Re: Farm Bill Implementation Listening Session on Hemp

Since the Agricultural Act of 2014 authorized farming industrial hemp, production across the nation has exploded. In Oregon alone, production in 2018 exceeded 11,000 acres and is expected to reach at least 40,000 acres in 2019, making it the state’s number one commodity. I applaud the 2018 Farm Bill’s further legalization of Industrial Hemp.

However, the testing standards need to be addressed to clarify that testing labs should not be changing the molecular make-up of the plant prior to testing, by heating it, and thus changing the results that would otherwise be obtained. The 2018 definition calls for a “delta-9 tetrahydrocannabinol concentration of not more than 0.3 percent on a dry weight basis”, which is consistent with the 2014 definition and is what the industry has become accustomed to.

The potential problem arises under the new testing procedure which calls for “using postdecarboxylation or other similarly reliable methods, …” I would ask that the USDA allow the “similarly reliable method” to be the preferred method and adopt the current standard of a non-decarboxylation test for delta-9 tetrahydrocannabinol concentration. A change from the current standard would render many of the strains, currently in production, illegal and would result in an immediate disruption in this rapidly growing industry.

The current non-decarboxylation method has been the industry standard since 2014 and has been proven to be an effective and reliable testing method for the industry. I would ask that this testing method be adopted under the new rules and continue to be the standard that the industry has come to rely on.

Thank you for your consideration,

Matt Cyrus