 everyone to our final scheduled meeting of the sustainability subcommittee it's been a fun fun ride call the meeting to order at 1201 on the call we have Nellie and Kyle from the Vermont CCB from the sustainability some committee we have myself Jacob Paul and Stephanie Smith and from NACB we have Tom Nolasco and Gina Graham Winkle as well do we have any members of the public we have two members of the public here and two members of the public fantastic so with that we'll get started with approving the meeting minutes from October 21st and October 25th I sent those out with revisions that Stephanie had sent and got written approval from Billy and Stephanie I assume but it's verbal confirmation that with those changes you approve them as well and I grew myself so they pass unanimously and the meeting minutes from October 21st and the 25th have been approved so for today's meeting it's kind of a wrap-up of some just kind of outstanding business and helping Kyle with some presentation material he's got for the rest of the board so far we got in approval from the Commission or the cannabis control board for kind of the energy water and waste recommendations that we've discussed I guess before we get into that I guess the next order of business moving forward is I'm going to be I'm in the process of kind of typing up everything that we've discussed as far as energy water waste land management and pesticide use air quality to provide to the CCB and the plan is to kind of have a draft available for you Stephanie and Billy to review by Friday the 5th in the hopes of getting that out to Kyle the following week I believe these guys kind of a deadline of the November 26th to kind of have most of these things submitted and so on that note I guess Stephanie wanted and Kyle as well see what makes the most sense as far as like format of this document so I was thinking kind of following a bit of kind of what the PSD did and have kind of for each section explaining the issues and like I'm providing justification for why it's important going over what we've decided kind of the high level you know 30,000 foot view then go into the specific regulations that are already in place kind of cite what regulations and how they would be abided by kind of then move into specific or like example language which I know that the CCB will actually take the bulk of that over with as much as we can from other states as needed if there's gaps and then kind of go through with like outstanding issues or other areas of concerns or kind of break down how to think about certain things that maybe we haven't come to conclusion or depending on what the other committees are you know have determined anything I'm kind of missing there or any other I know insights or structure-wise no that makes sense I the yeah I mean there are recommendations to the board so they can you know be couched as such that you know we agree to something and we're recommending this but yeah no I that that seems to address all the addresses the is a good format to share information with the CCB yeah I think it's a good format to and again Jacob did did reference I have presented our conversations around waste disposal energy water in the context of what to what you're gonna need to show and prove from a municipal local utility perspective depending on where you are in the state and whether or not you're you're pulling from municipal water or on-site water everything's been very smooth at the board level some questions that I was able to navigate fairly fairly easily although I wish all of you were there to help me some at points but hey that's that's that's process right so we've gotten approval to move in a lot of the recommended directions I still think this report will be very valuable as we move towards the rulemaking phase because this is where the rubber will kind of meet the road with how we kind of shape this directional you know perspective that we're that we've been that the board is fully comfortable adopting from the subcommittee so just wanted to say that even though I've started to kind of check boxes off from my perspective this report will be very very helpful and informative as we start to enter a new phase of our work yeah oh and also add I forgot to mention part of that will also be kind of compliance implementation aspects so like actual you know what's on the ground so like you know we was looking at kind of like pesticide lists so kind of going through what's already done and how what other states are doing kind of justifications for EPA or like whatever the federal guidelines are but then also like the practical aspects of you know worker health and safety and you know pesticide application or applicator trainings or courses or like you know what that looks like and then have a list of kind of outstanding guidance materials materials that like can or could be created to kind of help you know the licensees or implementation so lay those out as well I just wanted to also add based on what you just said Jacob that the agency we do have training and exams that individuals must take in order to use pesticides so we have a lot of that already built within the agency but certainly you know and it's in accordance with federal laws well as state laws so it does exist just so you know you don't have to spend a lot of time maybe on that because we do have a process in the state of car yeah no perfect yet I think for a lot of these things would just be like linking to either the agency or the materials are already there and yeah and then essentially just like it's like you know kind of offering our advisor recommendations on who could oversee this or yeah what's already there and so it's not going to be like a hopefully not a hundred you know hundred base document but that it's a great great point all right so then I think to start I know how you wanted to talk to us about you know cultivation standards but specifically kind of like the cultivator operational requirements yeah so and I can give an overview so one of the things I'm gonna be speaking with the board tomorrow about is specific operational requirements for cultivators to me that kind of resembles a farm plan or a cultivation plan or an operation plan however you want to characterize it but but the content within that plan I think is important for us to discuss and get to your perspective Stephanie as you know in your role overseeing the HEM program what's kind of asked of folks at the beginning and things that I'm considering or thinking about asking and I don't want this to be overly burdensome I'm thinking like a 10-page I guess it's kind of like a in some way a some degree kind of like a business plan but not from the you know just just from the cultivation perspective of that plan so it's stuff like you know and some of this is already being asked for in our application but I think it's important to have kind of like a standalone document so we understand cultivation techniques what you're planning to do so on and so forth and wondering how often they should be updated those kind of questions are something that I thought would be good for discussion here today but I was thinking you know site description cultivation schedule your propagation and initial transplant mix like cultivation plan of applicable irrigation plan and schedule of applicable how you're planning to harvest dry and trim your employee plan how many employees are you planning to have who's in charge who's the lead cultivator system cultivator are you using seasonal laborers and then the use and storage of regulated products and I mean they're in you know nutrients pesticides fungicides stuff like that and I think recognizing your your expertise and I can talk to others at the agency of act to if we need to what's best management practices there making sure folks have a waste disposal plan I think we've talked about that in its general context and provided options for people but what are they actually going to do and then a product and product management so they're testing plan and plan to control inventory before transportation up the supply chain so that's kind of generally speaking what I'm thinking of when I talk about an operational or cultivation plan you know I know that jurisdictions require this as part of their application checklist so to speak I'm I haven't really talked in this about environmental considerations yet and it's something that I think we should talk about here what's a baseline information that we should include in an operational plan from an environmental perspective recognizing that we under 164 have to prioritize folks with how sustainable their cultivation techniques are going to be and so I want to make sure if we do develop the sustainability matrix that I've discussed where's a good baseline to start recognizing that people might want to prioritize themselves by giving us more information there any initial thoughts I think when you ask for the information to the yeah you're gonna need to as you mentioned build a mate at least from the sustainability perspective building a matrix so to see whether or not people are meeting the board's expectations to then be prioritized down the road obviously I mean you mentioned that but collecting information that's useful to the CCP that helps you understand some standard or requirement that you guys are putting in your rule which we may or may not know at this point in time but you know like some of these are just business practices and they may change or shift and so gathering information about an irrigation schedule or whether or not they're you know gonna use of some kind of time-controlled system or you know like but understanding that that might change like I just think you know getting that information if it's help you it helps you to make a decision is great but if it changes you need updated like how much interaction are you gonna have on a regular basis I guess that's my thing that I just something that I would be concerned of laying out a clear expectation for that interaction and what changes are made so that that's my contribution to the conversation at this point thanks Stephanie do you have any thoughts there I know that these are present in other jurisdictions I'm assuming you've probably laid your eyes on on them and understand to Stephanie's point things change when you actually try and apply something practice from your plan at some point yeah I mean there's a lot of states that require you know in the application process many can be like 300 pages long and they want like everything like all of the SOPs and all of that and that really has led to you know quite a robust like consulting business which just leads to you know a lot of costs and a lot of expertise so I think kind of moving away from that something that is kind of one barrier of entry I think you know schedule is not as important as potentially knowing like harvest cycles which kind of goes into you know knowing if they're gonna be like indoor outdoor greenhouse you know are they gonna be doing you know like to have to harvest three harvest you know four to six of their indoor you got that kind of stuff I think propagation is important like how are they going to actually be sourcing you know their ingredients because I was kind of like the you know immaculate inception of an industry like how do you get the genetics and you know and whatnot and then I think from like an SOP I think more broadly talking about like what kind of lights are they using on the using climate control what's their irrigation system going to be like so maybe not like necessarily the schedule but are they gonna be doing you know drip irrigation or micro emitters or even flow you know that kind of stuff or hand watering I think knowing that the grow medium and grow style is you know relatively important you know is it a hydroponic system or soil is medium or living soil because those kind of things will kind of just let you know kind of what their resources would be on like kind of a macro high level I think understanding kind of materials list you know could be important but I think like definitely IPM the integrated pest management that's gonna be probably a big thing just because like we see you know growers use the wrong thing when it's an emergency and they're kind of facing a critical crop loss so just making sure that they are kind of at least thinking about how are they going to deal with you know common pests you know we try to spider mites powdery mildew a fits that kind of thing so that there is like a plan in place and they're prepared for that so that you kind of you know are losing some of the you know shadier practices that we've seen in the cannabis industry and then yeah waste disposal and then I think from a sustainability environmental impact would be to have like what are their efficiency practices and how are they thinking about it so they not at all or they you know capturing their water recycling their you know fridigation you know the doing constructed wetlands for you know some of this stuff or you know whatever it may be and then kind of like dividing into maybe that's like either a checklist or you know what not I think are they you know using water efficiently if so like how you know that kind of thing and yeah that's gonna my thoughts on that yeah I was thinking just as as Jacob was going through the list there because there are recommendations relative to what the PS the public service department has recommended and or what is recommended from the air pollution and climate division and then you know in the need for wastewater permits or not that kind of stuff like I feel like your checklist could really integrate with that so that you can receive information from the applicant to see the direction that they're moving in that otherwise complies with those recommended requirements so that there's a link and then if you do get the information thinking about how you're gonna respond to that information if something seems amiss as well and what that process is again you know getting information and and asking for the information that you actually need and being transparent as to what you're gonna use that information for I think is really really important because otherwise people think they're submitting information into a black hole and they don't know what the purpose is and that can be very frustrating I think for any kind of applicant any process and you know it you could start off small and get bigger you know it doesn't have to be like check the big boxes right now to make it you know like you're always we're missing this piece of information so we need to make a change and then everybody for what that changes down absolutely and I'm not I'm not trying to create another paperwork exercise for folks and thinking a negligible five to ten page document the kind of outlines and ensures that they've thought about certain requirements ahead of time instead of us having to do all that education and hopefully not enforcement but enforcement on the back end when things kind of do go amiss so it's just getting folks moving in a certain direction yeah collecting information and support of them showing that they're gonna be compliant with whatever your rules are that I support that link absolutely yeah I think like what's super beneficial is just thinking about like how like Illinois rolled it out where they're already like two years behind on you know actually giving out licenses and like their corrective actions weren't really like understood very well really hard to interpret from like you know after bill of submitted applications they're also in a different system because I think they would be a limited number of licenses in each category being distributed so it was a much more I think like competitive environment than Vermont's trying to roll out but I think having yeah just kind of with like Stephanie saying it's just potentially having a list of just responses so like this was playing or this was an adequate thing you can already have that done and then providing resources you know that are available so like efficiency for Mon if they didn't have like a you know an ever bus energy plan or whatever so that they can you know essentially figure that out I mean I'm just like hey we need an energy policy and then there's like I don't even know what that means you can at least you know put them in the right direction because I imagine even for like manufacturers there's gonna be a lot of you know international fire code stuff and all the safety things and that you know if there's certain things that are not there you know they're gonna have to do that or think about like the recommendations of me for like the 1.7 you know PPE for lighting fixtures you know having you know a resource to that you know linking to like to design like consortium or whatever so they can you know at least understand what that you know I think it was yeah and just just on the energy stuff specifically I think it was clear from my conversation with James and Julie yesterday the energy code and energy lingo is its own skill set when it comes to understanding things and they're comfortable with all those recommendations but just want to make sure we develop guidance for folks that don't understand what that necessarily means not assuming that folks don't but just making sure folks understand the requirements in plain language. Yeah and then also like how these things are being determined so you know I think we've done it on a fixture level so like what does like 1.7 mean working and find that you know and then essentially relating that to you know how growers understand like most light standard is like at least really HBS or metal highlights or whatever it's like using a 4x4 footprint so you know how do you estimate you know your you know footprint I guess that's actually how part of the regulations and things like that. Well this is so I got an update for well I guess everybody it's kind of tangentially related to this but it is related to land use and environmental practices I think from a certain perspective so I had a good conversation yesterday with the current use program at the tax department and Jacob and Tom current use is how we define at the tax level agricultural land and how it's taxed differently than other commercial residential areas hopefully that's a good overall description Stephanie you might know you might know a little bit more than I do but because of the way that this is classified as a non agricultural product only thousand square foot growers can really grow on land that's zoned current use right now and so all of our outdoor grows that our perspective outdoor grows operating at 2,500 5,000 10,000 20,000 and the 37 5 eventually would have to take their land or a part of their land out of current use and Stephanie I know we have had some conversations about unpacking what that exactly means and what perceived penalties may need to be paid to the tax department if you're gonna take something out of current use and I thought given the nature of 164 and this not being an agricultural product I think the current use program seems to be willing to work with us to the extent that they're able to under the law so they kind of told me the first I said how often does this happen they said thousands of people change their current use status every year so they're not new to this process which is which is great on the flip side of that we're putting a lot of work on them to an agency that already it's developed or already has some bandwidth and backlog issues but they told me you know let's say of a hundred acre parcel you want to enter a 5,000 square foot canopy tearing size outdoors you can take just a small portion or parcel of that thousand acre track out of current use it doesn't need to be the whole thing and they're gonna assess it for value but not penalize you unless you plan on actually developing it and they're not defining cannabis as development it's just a different use on the agricultural land that's not agricultural but if you do want to build like a drying facility or a curing facility then you might have to pay something it's really dependent on operation but you can take a half an acre out and we could write rules around you know if you have a 5,000 square foot total canopy you want to take a half an acre of your hundred acre parcel out of current use you could rotate that 5,000 square foot canopy around that one half acre you know every season depending on how you because it's harder to crop rotate considering everything and how things are written as is but just want to give you that update that it sounded like for all intents and purposes they're of a similar understanding to us and want to make sure that folks aren't unduly burdened that are just trying to enter the market they also kind of indicated as long as the paperwork is submitted they're comfortable with people putting plants in the ground they don't need to wait for that actual change of status to actually occur on the back end they told me it can take 60 to 90 days for that change to actually happen and they know that we can't wait for that so as soon as somebody files their paperwork with the current use program they would be comfortable from a tax perspective on on a cultivation site for those outdoor tiers that are over a thousand feet. I have a question on that though with taking out of the use for the land is that also include like farm structures so like if I'm a you know cultivator and I have a barn that I'm storing you know one of my agricultural products or you know one of my materials can I also use that barn to dry you know and store usage in the cannabis business or does that actually have to get you know do I build another structure that's not in previous agricultural use or how's that working. They were the focus was building a new developing this parcel not an ag not in current use and that's when you would trigger penalties. We didn't necessarily talk about existing structures that are part of your farm operation. I mean existing facilities that you want to dry or cure and will still have to be updated potentially to kind of meet security requirements we're going to put in place for those those facilities but they didn't seem to be all too concerned with with sharing buildings that are otherwise farm buildings. You said as long as it's not processing if you're just changing you're just growing cannabis it's still it's still considered ag right there's not that change in use. They told me that they need to assess it for all intensive purposes as if you were going to pay a penalty that change of use of the land but they're not going to require you pay that penalty unless you physically develop the land and they're not saying cannabis is development. They're talking about a subdividing it or something like that down the road. Yeah I think based on what Kyle said sounds like you have to remove that land from the current use program so you wouldn't no longer it would now be assessed at its highest and best use from year to year but you wouldn't incur a penalty unless you physically built something on the ground. Yeah they're gonna assess it in record. Does that make that accurate? That's accurate and I'm sorry that I'm not the best tax lingo interpreter but this is this is the gist of the conversation and so I thought it was about as good as we could have hoped for and expected considering how this is treated through a 164. Yeah I would just clarify or encourage the enforcement of that to allow for shared building so I'm just thinking like if I'm a you know manufacturer and I have a warehouse that I'm using part of my warehouse for something else I'm going to be able to use the other part of my warehouse for cannabis you know manufacturing if it's up to coding everything like that without you know incurring any issue and so it's just kind of potentially burdening you know farmers when other issues or other aspect sectors of the industry are not going to have that issue. I'll double check but they didn't seem to be overly concerned with that it was more about the you know something is the assess that is highest value and then you're building something on it you know so versus existing structures but I'll double check on the flip side of this for those farmers that are enrolled in current use taking land out limits their ability possibly I don't have any statistics but you have to meet a certain standard either I think it's income it's a whole bunch I mean there's eligibility requirements for being enrolled in current use so if you take land out it could impact your ability to continue to be enrolled with the other land so that's just a connection that we haven't talked about but that's possible as well. We pulled a string of yarn I'm sure we'll do a lot more of figuring out how you know they understand that we're in uncharted waters considering how this is for all intensive purposes of playing carding out of the ground not not legally considered one so what we're doing our best to kind of unpack and educate ourselves and each our sister agencies ahead of time so we can anticipate as much as we can and start developing guidance for folks that want to seek a license higher than the thousand square feet where this wouldn't be an issue. Perfect yeah so that's everything on that so I've got pesticides down here I know we weren't talking about pesticides specifically but I think it was the actual what would be required from like a compliance side. So yeah Stephanie let me tell you what I'm asked to talk about tomorrow which this is the bullet pesticides or classes of pesticides that may be used must comply with ag pesticide control regs and that kind of comes through 164 and I know we talked about pesticides on Monday I just need and I can talk with Kerry and David you know at ag to kind of walk through how I should present that we want to make sure that anything that anybody's using isn't is approved through the Agency of Agriculture. I don't know if you have a subset and I know EPA is starting to wander into these waters now that it's federally legal but how do we want to message what can be used or how to determine if something can be used to this new market. Well I can share what we use prior to EPA approving pesticides for use on hemp, a PDF of a document you could either change the word to hemp or I could I mean change the word to cannabis or I could change the word to cannabis and share that with you and that's specifically related to active ingredients which we talked about last meeting and then relative to the actual regulation like a pesticide misuse or pesticide residue or whatever my assumption was that the agency and I don't know this I guess the I'm only one member of the subcommittee with the recommendation I would give is that the agency regulate and enforce those requirements both related to education and training of those individuals that are you know like they have to be certified applicators for the class of pesticide that's being used and then obviously those operations that are selling those pesticides retail need to be licensed to do so and to provide advice to individuals that are buying those pesticides like that's a whole it's very nitty gritty it's you know 72 pages of regulation that the agents I mean under the new regulation that the agencies going through the administrative procedures act on so yeah again my recommendation is we can provide a list of things that of active ingredients that are allowable produce on cannabis and then the regulation of pesticides and applicators and education training requirements will be regulated by the agency of agriculture you can send me yeah if you could send me that list and then put into email that sentence or two that you just said how we can use the agency of agriculture and their expertise that's all I need at this point in time and we can kind of dig into this list when we get more to the proposed reg stage this is just kind of signaling that we want to not run afoul of what the agency of agriculture is trying to accomplish with requiring certain tests for applicators you know registration for selling so on and so forth in our in our regulations so that would be extremely helpful yeah and then in addition to just letting the agency regulate the agency would enforce misuses and all that stuff as well like the whole I think I think that makes sense we need to you know work through experts at what they're what they're doing here and squarely in within the agency of agriculture from that perspective so I understand that and also have I can send out to you as well as a good write-up I found that kind of goes through where the EPA stands is like what is kind of how they came to their decisions what their current thinking is because I know in the you know you would send me Stephanie goes through on kind of how they're classifying things so like it has to be like registered for non-specific crop product all of that and then also kind of what some states are doing from a pesticide residue limit so they're kind of doing the most stringent for any food product so like in Oregon it's like point one parts per million of any kind of residue but then also this this document about has like every state and where they land on all of this and I don't question actually reuse Stephanie was where do we're just like 25 B exemptions come in to play I was kind of going through the least you provided me with the Washington Oregon Colorado that actually have the active ingredients list but then also the products list and so there was a few on there that were acceptable because it's you know I can't think of the technical or like generally considered safe for non-harmful or whatever so there's a few things on there I think was like sulfur and maybe some other things that are allowed that weren't necessarily on your list I was wondering because those are a lot of those are like 25 B exemptions yeah I think it's and I could be wrong I should check with Kerry but I think it's generally 25 bees that are on our list and then I think oxidate is maybe the only item that's not a 25 B but then could be used but I would have to check with Kerry I'm I'm not entirely certain about that and then relative to the you also mentioned earlier Jacob the list of pesticide like a residue on a crop that's otherwise not on that list so like there's the difference between the list of allowable products and then there's the contaminant list that interview that states test for and we do have a list that we use for hemp it's I think it's like 12 or 13 compounds that are high concern for the state of Vermont and I do know that there are other states that have much longer lists and with you know the the maximum amount of detection after testing so so we do have a list in the hemp program and the CCB can adopt a higher actually I want to say that the that under our chapter our title six in chapter 34 relative to the cannabis quality controlled program the agency of agriculture sets those that contaminant list and the action limits for pesticides I think that's within our control currently but I can share that with you the statutory citation as well as that list of 12 13 compounds that are that we test for at least on both actually on cannabis and hemp that we require to be tested for if it's on cannabis today we don't have any authority to enforce because we don't enforce cannabis law but we do enforce on him um perfect yeah and I can show with you I I would guide I can't think when it was shared with me but it's like from California was kind of like inspector list of like commonly used pesticides for illegal cannabis growth like what you would come across I want to say there's like 34 different things on it Michael you know all the really nasty stuff and so we could see if like that list needs to be expanded or at least just things for them to kind of keep an eye out for that like is you know used or has been used so like especially with like you always have that period of the legacy growers coming into this market and knowing what they know and what works and you know what's not acceptable kind of thing and then I wanted to see if there was any thought on putting in I know we talked about briefly like timing the singing for like what's a lot for like last resort and how that factors in into things I would like think about like for an IPM strategy if you're looking at like you know genetics and then plant spacing the beneficials you know travel all of that and then going into the spray is like what's allowed to be done and preventative at what stages and then what can be actually used flowering you know as a last resort and for what and if there is going to be any kind of requirements on you know showing and pester disease pressures when using something or that's kind of just going above and beyond I you know I did have this conversation with Kerry this week about considering providing a list of guidance on how and when the allowed active ingredients could be applied to a cannabis plant and we talked about how like the decisions are business related and we wouldn't provide a guidance we would just allow the business to operate so long as they're operating within the approved or the list of approved active ingredients they comply them when they when they see fit based on what they're what they decide it's again it's their their business so we wouldn't necessarily get involved in that quick question transparent that you know we're going to test for these things and you can't use these at all right all that list those aren't allowed and then have some kind of microbial based type of active ingredients they would have to weigh the consideration of when to apply that in light of the fact that there will probably be a total combined yeast and mold test that they will have to satisfy in order for that crop to enter the market and so they need to make their decisions about when to apply again and that is definitely a concern I think for a lot of how to grow living soil you know a different soil fertility things because of that and so I was wondering actually Kyle has the live testing protocols kind of been recommended are they doing total colony forming units or are they actually going to be looking at like pathogens and harmful bacterial loads rather than just broad spectrum I haven't seen anything from Kerry yet so I'm not at liberty to answer your question but I think I know Brynn has talked with Kerry and Kim Watson who's also on the lab testing subcommittee and I think they're about at a point where they've kind of got some proposals ready to go I just haven't I haven't seen them at this time but but back to you go ahead Seve I just can I yeah I wanted to mention another thing like the the program does have guidance regarding harvesting and when it's appropriate to you know like if you drop a flower on the ground like that's done you don't put that in the basket and so we do have guidance relative to that in order to I mean reduce pathogens and risk during harvest activities and during packaging activities so we have a FAQ about that on our website and that's primarily based on the produce safety program guidance from FDA and the agency the agency has delegation to administer that program so that's generally of a you know that's out there as guidance and then the other item I wanted to mention is that the agency of ag beginning in November I believe maybe November 15th is going to begin registering soil amendments with the agency so so that's something that we are doing and then I mean obviously it's a I don't know that it's an assurance to any cannabis growers but but we will have our eyes on labels associated with that and then generally like raw manure should not be you know it has to be cured and developed it can't just be raw manure in a field when crops are intended for human consumption so but those are just general those are out there already like that's not should well maybe it's new information for new growers but these are standards that exist are you recommending like gloves and beards and hair nets and all of that in the processing of things and we don't go to that level of detail but there's probably the most important thing that we go into detail about is the necessity to provide hand-washing stations and sanitary facilities in fields obviously this is outdoor cultivation within appropriate proximity and the requirements wash your hands a lot not just like all the time just general hygiene is probably the most effective tool in reducing transmission pathogens what what about surface contamination as far as like what materials can be used being like you know the purpose of like the quaternary things that's like it's not a lot in organics but a lot of people use it for like sanitizing of you materials tools and yeah I can't remember what we said in our guidance but I think again our guidance is based on the produce safety program administered at the Agency of Agriculture and if it's not safe for food consumption purposes then I think we would we would move people away from those products but I can't remember specifically what we said about cleaning surfaces and the appropriate products for that purpose I just bring it up because like I know if it is based on produce safety it's still with a lot of those things it's still based on materials being washed in cannabis I think it's one of the few you know our cultural products that may never touch water from harvest to consumer and so there is like potential issues there and it's not never never being tested you know for those kind of things and then that kind of brings it up it's a little of a tangent but we never talked about like purple pipe reclaimed water and the usage of that on cannabis I don't know what for months laws are if that's even allowed in agriculture but it's a term I'm not familiar with but I was reclaimed water so it's like waste it's been recycled usually it's you know it's through municipality but it's a voice of gray water systems okay yeah I think we do have guidance with respect to water and the source of that water and it depends on if you're and I'm thinking about actually drawing from surface water which isn't gray water but if it's like you don't want to spray water that's not fit for human consumption over the canopy of a plant but if you're doing irrigation and it meets specific standards I think we have water quality standards it can be direct irrigation to the soil possibly but I but I think we do have requirements for a base level cleanliness lack of a better term yeah and I feel like for the most part I mean to avoid but try this and so many things better mother like most people are not going to be spraying anyways but good good to know there's one other thing I remember right now I want to circle back to one thing and I know you know Stephanie you had said we don't want to get super prescriptive about when folks should be playing you know inputs or pesticides or whatever you want to call it but if I'm thinking back to this cultivation or operational plan if somebody's planning to use something should we ask them to disclose that product in that operational plan I can't remember if we talked about this beginning of this call or not but we didn't specifically again because it's a plan I I mean you can ask for what you want but it's a plan and we'll never know until we have a misuse of some kind or an issue and people's ideas change too so I am not sure about that level of detail there might be a reason to ask for that level of detail but I can't think of one right now at this moment I'm not saying I just like maybe you can ask what I think the plan is probably what would be more useful maybe is then a records inspection after the close of a season asking for people to keep records so that you look and see what they applied and so and actually when I was looking at the agenda I was thinking about like oh yeah record keeping record keeping is really important so while we might not get it on the front end you may want to look for information on the on the back end and then review those records with inspections at the end of the harvest season or throughout the course of the year if we have a bunch of indoor growers I mean they're gonna be doing this year lap or year round but taking advantage of the seasonality of the crop and you know who's enrolled like in being able to space that out those records inspections out and actually records inspections are easily done over the internet just through email so you can do a fair bit we did that you know due to COVID within the hemp program we just started to do requests for information via email so that we can still be in touch with our growers and I think that's a perfectly reasonable way to do that outreach and look at records but also going on to the farm and looking at those records again I don't yeah I think I think on the input side I think at least a an expectation that we will want to see records of what you've done isn't you know out of the question I think it's easy on a count on a calendar year cycle to do that for outdoors but I'm wondering Jacob if we were thinking about the indoor grower how many how many harvest would we allow an indoor grower to realizing that they're not operating on the calendar year like the outdoor growers would be how many harvests do you think we should do like three or four before we require this kind of records request being sent to us does that make my question make sense yeah I mean I think that there's there's value at least for pesticides especially with your you know one of the goals is to bring the legacy growers being like this is a lot this isn't allowed you know at least from an active ingredient and have that you know checklist I mean there's a lot of states Colorado does it I know quite a few I don't know the reason behind it but you have to put what pesticides you use in some states it's all materials on the actual you know product when it goes for sales and I want to say my assumption is that has to do with like the medical side of things and for like I'm you know compromise or sensitive people knowing like what they're ingesting and if they might have like a reaction to that so it's just like informing the consumer but I'm not sure but I do know that like you know when you buy products in a lot of states it'll have all of the at least active ingredients on there so there is that requirement you know I I would say you know we really push for the growth of we work with is to have very robust recordkeeping because you know you're essentially facing a massive financial you know critical crop loss or something if this if you guys are testing it or if it does get tested and there is a you know band material in there you have to destroy the entire batch or the entire row they need to have that supporting documentation to figure out where that happened like were they the ones who did it or did it happen at the processor using contaminated equipment from someone else or you know whatnot and so it's just like a risk mitigation you know insurance like issues which is like best practices but knowing that you know a lot of legacy growers documenting everything was kind of like their court case so like it's a learning curve and you know a change of mindset so there's definitely you know bringing them in and giving them as many as much guidance as possible but so yeah I would on the basis of if they provide a list and you know this whole application is being signed as like a legal truth that you know it's from when they submit it you know I think there's not necessarily a main reason to have to be like oh you can't do three car vests you know more than three hours without an inspection or without providing it's information you know it's all kind of self-reported I think it's more allowing to do business until some until proven otherwise kind of thing because also I think like what is your guys is capacity going to be on the state lab level or you know laboratory level in the reporting and how many auditors you're gonna have to actually you know assess these things I think it's like easier to kind of say provide at least the best of your knowledge what you're using potentially submitting a afterseason report if someone's actually gonna review it and then you know kind of see if anything happens and then if like you know I think having good reporting from the lab side of things so that if something pops in a test that's being reported to the state and that you guys can send out an inspector and figure out what's going on Jacob I think I was just asking as far as record keeping is concerned the difference between an outdoor and the harvest cycles and the indoor harvest cycles and that's how much more an indoor might be burdened just given the increased cycles in the indoor do you have a sense of that you know I just I mean I feel like when you're cultivating on a commercial scale or even like a home set scale I mean it's you still SOPs I mean like you should be you know reporting internally at least every time you're using something so like it doesn't matter if you're you know harvesting your third you know crop but if it's still like August 1st and you're doing something you know it should be written down so I don't think necessarily um you know if you're indoor or outdoor it'd be like one full season grow first you know quite you know turn and burn weekly harvest I don't think that necessarily matters as much of a burden on like what materials you're using that makes sense so Jacob so I'm thinking of just in your language the submitting after season report should that be like submit a report by Thanksgiving no matter if you're indoors or outdoors that gives people time to get their plants out of the ground and transport it off their cultivation site but recognizing folks could still be in mid cycle depending on their indoor operation they just still need to have what they've done year to date by a certain date I guess is I'm just trying to make sure that indoor and outdoor if we're asking for an after season report makes sense for both growing styles. Kyle I might even suggest that um and we're just coming to it now in the HEM program is is requesting planting reports you could either request them to be sent to you or that they be maintained by the registrant so that you know when when plants are going in the ground you might you know in specific information about that particular planting clone seed whatever and maybe this goes to the process of how you got your starts or how you developed your starts um and then um by cultivar or by harvest lot when maybe you want harvest lots to be cultivar specific like these are you know that that's the kind of that record keeping detail um and you can ask for that information to be sent to the CCB or you can just make sure that they keep that information so that it can be inspected at some point during the course of the year based on a schedule that you've set and I think you could be I don't know you want to do random do you want to assess risk on when you do inspections like there's a couple of ways you could do that anyway just lots of lots of ways and they can change over time like it you know it doesn't necessarily have to be dialed in like really fine within the rule just so that people who are participating have given fair notice as to what's being required of them and that it might be random which is perfectly acceptable yeah I would say from a practical point of view having an application report at least for pesticides submitted or on hand at the either time of harvest or when it's being transferred because it doesn't make sense to do it mid-season because you're not going to get the full picture and I think even for an indoor that's doing multiple harvest a year ideally they're going to be using the same products and then most of them will just have a list of everything they would potentially use and they'll just submit that even if they didn't use everything so they're covering other bases so I think like having that requirement um because it just like makes makes them a sense um something is like if you did it let's say like September we sell plants in the ground or November and like the season's going late you know you just don't know um and so I think like you know you're requiring them to have that on hand in case there is an inspection um or and then they get issued non-compliance or you know some other issue is not there um or you know passing that along to the um you know within the manifest or something you know it just depends I think on what Vermont wants to to deal with that information um but then I also think there's an opportunity there for like third-party certifications organic all of that and you can essentially say if you've been third-party audited you know then you may be exempt from this requirement and something like that got it well we don't have any both of our public uh members left so they must have been bored with our conversation but I have been very um pleased and this has been really great for tomorrow I know we have a couple minutes left Jacob said one thing that reminded me I have to at least discuss it initially tomorrow and that's disposal of crops if it doesn't meet um in testing standards or just quality standards as it's coming out of you know a field or an indoor grow operation and Stephanie I know you've got procedures in place from a hemp perspective for hot crops and how to dispose of them but this is slightly different than that so I'm wondering Jacob what's like the industry standard for those set of circumstances I just laid out let's say you do a quality test it's not up to stuff you don't want to enter it into the retail market how do you dispose typically of that crop yeah well now for better or worse there are so many different remediation processes out there not so much for flowers like flowering that's like what I would hope to avoid in Vermont with the um testing is like so many people know are like x-ray irradiating um cannabis you know originally people were using like um like hydrogen peroxide and doing a spray when they were harvesting but now I've been seeing more and more of these just like massive x-ray machines and I'm pretty sure that within the Vermont guidance that's supposed to come with like a radioactive symbol on the product but um you know everyone's just doing that so that it doesn't fail um microbials but then um you know I would say that a lot of the industry is if there's like a pesticide issue or heavy metal issue um the most likely will um you know blast it through with the some kind of like into distillate and then there's a lot of different um filtration methods out there now not too big on it um but I know that there's a lot of like I think um clay or colloidal clay carbon filter um yeah activated carbon or whatnot that will like remediate that so I would say that potentially requiring the flower to be destroyed you know it's going to put a lot of people out of business so I think like ensuring that whatever and you need to get flagged I think um but then you know if there is a safe and efficient way of remediating it into oil that removes everything or at least gets it below whatever the level is you know I think that would be what most growers would want to do but I don't think that flower can be remediated itself I think you would usually get um concentrated into distillate and then that distillate would go through a filtration process. Stephanie any thoughts? Yeah no I mean I agree entirely um I don't think there's gonna I mean hopefully there's not mass destruction of a flower in this world then it does get moved through the system for another purpose but I do think even if it gets moved to the system for another purpose following on Jacob's comments it still needs to be retested so that you could prove that it's met the standard whatever that standard is. So a question that I have and it's just how our licensing structure is is teed out right now nobody who holds a cultivation license has the ability to do any type of processing with just that cultivation license any type of cultivate any type of processing has to go through the product manufacturer license and there's multiple tiers depending on how safe their specific operation is when it comes to manufacturing should I should the board suggest that from a remediation perspective that cultivator would be able to do this without a manufacturer coming into the picture or you know I know that there's different ways to do it it's not necessarily safe would they have to work with a manufacturer to remediate this for them? I I think so just because you want to make sure it's done appropriately you know it's a big public health and safety thing so I think like having that done by professionals is probably the best way cool knowing that there's a lot of cherry picking going on with like representative samples and actual testing and stuff you know so they easily could you know take something from a different batch or whatever that tests clean and then that gets into you know the thing I think like having a professional thing to do that is probably the best way. Stephanie? No I totally agree and it just means you're you're either selling into another market or you're moving your crop into another market I think you could still be registered as the lower tier manufacturer to get that distill it back in your possession to then do an edible product for instance it's just but I think it's yeah no I think that's fine. Yeah okay just want to do I think it might be like sign in fact. Yeah it was just something I ford saw the way this conversation was going to make sure we're clear that you can't do this yourself necessarily you still need to work and I mean you can hold multiple licenses of different licenses so you could do it yourself but you have to have the license to do it yourself it's it's what I'm saying. Yeah and I would also say like but I do on that note I was reading what the the recommendations from like the BCA and all of that and I do think a really bad point that I think farmers forever should be able to do solvent less extraction on site you know making bubble hash essentially raws in anything that doesn't use the solvent I think is one it's going to really help small farmers you know be able to process their own trim or whatever create a new revenue stream but also you know help them brand themselves and not have to pay you know a bunch of money to get that process you know they're already going to be losing quite a bit you know requiring with the trimming and all of that so I think potentially allowing low tech non-hazardous non-harmful ways of processing cannabis would be ideal at least on a small scale. So long as it needs the standards for contaminant testing otherwise concentrate. It's like different from like the contamination I'm just saying in general like if it's clean and whatever is you know if they're able to at least you know process some of their own product I think is you know is useful. Well Stephanie I know you helped create you are on the market structure subcommittee we do have two tiers of product manufacturing licenses but if I were to suggest something like Jacob is considering and suggesting how is that different from that lower safer tier product manufacturing category that we've already developed and I don't know what it is. I will admit I don't remember I've back participated it's been a couple weeks and now I don't remember so I can't answer that question but I can certainly look into it and email you to see whether or not the lower tech bubble hash rosin resin processing is available to the cultivator small cultivator or any cultivator and I have to look into it I don't remember okay yeah I'll also throw in I can't remember I'll have to look into what specifics I do you know there's like so many cultivation facilities early on where we're being raided and being and plants are being destroyed like they're using even 20 and I can't remember exactly if like remediation didn't exist them but I think that's also just like a public health issue of just like exposing your workers to that without proper PPE so like there is I think some red lines on like when product just has to get destroyed as well depending on like what they've used because like if I remember correctly um like eagle 20 is just like it's a rivet of like agent or and it's like really terrible stuff um like yeah Michael but you know it's just it's terrible and then hugely impact the um I mean consumer issue you know so I actually have another meeting I have to jump on too so thank you so much for the conversation Kyle I will get back to you with some information about pesticides a recommendation and then citation to the cannabis quality control programs ability to set standards for cannabis and I think that was it those are the three things out oh and then the market to look into the licensing structure in the marketplace but I gotta I gotta run gotta jump thanks everybody just appreciate it thank you Gina thank you Tom thank you Jacob all right thank you everyone