 I'm Kim Watson, a member of the Science Advisory Board for the state, and... Karen Jugeer, Hermione Agency of Agriculture. Kim and I are going to try and flesh out what standards and testing procedures should be in place for a regulated cannabis market with your help. You can see a lot of familiar faces in the room while we're still going to send around an attendance sheet, just because there is no protocol for subcommittee meetings yet. We don't want to be remiss if that becomes a standard. And I think we'll go around the room real quick and just do introductions. If that helps, I'll start with you, Scott. I think they'd be attending the sheet. Well, let's start with you. I'll finish with me, just so you guys know a little bit more about me. Yeah. I'm a retired worker from the Stone and Gourmetals, which was in multiple areas. And I have been working with the state of Oregon in their protocols for sampling and making sure that we get representative samples for cannabis, product, flour, and any kind of oils and things like that. So that's all I got asked by Julie Moore, who we used to also work as Stone Environmental to be a member of the Science Advisory Board. My name is Scott Waring. I have an involvement of New Baldwin Association. I've been working out for, I'm working now, working for the group to purchase a piece of processing and working on building, or bringing that into the whole back to life. Hi, my name is Keith Griswold. I was, I currently run a consulting company called True Measures, but I was formerly of the original Northeast Process, a little bit testing. So I'm currently working with Scott to get the Northeast Processing Lab for cannabis off the ground again, in addition to a couple of other small processors located throughout the state. Jeff Mapp, everybody? My name is John Burgadia. I work for a small company. We were doing some kind of planning or interested in getting into following the cannabis. How's that? It's Lee Gleister. I'm Kim Kaufman. I'm brought together some small hemp farmers in Worcester. They're very interested in moving into cannabis. Jimmy Goldsmith. It's the same thing. Go ahead, Steph. Stephanie Smith of the Agency of Agriculture, I currently manage to have programs for the state of the month. Chuck Starleau, I'm a public affairs, I think. Mr. Waring, you're our client. Could be. I'm pinch-hitting for somebody else in the tournament. Yeah. Was they able to spread them? Yes, me too. I'm Virginia Bradford, and I'm here today representing the Mott Campus Trade Association, which consists of the existing and medical responses. Good morning, everybody. My name is Jeffrey Pistola. I'm here from the Vermont Grurbs Association, and I'm representing the, not just the illicit, but also one of the people who serves in small doses. All coordinated to work, and not just for instance. Great to have you here. I'm Julie Goldsmith. I'm a member of the Cannabis Control Board, which I feel like a program already all year long. Thanks. Thank you. Yep. And I'm Bryn Carr, the executive director. All right. Thanks. And sort of just a little background on my end. I'm the director of the Public Health and Resource Management Division here at the agency. It houses the HEM program, and it has a lot of consumer protection and quality control program. It has a pesticide program, DT Infernalizer program, and when asked by the then Governor Peter Shumlin what consumer protection and quality control program would look like for cannabis, we used a lot of the material that was out there, was in touch with other states that regulate cannabis, and it came up with a protocol that you see in the HEM rules, but I'm hoping that Tim's experience in Oregon helps us improve those, as well as input from everybody here. And with that, let's begin. Where do you want to go? So, I noticed that you have a lot of tests that you're requiring on the HEM, which would be similar to what you'd want to require for medicinal and recreational. And I think they're both being included once it's all on the board. Yeah, they're going to make just one universal for both and recreational standards. So, go list. Is it enough? Do you think it's enough for public health? So, what we did in the HEM program, Steph, always feel free to chime in as well, and it's up there on the screen while we're talking about for people who are interested. We want to make it not overly burdensome for the producer, but still protective of public health. I think we've done that, but extra eyes would be extremely helpful. And I wanted Stephanie with the Agency of Ag. The other thing I wanted to point out is with HEM, specifically nationally and in the state of Vermont, we're required to test harvest slots for potency, specifically to meet the definition of HEM. And so, that's potentially a little different, but not entirely different because I understand that there is currently a limitation of 30% THC on cannabis to be grown. But that still probably is at the product level, and not at the harvest level, even though they might be the same. But anyway, so, but if you triple the flower or not, I mean, that's potentially the concentration is greater than what you would collect in the field. So, that is a little, maybe a little different. So, I just want to highlight that. Which everyone in terms of color, you know. You know, most states require that you test both the harvest slot and the crop, you know, the flower, basically. And it depends, yeah, yeah, what it's going to be used for. For recreation, because it goes right, the flower goes right to the dispensary, and other flower may go right to processors or producers. I think the point, Stephanie, was trying to make it correctly for our own stuff, but in the hemp market we're testing potency for compliance and a regulated market is for marketing, right? Yeah, yeah. And it's possible that the flower would, at the grower level, it is possible that the grower not test at a harvest stage because that flower would be trimmed up and it's when it's sold that you would want to know what the potency is at that point and not necessarily out of the field where there might be leaves and other additional substances that might otherwise pollute what might get sold in a container at the dispensary and or retail level. So, is it, and this is an open question because I, again, I work in the hemp world. One of the interesting comments is whether or not it really is the product that we're testing and would the grower need to take a harvest sample, would it be incumbent upon them to do it and pay for that service at that point in the process? Am I making sense? I don't know. I feel like they may be able to certify it better. What's the timeframe on the testing? Are you testing pre-harvest? Are you testing... So, for hemp it's pre-harvest, but I think in a regulated market it's the final product that would need to be tested, you know, depending on your math. Like, we're trying to, I believe I would like to see applied a level of sort of sanity, like if it is going for extraction, depending on the type of extraction it's going for, you might not see some of the micro-topping, toxin testing, but if it is smokeable flower, then microbial contamination on the flower is important. But this is all stuff that needs to be talked about and fleshed out. I don't want to be the be-all and end-all. Like, I'm willing to be educated here. Well, that's what we try to do for that hemp, folks, just so they weren't having to do a battery test that weren't necessarily going to be protected by public health. So, basically we have potency, pesticides, residual solids, and microbial contamination. And the moisture up there is also important, but less so in a regulated market, because if your moisture is too high, it's going to take care of itself. We need to do that because in the hemp rule we said, that needs to be tested on a dry weight basis, and we said 13% is dry. If, unless, yeah. But other than that, any thoughts? What did you see in your order? Well, we really, I mean, we really would focus for recreational on the trim flower and the concentrates, depending on the products and infused products. And the real key was that the laboratories were required to go to the producers with a trained sampler who would sample the flower from these lots. And they could be 10 buckets of flower, could be one bucket of flower. It could all depend upon what the producer is producing. It really depends on what you're bringing to the recreational market. And most of them had their own recreational facilities as well, where you would purchase what they were selling. And it was all about the laboratories who were required to go. The producers could not send their own lots and the increments of what you were preparing into the laboratory. The laboratory would send out a sampler who was trained in representative sampling who would determine how many increments to produce and bring back to the laboratory. And they were required to be trained on an eight-hour training day on how to collect the flower, the concentrates, or the products. And that training would include, you know, how to take increments, how to randomize your tests and everything, or, you know, your increments so that you were to ensure that you could get a representative sampler. But the most important part for that was their pesticides. Because, you know, we know in the markets today and in the facilities today, they're starting to use pesticides. I mean, when they were growing in the 70s, nobody had to use pesticides or had as much as they are today, especially in greenhouses and things like that. I've always felt like the pesticide misuse was, by far, the most important part of the ceremony. Yeah. Yeah. I mean, heavy metals, that's, I'm not really sure. I've never seen a lot of heavy metals. That was important for them. Yeah. Because it remediates the soil and we're planting in unknown. The indoor grows. You can control the media a lot more and help us growing in the fields and some of those samples we're seeing highlight. Yeah. And probably our snip just because it's natural. Soil's in Vermont? Mostly lead. Mostly lead. I don't know why. Northeast processing folks, is that a bigger experience as well? Lead and then cadmium, actually. Lead and cadmium. Some of the soils. And this is just here saying that apple orchards tend to have that issue. We do know that. Yes. But that certainly makes sense. I mean, in the context of cannabis testing, where sampling, obviously results could be skewed based on the sampling method. I'm just curious though, so the trained samplers for the employees of the laboratories at Howard's, they actually hired by the laboratories. So is that built into like a sampling, and I don't want to digress here, but a sampling, is that built into the cost of the testing or how is that after costs? I'm not sure if the producers would have to help pay for the samplers to come out. We didn't really get into the cost. I got into more of the certifications of the laboratory in accordance to the Department of Health. They control standards or their certifications for their cannabis laboratories. And a lot of the ISO 17025 labs also employed the samplers. There were some independent samplers, but most of them worked for the lab. Just thinking about it from the research perspective, just the little red labs. Yeah, and the dispensaries also may have, you know, had connections with the labs and the samplers, but the dispensaries typically had one lab that they used all the time. Right. I mean, there's a lot of labs. There were 75 people that showed up on the training facility. The one day just because they had, you know, had to do it. Does anybody in the room feel like we're missing anything? One thing to keep in mind that we currently see in the illicit market at an increasing rate and also emerging in adult use marketplaces, and that is the notion of basically rehabilitating, right, a product in the process of making it a concentrate. It's often part of mediation. And it is often an opportunity, this is why I bring it up, for otherwise a product that tells it has to then find a pathway to market elsewhere. I don't know exactly what the solution is. I do know that others are thinking about this. So something to keep in mind, so in an act it would be, I've got a field of raw flour. It fails, say, microbial heavy metal steps. Can I then shop around to a lab to get that turned into a concentrate that may or may not theoretically, you know, deal with that issue? So like making a distiller out of a failed material? There's a manifest on most flour and products, you know, that is tracking. It's lot number and it's use. So I don't know what the hemp market has done in terms of a manifest to keep track of your harvest lot. Yeah, in the hemp program we do require that it should be maintained of flour or concentrate moving and where it goes and ends up. So even if I have a product on the shelf that I've made, if it comes from a concentrate, I have to be able to, there's trace back and trace forward. Through records. Now we don't maintain those records here at the agency. The individuals require to maintain those records and they have to be available for inspection when we ask for it. Our rules have been in place since May of 2020 so we're just a little over a year into it and we do fair amount of compliance assistance with everyone. But let me make them aware of these requirements. So yes, we do have that in the hemp program but to some extent my understanding is that some of the organic issues can be resolved through a solvent extraction process. I could be wrong. But even if you did do that you would still have to have a clean record for the concentrate that you make. So if the flower is cleaned then you make a concentrate. Potentially that record follows that concentrate but we need to have a system or there has to be records that are maintained that show that the concentrate is linked to a clean crop in the beginning and if it's not then you could potentially remediate. You could take that time and spend that money and have that test run again and that's fine too if it is a fair remediation step. I don't know with certain concentrations and exposure limits in the pesticides there's no... Oh no, I was thinking microtoxins. I wasn't thinking heavy metals. I think heavy metals are probably concentrate as well. But like, yeah. So if we didn't find any of the traditional chemistries as far as pesticides go it would be a misuse and the sort of list that we have for hemp really relies on organic products or mineral risk products. So all of those active ingredients up there. How many others? Oh, that's what we would want to test for. That's what we test for. Yes, that's what we test for. You only test for 15. Do you require any of the producers to document their use of pesticides? Sort of the folks who have gone down the path of certifying organic have to document what they're used and that's a pretty good percentage of hemp growth right now. If they are a private applicator they do have to sort of record their use. And are they certified through VOF? Organic? Farmers? A certain number aren't but the licensed applicators are certified through the agency of that. So you have auditors like the law? Yeah, field of agents, yes. And our habits inspector look at their pesticide storage generally visits a farm as well? As does fire safety. As does fire safety. Carried the hemp pesticides approved by EPA for use on hemp. Are you watered? I don't think we would add those to the list. No, not to this list but just generally available for use. Yeah, so what do you think? On recreational camps inside of anything. Yeah, no I wouldn't. Primarily some of the minimum risk stuff, yes, but the pesticides that EPA is allowing on hemp are all for seed and grain and they do a dietary risk assessment but not an inhalation. That study's called something. Did you ever do that study? The inhalation studies? No. I don't even know the list of EPA pesticides or food to go on hemp. I didn't think they were any. They're all. Are they biopesticides? No. Because like I said they've been evaluated for grain and fiber crop. So you can eat them but they're not considering a smokable flower market. So the list of 25 bees? It's okay. The 25 bees are the minimum risk. I know there's 15 unit organ loss for 25. Yeah, no I've seen the organ and a lot of those you can't get anymore. So it took off the ones that haven't been for sale for a little while. You think you can't get them? No, we're pretty sure. We've been running a disposal program in the state and it's been pretty significant. And a lot of those products are around. Yeah. If it hasn't been registered for sale or use for the last 15 or 20 years we didn't add it to the list. So where, what labs are they, the state using right now? So for pesticides currently our labs are in the Round Robin stuff. We have eight. Eight? Yeah. But we have two, we're certifying labs as well in the state of Vermont. And we currently have two. And then we have Vale, so the state lab. And then we have a bunch of other labs that are interested in those who last at the dispensaries that are currently operating. So the Department of Ag is certifying that it's not the Department of Ag. Correct. And that, and the accreditation bodies that are doing it, are they certified by particular accreditation programs? So we require the certified labs to be ISO 1725 compliant. And then we don't necessarily require a specific cannabis accreditation. Just that they're following 1725 with respect to some standard that they have at the lab, or some analyzer. And we actually don't require it. We require that someone either have it or be working towards it. Because we wanted to give a leg up to folks that are entering the system but haven't quite met that far as of yet. So they have to be working towards it. And we limit those that are working towards 1725 accreditation to only testing potency, moisture, and one more, but I can't remember. I think it's pesticide, actually. I think it's worth sharing the certification document with Kim. Yes. This is what we're looking at right now. I can share that. I will send that to you. So just out of curiosity, what certification does the, the, what is it? State lab. State lab. I think what is the AAL? Is it fail, Vermont? Environmental lab. Okay. Oh, the AAL. Okay. And what, what accreditation do they require for them right now? So that we're, we're designing what requirements that the lab will hold, but the lab does environmental work. They have the National Environment, a lot of accreditation. Yes. They're moving, moving toward the 1725. They're looking for DEA certification in Israel. And we have other certifications for FDA. And What is DEA? So that's Drug Enforcement. DEA. Drug Enforcement. Yeah. Well, that's what I thought it was, but just in case. Yeah. Wanted to get all of something else. And we're accredited through FDA as well for our dairy lab, for the Central Dairy Testing Lab in EPA. So they really grown there. We've always had, our lab started off as a dairy lab. Okay. Yeah, no, I know. Yeah. But the one that was here, but they really, is it all in Randolph now? It is, yeah. So the lab was in this building for many years. Yeah. And then we moved to the lab in Water Barrier, which was destroyed during our reading. We squatted at UVM for eight years and built a new facility in Randolph. And that's where we are now. Yeah. The QA manager used to work at Stanford. Who was that? Dave Crosby. Dave Crosby. Perfect. All right. Totem, everything he knows. Dave's great. Even I noticed he has a really nice quality management point. Mm-hmm. Yeah. I have a question just about, so have you given any thought as you move through this to what size you're going to allow, how much are you going to allow a grower or a dispensary to grow in terms of capacity? Because how will affect your testing automatically if you're going to have very small grows? Mm-hmm. It's very easy and probably a test. Mm-hmm. Yeah, that's not our charge. No. Specifically that Julie and Kyle and James, they'll be having those conversations. But I was kind of what's sort of in this conversation what's sort of sticking in my head is a sampling and a sampling protocol will become important. Our list isn't too far off. And pesticides are the primary focus for consumer protection. It's sort of what's, what I would have for bullets. This is as well. Probably the residual solvents as well. And residual solvents from extracts. So for concentrates. Now what we want to test, again, I think we almost need a HACCP plan for facilities. That's sort of the critical control point. Because if you're extracting to make edibles right into butter and not concentrating first, maybe we're not looking for residual solvents. But if you're starting from a crude oil or distillate, or then we should be looking. And I'd like to sort of build on that flexibility, but I don't exactly know how about being right up in everybody's business. Right. What's the process of doing what is the producer doing everything? Or if they did residual solvents on anything that got concentrated into a liquid or a oil or a... I think that, so your smokable concentrates I think would all need to be tested for residual solvents. So one of the things that we did for most of the producers and the processors was we created standard operating procedures for the samplers. So the state of Oregon has a free standard operating procedures for the samplers. I don't know if you've seen them. Yeah. I don't have copies, but I have one. Yeah. So we helped write those. And basically it allows you to know how the samplers can collect first lower and how you produce your ingredients and stuff like that. And then each laboratory had to make their own standard operating procedures set up so that they, because they're the ones who are working really close with producers and the growers and what they're going to put on the line. So we envisioned sort of a similar model in Vermont or would that create too much of a bottleneck? Because if they did move forward with an unlimited number of small facilities then that's more testing than if it was a few big ones. So having the laboratory responsible for taking the samples, would that create a bottleneck? I don't know what appropriate, how to put up a Vermont stamp, but make it ours. Right, right. So what I hear you asking is that would you allow the growers to have their own samplers and send them off to a lab versus whether the laboratories had to go out and provide all that service? Yeah. So in the cost of what's your auditing process look like for bad actors? I mean their enforcement. Yeah. Because that puts a lot of burden on you as well. Are you going to go auditing samplers and making sure that they're not just going and picking their one? Right. Like they purge this, concentrate a little bit longer so that they send it all out. I mean when you have a product or a harvest lot that even had any of pesticides in it over the action limit is destroyed in most cases. Yeah. Or even microbial stuff or whatever. Do you think you can fix it so that it works? I'm not quite sure about who you're going to trust to do that. Yep. Because nobody likes to throw away pot. Right on. Nobody. I mean even when they... Your operation is going to just increase your cost of compliance you know higher and higher and that's probably not a burden you want to lay on. For all the reasons that you just brought up it's not something you want to lay on. It's something you want to control from your side. Yeah. And it really... How big are you allowing these harvest lots to be? I'm not really sure of what... You know. Because when you go to get an incremental sample from a table this size it's quite an effort. We got a representative sample from a 3 acre hand field stuff. No. We had way more than what I was willing to take. Right. Right. I mean so that's... That's the big picture. How are you going to take 3 acre field and get it down to three buckets of flour to make a sample and then not only that how much of that can you send back to them after a sample or have you got to get rid of it all? You know. Some of it doesn't... I know in Oregon some of the labs are having a bigger problem than rid of all the extra. Mm-hmm. I just... That chain of custody the verification is... is our biggest issue I think. I think we have... Documentation, documentation, documentation. Even for the sample. There's... number lot numbers and specific weights and documentation of how they got that representative sample. I mean I don't know having not been involved with any of the state audits that you're doing right now I don't know how you're doing to have documentation. Like... Do... There's gamut operating procedures for the samplers right now? So... We have put together a post-harvest sampling guide but it's just guidance to help people understand how to get a comprehensive sample or you know represent. Representative... Yeah, something like that. A representative sample. So we do have this and it's kind of a recommended practice. I'll admit. That is on the website. Yes. And then we also have forms. Yeah. Also on the website. So we're running... We're sort of running a TRESPA verify system at the camp program. USDA under their... What's it called in TRESPA? It's not called that. It's sort of what we're doing in the program. We trust that folks are doing it right but we do send... We do take really new samples ourselves and running that around. So we have post-harvest and we also have pre-harvest sampling documents. Sampling protocols sampling forms and a chain of custody forms as well. These have to be followed because it's associated with our pilot program and eventually it's going to be a state approved plan. And now it's... What's working? What's your... It's... Most folks want to do the right thing. Everybody wants to... It happens of sort of... Everybody's sort of muted as a gift but you know it's the first time that we've come out of Canada's prohibition is with the health market. And folks have been very straightforward and have been trying very hard to do the right thing. That Keith will work for Northeast Processing if somebody's health was over 1.3 then we would take him. So it was on the producer and the processor and everybody was sort of doing their best to be compliant. Yeah, we have about a 70% compliance rate relative to the preharvest sampling and all of our testing requirements and we're only a little over a year into the program and I feel like that's pretty good. And that's based on the folks that we've reached out to and we try to get to 20% but we reach out a lot. We do a lot of education work in PBM but I think it's going pretty well. It's primarily like it might be failure to test on a contaminant and failure to provide a record but that does, we can again provide compliance assistance to help educate folks on the complete breadth of what they need to participate in the program. Where some of the producers or growers got into trouble with growing 20 varieties of hemp and each individual variety was the hardest lot. And the hardest lot it was okay to test for one or two but when you were testing for 20 with a full battery of tests it was cost-per-hit. So the percentage for what they used for sampling of either cannabis or any other product. So, you know, percentage of the total a lot meant. So for instance, in California it's at 0.35% of the entire you know product whether it's flour or concentrate or if it's more than that we tested. It depends on the hardest lot. I mean, what are you talking about in terms of potency or just the percentage of the increments that they need for sampling. Yeah, it's all in there. So that's a view of the sample in other words. Yes, they tell you what their increments are how much the percentage has to be. Yes. So the scale of the lot determines the amount of material however the lab may then is that some sample that can use some sub-sampling. Yes, it depends. And then they only test that sub-sample. So there's still this volume of material left over like the lab that needs to deal with which is what you said earlier. Having those clearly defined I think would be advocated for increments especially small things. Yeah, a scale rather than a yeah. This is different for post-harvest sampling protocol. I want to say that we actually might refer to the amount of material that needs that there's a fair bit of scale. Remember? Now we do collect depending on the size as well. But then we also I think acknowledge the fact that we know it loosely that we don't want to take too much material either and that an individual should be in contact with their lab to understand what it's needed in order to get to run a test. Yeah. So we might need to lend two things into one. This is available on our website. I mean in terms of what you require these items right on So I think for our next steps should I track down the Oregon SOPs or you said you were involved in writing them? I have them. I can even email them to you. Yep, send me the Oregon SOPs and we'll get them to you. They used to have three. They used to have one for for product. But then they included that it would be easy enough to just put the concentrate with the product. That makes sense. And we'll send you the our lab certification and lab certification to look at and we'll think It is pretty expensive for them to get the 17.025 accreditation. I think is that why you guys decided to do that versus Is that your continued effort to do? Are you going to continue to do that? So these are hemp labs and Some are food labs. Some are food labs. I think there ought to be a way outside of that third party sort of certification to I mean you can be ISO certified it doesn't mean you produce a good result because it's documented. I would rather see a performance standard but for right now I think ISO is what we have. No ISOs probably one a year. And the thing is as we move this market forward we're going to need a lot more than eight labs. I know. Are you going to have the manpower do that? So we'll have a state lab but that'll be sort of mandatory lab. So these are what this looks like. Do you have an HDMI connected on the side of here? Yeah. Unfortunately it's going to have to remember them down here. Okay that's not long enough. I think it's probably the other day though. The HDMI. I noticed a lot of other states that are missing. Are there products? Yeah. So without the different set of requirements for the next years and for the straight plan. So at that point it's no longer hemp. The product is no longer a hemp product. So that will be up to the control board to decide. I hope to see it. One is a regulated cannabinoid, one isn't. Which product? I think the protocol for those will be an evolution of discussions. We do see a lot of demand and need for mixed cannabinoid flour and concentrates. So what happens to the hot hemp growers then? And then put their product in place? Or they'll have to be cannabinoid devices? So that will again be something that the control board will have to make a decision on. I know what my opinion will be but I don't think that's what U.S. didn't have in mind when they said you can bring me a hot crop. Right. And at that point where do you fit? You've just grown 10 acres. Everybody else is allowed to grow 1,000 square feet. What then? And I know there are folks in the state that are making Delta 8 and Delta 9 out of CBD that the control board will have to decide if those will be allowed into a rec market. We're just working on the lab stuff right now. I think those are questions that are more directed at commissioners of the board. I'm sorry, I mean I would love to answer your question. But it's not my call. I'm curious. So what can you do right now with him that's over focusing? Destroy it. Destroy it. USDA has a provision for mediating crops but it's more or less destroying the flower or there's another opportunity for the camera. Oh, biomass. So until moving the flower with stock material to bring it below the 0.3 those are your only two options under USDA. So you were asking about the percentage in this increments. There is a whole table in the back of these SOPs for the the size. Are they based on policies set by the health department and or commission that's set in law? These are all done by the Department of Health. Okay. No, so they because they have a whole another set of laws on the whole manifest for the harvest lots documenting that and there's a whole that's all but these were done for the laboratories and I mean they at the time we used a lot of different people to get them into into law. They are pretty much law I think I mean you have to follow these and document it for the food but when you get down to the processing and the increments the sample size are pretty much and it is all about the batch size. That's acceptable. Can we find out sort of the cost of a battery at tests in Oregon that we can call for? I probably could find that out. I think it would be worth it. I actually have some good laboratory contacts there as well to you know Rose City and some other ones that both have their own facilities as well as their their producers. I think that would be an important data. Yeah. Looks like they've done a lot of good work there. That's the one that's for flour or usable they call it now they don't even call it flour. And then this one is for concentrates extracts and product and I think you mentioned California used a lot of their stuff as well because the same people were asked by California to help them develop some. But they never got down to this detail. Yeah, I mean thanks for mentioning that. I would add that our organization is close to the Humboldt County Corrosion Alliance and we're pleased with what California does and also Oregon also specifically for my program now that's sort of becoming a contentious issue. So you guys do a good job with that. That would be interesting for a lot of the systems. But they do require training. That's the one thing they say the samplers have to be trained and the training has to be documented. They have to know what they're doing. They have to so here it's always based on the weight the batch weight. And so in Oregon the labs are the ones that employ the samplers. Have you ever heard of any discussion or aware of other states where it's just an industry that arises of its own and samplers are just the industry? And you said that there were some in Oregon but doesn't they now wear for the labs? I wasn't sure. Most of them were all labs that I worked with. They've been revamping it a little bit more because they have the training within their own facilities now. They contracted with me to do the training as well and I'm like you can train the training. I don't need to come here every year because every year you have to document that these samplers are trained for an eight hour day just like if you were doing OSHA. You're doing and so it was really within their own groups of producers and processes and laboratories. So I don't know let's see what they changed. I mean I think yeah this just had to do with quality controls and some of the things that were going on but that's all available on their website. But I can email these to you too. Yeah let's do that and we'll make sure that the board has a copy just so that will be our and then it's essentially a couple of options. In addition to training in addition to testing specifically is there any interest from the consumer protection world whether or not there should be specific actions that a grower or processor should take in order like besides testing which is important but like risk reduction in their actual practices and say that again. So growers and processors should this program include risk reduction activities. You mentioned the asset plan but is there should we outline what those are or suggest that that be included for growers and processors that you under if you That was more or less the triage what tests were needed on end product. That's right. But still this could just be you've got to follow these practices and you have to do these tests I think we quality starts before testing I think we build the goal standard and then put it out for comments because of the balancing act between we don't want to make the regulated product exponentially more expensive than the non-regulated product or we're not going to balance the market so we have to see what the cost is and what sort of I think I hadn't even considered the price of having the sample taken that could be significant your charging mileage to and from just about well I think there's a balance here and I don't know what it is but let's build the goal standard which would be all product tested using certified licensed samplers going to certified licensed labs and see what that looks like I mean they didn't require their samplers to get any type of certification documentation of the training and as we used to tell them once you get trained or once your quality assurance person gets trained they can train the other samplers as long as it's really well documented and they have a training program of some sort the same way when NELAP requires you to get ethics training you know that kind of training on a GCMS or an HPLC you have to demonstrate some kind of competency in that manner the other sort of thing that could happen is we build the we have these certified labs but we do a sampling of the product on the shelves to test for all these parameters and that would not be on the producers but it wouldn't be every sample it's kind of what we do with our feed and fertilizer programs and just that sort of enforcement presence ups the quality of the product in the state in those particular programs I do like the idea of how to test it but if we're dealing with everybody and their brother growing moving their backyard to 1,000 square feet of chemistry in the cell I don't see if it's going to get tested on in a timely manner but we'll build that first like what happened in Oregon their market crashed because the labs weren't up in run I think they've recovered but how do we avoid that? Yeah I mean this doesn't solve the problem in the first year or two but if you have people who participate in the program and do all the testing and they have a proven track record then you get back because that's an opportunity to be a producer that dials back too but then it just becomes Yeah how are you going to limit the cost and that's probably the biggest thing I mean I don't know how you're doing it with the M program right now like you said how is it happening right now? We require the tests We require the tests and how much is that costing you guys? It's a lot It's expensive and that's with the grower at least from last year we didn't grow the ship but taking the samples yourself I know they have the documentation that you followed so trained but then dropping those samples off to the lab requiring the lab to send out a trained sampler to the understanding from the state's perspective that's going to drive up the cost a lot for the lab to be charging when I say a lot it won't be any expensive especially to where you have So where do you send your samples now up to the state or do you First we were working with a private lab in Waterbury as far as I know it's accredited by the state and then at some point we had to deal with a lab that was DEA certified so that was done before which obviously would be impossible In the event that you decide to go to a level of screw minutes where there needs to be DEA certification I don't think one exists and a lab exists in the state but one exists in the area There's one DEA but I think I mean from the hemp perspective all labs beginning in 2023 will have to be DEA registered for hemp production my understanding is that in Oregon the labs that are certified by the Oregon Health Department are also labs that do testing for both cannabis and hemp and my understanding is that DEA is not going to get in the way of that certification program and the ability for those labs to test for both hands crops and hemp crops I'm not in Oregon I don't know how that's playing out but I suspect we maybe could inquire see how that's working That's one of the things I have to say to believe behind me because we didn't do anything but with that lab before it was not exponentially but more expensive than the lab tier and they have the extra levels of accreditation so just speaking to cost everything we're discussing I'm just going to keep driving costs higher and higher to the farmer I have a question do we know how much of the testing is exactly how much of the testing is happening out of state right now for hemp? What do you know that testing is happening out of state? The difference is the hemp producers they could have a tank or field that is one or a slot and they're required to do one battery of tests whereas the high THC cannabis you're potentially going to have a thousand square feet every eight weeks and if it's just one variety then maybe that's your harvest slot if there's multiple varieties in that grow room that's multiple harvest lots so what the hemp producers are required to do once a year the indoor growers are going to be required to do five times a year at a minimum on every different variety so we have the hemp growers saying it's expensive to do the battery tests hemp is worth about half as much depends on who you're selling it to but people are still getting a substantial amount for cut flower for multiple flower and you're growing 10 acres and it's still expensive whereas the high THC that could potentially be overburdening with testing I don't know what the answer is the problem is the equipment is so expensive whether you're doing heavy metals that's the big problem for the lab Keith had his own half million dollar lab just a couple of months ago so it meant the ongoing costs cost but it's not cheap so let's think of action items I'm going to send you those I'm going to kind of agree that the tests are sufficient yep I'm going to apply action items to look at some costs and what the difference I always think that they've included the samplers in the test costs because they have to employ the employee anyway whether the lab is using the sampler for cannabis or water testing they'll go out and collect water samples to maybe charge a little for mileage but not necessarily interested in how many of the labs of the 75 in Oregon are testing beyond cannabis because if you have the equipment to do other tests you're dividing that equipment up amongst many things I can ask that I'm wondering if that feeds to the issue as well because it is the environmental labs that are also inquiring about hemp circulation are they? yes Eurofins I think yeah is a foods lab but they're also going to a cannabis lab or a bill so we'll send you our lab certification we're looking at you send us the Oregon SOPs and check into what the costs are and then we'll we'll meet again this can be a month or something we don't know I think for the start it's going to be we'll meet again in a week or two yeah let us schedule is what it is I'm busy like I said September 1st of October all of the labs excellent alright so we are done for it today