just say that I'll have, then have had time. So, I mean, is that too far out? I don't think so, especially because if, if we have enough time and get this right, I'll send it to you. You can look at it. Find out Robert's availability. We'll have, we'll each have time to sort of look at what this looks like and hear from Robert and I think we should hear from some other folks who are burdened by our sampling protocol and actually want us to sample more. So, both ends of that spectrum from, from folks. So, the week of October 11th could be too far away. So, the next month, I am like swamped. So, so it's either the week of October 11th or October 18th. The 11th is probably not going to work. It has to be the 18th. But we could, we could communicate a lot through, you know, so, or we could have those SOPs and if you got them, I could review them. The only other day that would work is the week of the 20th, like on the 23rd or 24th. Is it September or October? September. I mean, because I'm actually away and I could not, I could do it via Teams. Yeah. Maybe the week of the 11th. But, I'm actually going to be away. Let's bounce it back and forth. Yeah. A document back and forth between us. And then if we need a Teams meeting, we'll set one up. Okay. You don't think we need it, one needs to be set today. I just wanted to show you. Oh yeah, I know. I'm just trying to, Thank you for your next month. Yeah, I'm like thinking through, I have to go to Tennessee, Minnesota, Key Lardo, Florida. I'm like trying to figure out what's going to happen. Is it a good time of year to be in Florida? Well, that's my sister's 7th birthday party. Yeah. Yeah. That sounds fun. Yeah, so, yeah, I mean, not really. It's, but it's the best time for our family. No, I didn't know what the weather was like down there. It's always nice. Yeah. Maybe. My oldest daughter, when she was going to college, you know, we worked it all out and she decided she was going to do two years of community college first. Yeah, yeah. So she went to remote community college here in Montpelier for a semester and then realized she could actually go to community college anywhere. And so, from December to, she would say that in the summer, she would tell you to the keys. Oh, did she? She went to community college and I, Alvarado? Yes. Yeah. Nice. Yep. Did she become a diver? She did. She did. She spent a lot of time on the boat. Yeah, yeah. Yeah. My mom lived there for 25 years. Oh, my God. Anyway, okay, so let's do that. We'll plan for, like the third week in October. Yeah. And we'll see what Bryn wants to think. Sounds good. And, but the action items are she's going to draft the SOPs with my review where we can hopefully have something hashed out to, for a product by the next time we meet. Mm-hmm. Great. All right. Pull the comment. Do you have a comment? Yeah. Yes. Roy Rose. Okay. How many cheminoids out of, there's like 146. How many are you guys actually, but there's some that are doing like five. Yeah. So we can do eight in our lab right now. Okay. Is that like, I mean, for a standard, so if I had a lab, yeah, eight would be like where you want it. So I think that's going to be market-driven. Okay. Um, CBD and THC and then CBD and THC are pretty standard and those are the most, um, the cheminoids most are interested in now, but, you know, everybody wants CBG and THCB. So we have those standards as well in our lab. But I think, I do think that's going to be market-driven. Um, let's see. Do you have any other thoughts coming? We'll maintain a suite of eight. I think the more there are as many as you can, it'll be good just so people know how to have information. I think more and more, I mean, you see, I was, I hadn't finished the article, but ACS just put one out on the delta and some other things. Delta eight. Delta eight. I think eventually it's going to end up going through everything. Eventually. Yeah. It just makes sense. It's just going to do it. Yeah, yeah. Whatever you can see. Somebody's going to do it. It's just going to set the it's going to set the bar right there. Yeah. I was trying to see which. I mean, I think it makes sense that it's going to be market-driven. There's going to be so many different types of consumers. I kind of. Yeah. That's why I say eventually somebody's going to end up making a lab that just goes through everything. Yeah. And then everybody's going to end up sort of be a. And then testing, you know, and standard it will also require what people can do. And right now most of our Vermont producers are saying because it's largely not market at this point that's using the commercial labs, although home growers are they're asking for CBD, CBG, and TAC. But all the method is set up and they can just add in the standard. Is this a state lab? You guys are just going in and testing random tests or are people actually coming to you and getting tested if you guys are getting tested? We're not. We could potentially in the future offer a fee-for-service. But right now we're just a regulatory lab. And if we're, if somebody wants fee-for-service, there are a few labs and state and a few labs out of state that offer that service. Okay. The training and certs is it going through a state? Is that third party? What's going on with that? So, for example, the the liquor control board and all that stuff, bartenders have to get certified through a state. Is that the same thing? Yeah, that's a question. That's a question for Kyle or the board. We don't know if they're ready to answer that. But in terms of certifying analysts and certifying labs, we're proposing that the program, lab certification program sort of become a surrogate for the ITC and this lab certification. Yeah. With an option of possibly getting your equivalency of like something like 17.25 or are you going to... We do, yeah. Yeah. Like, what do they call that? It's... I don't know. I don't know. No, I'm just thinking whether your reciprocity or something have... Yeah. Yeah. Because I do know that like even with the DOH, if you have your NIEF lab accreditation, it works for... Well, think about that. Like we're sort of requiring the 17.25 for more hemp labs, but we're not using our lab as NILAC which is the environmental... Right, right. NILAC certified. I said certified, but we still want to get certified in the hemp programs. Okay. So our specific criteria. But 17.25 gets you... Absolutely. Yeah, yeah. Get you there. Yes. You don't have to... Yeah. Because you'll respect that accrediting authorities of inspection. Yeah. Sort of like... Sort of like the proposal for a NOFAR cleaning initiative. Yeah, yeah. Yeah. So you're somebody else that's looking that you're doing things the way you say you were. Yeah. I don't... Okay. Does that answer your question? Yeah. As much as we can. Yeah. I have a few points I'd like to comment on. Okay. I personally feel as though it's imperative to have a positive release so finish good. Meaning that all testing has been done before a product was on the shelf. Mm-hmm. The purpose of testing is to ensure that people are not putting harm in their body. And that's the only real way to do that. Spot checking is good for auxiliary. But at that point the horse has left the barn. Products at risk, recall processes are clunky at best. But I think that's imperative for the safety of the consumer. I do hear the costs associated especially with smaller operations. And I'm wondering if some of this risk mitigation can be done further upstream of the process such as doing a facility process audits, process validations, things of that nature based off of a supplier's scorecard if you will. Perhaps that puts them into a tiered testing of they have a certain score that's favorable. Maybe it's a skip-lot testing scenario or based off of a number of units or lots produced on an annual basis. If they get a less favorable result the frequency increases. Something to consider there. When it comes to sampling I'll have a point here. Well, I feel as though the sampling piece should not that bonus should not be on the testing laboratories. That's not their specialty. They're analytical chemists. If you're looking to decrease the cost of testing that's just going to be more overhead for a testing lab ensuring more employees, ensuring vehicles, time on the road, gas, et cetera, et cetera. Carrie, I heard you mentioned the Emerald Test earlier. Our operation does enroll in the Emerald Test. To my understanding it's the only proficiency test offered for the cannabis and hemp industries currently. We've been enrolling in this. I've been with this with my organization for about three years now. The organization has been enrolling with Emerald for about five years and about the three-year tenure that I've been there. We just keep adding on the types and numbers of Emerald tests that we do. Originally they only had samples that were to shoot or to dilute and shoot. Minimal prep or extraction required. They do now offer samples in particular matrices whether it be hemp oil or gummies or flour for that matter where the extraction process is critical in the analysis and is also matrix specific. So I feel like there are more options on the table in that realm now. I just want to make people aware of that. Yeah, I know. Thanks. I actually wasn't aware. I thought there were more than Emerald too. I mean Resolute and some other facilities aren't doing that. There are tons of vendors to be able to get cannabinoid standards. Okay. But for a proficiency test where you have an unknown and you're reporting out on that unknown Emerald is the only one that I know of currently at least in the US. Right. So just wanted to clarify that and I totally agree and support everything that was said in regards to organic and clean green and such. Just one thing that I want to think about even a farmer with the best intentions following organic practices and following and how that maintains a clean green certification could potentially be put at risk by a neighboring farmer, different crop, different pesticide application practices. If that person or individual who has maintained clean green certification if their business is at risk for things that are outside of their control I don't know how that is handled but that probability is probably rather high especially when you're considering outdoor grow. Yeah. And this state doesn't necessarily require the neighboring farms to let you know when they're applying pesticides. Sure. Well, there's a buffer that's required. Yeah. But that's on the grower. I mean, I know we have the same problem just in general with your organic certification. The buffers are great but if you had, I mean drift is a lot different these days especially if you're using things like dicamba and stuff like that. That's going to wipe out the crop though. I know. You'd know both. Yeah. But, yeah. The stuff that gets used in Vermont are primary crop is field corn and that doesn't get fungicide or insecticide really. So it would be an herbicide. An herbicide drift would the crop wouldn't make it to market. Yeah, yeah. So there'd be suits before that but he's been after it. I'm trying to think of that. Your point is valid. Sure. Our cropping systems are such that it would be limited situations where we'd have to worry about drift that didn't kill the crop. Sure. I just heard that it was like one strike and you're out and I just put myself in the corner of my shoes that's playing by the book. Oh, that happens. Got it. Got it, got it. And then there might be hoods at risk. I think the one strike and you're out thing would, well, I'm sure this will get touched upon on the compliance and enforcement subcommittee but I think fault would have to be determined there. Established. Yeah. In our lab I can tell the difference between drift and an application. Sure. I'm just trying to think of the small difference. Yeah, yeah. Appreciate it. Well, because it makes sense because if we actually only caught it in an extract and not on the crop because you're concentrating the same equipment that is used to extract canvases is the equipment we use in the pesticide lab to extract pesticides. So they would be concentrated if it was drift in a concentrate. Good point. I'll capture that in the red key. It'll get posted on the website. Sure. So grab it and look at it. And if you see anything else like that definitely shoot this up. What is the website again? I think he's referencing our website. Cannabis Control Board's website. It's ccb.vermont.gov. They're not, I think, Kerry's saying once they're drafted they'll be put up for the public to review. They're not there yet. But if you need to see any of the hemp what we're talking about replicating for the cannabis side you can go to the hemp website which is under Vermont hemp rules and the agency of agriculture's website. The agency of agriculture's website. Under the hemp, just click on hemp in the sort of framework that we're using for Oregon's website for them now. Do you guys know how many labs you have right now for hemp? Let's see. There are 13 participating in the check sample program but some of those aren't available for commercial testing because they're associated with dispensaries and they're just doing in-house testing. You figured they're all going to add TAC. They're currently doing TAC. So they're fully lab. There may be a list. Do you have a list of your facilities on that website as well? I will say that the board has not called every single one to get their 100% acknowledgement that they will be participating in this market but there's a lot of anecdotal conversations that make it seem like a majority of them will be. Yeah, they don't have to change a thing from the hemp program to the THC cannabis. All right, any other comments? No. All right. Good to see you have your travel. Yeah, we're going into adjourn. Second. Thank you. Thank you. Nice to meet you guys. Thanks for coming. Yeah, I was. So, didn't get any answers.