 Confusion, I think Carrie had dueling combos with Pepper and with Bryn and I guess Pepper thought the meeting was canceled. Bryn thought you were studying for Carrie and we were going to try and have a conversation still just considering that we haven't had one in a while. So you know, I think this is a, are you recording now? No, yeah. Okay. Let's start the recording. Okay. Okay. Things will do the introductory and then I'm going to turn it over to you, Kim. All right. We're getting that rolling. Okay. All right. Do we have an agenda that I'm supposed to be looking at or is it one topic, a recap where we are and what we're going to do going forward? I think that, I think that that works because I don't think that there is a formal agenda at the last. No, I didn't use agenda. Yeah. I don't think anybody gave me an agenda and this is kind of. Yeah. To nobody's fault, you know what I mean or anything like that, but in the room we have Nellie Marble and Kyle Harris from the cannabis control board. We have one member of the public listening in, Kim Lawson, advisory subcommittee member, Stephanie Smith, also advisory subcommittee or advisory member of filling in for Cary Gere today who is double booked and we have Sherman Hong who has provided a lot of comments to the board given his background and expertise in lab testing and he was invited to listen in and to provide any comments. Kim, so thank you Sherman for being here. I'm going to turn it over to you Kim. I know it's just kind of an update on where things stand that would be very, I think helpful. We're hoping to have some understanding of where things are for our board meeting on Friday and help kind of go along with the phase one of our scheduled proposed rulemaking plan that we're hoping to develop over the course of this coming year or excuse me this coming month. So I, you know, I'll start but I think Stephanie can probably fill me in better than I know because it was kind of left in Cary's hand that we agreed that marrying or with a few adjustments the hemp program as has the department of the agency of AG is doing, they will continue on that vein as I understand. Is that correct Stephanie? Yeah, my understanding is that the agency's cannabis quality control program set up would apply and I guess relative to action limits and the one, what I understand is that maybe the standard operating procedures for taking samples may change or would not be the same but they would not be the same as the hemp program is necessarily. Does that sound, and I'm referring back to Kim, does that sound accurate? That is correct because we recapped because we figured as I got from Cary the hemp program as it's working is doing well and I think, you know, there's a lot of, we put a lot of trust in the agency in terms of auditing and ensuring that we're getting data of some known quality and that the agency laboratory has stepped up to the plate with regards to their programs to help with the analyses and things like that. I'm not sure where the certification programs for getting other labs into the program is at this point in time and whether, I mean I personally highly recommend that they go to some kind of ISO 17025 accreditation rather than the agency accrediting because it is, it's hard to keep track of, you know, if we don't have a standard set of, you know, quality standards. Yes, so let me at least share a little bit about the agency certification program. So the certification program as it's being applied currently is we do require ISO 17025 accreditation or at least working towards that accreditation because we know that there are some labs that aren't actually accredited at this point in time and it's a fairly big lift. If you're not currently accredited then we limit your testing capabilities and I'm talking specifically about the hemp program. We limit your testing to potency and moisture and maybe pesticides and that would be on crops. Actually, no, you would be able to test potency in a finished product as well, but it's limited what you can test. You can't do mold and mycotoxins, aerobic bacteria, you can't do pesticide, no solvent analysis. So, it's, anyway, it's limited and you have to be working towards it though so it doesn't mean that you're not, you know, you got to start moving and if after a year there's no progress then, you know, we would consider the facts around why there's no progress and maybe make a determination whether or not we would allow you to renew your certification with the agency. And so, so we do require that 17025. Right. Yeah. Yeah. And then additionally, the certification program looks at how you're reporting the information out in order for us to have some consistency from lab to lab to lab and also to be in compliance with USDA's requirements because we have that added layer. We require reporting on as packaged for products. We want to make sure or try to establish in Apple's Apple's comparison regardless of the lab that's doing the analysis. So, we look at the reporting as we look at, we review your starting operating procedures, we review your people that are working for you, you know, we require some resumes. But it's fairly, it's fairly quick, you know, we're ground to thinking also we felt that it would provide, I mean, not only can an individual complain to ISO certification folks concerning that lab's ability to reform, they also have somebody in the state that they can report to because we've certified them. And sometimes that conversation can be easier and then we can also work with the accrediting agency as well, we can have conversations with them to establish what's going on, I guess. We also require some proficiency testing by those labs that are certified by us and organizations do as well very recently, so I'm not entirely sure. Yeah, no, that's all I, you know, the summary of that is really excellent, thank you. I knew there was some on the hemp side, but I wasn't sure where we were going on all of the cannabis side, you know, the, well, I knew there was some on the medical marijuana side as well, yeah. Okay, yeah, public safety requires or doesn't require relative to testing. What I do know is that the cannabis quality control program authorizing legislation does include cannabis and cannabis products, and so currently our action limits apply to those products despite us not being the regulatory authority. Right, so that's a good recap, and then the standard operating procedures, I don't know where that's at. Kerry said he was going to do it, if he needed help, he was going to let me know. Okay, okay, we do, on our website we do have, I guess it depends on at what point, you know, like are we tested, we're probably only testing product, I guess it's an open question whether or not the cannabis control board will require only testing of final products and not necessarily earlier in the stage, you know, like obviously businesses can have business agreements to do testing so that they can formulate products and they can require that products go through certain tests so that they're clean when you're making a product, but are we only testing final products for all of these action levels and leaving the business relationship to deal with what's before the final product? I thought there was going to be some randing testing of flour and that, yeah. Okay, that's entirely possible, yeah, okay. Yeah, yeah, that the agency would do during their audit process of the, you know, on site as they were looking at, as they were looking at, as these suppliers were sending their product to, per sale, that should get done at some point in time. Okay, I don't know, it was based on your audits that you were going to start off or what your program for auditing was going to be set structured as? Yeah. So you are hiring new auditors and things like that? So the agency does, we do inspections and we touch approximately 20% of our registrations on a, registrants on a given year and that inspection includes review of records. So we operate under a trust but verify system and we make sure that they're, you know, we evaluate whether or not they're doing the right testing and whether or not their results are accurate and if they're not, you know, what our next steps are with respect to that, sometimes you can mitigate or remediate a crop if, you know, and it can go through additional testing as it gets further processed. So anyway, we address the facts of the situation. We provide compliance assistance through letters and then we follow up with those registrants that otherwise have had issues because our goal is compliance. Is people meeting the agency where we are relative to our regulations? The sampling procedures. So we do have the standard operating or we have procedures for sampling both in the field, which is based on USDA's, which isn't necessarily applicable to candidates. And then we also have a process concentrate and obviously package products, you know, we would just grab those off the shelf or not grab, but we would take them as packaged. But in order to get a consistent sample of a larger volume of material, we have written a process for that specifically as it relates to hemp. So I just wanted to offer that. Yeah, I've read those. Yeah, I've seen those and you talk about, you know, incremental sampling and providing in terms of getting a representative sample, there's some, you know, randomness associated with how you're doing that. And that's just as extra important when you get to recreational marijuana. But they do, you know, there is batch, I mean, I'm not sure how much there's batch processing of recreational marijuana that has to happen prior to it even getting to a shelf, you know, for sale. And I think that, you know, we talked about it some, but not really in much detail. Yeah. And I don't know, like, if it's going to, you know, certainly there is value in evaluating for contaminants, the concentrate level program, because we just, we want, we try to establish at which point made the most sense. And because individuals are generally, when they register, they register as both growers and processors. So in many instances, they're in control of everything along the spectrum that they can kind of pick and make a decision as to when it is most cost effective for them to test. And then again, the overlay of USDA, which addresses potency, which we don't have much choice on. So we, so we do have a little bit of flexibility in there for those individuals that are in control of every step along the process. I think in a cannabis world where there will be manufacturers or processors that are creating the concentrates that may be sold to another individual or another business who makes final products. I think Adam, if the cannabis control board wants to fill the void to ensure that what's transferring between those two entities meets certain standards, they could require testing of a concentrate before it gets sold to the next step in the level, next step in the process. But it could also be the business relationship, you know, it could be the business business relationship where the person's purchasing is making the concentrate producer to do those tests that they're insured of getting something that's of a specific quality, quantity, potency, so that they can formulate their products too. So anyway, it just depends on how the board wants to set that up. But if that doesn't make sense, then I, you know, I would please share other ideas about that. You know, like sometimes I get my mind set on a particular spectrum of work and there's probably other potential ways that it can go. So I would appreciate any additional comments from others. So can I ask a question? What do you feel, because hemp isn't necessarily smoked the way that flour will be smoked on the recreational level, where, I mean, as I understand the percentage of maybe flour that's tested is very different in the amp world than it is in the recreational world, correct? Yeah, I mean, that's, that's possible. We actually have a pretty, in Vermont, a number of our producers do grow for flour to create pre-rolls, a smokable product. And so we do, you know, that's a shorter process, obviously, like you're trimming, that's probably it. We do require testing for contaminants before it goes to market for a flour product, because that, because that makes sense. Yeah, yeah, that's what I'm mostly concerned with pesticides, you know, and are they being required to produce, you know, and if they had a pesticide detection, would you be notified? Or is it upon yourself to find that notification? Or do they send you results? I, we don't receive results on a regular basis to confirm. We do have action limits for pesticides that would have to be tested for prior to a smoke, and they would have to meet our action limits before that smokable product would make it to market all off the top of my head whether or not we require a notification on that if it exceeds the limits. I, I know we do for, I think we do for flour. I know we do for potency. Yeah, I know you have to do for potency, but I wasn't sure if there was any notification for pesticides, or could it fall through the cracks that it just gets out there. Part of what the HEP program does, certainly the cannabis control board could require the information for review prior to products making it to shelves. I mean, that could be a requirement that, you know, obviously there would have to be a system in place that makes it efficient for everybody involved. Yeah, I, because I know, I know even right now with pro with potency in products that are on the shelf, there is a place on the label that says you can call this lab to get the actual test. So, I mean, I've done that before. I've called the lab and actually got results from some lab in Massachusetts. It was Kabucha that was on the shelf in hunger mountain co-op, and we were curious, you know, because it said on the label, oh, this is approximately below the level for potency. But if you want to get the result, you can call this, call this facility. This lab. Well, that's interesting. And the lab sent me the results. Sent you the results. Yeah, I mean, that's putting the information sharing is outside of the regulatory agency. Yeah. And that could be a marketing thing from a company perspective, but that doesn't, you know, but that same idea could be applied with the cannabis control board. Unless the board had requirements for labs to report results based on batch or process lot numbers in association with the issuance of their registration for the cannabis control board, it would be, it would have to be a requirement for that communication to occur. And that, I don't, you know, I don't know the willingness of labs to provide that information. They may feel that they have a client relationship. Yeah, client privilege relationship. I mean, there's definitely going to be something there, but they, I mean, that's the kind of thing you want to allow to happen, you know, if, yeah, if you want a client to be transparent. Yeah, yeah. And it also puts the burden on the lab to provide that information to make you available, like whether or not the cannabis control board wants to be the one that's in charge of that based on process lot numbers, you know, like, yeah, or could be part of a label review, like that's another thing. We don't do that in the hemp program, but as a part of a label review, you could require both the label and all documentation that testing was completed by process lot number to be made available to the CCB and that product registered with the CCB before it actually makes it to the shelf. And that would be a way for that review to take place. And if you don't do that in the hemp program, but that is certainly something that, you know, the CCB could assemble. I see Sherman's hands up. I also want to say that we have discussed putting a QR code on on a label that can link to, you know, the full panel suite of tests that a product is on. Nice. Nice. Go ahead, Sherman. Well, yeah. Thank you very much. One of my responsibilities in medicinal and general analysis to read regulations from as many states as I can. And the one thing that I have noted is that most, but not all states require that whatever batch is being tested is held until the certificate of analysis is completed. And that if there is any analyte in which the action level has been exceeded, it's required by rules that the laboratory reports it to the regulatory agency so that some action can be taken. The second point is that I've also noted that some regulatory agencies through their seed to sale tracking system, every certificate of analysis from every laboratory is submitted. Now, of course, it all depends on funding for the regulatory body and the personnel that you have. But one issue in many states is a concept called lab shopping, especially in the cannabis world. And so real time analysis or as frequently as you can is to look at the certificate of analysis and see the failure rate and all kinds of things and that you can catch laboratories that are definitely not doing the right thing. So this is a couple of comments to start with and also concerning PT programs or proficiency testing programs for hemp programs and cannabis programs. There are issues since the cannabis is a more complex chemically than hemp in terms of the higher levels of cannabinoids and so forth and so on. I have issues with PT programs utilizing hemp as a specimen sample and I know that because it's federally illegal for cannabis it's so much harder to have PT programs using cannabis as your sample type. So there's a lot of things to really consider. Yes. On that front, I guess maybe it's not that Vermont is relatively small to our four corners of the state and we do have a lab and we actually started a process and I'm just thinking out loud here. I can't commit our lab to anything but we had started a process of creating an interlaboratory study where we would create the homogenized sample within our lab and then because it was going to be hemp we were going to use US mail and ship it out to the labs because we were interested in participating and then we would just look and see on the curve as to where everybody sat and then we would also request some information regarding their processes and samples to see if we can dial in what might actually be a better process. Maybe I'm representing that not entirely accurately. I actually don't work in a lab and so I apologize if I'm talking outside my scope of understanding. So what I hear you saying is you're going to actually create the PT samples that the lab is looking into creating the proficiency testing sample for hemp. So we didn't want to say it was a proficiency test. It was an interlaboratory study because there I think proficiency test meant a very specific thing that we probably were not able to achieve but we were still going to do a survey or you know amongst labs that existed with a homogenized sample to begin with. Yes. Yes. Right. There's a certain ISO certification that an organization must have one seven oh four three to be able to have a proficiency program and the only company that has a cannabis based proficiency proficiency testing program is a company named Fanova. They have one staff his name is Ty Garber and so states make contracts with Fanova. He flies to one of the governmental laboratories in that state. Then cannabis is procured. He has a way of mixing and matching and he's created what PT's for cannabinoids and infesticides and metals. He hasn't quite gotten microbials and he's out on extended leave not because I wanted to ask him what he was going to bring online and microbial one but I'm sure that's very expensive because once he makes the test blind samples he actually has to transport them in his own vehicle to different laboratories and so I've been in the game since 2011. So I thought Absolute had it also. They don't have them. I thought I know they advertise that they do. I think that what we are really looking at whole regulatory landscape the PT's and they advertise it but they are hand samples. That's not the same thing. I come from the diagnostic world from the clinical chemistry with DOH and so we're used to getting specimen or sample types that mimic what we actually test in our laboratory. I was with the end on New Jersey Department of Health for 20 years and so I expect the same thing eventually for the cannabis space. So many individuals that are writing these regulations without thinking through everything they just write rules like it's a mature industry and it isn't but I'm just trying to point these things out and participate in the dialogue and make point these things out because it's causing problems for our company. We're based utilizing molecular technologies and all the PT's like an NSI therefore plating and auger plating puts us at the greatest advantage. We're just trying to make a level playing field that's all. Thank you. Do you have any questions that I'm missing? Again I just want to make you guys have information that you need and if you wanted to ask questions from that I can provide answers from the hemp world perspective. No I appreciate you being here. I know you can only answer with no. I would say just just Kim for your reference I think we need to move and carry there's multiple times where Stephanie had said if the CCB wants to do this if the CCB wants to do that I'm trying to take notes on on those specific inflection points but just as we've done in other subcommittees it would be great to get a recommendation from this subcommittee on those specific points and how we should approach certain things just because you know three of you and Kerry are really the quote-unquote experts as it relates to this and I feel like I don't want to be making a decision without a recommendation on how to proceed you know what I mean? Well and yeah and so one of the items that I heard that I may have said that related to and I think Sherman actually offered you know through review of multiple regulations requiring a staff person at a regulatory staff person to review all the COAs prior to a project hitting a product hitting the shelf based on that process lot number so while I mean that sounds amazing like you would have the review and compliance would have to be achieved before something hit the shelf and that's probably a rigorous process that needs staff so while you know what that seems like a great recommendation there's there's this other piece of people that you know that in volume of products that I don't know that I could that I would be able to provide way in on I guess is you know where it also comes into play but maybe there's like if we took a step back what's if that didn't happen because it required a couple of people or what that process looks like we actually don't know what that process looks like is there something that's not quite as rigorous but provides the same a similar level of review or enough eyes to to make both the consuming public and the regulated community step up and I so I'm asking that question I don't really answer but I'm wondering if Sherman has any suggestions oh yeah this is this this is you know I I'm from government I understand okay I really do and you got to start where you can but eventually you might want to consider what they did in Washington in Nevada it was more of a retrospective there was a laboratory scientist under the state of Washington who requested through the public information hacks in each of those states to be able to after it was all the information was de-identified but at least it said lab A lab B so forth and so on able to get let's say six months worth of COAs then he had a way to analyze it so he broke through in the state of Nevada and he noted that one particular laboratory over that period of time did not fail a single sample while the average of failure rate was 10 percent for all the other laboratories so that says something so then there was an investigation of that laboratory but nothing about and then certain and then there was like an average THC level and so there would be certain labs that had three or four percent more on the average so what's going on here so these are the pieces it's like deep mining to see trends and possible gaps because you want to have the good players really by the testing to protect the public I come from public health you know so that's what I was talking about in you know I got into regulations as a hobby at the Department of Health it wasn't assignment and to make this compending and then updated five times for all the states that had rules for testing they compiled and did observational and gap analysis and and the point that you made about the concentrate this is just your example that might be processed by one company and would then be transferred to another company to make like an infused product you know one might want to consider testing that before it's transferred and not make it a business business relationship because we did it like the gap analysis for pesticides and we did the best we could to go through the literature uh pure reviewed literature non pure reviewed literature and from government documents to find every pesticide that had been identified that had been in at least one market of cannabis products and I think we found 25 pesticides then we looked at what pesticides are required for testing from all the states I found nine pesticides that was not tested in any states I just wanted to try to just educate the regulators from all the cannabis programs throughout the United States of America that you know by doing this kind of analysis one can you know look at one's own list of pesticides and consider adding additional pesticides things like that that that was simply my hobby and so since now I work for a company focused just on microbial um I'm really honing in on that and one concern I do have is simply a phrase I found in one of the minutes for what one of your meetings came and that was looking at the Oregon testing rules the required testing rules and we had done a comprehensive comparative analysis in 2019 COVID-19 shut me down I was going to just continue every year but in 2019 at the end of the summer around version 5.0 there were 27 states that required microbial testing believe it or not there were 16 distinct combinations of required testing that was all over the place and so you know what is the most science based reasoning behind what you required and you know I have my opinions other people have their own opinions but I would hate to have the required test in which you got the results and it gave no information on whether the Canada sample had any microorganisms that were dangerous to human health for a patient or a consumer and Oregon wasn't quite an outlier I don't they're in the process of actually changing their required for microbial and they only had coliform they actually said that they only required one test total coliforms and not all and any microbiologist knows it's not all coliforms are pathogenic and so you know I've been favorable as I've said in all my documents I've sent to you is the you know it's required testing for known pathogens that have been found in Canada I agree with you but the difficulty lies is that the laboratories that can do some of these other microbial tests are not available I mean or you they're extremely costly because even with living on a dairy farm I mean we're only testing for E coli because it's the indicator compound it is an indicator that there's something going awry and and so I can see where you're yeah that that's a big concern but I do have to admit that at least Oregon looks for all of those 25 pesticides right they have a one in the longest list but in terms of microbial how we've overcome that being I've done plating all the way to whole genome sequencing and the digital genomics has has multiplexed so the six tests the four aspergillus pathogenics dcs all salmonella species and step E coli you just run two tests that's it and the the aspergillus multiplex test is now certified by a oac and our south step certification will be achieved by the end of the year and you just run two tests that gives you all the information just want to mention that and now how what's the cost of those now I just curious well that's the thing is I'm not on that and the things I've only been with MGC since many and also when you asked about cost I used to do cost analysis for you know my laboratory in New Jersey and it's just not the cost of the reagent but it's the labor and everything and they haven't really done that analysis I developed a template for the association of public health laboratories of how to determine a cost per test taking in consideration of every parameter you can think up down to the number of big tiles that you use and so it's pretty amazing when it comes down to that and a lot of sales people from various competing companies will throw some costs down per test but they you know it turns out to be a lot more than you you know and also turn around times important and so forth and so on but I can get you that information it might be interesting to get that because we didn't get a summary of what the other tests were costing but we think so much on the microbial right yeah right when it comes to microbial plating seems to be cheaper but the labor yeah labor really is the largest component because you gotta include their benefits and it's not easy in a production laboratory I mean I don't what does the agency have for a testing Stephanie on that side of things I don't know what I can say though is that they the agency's laboratory while from the hand perspective again I can only talk about that is they are certified by the Kansas Quality Control Program to do the moisture analysis and the potency test they are working on the microbial testing and developing their method and validating their methods at this point in time and hopefully by next year we'll have they'll have actually the sweetest week of tests that are needed for the hand program they'll solve it microbial testing and pesticides ones are worth but I mean but the lab does do I mean they have it's a lab that does lots of different tests relative to dairy beans eat for you know like they do a lot of tests I just don't know I can't yeah yeah yeah I worked actually Sherman I worked with this department of health in New Jersey when we were doing 524.2 analysis 524.1 analysis looking for turf butyl alcohol and the labs were falsifying that they could see it you know which uh which agency in New Jersey was that it was the Department of Health I don't know what the health well that would be yeah yeah environmental laboratories yeah this was way back in probably the 90s because they were telling us that we had to have a reporting limit of 10 ppb and I said there's no way you can see it at 10 ppb and they were like well all our labs are seeing it that and I'm like well then all your labs are falsifying the data and I recovered that I found that out for us and then it finally changed to 50 ppb because that was the concentration at which we could see it right we understand that yeah the the hand program is also Sherman you had mentioned earlier about falsifying lab or not falsifying but looking at labs and looking at their data to determine whether or not lab shopping is occurring I guess or the poor rightness of the lab and we have started kind of like our our onsite we call it like an onsite investigation kind of process and it's still we're still working on it but to look at that that very thing like look at test results and determining or even successive because sometimes you don't really go that far it's the same thing for you know the runs are all the same and all the data is the same um so so we we do we are kind of putting that process together for the labs that we certify because we know that you know it's not it's not enough just to be certified but you also have to do inspections and and be consistent in the inspections that you're conducting so that's why we're putting together the process so it's always the same generally that we're looking at right yeah and also there's the poor rightness of the cultivator to because it's yes the thc is king the cannabis world and there's been known instances of lightly spraying one's counts cannabis flour with diluted thc solution to increase the analysis so that they can put a higher concentration on the label um but the thing is that certain strains of cannabis is known to have a range of thc so one particular lab director sent his staff around to different dispensaries and bought let's just say blue dream like 20 samples you know and that certain ones came from certain dispensaries like five percent higher than all the other blue dreams so there's something going on you know um it was advertised five percent higher than it actually was um but when it was tested at the laboratory that's when they lightly sprayed you know their lot there's a lot of yeah there's a lot of stuff going on yeah just to be aware of yeah i like the idea and in the board might think about this is um requiring a coa of by batch of some sort either going to some i mean even if you had to have a third party regulatory like agency i don't know you know we have to have that all the time for any um standards in the laboratory world anyway so to ensure that you know when you're looking for chlorinated solvents the standard that you're using is of some known purity in order to make sure that the concentrations are coming out right when you're providing data to you know in the real world so i think that's a really good idea to think about i'm not i know that it's a manpower issue but even if it's filed somewhere where you could go and call it you know just like it costs you more money to get a coa with a standard per se but if you had the ability that those coas were filed with the laboratory and you could call on it to look at if you had some concerns to tease that out a little bit um because i think i'm a little out of my depth but i want to use the words that i that i want to make sure i'm going to repeat what you said so i understand it the the it's the standard by which the actual test is the thc test is being brought so there's the blue dream or whatever tc but then there's the standard that it's that the equipment is compared against is that am i is that right and that that standard is consistent and that coa for that standard is available for inspection at the lab is that what you're maybe i'm not saying that right well so i i i brought up two subjects so i probably shouldn't have done that so one the certificate of analysis that comes say for a flower or a potency of it comes from the laboratory and it's shipped back to the product owner and says here's what i mean for my standard it's compliant with all of these things you know it's the right potency it has no pesticides blah blah blah so it's certifying that this product is x what i was saying is that we require you know analytical laboratories when they buy a standard for whatever tests you might be using whether you're testing for cannabis or potency um you for thc you buy that standard to run your tests against and that is required to have a coa to ensure that the potency test is being run with a known concentration purity standard you know i guess that's the better way to put it okay okay yeah no that makes sense that way i'm just um i i wanted to understand that second piece yeah yeah first piece um the second piece more um from the perspective of that the agency has that certification program and if we don't and i don't have all the details in my head but if we don't actually require that second piece that could be something that we might want to consider adding or um it would be a difficult requirement that recommendation to the ccb that labs maintain that information all right forward yeah okay and um i just want to quickly mention you know more and more states are adding um i mean many states already had salad stack but now 12 states have the four astrogelous pathogens colorado they drafted rules i went to their hearing just the other day and so that looks like that's going to be put in place in july so i did find a document from actually a consultant the vermont medical cannabis program first got started and the vermont consultant recommended it i believe sell stack in the four astrogelous but i guess it was never considered this way before my time but i i've been digging into historical developments in vermont best i can we do have a copy of that doc i think it's from 2016 it was produced by um via diagnostics and another lab out of water very i think i don't remember the name of that lab um yes i we are aware or i am aware of that document i can sure certainly share um that information with the ccb thanks stephanie it's called 55 our our our friend who joined us from the public left um so there's no public comment but i just i i think it would be helpful for myself and for and for brin and brin i know you've been talking to carry um just to kind of understand where things are in the process can i know you're waiting on some draft sop and this is forming the basis this isn't necessarily forming our proposed rule per se but the basis for the ccb to look at as a proposal from you can and carry the subcommittee and so i just want to yeah i know you kind of alluded to where things were at the beginning but in terms of producing like a tangible document with recommendations i'm hoping you could you could refresh my memory on where things are i know you're waiting from i know you're waiting from information from carry on sop is is that correct um that was i mean what i'm i'm not completely um on board with what they're expecting from me for a document i thought we were going to mirror image kind of what the hem program was doing and then so you basically have your standard documentation but with some added um emphasis on on the sampling and you know what he needs at the agency for assistance you know what i mean he was developing what what the agency was actually looking for to ramp up their own program to cover the recreational side of things okay so so my understanding is that you're waiting on some sop recommendations from carry and once you have those and you've done your review um and comparison with the origan sop's and and your like the the inclusion of your recommendation we should come back together for another meeting um does that yeah i think i think that's true for an action item and then what what are you looking for from carry and i has documentation to support you going forward because as i understand there's quite the documentation in the hem program is going to be very similar to the documentation in the recreational program and maybe talking about a few more requirements like maybe a c o a to be on file or for a product or a flower that gets tested and it be available upon request from a particular laboratory i don't know are that is that what you're looking at i mean just that's what that's what i'm just going to try that that's kind of some of those types of recommendations is also what i would find very helpful some of the the testing requirements before or after it's transferred or a business to business relationship how should we proceed as a board for those types of inflection point decision-making that we're going to need again because i want to make sure i fully understand um recommendations that would be coming from you ken and and Stephanie and carry it and the hem program and i'm sure that a lot of your comments will be sprinkled throughout the conversation again i want to make it clear that they're not proposing the role at this point in time it's just a direction for the board to go so i'm not expecting ken that's a whole role quote-unquote be you know fully fully written as such it's it's it's pretty directional at this point and we can kind of work through certain things and sure i'm sure you've been very helpful in this sorry that's okay i didn't know what was coming from i'm sorry but that's my phone yeah there'll be this is like the the start of the process not the end of the process there'll be opportunities to comment or find so on so forth as we go but it's these kind of inflection point recommendations on how we should proceed at this point okay sounds good and i am um i have a document from the woman that i who has worked with the cannabis industry through the department of health now is on her own and does auditing under 17 025 all these things she wrote up a document on um the industry specific risks and challenges that i'm going to forward on to the board for review it just identifies you know where what's happened in colorado the differences in other states not requiring certain tests you know the the whole fact that every state is doing their own thing and what are we going to do when the federal government finally legalizes this right and we're you know we want to make sure that we aren't off on our own tangent because you want to be able to roll it into the regulation the federal regulated community at some point in time that makes sense i think i think we'll follow up with kary to try and get you that information as expeditiously as we can because i don't really want to wait another month and a half to have another one of these meetings i don't think we can we can afford to given our timelines coming fast and furious out of the screen okay i want to thank everyone for this opportunity to dialogue with you and i'm available at any time to continue the dialogue and i hope that you'll allow me to be included in future meetings and kim i'll get you those boss yeah you could forward it to all of us the cost estimates all right great that sounds great and any other action items i guess i'm i don't think there's any other actions that stephanie's going to work with kary to keep moving forward i'm going to send off this specific risk and challenges and be patient and and we'll go from there sounds great sir me do you have kim's email do you have all the emails that you need yeah i think so because there was well maybe i should get i think let me see the confirmation of exactly which emails i should send to because i got the invite and the invite have just a bunch of people and i don't want to send whatever i send to the people okay does that sound okay with everybody yeah mine's pretty easy because it's k watts in 45 so at aol i'll coordinate getting email addresses and this is nely i'll coordinate getting email addresses and and disseminating all that information right yeah on the last thing that nely said there's only eight of us on it anyway so in year one of them right yeah i appreciate that nely and then um yeah i might send you a presentation i recently gave to half dough of the regulators from the food and drug industry concerning cannabis and kind of like a landscape type presentation i'll include that thank you everybody thank you very much thank you thank you thank you bye take care bye bye