On November 20, 2019 Oregon hemp advocates Senator Wyden and Senator Merkley submitted a letter to USDA Secretary Purdue outlining concerns with the IFR, inconsistencies with legislative intent, and request particular fixes.
“We appreciate USDA’s commitment to hemp producers across the United States, and are pleased by your efforts to grow and support domestic hemp production. Farmers in Oregon and across the country are on the precipice of an agricultural boom that, with the right regulatory framework, stands to boost rural economies in every corner of the country,” Oregon Senators Wyden & Merkley, letter to USDA 11/20/19
The letter made the following requests:
Follow the Oregon model and extend the timeline for testing before harvest to a more realistic timeframe, and provide a reasonable timeframe for post-testing harvest;
Remove the requirement that testing labs must be Drug Enforcement Administration registered;
Allow testing for delta-9 THC using methods that do not involve the application of heat or decarboxylation, and to remove all requirements for converting THCA into THC, as the 2018 Farm Bill allows for flexibility in testing methods by allowing “other similarly reliable methods”;
Follow Oregon’s pre-harvest sampling protocol that a “sample shall be obtained from flowering tops when flowering tops are present, and shall be approximately 8 inches in length,”; and
Set a negligence threshold greater than 1% for THC content—if one must be set—as the interim rule’s current threshold at 0.5% is arbitrary and far too low.
To learn more about the letter please check out Senator Wyden’s webpage.