HEMP
RULE ALERT

– Comments Closed –  

Our CEO – Josh Schneider, Meeting with the USDA

Please help our group convince the USDA to make substantive changes to the hemp program rules. Our suggested changes will provide clarification for farmers, state regulators and downstream processors to help move the hemp industry forward.   Additionally it will make the program much friendlier for small and medium-sized farmers.  Read below to learn more about how you can help.

Cultivaris Hemp believes that active engagement in the political and rule-making process is critical to protect our industry and establish a strong foundation for both food and fiber hemp as well as high cannabinoid hemp.

Our own Josh Schneider, CEO and Co-Founder of Cultivaris Hemp has been in Washington DC meeting with USDA and members of Congress to help build support for changes in the rules.  He and the policy team have worked hard to develop a list of what it is possible to change. What we found at our time in DC with hours of meetings on Capitol Hill and with USDA was that very little scientific justification in their rules. We aim to provide science-based direction to guide future rulemaking. The goal is to get an adjustment to the rules as quickly as possible to provide some predictability for the coming season.

If you need more information please don’t hesitate to email us at hemprule@cultivarishemp.com

The deadline for submitting public comments on USDA’s Interim Final Rule on Domestic Hemp Production is on January 29th, 2020, at 11:59pm ET.  Comments may be submitted online at https://www.regulations.gov/comment?D=AMS-SC-19-0042-0001 and may either be uploaded to the site as a PDF or Word file, or copied and pasted into the text window provided on the site.

So far about 2113 comments have been submitted; it is critical that the Department receive as many unique and substantive comments as possible.

PUBLIC COMMENTS MATTER!  Even though the interim rule has already been made effective, USDA must still finalize it before it becomes permanent, and they are required to take into account—and respond to—all substantive comments submitted by the public.

Comments need not be lengthy, or beautifully written.  But in order to be taken into account, they must be substantive, unique (no form letters), and clearly state how the rule directly impacts the commenter’s personal and/or business interests.  These are the key points a comment should cover:

  • Identify a specific issue, topic or provision in the rule, state how it impacts you directly, and suggest an alternative that would better serve or protect your interests.

  • Identify credentials and experience that support your position. If you are commenting in an area in which you have relevant personal or professional experience (i.e., scientist, attorney, farmer, distributor, retailer, etc.), say so.

  • Support your position with specific examples from your personal experience: how does the rule impact you or your business?  What specific costs, burdens or missed opportunities result?

  • It certainly helps if you also have concrete information about the rule’s impacts to others in your community or field of business, but with just ( Comments Closed ) to submit it’s fine to skip the research paper and simply write from your own experience.  That is ultimately the most powerful story to tell.

Please find below our policy memo discussing the rule’s impacts on hemp producers, and a comment being submitted by an individual farm that is experiencing significant impacts relating to the issues raised in the memo as an example to guide your writing.  While commenters are free to repeat some of the same arguments, it is important that all commenters indicate in their own words how the rule specifically impacts them and their business. Feel free to copy specific language from the policy memo and insert it into your document under your suggestions for change.

View Meristem-Cutlivaris-HempExchange Policy Memo on USDA hemp rule.pdf

We have also posted here PDFs of the academic papers that are footnoted in our policy document.  You are free to use these to gather further information. It is also helpful for you to spread the word about the comments as widely as you can.  

View Orser 2019.pdf
View Dussy et al 2004.pdf
View Taschwer and Schmid 2015.pdf
View Iffland et al 2016 (EIHA decarboxylation paper).pdf
View Small and Cronquist 1976.pdf