Comments Document

Hello, Please see the attached public comment for the Hemp Task Force from the Hemp Industries Association. Thank You, Jody McGinness Executive Director The Hemp Industries Association

Comments Document

Comments address VDACS's "regulatory response" to the recently enacted budget, which affects the status of "synthetic cannabinoids" under the agency's interpretation of Virginia's Food & Drink Law.

In 2018 my family and I started our journey in the hemp industry since then we have noticed lots of our customers see improvement in a variation of ailments. and the fact that they’re calling delta eight THC synthetic and the same synthesizing process is used for the majority of products that we consume daily. we have seen people use different cannabinoid‘s to stop doing drugs to stop drinking a lot of positive things we would like to continue our mission to help people and criminalizing delta eight and other similar cannabinoid‘s is going to be detrimental to this industry bottom line is with all these new cannabinoid‘s THC is changing and change is good

I fully support hemp farming. In addition I think a hemp product industry should be encouraged in Virginia. Things such as packaging products produced from hemp would be a green initiative to look into. Science should be available that would allow the products being grown to be tested for chemical makeup and marketed accordingly. I think the sale of all products that contain THC or any other chemicals proven to be psychoactive should be regulated by the Board of Pharmacy per guidelines set by the General Assembly. I think products that contain CBD should be available to the general public as is any other OTC herbal product. Thank you.

Hemp-derived THC (whether delta8, delta9, HHC, THC-O or other isomers) are often produced using strong solvents. Companies need to provide independent third party testing for cannabinoids, solvents, mold, pesticides, etc. if these are going to be officially made legal.

Good afternoon, I work for a CBD store, but i am not speaking on their behalf, but sharing my experiences. Our customers are seeking health benefits and relief from depression, pain, anxiety, insomnia, PTSD, cancer and more. The products work! Ratger than these products leading to addiction or abuse, they help peopek with addiction and abuse. Our customers should jotbhave to worry about their medicine being taken from them by their government. Our products are independently tested and naturally derived. Anybody of any age is safe taking Cannabinoids While I appreciate you trying to protect us from potentially unsafe products I am confused by your concern about synthetic derivatives of delta 8 when the entire pharmaceutical industry is synthetically derived. Brewery and winery openings are being celebrated as people are routinely charged with DUIs. Alcohol has no medicinal benefits. Cannabinoids do. It seems like you are coming up with solutions and then looking for a problem all while supporting some industries over others. Hemp has so much potential in job creation and real help for people that would be a boon for Virginia. Why aren't you supporting it rather than seemingly holding it to tougher standards than others? I welcome any of you to our store at any time in Creekside. Thank you for your time and consideration. Sincerely, Pam Kirschner

Good afternoon, Thank you for consideration of my comments below. On behalf of my woman owned, family run small business, we appreciate your dedication to safety, and high quality, equitable regulation of hemp derived products. However, I would be remiss if I advised that I feel comfortable about the process thus far. My partner and husband submitted comment as well, regarding our feelings on safe labeling, packaging, testing, age requirements, conservative yet reasonable dosage, and some other items. I am not only a business owner, but an elementary school teacher in the public education system. I am about to enter my 20th year of teaching young people. In wearing both of these hats, please make no mistake how VERY strongly I feel about responsible business practice, public health, high quality industry standards, and about developing high levels of integrity in our progressing legal cannabis industry. However, I also feel that development of exemplars for labeling, testing, regulations regarding manufacturers, processors, and producers of hemp derived products, is not being handled by folks who truly have the knowledge and realistic facts about cannabinoids. I have heard, read, and battled over more untruths, than I can recount. I am amazed at the one-sided statistics I hear and read about, regarding cannabinoids, and feel very much like a continued double standard is what is being perpetuated in many ways. I feel investment in development of local subsets of collaboratively curated groups of cannabis business owners, experts, as well as policy makers, with EQUAL say in their collaboration, is a large piece of what's missing here. In the absence of firm policy, and well outlined safety measures, we as a Commonwealth, are losing millions - billions in tax and local commerce revenue that could be uplifting higher quality roads, schools, public buildings, buses, and more. I feel we are focused too heavily on the wrong pieces of this puzzle, and would very much like a chance to meet with the task force, politicians, policy makers, etc, to suggest some concrete, REAL action steps, so we can try to help this industry bring the best that it can, to our communities, and to our shared citizens. Thank you for your continued consideration, your dedicated work, and your time reading my comments. Gratefully, Leigh Anne Kuhn COO, Albemarle Hemp Company

My company has been in business since 2019, and I have attended, and spoken at several meetings of this fashion. My advocacy comes from a genuine place of desire to help build, model, and collaborate on well designed public health and safety regulations, that do not cost my business, and others like mine, to shut down due to overreach, or due to poor and invalid policy design. In thinking about VDACS' recently sent questions for collaboration on this matter, here are my thoughts; I believe that manufacturing safety should be regulated through appropriate licensure, inspection of facilities, and COA lab testing of hemp derived cannabinoids. This includes ALL oral or inhaled products. Regarding the safe sale, I feel proper labeling, created in conjunction with established, reputable hemp businesses and the Oversight committee, and Hemp task force, should include 21+ labeling, ingredients, proper warning info regarding driving, pregnangy, etc, conservative suggestions on dosage, company credentials, manufacturer, and bath/date info. These are standards my company has held ourselves to since we began, in the absence of such exemplars from our government and regulatory agencies. I also think all consumers must have 21+ id for all sales, at all times. I think you all have not adequately considered, nor approached the businesses who are doing poor business, and making things look negatively for the rest of us who are working tirelessly, to conduct proper commerce and responsible sales. We also provide educational literature, which should be included in all sales, so that people are armed with the resources to make responsible choices. This is more than any bottle of alcohol will provide in any ABC store. Finally, as an industry, we are offended at the continued skewed, biased news reports that continue to target cannabinoids, as well as people speaking about manufacture and production, who have virtually no experience or knowledge of these practices. I have heard things like "made with battery acid," which, is absolutely, completely untrue for any products my company carries. Finally, I think you would do well to invest in businesses in the USA who manufacture and produce hemp derived products, and increase regulations on products coming into vape shops that come from who knows where, and contain who knows what. I assure you, there are MANY reputable businesses who are working diligently to offer high quality, purely processed and manufactured products. These poor quality products in these vape shop stores, being sold at irresponsible dosage amounts, to underage people, are the problem you are not addressing. Your internal lack of knowledge regarding cannabinoids, is a LARGE problem you are not addressing as government agencies. There is so much more here, but for now, I hope you will consider the points I have addressed. I appreciate your time and collaboration, as always, Joseph Kuhn, CEO, Albemarle Hemp Company

This is a 1995 study that concludes that Delta 8 is an excellent treatment in pediatric cancer treatment….. with 0 side effects!!!!! Have ALL of you researched the health benefits of these products? The other advantages? How about its’ efficacy in reducing fentanyl deaths? DO YOUR RESEARCH 🧐!!! Take your responsibility seriously!!! You have already decided to ban it, that is obvious from your choice of Presentations…. —————————- An efficient new cannabinoid antiemetic in pediatric oncology A Abrahamov et al. Life Sci. 1995. Show details Full text links Cite Abstract Delta-8-tetrahydrocannabinol (delta-8-THC), a cannabinoid with lower psychotropic potency than the main Cannabis constituent, delta-9-tetrahydrocannabinol (delta-9-THC), was administered (18 mg/m2 in edible oil, p.o.) to eight children, aged 3-13 years with various hematologic cancers, treated with different antineoplastic drugs for up to 8 months. The total number of treatments with delta-8-THC so far is 480. The THC treatment started two hours before each antineoplastic treatment and was continued every 6 hrs for 24 hours. Vomiting was completely prevented. The side effects observed were negligible.

Comments Document

(Abbreviated version -- Full comment is attached below in pdf format) To Whom This May Concern, Thank you for the opportunity to comment. I know you all are facing a very difficult task in trying to regulate hemp industry and I appreciate the opportunity to voice my concerns on the matter. My name is Barbara Biddle, owner of District Hemp Botanicals and I’m also here as a representative of the Virginia Hemp Coalition. I’ve been operating in Virginia as a retailer since 2017, with locations in Manassas and Leesburg VA, as well as a location in DC. My business works with both local and national manufacturers to provide quality, lab-tested products to tens of thousands of customers both locally and nationally. First, my main concern is the timing at which enforcement of the new regulations may begin. From a retailer's perspective, there are many moving parts as far as implementation, a lot of which are beyond our control. We’ve already made our manufacturers aware of the necessary label changes needed to be compliant, however they will need anywhere from 1-3 months to be able to make those necessary changes. Another consideration is the inability to package certain edibles in child-proof packaging, for example, honey and drinks. There are unique elements to these specific edibles that can help boost the bioavailability of cannabinoids compared to generic gummies and capsules, and I fear that little consideration is being taken into these nuances. On another note, the childproof packaging will also severely limit those with arthritis and pain issues from accessing certain products that are most effective for them. I strongly encourage allowing at least 6-12 months for companies to make these changes and retailers to sell through products before taking any punitive action against otherwise law-abiding businesses. Some other fixes include allowing retailers to provide edible products in a complimentary “child-proof bag” that can fit multiple products as a fix. Second, I have deep concerns about the interpretation of the law as it applies to the legal state of hemp isomers and derivatives. A lot of the controversy stems from what seems to be a lack of education around the process of which these compounds are manufactured and misconceptions around the term “synthetic”. In a letter dated September 15th of this year from the DEA’s Drug and Chemical Evaluation Section states that only cannabinoids extracted from non-compliant cannabis or synthesized from non-cannabis materials are controlled substances. The letter also clarified a frequent point of confusion in discussions of Delta-8 (and the other 130+ hemp cannabinoids): namely, that the use of chemical synthesis to produce these natural compounds is not relevant to their control status. The term “synthesis,” which has varied meanings in scientific literature and no established meaning in the law, along with the DEA’s definition of “synthetic THCs” (a class of man-made THC analogs not found in the plant), has led many to think that Delta-8 was illegal because it is primarily produced from CBD through a process called chemical synthesis.... If hemp derivatives such as HHC are considered “synthetic” due to the manufacturing process, household products such as margarine and creamer would also be considered “synthetic” due to the fact that they are both produced using a chemical process called “Hydrogenation.” (click .pdf for full comment)

Where is the presentation on "The Endocannabinoid System and Our Health?" or "Hemp Derived Products for Global Markets"? You ALL should be ashamed.... you are not even accept public comments at the meeting because the fix is in.... you don't even pretend to listen.... how many of you have done ANY research on this subject? YOU are the reason there is NO respect for Government..... when it falls..... and it will .... YOU are the reason..