Comment on a new USDA Hemp Production Program
It’s vital that you know what the USDA Interim final rules mean and how they effect the U.S. hemp industry.
We believe these rules are burdensome and place shackles on both the hemp farmer and industry.
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I am writing to comment on the USDA rule from October 30th regarding hemp production. This new rule places undue pressure on farmers and labs in this new industry.
By changing to a Total THC standard, the number of strains available for farmers to grow decreases by 90%. Instead of changing the standard, we would ask that you leave it where it is, but change the testing mechanism to a Homogenized Test Sample. By testing more of the whole plant (leaves, stalk and flower), we can more accurately gauge the true THC percentage.
We also ask that the farmer be given the opportunity to have his crop be remediated if it were to test over the .3% total THC. Destroying a farmers investment and hard work far too strict and is an unnecessary rule to keep products within the legal boundaries.
Furthermore the test-to-harvest window be increased to 30 days. The current test-to-harvest window of fifteen days places undue pressure on regulators and farmers.
Finally, we would ask for a streamlined procedure to DEA certify the analytical labs which are doing hemp testing. Since so few are now certified, labs need a quick way to become certified in order for farmers to continue to deliver their product to the marketplace. Thank you for your time.
The comment period is open until December 30, 2019
Educate the USDA. Let them know how you feel and how these proposed rules would impact your business. Use Data and address one or two important issues that are specific to you.
PLEASE share your comments with the USDA by following this link.