We respectfully ask you vote no on HB1922, HB1973 & HB2294 HB1973 & HB2294: No one in the hemp industry is opposed labeling, testing or packaging of products. We have met every new regulation in labeling and packaging as they have been introduced. In fact we welcome stricter regulations on labeling, testing & packaging as we believe it helps weed out bad actors. But both of these bills have a 2mg per package limit for ANY THC (even naturally occurring D9). The current limit of quantitation (LOQ) for modern testing is 0.01% or 0.1mg/g. That means that in a 20g or smaller package, detecting ANY THC would make the product marijuana. The purpose of these limits is to only allow hemp products that contain zero naturally occurring THC (even non-intoxicating levels). These mg caps will absolutely end every hemp retailer, processor, and farmer in Virginia. 1000s of living wage jobs will be lost. Millions of dollars in infrastructure will be auctioned off to neighboring states. Most Va hemp processors and retailers are not selling intoxicating products, even though their products contain low levels of THC (0.3%). NON-intoxicating hemp products with low levels of THC will still be widely available from out of state via the internet, but Virginia small business will not be able to participate in the federally legal marketplace. The requirement of bittering agents in topicals is yet another blow to small hemp businesses. No one is going to buy topicals with unnecessary additives that are specifically made to be unpalatable. This will spell the literal end to all hemp topical manufacturing in Virginia. But, consumers will still be able to buy non-bittered topicals from out of state via the internet. Again, Virginia small business will not be able to participate in the federally legal marketplace. On HB1922: Delta 8 THC is found naturally in Hemp biomass in small concentrations. This bill would make all Hemp and hemp products with small concentrations of naturally occurring Delta 8 THC illegal. Would the Hemp industry be forced to find cultivars that have non-detect concentrations of Delta 8 THC? This bill creates a number of legal question and problems for VCDACS and other stake holders. For this bill to not have unintended consequences it must call out an allowable percentage to include what's found naturally in hemp plants and products (<0.3%).
 There are a number of hemp derived, (federally legal) psychoactive chemicals that are not Delta 8 THC. This bill would have zero effect on the proliferation of these widely available chemicals. This bill would not have the intended effect of reducing psychoactive access or harm.

Comments Document

I echo Griffith: Please vote NO to the following bills: HB 1973, HB 2294, and HB 1922. These bills would put thousands of Virginia hemp businesses out of business overnight when we have been operating by the law for the last 5 years. If the objective is truly consumer safety, then establish moderate regulations that legitimate Virginia owned companies can comply with. Consumers are already used to buying these products on retail shelves in Virginia, and by criminalizing the sale of these products in the state will only force consumers to the black market or the unregulated online market. The best way to control the market is to moderately regulate it in a way that does not exacerbate black market sales, and also does not put thousands of Virginia owned businesses out of business. We all want consumer & child safety, and the only way to do that is by regulating the recreational market. Prohibition is never the answer, and by voting yes to any of these bills, you will be a direct contributor to the issue you are trying to resolve. Please consider this as well as the thousands of families whose sources of income and their life’s work will be ruined by passing these destructive bills. We are real people and we are asking you respectfully to vote no on HB1973, HB2294 & HB1922

This is an outrageously egregious bill that would attempt to put the entire hemp industry in Virginia out of business for the benefit of the medical cannabis monopolies. A $1000 annual retail sales license PER LOCATION for products whose competitors are bought on Amazon does nothing but punish Virginia farmers for attempting to do business in Virginia. There are hundreds of small businesses in Virginia who do less than $2000 in gross annual sales of hemp and cbd products, but make up large portions of small Virginia hemp farmers' businesses. These people would immediately be forced to stop selling locally produced and VDACS regulated cbd products. Perhaps that is what the medical cannabis monopolies wanted when they donated $3500 to Del. Leftwich last year, per VPAP.org. A $10,000/day civil fine for not having said sales licese is a violation of the 8th Amendment, and a Class 1 Misdemeanor/day for not having said sales license is an outrageous money grab and extortion attempt against Virginia business owners. VDACS and Virginia have an agreement with USDA regarding the Farm Bill & Industrial Hemp and federally protected hemp products like CBD, and this bill would absolutely violate that agreement. Forcing product manufacturers to put ALL cannabinoids on the label is a scientific impossibility as more are discovered every day. Additionally, the testing costs once protocols were discovered for the new cannabinoids would be entirely cost prohibitive. Product labels would be out of date the moment they were printed. VDACS ALREADY has testing standards in place for the cannabinoids that are advertised on a product. Those are working just fine. If a product doesnt have those, then go after them. All this bill will do is destroy small businesses, push millions of dollars in business out of the state, and force people to get the same cbd products online, out of state, that they were getting from their trusted local farmers at their trusted local store, manufactured under VDACS quite capable current standards. This bill is an unethical power and money grab by deep pocketed out of state interests and needs to die.

Greetings Delegates, The selected biils are Detrimental to the small farmers and retailers in the state of Virginia. As a member of the Virginia Hemp Coalition I ask that you vote no on these bills. Also add the Social Equity back to all of the cannabis legislation. Thanks for keeping Virginia first!!!! Sincerely, William Hill New Century Farmers Group

I sent the committee an email about this early this morning.

I oppose bills that restrict the re-emerging hemp wellness industry in favor of state-controlled medical / recreational cannabis industry. Bill's before this committee will allow the the government to choose out of state corporations as winners, at the expense of registered and federally compliant small hemp businesses. There is space in Virginia for industrial hemp, hemp extracts for wellness, and cannabis for medicine and recreation to coexist in Virginia. That space should allow small, medium, and large growers, producers, testers, and manufacturers to enter, without exorbitant entry and maintenance fees. Bad actors should be held accountable for irresponsibility marketed products, however, a whole legal hemp industry should not be criminalized and punished. There should not be new criminal penalties for hemp or cannabis products. There are current laws in place to deal with unscrupulous products. We should be researching and studying hemp and cannabis as alternatives to pharmaceuticals, educating, marketing and building safe access to hemp and cannabis products. We should include many Virginian workers and small businesses and create tax revenue for our Commonwealth.

Please vote NO to the following bills: HB 1973, HB 2294, and HB 1922. These bills would put thousands of Virginia hemp businesses out of business overnight when we have been operating by the law for the last 5 years. If the objective is truly consumer safety, then establish moderate regulations that legitimate Virginia owned companies can comply with. Consumers are already used to buying these products on retail shelves in Virginia, and by criminalizing the sale of these products in the state will only force consumers to the black market or the unregulated online market. The best way to control the market is to moderately regulate it in a way that does not exacerbate black market sales, and also does not put thousands of Virginia owned businesses out of business. We all want consumer & child safety, and the only way to do that is by regulating the recreational market. Prohibition is never the answer, and by voting yes to any of these bills, you will be a direct contributor to the issue you are trying to resolve. Please consider this as well as the thousands of families whose sources of income and their life’s work will be ruined by passing these destructive bills. We are real people and we are asking you respectfully to vote no on HB1973, HB2294 & HB1922. Sincerely, Savana Griffith

We respectfully ask you vote no on HB1922, HB1973 & HB2294 HB1973 & HB2294: No one in the hemp industry is opposed labeling, testing or packaging of products. We have met every new regulation in labeling and packaging as they have been introduced. In fact we welcome stricter regulations on labeling, testing & packaging as we believe it helps weed out bad actors. But both of these bills have a 2mg per package limit for ANY THC (even naturally occurring D9). The current limit of quantitation (LOQ) for modern testing is 0.01% or 0.1mg/g. That means that in a 20g or smaller package, detecting ANY THC would make the product marijuana. The purpose of these limits is to only allow hemp products that contain zero naturally occurring THC (even non-intoxicating levels). These mg caps will absolutely end every hemp retailer, processor, and farmer in Virginia. 1000s of living wage jobs will be lost. Millions of dollars in infrastructure will be auctioned off to neighboring states. Most Va hemp processors and retailers are not selling intoxicating products, even though their products contain low levels of THC (0.3%). NON-intoxicating hemp products with low levels of THC will still be widely available from out of state via the internet, but Virginia small business will not be able to participate in the federally legal marketplace. The requirement of bittering agents in topicals is yet another blow to small hemp businesses. No one is going to buy topicals with unnecessary additives that are specifically made to be unpalatable. This will spell the literal end to all hemp topical manufacturing in Virginia. But, consumers will still be able to buy non-bittered topicals from out of state via the internet. Again, Virginia small business will not be able to participate in the federally legal marketplace. On HB1922: Delta 8 THC is found naturally in Hemp biomass in small concentrations. This bill would make all Hemp and hemp products with small concentrations of naturally occurring Delta 8 THC illegal. Would the Hemp industry be forced to find cultivars that have non-detect concentrations of Delta 8 THC? This bill creates a number of legal question and problems for VCDACS and other stake holders. For this bill to not have unintended consequences it must call out an allowable percentage to include what's found naturally in hemp plants and products (<0.3%).
 There are a number of hemp derived, (federally legal) psychoactive chemicals that are not Delta 8 THC. This bill would have zero effect on the proliferation of these widely available chemicals. This bill would not have the intended effect of reducing psychoactive access or harm.

As a scientist concerned about quality assurance testing for products in the Commonwealth, I have reviewed HB2294. It is my opinion, from an informed position regarding quality testing and in having spoken with other stakeholders in patient and consumer safety, HB2294 has the strong language to protect consumers from poorly made, contaminated, and adulterated products.

Comments Document

I echo Griffith: Please vote NO to the following bills: HB 1973, HB 2294, and HB 1922. These bills would put thousands of Virginia hemp businesses out of business overnight when we have been operating by the law for the last 5 years. If the objective is truly consumer safety, then establish moderate regulations that legitimate Virginia owned companies can comply with. Consumers are already used to buying these products on retail shelves in Virginia, and by criminalizing the sale of these products in the state will only force consumers to the black market or the unregulated online market. The best way to control the market is to moderately regulate it in a way that does not exacerbate black market sales, and also does not put thousands of Virginia owned businesses out of business. We all want consumer & child safety, and the only way to do that is by regulating the recreational market. Prohibition is never the answer, and by voting yes to any of these bills, you will be a direct contributor to the issue you are trying to resolve. Please consider this as well as the thousands of families whose sources of income and their life’s work will be ruined by passing these destructive bills. We are real people and we are asking you respectfully to vote no on HB1973, HB2294 & HB1922

This is a ridiculous bill that both violates federal standards for federally protect CBD products via the 2018 Farm Bill, and violates the basic tenants of math and science. I'm certain that the $26,500 that Delegate Kilgore took in last year per VPAP.org from the medical cannabis monopolies had nothing to do with the fact that these medical cannabis monopolies stand to become the only places in the state where people could buy products in person that are federally legal in every other state. For starters, the federal threshold for CBD products is 0.3% THC. It is not 1mg per 100 grams of of product weight. That is 0.0001% THC. The 2 cannot coexist in the same bill because math exists and 0.0001% is not equal to 0.3%. This bill outlaw the most basic of cbd products - cbd oil. Any full spectrum extract cbd oil will contain trace amounts of THC. For example, a 500mg bottle of cbd oil that contains 0.05% THC is 6x below the federal limit, but at 15.9mg in total thc in the bottle, is still 16x over the entirely ridiculous limit in this bill. The portion of the bill requiring bittering agents in non-edible cbd products is both scientifically ridiculous and practically absurd. No one is eating cbd soap, lotion, salve, or bathbombs. However, given that most cbd products are formulated to be as natural as possible, forcing manufacturers and farmers to add additional chemical compounds to these products both ruins these products, and potentially harms the consumer. What happens if an alcoholic buys a non-edible product that has ethanol in it as a bittering agent? What happens if a bittering agent triggers a skin reaction on someone with sensitive skin or a skin condition (which is a sizeable portion of people buying cbd products)? The end result of this is that even more businesses in Delegate Kilgore's district will slide across the border to North Carolina, Tennessee, and Kentucky - just like many already have. In short, this bill - while violating federal law and the 2018 Farm Bill provisions - will simply cement that far from helping Delegate Kilgores region regain an economic footing so desperately needed, he has instead presided over their long, slow, altogether avoidable, slide towards economic destruction and abject poverty. This bill needs to die.

Greetings Delegates, The selected biils are Detrimental to the small farmers and retailers in the state of Virginia. As a member of the Virginia Hemp Coalition I ask that you vote no on these bills. Also add the Social Equity back to all of the cannabis legislation. Thanks for keeping Virginia first!!!! Sincerely, William Hill New Century Farmers Group

With reading this proposed bill, I am confused about the inclusion of a bittering agent in non-consumable hemp products. I have created and am pushing to market hemp fire starter, fire logs, etc, which utilized all parts of the left over materials from the plant, leaving zero waste. All parts are used. You can view this product on my website www.crystalhillcannabis.com But in this proposed bill, it states that a bittering agent will need to be added to any non-consumable hemp product. Does this include my product? Does this include the exploding building industry that is utilizing parts of the plant. Does this include pet bedding made from the plant. I find the inclusion of a bittering agent in any non-consumable hemp product to be overboard and lubricous.

I oppose bills that restrict the re-emerging hemp wellness industry in favor of state-controlled medical / recreational cannabis industry. Bill's before this committee will allow the the government to choose out of state corporations as winners, at the expense of registered and federally compliant small hemp businesses. There is space in Virginia for industrial hemp, hemp extracts for wellness, and cannabis for medicine and recreation to coexist in Virginia. That space should allow small, medium, and large growers, producers, testers, and manufacturers to enter, without exorbitant entry and maintenance fees. Bad actors should be held accountable for irresponsibility marketed products, however, a whole legal hemp industry should not be criminalized and punished. There should not be new criminal penalties for hemp or cannabis products. There are current laws in place to deal with unscrupulous products. We should be researching and studying hemp and cannabis as alternatives to pharmaceuticals, educating, marketing and building safe access to hemp and cannabis products. We should include many Virginian workers and small businesses and create tax revenue for our Commonwealth.

Please vote NO to the following bills: HB 1973, HB 2294, and HB 1922. These bills would put thousands of Virginia hemp businesses out of business overnight when we have been operating by the law for the last 5 years. If the objective is truly consumer safety, then establish moderate regulations that legitimate Virginia owned companies can comply with. Consumers are already used to buying these products on retail shelves in Virginia, and by criminalizing the sale of these products in the state will only force consumers to the black market or the unregulated online market. The best way to control the market is to moderately regulate it in a way that does not exacerbate black market sales, and also does not put thousands of Virginia owned businesses out of business. We all want consumer & child safety, and the only way to do that is by regulating the recreational market. Prohibition is never the answer, and by voting yes to any of these bills, you will be a direct contributor to the issue you are trying to resolve. Please consider this as well as the thousands of families whose sources of income and their life’s work will be ruined by passing these destructive bills. We are real people and we are asking you respectfully to vote no on HB1973, HB2294 & HB1922. Sincerely, Savana Griffith