image_pdfimage_print

While misinformation seems like the new normal in this country, I had hoped with a strong state acceptance and strong trade association, we could quell the bad data that permeates this industry.

Alas, this week, FDACS, the Florida Department of Agriculture and Consumer Services, the state agency that will oversee enforcement of the State of Florida rules, released this statement:
 
“Good afternoon,
 
In the last week FDACS has received many calls and emails from Hemp interested parties about program details. Many of the rumors and information out there is just not accurate. Please use the “trust but verify” approach. FDACS is the best source to get information on the program.
 
Clarifications:
Permits are not limited in any part of the process.
The Program is horizontal integration. This means you can do any part of the process you want. You can do one part, a few, or all. This will be a business choice you make.
Certified Seeds per SB 1020 are seeds certified by AOSCA. https://www.aosca.org/
 
Time Line on Rules:
Food Safety Rule has been filed for adoption.
Hemp Extract (CBD intended for ingestion) incorporated into existing FS programs. Effective January 1, 2020.
Available 1/2/2020 (1/1/2020 is a holiday): Permitting, testing, and enforcement for processing, manufacturing, distributing, and retailing.
 
Feed Rule has been filed for adoption.
Hemp Extract in animal feed incorporated into existing AES programs. Effective January 1, 2020.
Available 1/2/2020 (1/1/2020 is a holiday): Permitting, testing, and enforcement for processing, manufacturing, distributing, and retailing.
 
Seed Rule will be filed for adoption in January 2020.
 
Cultivation Rule should be filed for adoption January 2020. Please note that this rule is slightly delayed due to a need to align the Florida cultivation rule with the USDA final interim rules which were released on 10/31/19. FDACS still expects cultivation to happen in the first quarter of 2020.
 
We will be updating the website next week. Please visit https://www.fdacs.gov/Cannabis/Hemp-CBD-in-Florida.”
 
The Florida Hemp Council continues to gather information from the state, academic researchers and industry leaders to give our members the most up-to-date information and the best hypothesis of the future, based on the data we receive.
 
The industry will be made up of tortoises and hares. There will be those rabbits out there that buy seeds, regardless of genetics or traceability and plant, whenever they can. They will race to be first to have plants in the ground. The risks they have are:
1. Hot plants ― Plants that test in excess of .3% total THC by equation
2. Male plants ― For those growing CBD-heavy, male plants are a loss
3. Mixed genetics ― Depending on where you buy your seeds, clean genetics is the biggest risk; we have seen as many as five different strains in 10 plants that were claimed to be the same genetics.
4. No infrastructure for fiber or in some cases, CBD extraction ― For fiber farmers, the degumming and decortication plants are not even on the radar (as far I know.) For CBD extraction, millions of dollars are on the sideline waiting on state and local support for that investment.
 
The tortoises may be late to the game, but they will be more deliberate. They will make sure that the above risk and the unknown risks are mitigated to a degree for which the rabbits are uncomfortable waiting.
 
The game will be ― can the rabbits afford the mistakes; can the tortoises wait too long and miss the race?
 
Regardless of the participants, we look forward to the race, and we hope that both the rabbits and the tortoises join The Florida Hemp Council (www.TheFLHC.org)