My Comment Letter to the USDA
I’m Sophia Blanton and I work in education, community development and branding for the Hemp Industry in Oregon. I’ve also benefited extensively from CBD.
On a daily basis, I’m in contact with all levels of this sector – from farmers, processors and retailers to organizations like my own (Hemp, Inc/Hemp University) who advocate for the American Family Farm.
The recent rules proposed by the USDA for the Domestic Hemp Production Program are alarming in that they show how far removed bureaucratic thinking is from the reality of Industrial Hemp farms and businesses.
Without a firm foundation in science and research, an entire industry has organized itself around the .3% THC baseline, which is now widely known to be based on expedient guesswork by the Canadian scientist Ernest Small in 1976.
From this shaky foundation, rules and regulations have been established that do not align with reality, the well-being of our American Family Farms or the best use of this powerful plant.
More scientific research needs to be done to establish reality-based thresholds of psychoactivity and to determine what levels of the Entourage Effect offer optimal health benefits.
It seems we’re replaying Reefer Madness with rules concerned more with paranoia about THC than about supporting the ample benefits of Hemp cultivation.
The proposed testing protocols are chief examples of this:
• The 15-day pre-harvest testing window is completely unrealistic as harvests cannot be accurately predicted due to scores of variables.
• Testing only the top 2 inches of the flower almost ensures a “hot” outcome.
• The DEA-lab testing requirement is totally unworkable in the State of Oregon as there is only one lab and over 700 farms.
• The proposed criminalization of farmers for producing crops at .5% THC is cruel and unusual punishment for honest people who have little control over the final chemical composition of their crops.
• The recommendation of destruction over remediation underscores paranoid thinking and closed-mindedness about the livelihoods of honest American farmers.
Instead, testing should be expanded to 45-60 days within planting, and state-certified labs should be supported instead of encouraging the extra expense and bottlenecks of requiring DEA-certified labs. The whole plant average should be tested, not just the parts most likely to turn up a “hot” reading. The USDA is supposed to be an advocate for farms and consumer protection, not arbiters of criminality. There should be wider options for crop remediation as well as more flexible licensing options for crops with different destinies – i.e. smokeable flower vs. biomass for extraction.
States should also study the cultivation-processing-sales cycle in order to avoid over-licensing and thereby encouraging output that has nowhere to go. There needs to be substantial investment in education and studies devoted to how the whole chain could work efficiently. What happened in Oregon was the unbridled selling of expensive licenses to farmers doomed to failure due to inadequate processing infrastructure, equipment, labor or support. While it may be argued that each licensee has the responsibility to fend for themselves, the reality is that the 2019 harvest season here is still piling up losses in the multiple millions due to the lack of a cohesive strategy, and that affects not only farmers, but scores of ancillary businesses that support the industry.
Industrial Hemp is not only a boon to state and federal economies; it offers a renaissance of the American Family Farm and a resurgence of American values such as hard work, cooperation and healthy prosperity.
My sincere hope is that the USDA will take to heart the responses from our industry and cooperate with scientists, farmers, processors & advocates in establishing fair, reality-based foundations for a thriving new economy.