Public Comments for 02/01/2023 Courts of Justice - Subcommittee #2
HB1922 - Delta-8 tetrahydrocannabinol; distribution, penalty.
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.
Delta-8 and other synthetic cannabinoids are not tested for potency, strength, or contamination. They are not safe for anyone, much less kids. Retailers are not being careful to sell only to ages over 21. High school kids easily obtain edibles and vapes. Small children can mistake the gummies for candy. The developing brains of our kids should be protected from these products. The availability of these products is a threat to safety in our families and our schools.
I support HB 1922. Delta-8 THC is much more dangerous than Delta-9 TCH due to its increased potency. Delta-8 and other synthetically produced cannabinoids are responsible for most of the accidental poisonings and emergency room visits attributable to vaping and edible cannabis. I do hope that HB 1922 can be amended to change Delta-8 to include synthetic intoxicating cannabinoids, as there are many synthetics that are as or more dangerous than delta-8, and new ones are also being developed. The needs of patients seeking medical cannabis can be met using the naturally occurring delta-9 form.
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
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
Delta 8 is a federally protected product as part of the 2018 Farm Bill per both a 9th Circuit Federal Court of Appeals ruling (A. K. FUTURES LLC v. BOYD STREET DISTRO, LLC) and per a Kentucky court via (Kentucky Hemp Association, et al vs. Ryan Quarles, Kentucky Department of Agriculture). Virginia adults have the right to buy, sell, purchase, or possess Delta 8 products for themselves or their adult friends and to give the same to their adult friends. The politicization of this issue and product by people running for higher political office has been disgusting and unethical. The simple fact is that adults shouldnt give or allow children to have access to adult products. Don't let your children have access to alcohol or guns. And if they are little, don't leave them unattended in the bathtub or near a 5 gallon bucket with water in it. We don't ban cars simply because children die in car accidents every year. What we do instead is force parents and guardians to take sufficient measures to protect children from the dangers of vehicles, including penalties for not using car seats or seatbelts. We do not ban people from buying or possessing cars. This bill needs to die.
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
Our kids are being harmed by delta-8 and other synthetic cannabinoids. They harm their brains and mental health. Young children are accidentally ingesting them as they look like candy and the kids are becoming very sick. They are available in edibles and vape cartridges that high school kids can easily obtain (and use undetected in school and at home). I am a former high school teacher and college instructor. These products are keeping us from developing the potential in our young people. I support HB 1922!
I am writing in support of HB 1922, but I do believe that it needs an amendment. I hope that the reference to delta-8 THC can be changed to include all synthetic intoxicating cannabinoids. I am a scientist and am aware that the potential for developing new types of synthetic cannabinoids is almost limitless. While delta-8 THC is clearly a more dangerous drug than the delta-9 THC found in the marijuana plant, there are other potentially more dangerous, high potency cannabinoids that manufacturers can substitute if delta-8 becomes illegal. A friend who is a therapist specializing in adolescence told me that he has worked with several teens who suffered brain damage from using K2, one of the most potent and potentially deadly cannabinoids. In the wake of the pandemic, the stress on our health care system has never been higher. We are in the midst of a mental and physical health crisis. Our health care system cannot support the additional stress from the huge surge in emergency room visits from synthetic cannabinoid poisoning. Furthermore, the lack of quality control in these products has allowed for other types of chemicals to poison consumers. Recently, a bad batch of THC that contained the rat poison, brodifacoum, resulted in the hospitalization of 52 people in Florida, 4 of whom died. This wasn't the first time brodifacoum had shown up in vaping and edible products containing THC. This problem has been ongoing in many states, including Virginia, over the last few years. I am appalled by how Virginia has been handling the sale of cannabis products. Synthetics are widely available, and most stores that sell them willingly sell to those under age 21. Even though this is illegal, the age restrictions are not being enforced. Cannabinoid use (synthetic and marijuana based) is a huge problem at my son's high school. Furthermore the products that look like foods have led to a huge number of accidental poisonings in people of all ages, including infants and toddlers. I am also concerned that we are not currently doing a good job at addressing driving under the influence of cannabinoids. There are some bills up for consideration to address this, but I strongly feel that these need to be implemented first, and that their effectiveness assessed for several years before cannabinoids of any kind should be legalized. I don't have much faith in the state's ability to regulate these products. I'm not sure why they were allowed on the shelves in the first place, but the safest thing we can do to protect our kids is to ban the sale of all synthetic intoxicating cannabinoids. Thank you for considering my concerns.
HB2011 - Family cemeteries; interment rights, proof of kinship.
HB 2011 - I supported Del. Roems' bill last year and I do again this year. This allows African Americans to be able to visit graves of their relatives. HB 2059 - This is the legal definition of a foreign born person who has not been naturalized to become a US citizen under federal law & the Constitution. HB 2056 - I do not support any one who may be here illegally to start a business. They are already violating our laws: what would be the purpose in starting a legitimate corporation where you are expected to follow the law when you're not even willing to follow it to be here in the first place?
HB2259 - Paternity; genetic tests to determine parentage, relief from paternity.
Please vote "YES" on HB2259. This bill is reasonable, rational, and necessary legislation to help put a stop to the prevalence of paternity fraud cases in Virginia. The issue of paternity fraud is not new, and not difficult to detect and prevent, yet legislation has failed to help put an end to the injustice. This bill is the legislation needed to deter persons from making knowingly false statements. And with DNA tests available for less than $100, an alleged father of a child should, at minimum, be given the opportunity to request the administering of this inexpensive, conclusive test. Historically, injustices occurred because there simply wasn’t the science to support or deny the claim of paternity, but in the year 2023 there is no longer an excuse for paternity injustice. Family Reunion is a national, non-profit organization that works with lawmakers, existing organizations, and experts dedicated to making much-needed changes to the family court system so the best interests of children can be supported. We focus on positively influencing family laws and policies that often discount one parent and ultimately harm the children.
HB1895 - Sexual harassment; nondisclosure or confidentiality agreement.
I support HB 1895. As I am sure you all are aware, retaliation in the work place happens all of the time. Employees need this protection. Please support HB 1895.
Birth In Color RVA is a doula collective with over 100 doulas around the Commonwealth. We support patients going throughout pregnancy, during the pre- and post- partum period and birth. 40% of US women have faced gender-related discrimination in their careers. 42% of US employees confirm they have faced or witnessed workplace racism and sexism. Our clients are no different, and each of our doulas has heard stories about discrimination in the workplace experienced by a client at some point in their work, including retaliation for trying to address the problems. As an organization committed to the health and welfare of our patients and our doulas, we know how devastating workplace discrimination can be. We strongly support both bills, HB 1895 and HB 2148 - as important steps towards ensuring that those who face workplace discrimination know their rights and are able to exercise them. We thank the patrons, Delegate Filler-Corn and Delegate Guzman for bringing these important pieces of legislation and hope that they are met with the support they deserve from the members of this Committee. Thank you for your consideration, Galina Varchena, Birth In Color RVA.
AAUW strongly advocates for new laws and policies to battle the problem of workplace harassment and discrimination based on gender, sexual orientation, race, ethnicity or religion. Workplace sexual and other harassment threatens women’s mental health and physical safety, erodes women’s short- and long-term economic security, and contributes to the leadership gap. Alhough Title VII protects women in the workplace, one study published in the Harvard business Review found that 34% of female employees say they have been sexually harassed by a colleague. Although federal law appears comprehensive and robust, employees who are harassed or experience inequity at work are often unable to access justice. Barriers include: business size (small businesses are exempt); exclusion of various categories of workers, e.g., contractors, interns, from coverage; limited time frame for bringing federal charges; onerous standards of proof; reduced liability; and nondisclosure agreements and mandatory arbitration. • HB1895 (Del. Eileen Filler-Corn), The Silenced No More Act, would limit the abusive use of Nondisclosure Agreements and Nondisparagement agreements (NDAs) to silence employees from speaking up about discrimination, including harassment, retaliation, sexual assault, wage and hour violations, and waste, fraud, or abuse. • HB2148 (Del. Elizabeth Guzman) , Know Your Rights requires employers to inform workers of their rights to file a charge of discrimination with the U.S. EEOC or the Virginia Office of the Attorney General within 300 days after an alleged unlawful discriminatory practice occurred. The bill requires an employer to provide this information as part of any new employee training provided at the commencement of employment or anti-discrimination training provided to an employee and when an employee makes a complaint. These two bills will be important steps in protecting Virginia workers.