North Carolina’s motto is taken from the Latin phrase, Esse Quam Videri, “to be rather than to seem.” ‘To be’ is a prideful term declaring virtue. ‘To seem’ is not.
Virtue is the very thing at stake concerning North Carolina’s position in the hemp industry and along with state officials, clinical laboratory scientists, and leaders in the industry, the North Carolina Industrial Hemp Association is working to help create the standards to make pride ‘be.’
There is much at stake that benefits all. Industrialized hemp has beneficial cannabinoids that work with all mammals’ endocannabinoid systems. Many US Patents have been filed based on hemp’s medicinal properties. Hemp is also a textile, fuel, animal feed, and bioplastic resource and is a superfood for humans. In short, hemp is going to save America’s farmlands and North Carolina’s favorable climatic region with its deep agricultural roots is inviting us to create a new legacy – a brighter legacy.
Tobacco barns, those rough pole-built structures with tin roofs, stand at the edge of North Carolina’s fields like mistresses deserted after war. War is a strong term for the tobacco industry, but that is what it became – a legacy built from the need to utilize the land to care for our families which ultimately grew into a medical nightmare. In the nineteen-thirties, before newspapers blasted the news that cigarettes were killers, my grandparents had already become addicted. One of the strongest memories I have of my grandfather is him praying in church, “Take it away, Lord, oh, please, make me never want another cigarette.” His prayers did not work. It is the same for millions of others who have fallen to tobacco.
That was then. This is now.
North Carolina is poised to rise above all other states in the growing hemp industry – because we have that kind of tenacity. We have the generational farmers. We have leaders in research, marketing, and a people so proud they will settle for nothing less than the best, and that is what we will give them – the safest, highest quality hemp products available. North Carolina will become the leader in the hemp industry by setting exceptional standards.
This – is the beginning of our hemp legacy, Esse Quam Videri.
As states are called upon to present industrial hemp standards and regulations to the USDA, hemp stakeholders may ponder the following over hemp’s leading consumable, CBD oil products: Consumers are generally spontaneous in purchasing and do not always wisely research products and wait to purchase. This denotes that time is crucial in establishing standards and awarding certifications.
State and county agricultural organizations are open for ‘free’ advice on both meeting compliance and exceeding safety standards. Members of the North Carolina Industrial Hemp Association receive professional assistance, advice and guidance.
While CBD Girl Next Door is an educational website driven to provide scientific research on hemp products – because relaying medical benefits is not allowed on retail websites, this educational website also drives responsible testing practices and the importance of full transparency through unbiased reviews. For example, although only THC/CBD testing is presently required to meet compliance, some processers follow the examples of Colorado, which has had years to create safety standards. It is common in Colorado to sync products on websites with verifiable full profile certificates of analysis. Consumers want to know exactly what they are buying. A full spectrum CBD oil has both THC at or below .3% and CBD, plus ‘other’ beneficial cannabinoids. Discerning customers want to know exactly what those other cannabinoids are and the levels.
This chart reveals how cannabinoids work together to benefit conditions, such as arthritis. An anti-arthritic full spectrum CBD oil contains THCA, THC, CBC, CBD, CBN, CBG and CBGA. Labels and/or inserts need to clearly identify these cannabinoids.
The US Hemp Authority has a certification program. http://www.ushempauthority.org/ This affiliation is part of The Hemp Industries Association (HIA), a non-profit trade association representing more than one-thousand (1,000) supporters, farmers and business members serving the hemp industries since 1994. In an email blast released 30 January, 2019, it is relayed from The US Hemp Authority – our united effort to promote high standards, best practices and self-regulation for the hemp industry – is off to a rocketing start. More than 175 companies have begun the process of seeking to secure the Certified Seal of the U.S. Hemp Authority™, giving confidence to consumers and law enforcement that their products are safe, and legal.
While the US Hemp Authority has created a certification program of its own, it is expensive and may not represent exemplary standards that meet the demands of all consumers.
That said, independent responsible testing and full transparency by hemp farmers and producers also provide consumer confidence. State licensure, required to grow or process, meets law enforcement guidelines.
The US Hemp Authority provides a booklet with the following excerpt:
1.5 CONTAMINANT TESTING AND HEMP CANNABINOID QUANTIFICATION:
1.5.1 Potency / Cannabinoid Quantification
To ensure that methods measuring cannabinoids are fit for purpose, laboratories should adopt the attached SMPR 2017.00s approved by Cannabis stakeholders with AOAC except for the following revisions:
- List only four compounds: THC, THCA, CBD, and CBDA as the main analytes of interest, with the other 10 listed in the SMPR optional.
- List all target plant parts of hemp (flower, leaf, stalk, seed) and oils/extracts.
The AOAC is the Association of Agricultural Chemists. They work on an international level to create standards.
North Carolina should be obliged to accept these standards if adopted by NC, but hopefully, NC will exceed these standards ‘to be’ proud of its hemp products, not merely meet compliance.
Consider the language of ‘laboratories should adopt.’ Laboratories are comprised of Clinical Laboratory Scientists who have the knowledge to create standards that serve the public. Reputable laboratories do not serve individuals. They serve the public – the good of all. The only reason to test a limited number of cannabinoids is to reduce costs for farmers and processors. This is not the attitude and practice of ethical Clinical Laboratory Scientists.
Many guidelines presented in the US Hemp Authority Certification are guidelines already present at state levels, such as GAP and OSHA.
Below is an excerpt:
How much does the U.S. Hemp Authority™ Certification Program cost and how long do physical audit inspections take?
· Grower Licensing Fees: o Flat Fee for Extract Varieties – Farms Under 10 Acres = $1,000 o Flat Fee for Extract Varieties – Farms 10+ Acres = $2,000 (Rev. 1/4/19) o Flat Fee for Oilseed & Fiber Varieties – Farms Under 100 Acres = $500 o Flat Fee for Oilseed & Fiber Varieties – Farms 100+ Acres = $1,500 *If the farm produces extract varieties along with oilseed and/or fiber varieties, only the extract varieties flat fee will be charged
· Processor Licensing Fees: o Flat Fee for up to Five (5) SKUs = $2,500 o Additional Per-SKU Fee (for SKUs in addition to the first five): $200 o Cap on Per-SKU Fees: $5,000 *Verified Licensees will not be charged for more than twenty-five (25) additional SKUs
· Audit Fees: The physical audit inspection costs $1,395 per eight (8) hour day plus the traveling expenses of the auditor.
Concerning the application fee for NCIHC, the North Carolina Industrial Hemp Commission: There is no fee to apply for a license; however, there are fees required for a license to be issued. Fees are broken into two categories; initial fee and graduated annual fees. The initial fee for all license holders is $250. The annual fees are $250 for 49 acres or less, and $500 for 50 acres or more. All licenses holders are required to pay an additional fee of $2/acre or $2/square foot of greenhouse, whichever is applicable.
The licensee is responsible for all the associated costs and fees of their project. Additionally, if a THC sample analysis is performed, the cost will be billed to the licensee. (The ‘field’ THC test is approximately 175.00).
Of course, once the USDA makes its recommendations on standards proposed on state levels, there will likely be additional fees. Testing requirements for various stages of processing will likely increase. Testing for various analytes and harmful compounds will also likely increase. These expenses are also tax deductions. Stringent standards and tighter protocol are not choices. We are talking about a revolution here, a sociological revolution when people are given back the ancient herb that was denied generations ago. This is the revolution of the twenty-first century that will change the course of history in America. Take pride in that and start testing with full transparency.
This article includes a few standard recommendations. If readers have recommendations, or have corrections, please email them to firstname.lastname@example.org in the body of the email.
Recommendations for Marketplace Standards
- A full profile COA for hemp products must include, THC/CBD levels, THCA, CBDA, plus the other 10 common analytes, (the US Hemp Authority suggests that the other ten are optional, but for discerning customers all analytes are needed to determine if the product meets their needs). See chart for explanation. Terpene levels needs to be tested, revealed and simplified. Potentially harmful substances including residuals and heavy metals must be tested. Concerning pesticides, an experienced lab such as Avazyme should create a pesticide testing protocol. Testing must include a formal microanalysis for mycotoxins, a pathogen report, not a mere visual check.
- The COA must be then simplified for the public, e.g. CBG is a cannabinoid analyte. THC is a psychoactive cannabinoid. Terpenes need to be simplified.
- Provide a list of each products’ specific cannabinoid analytes on the package, as an insert, or with COAs in a streamlined batch correlation, for easy reference as a courtesy to consumers. A proficient method is connecting the product to the testing lab’s results. Then add recommendations #2 and #3.
- Companies with in-house labs must be required by a state law to have a state agent randomly select a sample from their facility and have it fully tested at a third-party lab, such as Avazyme, before the product is released to the market and that that lab’s COA be fully disclosed on the product’s website for consumer confidence. Random testing in the pharmaceutical and food industry is standard. There is simply too much room for deceit with in-house labs.
- A Clinical Laboratory Science team needs to designate a selection of approved labs. This measure is critical considering that half of Nevada’s labs were shut down and heavily fined.
- That list of approved labs needs to be readily identifiable in a website search for consumer confidence.
- States must create regional committees to educate and oversee both farming practices and processing practices.
- An indemnification whistleblower clause must be signed by all persons working in the hemp industry. For example, when an agricultural agent informs a hemp farm to burn its crop due to high THC content and an agricultural agent leaves the field before the crop is burned, the agent and the owner(s) need to be held accountable, and if a whistleblower informs the state that an agent has left the field prior, the whistleblower will be financially rewarded. (This proposal is based on simple human behavior.) The whistleblower clause applies to being witness to banned or harmful pesticide/fungicide/growth retardant/and any other organic or synthetic which may be potentially harmful, to improper handling, to improper identification and other unethical practices, intentional or not. This applies to state employees and committee members. [Remember human nature and the fact that the good-old-boys’ network is under the same tendency to fail ethical standards when not held accountable.]
- A designated ‘state lab facility’ where the hemp is grown must be used for third-party testing. A state lab is less likely to take a bribe for favorable testing results. For instance, half of Nevada’s labs were shut-down and fined for unethical testing practices.
- Tamper-resistance packaging. [At present many oils are simply screwed closed and have no barrier or seal.] A strip of colorful adhesive or shrink wrap is tamper-resistant.
- Designate official fertilizers, fungicides, growth retardants, pesticides for hemp designated for consumables -make consumable hemp an organic crop.
- Create a ‘NC State Seal of Assurance’ for consumable hemp products to be available for framing in retail stores, to be available as sizable stickers for products and as an emblem for websites.
This is the beginning of North Carolina’s hemp legacy ‘to be’ proud.
Have a great day!
Your CBD Watchdog
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