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Oregon Declares State of Emergency Over Illicit Hemp Farms

by Travis C | Oct 22, 2021 | 420 News, Blog, Cannabis Law, Cannabis Law and Compliance, Cannabis News, Hemp, Hemp Law, Legalization

Ilicit hemp farms make up 50% of operations in an Oregon county

There were several concerns among states following the federal legalization of hemp in 2018. One of the primary being the regulation of both cannabis and hemp together in states where cannabis has been legalized.

One such state is Oregon, which legalized cannabis in 2014 and quickly saw a massive boom in the new industry. The state was producing so much cannabis that the price per pound tanked, almost causing the entire industry to crash in just a couple of years.

So when the government legalized industrial hemp on the federal level in 2018, many states including Oregon saw it as an opportunity to broaden the accessibility to the cannabis industry for farmers. Many in Oregon were looking for an alternative to THC-rich cannabis due to the oversaturated market, which led them to switch to hemp instead.

Others joined when hemp was legalized as they recognized the potential of the growing CBD market, and more nefarious actors joined to take advantage of one of the biggest overlying issues in the hemp/cannabis industry; figuring out the difference.

Illicit Hemp Farms

Hemp and cannabis are technically one and the same. While the genetics have branched apart from each other over time, the plant remains very similar at their core. Both contain THC and CBD, but while cannabis was bred to have more THC, hemp traditionally has lower THC levels already, making it easier to breed out.

The Farm Bill requires that hemp contain no more than .3% THC, an infinitesimal amount that can’t produce a psychoactive high. This requirement is what helped drive the CBD as market, as all other cannabinoids aside from Delta-9 Tetrahydrocannabinol (THC) are technically legal.

Since the plants look so similar to each other, a large portion of the farms claiming to be growing legal hemp, have actually been growing illicit cannabis without proper licensing.

With cannabis legal in Oregon now, these illegal farms operate with near impunity next to Oregon’s highly regulated cannabis market. With many western states being hit with drought this year, these illegal farmers are also illegally stealing water from the surrounding creeks and wells. One illegal cannabis farm recently raided by authorities was illegally drawing water from the Illinois River to feed over 72,000 marijuana plants.

The Jackson County Board of Commissioners recently declared a state of emergency warning of “an imminent threat to the public health and safety of our citizens from the illegal production of cannabis in our county.”

The illegal cannabis farms are often posing as legal hemp farms, the commissioners noted. The Oregon Health Authority and the Oregon Liquor and Cannabis Commission recently reported that nearly 50% of registered hemp farms inspected in the state are illegally growing cannabis, with a THC content greater than legal limits.

What is Delta 10 THC? Delta 10 Gummies and Delta 10 Cartridges explained

by Travis C | Aug 31, 2021 | 420 Culture & Travel, 420 News, Blog, Broscience Mythbusters, Cannabis Law and Compliance, Cannabis News, Culture, Hemp, Hemp Law, Science & Technology

When the federal government legalized industrial hemp in 2018, it changed a lot of things. It also opened up plenty of loopholes.

After the explosion of CBD and just about every hemp producer trying to sell their CBD products, the market became extremely saturated. While the market for CBD products is still huge (and growing), there are other cannabinoids that have been discovered in hemp that provide different effects.

You may have heard of CBG and CBN, two cannabinoids similar to CBD that have been shown to have therapeutic effects without producing a psychoactive high. However, there have been new, synthetically produced cannabinoids that actually do provide psychoactive effects while staying in a grey area of legality due to being derived from legal hemp.

The latest in this evolution of grey market cannabinoid products is Delta 10 THC.

Delta 8 THC and THC O Acetate

Delta 8 THC was the first synthetic cannabinoid to blow up in popularity, with advertisements of a legal high nearly identical to traditional Delta 9 THC. For some, being synthetically manufactured can be a major turn off, bringing back memories of K2 or Spice — entirely synthetic “cannabinoids” created from scratch and sprayed on various herbs — which resulted in numerous injuries and deaths.

However Delta 8 is made a little differently. Instead of making it entirely from scratch, Delta 8 THC is most commonly made from CBD. Through an isomerization process, CBD can be converted in Delta 8 THC. There are lab tested Delta 8 products that are reliable, and just as many that are not, so buyer beware.

But what happens when you take Delta 8 — which is made through chemical processes — and add more chemical processes? You get THC O Acetate.

While Delta 8 THC occurs in low concentrations in cannabis that must be extracted and isolated, THC-O Acetate — commonly called ATHC or THC-O — is not naturally occurring in the cannabis plant and can only be made synthetically.

THC-O is a man-made cannabinoid produced by using specific chemicals to acetylate THC. Acting as a metabolic prodrug for THC itself, THC-O works in the same manner as heroin does as a metabolic prodrug for morphine. That alone is enough to rub many cannabis users the wrong way, especially whole plant advocates.

However the high that THC O Acetate can produce is enough for many to overlook how it is made. According to anecdotal experiences form users, THC O Acetate has been shown to be nearly 3x more potent than Delta 9 THC, and has been described as psychedelic, producing visual hallucinations.

However there are currently very few reliable THC O Acetate manufacturers, with only one claiming to have a pure, clean process for making it. With over a dozen states banning Delta 8 THC, and not enough reliable producers or consumer information on THC O Acetate, consumers and producers are looking for yet another replacement.

They may have found it with Delta 10 THC.

What is Delta 10 THC?

The good news about Delta 10 THC, is that it’s made in a near identical way to Delta 8 THC. It appears in similar trace amounts to the point where it’s not worth the time or money to try and extract it purely from a hemp plant. This means it has to be created from something like hemp-derived CBD through a chemical process.

So in the case of how to consume Delta 10 THC, it will almost always be found in the form of Delta 10 THC gummies or other edibles and Delta 10 THC vape cartridges made from distillate. This is because there is no hemp flower that produces enough Delta 10 THC that could actually be felt through normal flower consumption.

User reports of Delta 8 THC claim that it provides a more relaxing and appetite stimulating effect, similar to what most would call an “indica”. Delta 10 THC users on the other hand report it to feel more like a “sativa”; uplifting, energetic, etc..

Neither Delta 8 or Delta 10 THC provide the same intense high that Delta 9 THC can. But according to David Reckles from Private Label Hemp Lab, Delta 10 could potentially surpass Delta 8 in popularity as it provides an uplifting high that isn’t overwhelming or accompanied by paranoia and anxiety that some feel from Delta 9 THC.

Is Delta 10 THC Legal?

Just like Delta 8 THC and THC O Acetate, Delta 10 THC exists in a legal grey area. Because it is technically derived from federally legal hemp which has a Delta 9 THC concentration below .3%, and the Farm Bill specifically mentions only Delta 9 THC concentrations, Delta 10 and other cannabinoids are technically legal.

However, in a ruling on CBD and other cannabinoids legalized by the Farm Bill, the DEA says, “For synthetically derived tetrahydrocannabinols, the concentration of D9 -THC is not a determining factor in whether the material is a controlled substance. All synthetically derived tetrahydrocannabinols remain schedule I controlled substances.“

Unfortunately as government is wont to do, the DEA failed to clarify what constitutes a “synthetically derived tetrahydrocannabinol”, leaving it up for interpretation. To Delta 10 THC producers, the fact that nobody is getting busted is enough to continue making it, whether it turns out to be illegal or not.

In the same vein, the caution is on the consumer when purchasing Delta 10 THC gummies or Delta 10 THC cartridges. Not just because of the lack regulation on producers which results in shady products that could potentially be dangerous, but also because it is still THC. In other words, it’s possible for someone who gets drug tested for THC to test positive, despite only using Delta 10.

While Delta 10 THC, Delta 8 THC and THC O Acetate may be “legal” alternatives to Delta 9 THC in states where cannabis is still prohibited, it could change at any moment. Whether that means you should stock up on all the Delta 10 and Delta 8 you can get your hands on or just wait for legalization to come your state is up to you.

Texas lifts ban on smokable hemp, with caveats

by The Real Dirt | Aug 6, 2021 | Blog, Business, Cannabis Business, Cannabis Law, Cannabis Law and Compliance, Cannabis News, Hemp, Hemp Law

Texas lifts smokable hemp ban but it can't be grown in state

An appeals panel in Texas issued a mixed judgment Thursday in a lawsuit challenging the state’s ban on smokable hemp. Regulators may enforce a ban on the processing and manufacture of products intended for smoking or vaping, the court ruled, but it cannot prevent such products made elsewhere from being sold in the state.

The decision creates a situation in which consumers may be able to freely purchase smokable hemp flower and hemp-derived CBD oils for vaping, but only if the products are produced outside Texas.

Four Texas companies challenged the ban in a lawsuit last year, asking the court to declare the restrictions unconstitutional and allow hemp products intended for smoking or vaping to be produced and sold legally. In response, a state judge eventually put the entire ban on hold, preventing the government from enforcing it until the matter could be resolved in court.

In Thursday’s ruling, a three-justice panel of the Third District Court of Appeals drew a distinction between the processing and manufacturing of smokable hemp—which lawmakers strictly prohibited its production when they legalized hemp in 2019—and distribution and sales, which regulators at the Texas Department of State Health Services (DSHS) forbade under a rule adopted a year later.

Writing for the panel, Justice Melissa Goodwin reasoned that lifting the ban on product sales was justified because the DSHS restriction went beyond the scope of lawmakers’ manufacturing ban.

“The Legislature required that the Department’s rules must reflect the principle that ‘the processing or manufacturing of a consumable hemp product for smoking is prohibited,’ but did not mention retail sale,” the judgment says. “Nevertheless, the Department adopted a rule that banned not only the processing and manufacturing of consumable hemp products for smoking, but also the distributing and retail sale of such products.”

On the other hand, the panel’s ruling will allow lawmakers’ ban on production and manufacturing of smokable hemp products to take effect. Thursday’s ruling reversed a lower court’s decision to prevent the state from enforcing that part of the ban.

“Because the Hemp Companies never provided ‘a plain and intelligible statement of the grounds’ to enjoin the enforcement of rule 300.104’s bans on manufacturing and processing consumable hemp products for smoking, we conclude that the trial court abused its discretion in granting the temporary injunction and enjoining the enforcement of that portion of the rule,” Goodwin wrote.

Advocates in favor of broader legal access to cannabis products emphasized the significance of the court’s decision to allow smokable hemp to be sold in the state. But they lamented the fact that in-state manufacturing of the products will remain illegal.

“The reversal of the ban on distributing and selling smokable hemp products is a big win for Texas farmers and hemp businesses. It is extremely important that regulatory overreach is kept in check so that Texas companies are not prevented from excelling in this market,” Jax Finkel, executive director of Foundation for an Informed Texas, told Marijuana Moment on Thursday. “I am hopeful that manufacture portion of the suit will end in a similar opinion.”

Read Full Story on Marijuana Moment

THC-O Acetate: Will it replace Delta 8 THC?

by Travis C | Jul 22, 2021 | Blog, Broscience Mythbusters, Cannabis Business, Cannabis Law, Cannabis Law and Compliance, Cannabis News, Culture, Hemp, Hemp Law

What is THC-O Acetate and is it like Delta 8 THC?

As more states begin banning and regulating Delta 8 THC, manufacturers are looking for alternatives to skirt the rules. Bring in THC-O Acetate.

Before we dive into the latest designer cannabinoid that aims to replace Delta 8 THC as it becomes banned in several states and regulated in some others, let’s briefly run through what Delta 8 THC is itself.

All cannabinoids, from CBD to THC and beyond begin as CBGA. Because of the shared molecular structure of cannabinoids, manipulating them is simpler than it may seem. While Delta-8 is relatively new, producers have been using these methods to manipulate cannabinoids for a long time to find exotic new cannabinoids.

While Delta-8 THC exists in a wide range of cannabis strains, it is in minuscule, trace amounts. To extract and purify Delta-8 from raw plant material with less than one percent of the targeted cannabinoid is unprofitable. This is why producers have begun converting other, more prevalent cannabinoids like CBD and Delta-9 THC into Delta-8.

Through a synthetic isomerization process, CBD is combined with a solvent to create Delta-8 THC. This is why the most popular products are vape cartridges and gummies. Cannabis cannot produce enough Delta-8 on its own.

Why Delta 8 THC is being banned

If you read the above section and started thinking, “That sounds pretty similar to those designer cannabinoids like spice that hurt a lot of people”, you would be on the right track. That is why over a dozen states have already banned Delta 8 THC.

Due to grey areas in the 2018 Farm Bill which legalized hemp and all of its derivatives (besides Delta 9 THC), producers of Delta 8 believe they technically aren’t breaking any laws. However unlike CBD which was immediately popular and thus regulated by the FDA for safety, Delta 8 has had no such treatment.

In 2020, the DEA released a set of rules for hemp production in the country. This ruling states that any naturally occurring tetrahydrocannabinols in the hemp plant that has a Delta 9 THC percentage below .3% is not a controlled substance under the Controlled Substance Act. In other words, it would seem like Delta 8 in the clear.

However the DEA also includes that for synthetically derived tetrahydrocannabinols (like Delta 8 which is created synthetically), the concentration of D9 -THC is not a determining factor in whether the material is a controlled substance. All synthetically derived tetrahydrocannabinols remain schedule I controlled substances. In other words, maybe Delta 8 is not so in the clear.

For the states that have already banned Delta 8 THC, it seems the easiest solution to a product that the FDA and DEA have made no mention of regulating. For producers however, THC-O Acetate is the solution.

What is THC-O Acetate?

While Delta 8 THC occurs in low concentrations in cannabis that must be extracted and isolated, THC-O Acetate — commonly called ATHC or THC-O — is not naturally occurring in the cannabis plant and can only be made synthetically.

THC-O is a man-made cannabinoid produced by using specific chemicals to acetylate THC. Acting as a metabolic prodrug for THC itself, THC-O works in the same manner as heroin does as a metabolic prodrug for morphine. That alone is enough to rub many cannabis users the wrong way, especially whole plant advocates.

THC-O Acetate can also be made from Delta 8 THC, so in states where it has been banned and producers may have a bulk supply of Delta 8, it can be converted relatively easily. And what truly makes THC-O so popular is the effects users feel.

Traditional THC Molecule:

Delta 9 THC vs THC-O Acetate THC-O Acetate Molecule:

What is THC-O Acetate and is it safe?

A better high than Delta 9?

According to user reports and the little science behind it, THC-O Acetate has been shown to be two to three times stronger than Delta 9 THC. You read that right. THC-O can be 300% more potent than traditional Delta 9 THC.

Users have claimed that THC-O Acetate is a much more introspective and psychedelic experience compared to Delta 9 or Delta 8 THC, which is likely due to the extreme potency. Similarly to Delta 8 THC, THC-O can only be made through isolation, which means most products will be either a vape cartridge or edibles.

While for most, normal Delta 8 or Delta 9 THC does the trick just fine and taking such a concentrated product would be excessive, there is a real appeal for medical applications of THC-O Acetate. For some, traditional Delta 9 doesn’t provide enough relief from pain, anxiety or other issues.

Due to its potency, many believe that THC-O could be a great beneficial medicine for those who want to use cannabis but need a more concentrated dose that isn’t easily attainable through traditional consumption. With that said, THC-O Acetate is treated similarly to Delta 8 currently.

That means in states where Delta 8 has already been banned, you may be unable to have THC-O products delivered, or find them at smoke shops. However since there is so little information on THC-O, few states actually know about it, which means distributors may be able to get away with it for a while.

Is THC-O Acetate the new designer drug?

Of course for now it is too soon to say if THC-O is likely to end up in a similar grave to Spice or K2. These were synthetically created cannabinoid products that ended up hurting a lot of people, leading them to be banned across the country. However the way these products skirted the law was by minutely adjusting their chemical makeups every time one was banned.

Because the government would ban specific makeups of these products, small adjustments made them different products technically. It is always possible, being a fully synthetic creation, that THC-O befalls a similar fate. In grey markets, profits typically rise above safety. As competition grows, just like Delta 8 became more widespread, the same will likely happen to THC-O Acetate.

Producers will try to create stronger and cheaper versions of the drug, the latter effort being that which leads to danger. We all saw what happened when illicit market vape cartridge producers tried to cut costs by including Propylene Glycol and Vitamin E Acetate in their products. This resulted in hundreds of hospitalizations and even deaths.

With any grey or black market cannabis products, it is always on the user to ensure they are getting a safe and reliable product. If demand for THC-O Acetate grows enough, you can bet there will be a market for it.

However as a non-natural cannabinoid, THC-O isn’t measured with most testing methods used for cannabis currently. While some have claimed to created a reliable process for measuring THC-O, nothing has become the standard. Due to this it might be a while before there are truly reliable providers of THC-O products, but that hasn’t stopped consumers before, and likely won’t this time around either.

Michigan Governor Signs Legislation to Regulate Delta-8 THC

by The Real Dirt | Jul 14, 2021 | 420 News, Blog, Business, Cannabis Business, Cannabis Law, Cannabis Law and Compliance, Cannabis News, Hemp Law, Industry News, Legalization

MICHIGAN — Today Gov. Whitmer signed legislation that will regulate, and cover delta-8 THC derived starting October 11, 2021.

This bill will update definitions regarding cannabis plant products making sure all intoxicating substances will be safety-tested and tracked through the MRA’s statewide monitoring system Michigan Executive Office of the Governor.

“This package of bills continues to show Michigan is the model for the nation in regard to protecting its residents and making sure that those who consume marijuana products do so in a safe manner,” said Gov. Whitmer. “I am glad to see Michigan continuing to lead on the implementation and regulation of a safe, secure marijuana industry, which has already brought tens of millions of dollars in new tax revenue to the state, as well as thousands of well-paying jobs.”

“The team at the MRA has always been committed to transparency and forward thinking and this was once again the case regarding delta-8,” said MRA Executive Director Andrew Brisbo. “We were proud to work with legislators and industry stakeholders to pro-actively address this issue and move an untested, unlicensed intoxicating synthetic product into our licensed and regulated system.”

“The voters of Michigan chose to legalize and regulate marijuana in the interests of justice and public health,” said Rep. Yousef Rabhi, D-Ann Arbor. “We know that banning these substances is not the best way to keep the public safe. But we also know that these psychoactive compounds are currently being sold with no public health standards to anyone, regardless of age. Instead of allowing these new hemp derivatives like Delta 8 to circumvent our world-class regulated system, this new law will apply the same rigorous testing and commercial standards that currently protect consumer safety in the legal marijuana marketplace.”

“I appreciate the support of Governor Whitmer and my legislative partner Representative Rabhi in helping Michigan take an important step in streamlining regulations for the safety of cannabis businesses and people around our state,” said Rep. Jim Lilly, R-Park Twp. “By mirroring Michigan’s existing liquor dram shop law and clearly defining the requirements for a proper injury lawsuit, we are bringing clarity to a previously murky area of our cannabis laws. I am extremely excited to see the Governor not only sign these bills, but also sign bills to protect Michigander’s from unregulated and untested Delta-8 hemp products. This legislation does the right thing by taking these products out of the unregulated marketplace and bringing them under the purview of a well-functioning Marijuana Regulatory Agency.”

Read Full Story on Fox 17 West Michigan

The Most Common Cannabis Compliance Issues

by Travis C | Jul 1, 2021 | Blog, Business, Cannabis Law, Cannabis Law and Compliance, Hemp Law, Legalization, Medical Marijuana

Operating in a legal cannabis industry, whether recreational or medical, comes with strict regulations that requires compliance for businesses. Underestimating the level of cannabis compliance has led to the downfall of many new cannabis businesses.

Cannabis compliance is more than just meeting required plant counts or ensuring safe working conditions for employees. Every industry is regulated in some form, however the cannabis industry lacks any form of federal regulations.

Without any federal oversight, states are left to create their own regulations and cannabis compliance requirements. These requirements vary widely by state, making operating in multiple states more challenging.

There are some common cannabis compliance requirements that any business owner will have dealt with at some point. However there are others that a new business owner may overlook. This can have drastic consequences, such as removal of an operating license, extreme fines, or even being shut down completely.

Licensing

Cannabis licensing is typically the first step any would-be business owner takes. Each state varies in how they handle licensing, from application fees and financial requirements to how many total licenses are given out.

Pricing alone is large barrier to entry for many, with some states like California charging higher and higher license fees the larger a business’ revenue. Others may just charge a flat fee for all licenses, but the fee is also high, and recurs annually.

Common licenses include manufacturing, retail, dispensary, and cultivation. Cannabis businesses need to know what’s required in their state and when to get their licenses and permits renewed. Having an expired or illegitimate license or permit can result in hefty fines and a risk of closure.

It isn’t just the business that has to be licensed either in many states. Employees are typically also required to have specific licensing to work in a cannabis business.

Cultivation

From plant limits to seed to sale tracking, every state can implement different cannabis compliance requirements for cultivation facilities and farms. This can include mandatory reporting of water usage and run-off, pesticide restrictions, limited employees permitted in the grow, and tracking such as METRC.

Justin Jones from Greener Consulting Group opened the first recreational cannabis dispensary in Denver, Colorado. He was also one of the first growers in the country to implement METRC tracking in his grow.

In the past, growers just grew. Today’s growers need real management skills in the highly regulated legal markets and just as much time is spent meeting compliance requirements as is spent growing the plants themselves. It is a complete turn around from the past. Programs like METRC that were resisted at first, have now become tools for improving your business and collecting data on production, potency, testing and more.

Justin Jones

There is no worse feeling for a grower than going through an entire season and having it thrown out or being fined an exorbitant amount for failing to adhere to cultivation compliance requirements.

Cannabis Testing

Testing requirements for cannabis cultivators and processors has been a hot button issue in the legal cannabis industry. Due to lack to federal regulation there is no federal guidance or requirements for cannabis products, again leaving the decision to the states.

While every state will have testing requirements in order to prove the potency and safety of cannabis products, the requirements can vary and the labs that do the testing can vary as well. One lab might only test for cannabinoids, while another may test for terpenes and heavy metals as well.

The majority of the time, these labs are not state-run either, which can lead to some shady business transactions between labs trying to make some money and a grower who wants their harvest to pass. Real Dirt host and Greener Consulting Group founder Chip Baker has plenty of experience dealing with cannabis testing in a variety of states.

He knows first hand how difficult it can be to find an affordable and reliable testing facility for a wide range of cannabis products.

Keeping up with the different testing regulations throughout the US is pretty much an impossible task. Every state is similar but different. Every lab is similar but different. Every state has different microbial and pesticide determinations. Some are lax and others are bordering on impossible to follow. You really have to be careful about the products you use on a plant. One day it could be legal and the next day not, literally. There needs to be a standardization of COAs (certificate of authenticity).

Chip Baker

Real Estate Cannabis Compliance

Real estate and zoning for cannabis businesses is one of the biggest hurdles to overcome. Not only do states create their own zoning requirements for cannabis businesses (e.g. distance from schools, parks, etc.), land owners can restrict cannabis businesses on their land as well.

Additionally, local governments and neighborhood groups who lobby them can also implement more restrictions. Cannabis businesses often face special zoning restrictions including security, lighting, crowd control, delivery traffic, parking, and drainage.

It can be a very time consuming process planning out a building design to meet the various strict requirements set by state and local governments. In turn, cannabis compliance in real estate can become more difficult dependent on the state.

Security and Surveillance

Any potential cannabis business owner will implement some form of security and surveillance out of necessity. So while it isn’t an aspect of cannabis compliance that is likely to slip the mind, states can still set specific requirements for security and surveillance that must be met.

These requirements will almost always include cameras and some sort of ID verification at the entrance. Other requirements may be hired security at the entrance, alarm systems, and even security patrols at cannabis cultivation facilities. Luckily security is something most cannabis business owners take very seriously, which makes cannabis compliance in this regard rather easy.

However like other state requirements placed on cannabis businesses, the costs of meeting security requirements can prevent smaller businesses from complying.

Sales and Reporting

Beside the age limit placed on medical and recreational cannabis purchases, states can add additional requirements when it comes to reporting. States may require an up to date record of inventory at all times, seed to sale tracking, purchase limits for consumers and more.

It isn’t uncommon for a cannabis business to try and skirt cannabis compliance in some of these aspects, and some have paid the price for it. Sales and reporting is a major aspect of cannabis compliance that will vary by state, and should be taken seriously.

More cannabis compliance requirements

The requirements listed above may be some of the most important for any cannabis business owner, but cannabis compliance is more broad than just a few key aspects.

Taxes, consumer privacy, employee hiring and practices, health and safety are just a few more that should never be overlooked, and can vary by state. If a cannabis business operates in a state with delivery options, that adds a whole new tier of cannabis compliance that must be met as well.

Similar to any business in any industry, the larger you are the more it costs to operate. The larger you are, more difficult it will be to maintain compliance in an ever changing industry with regulatory updates happening frequently.

Owning a business is no easy task. However owning a cannabis business is a challenge many won’t be able to handle.