WSDA/DOH Priorities and Needed Deliverables: Hemp in Food

What is this about?

This group is 2 months into a 5 month process to complete the Hemp in Food proviso requirements. With the end result being a final report to the Legislature on December 1, 2022 that includes recommendations for regulating and allowing hemp in food.

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Does not include draft bill language

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Feedback from last meeting:

• Timeline
• Agency feedback
• Agency resources/information need �

Timeline

• Final report to legislature December 1, 2022
• OFM/Governor policy review
• WSDA Director approval
• Group approval
• Group feedback
• WSDA drafting report – internal publications process
• Final recommendations

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Final recommendations by October 31, 2022

• Using existing sanitary requirements
• GMP for food manufacturing
• Lab testing by rule must include pesticides and mold, etc. �

WSDA & DOH feedback

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1. Realistic timelines & science available
2. Pre-packed foods vs “open dosing” or “onsite dosing”
3. Statute vs rule making �

Walking before Running

There are 5 principles we have identified for this first step into a regulatory black hole:

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1. The first step should be cannabinoids only.� Why? We have the most information about those extracts and that makes this� a good place to start from a risk perspective.

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• The first round of food types should be pre-packaged items only.� Why? This reduces risk to businesses and the consumers. Inspections and � regulation is then focused on food and beverage production rather than local� restaurant and free dosing in coffee shops, etc. A good place to start with recommendation for continued work.

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Walking before Running

3. Regulations should be in rule not statute. The regulatory agencies remain uncertain about the inclusion of numeric standards in statute. � Why? The statute is not set in stone but difficult to change. This is an evolving� area of science which makes the requirements to work within the legislative � structure difficult.

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4. Expedited rulemaking authority.� Why? The two main agency’s (WSDA and DOH) can move forward and be� nimble in addressing industry needs and concerns – example is the hemp � program since 2019.

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Walking before Running

4. Statute should include directions for GMP, sanitary standards, basic labeling (with rulemaking), laboratory testing requirements for pesticides, metals, mold (all with rulemaking).

Why? We agree with providing explicit instructions to the agency’s however� we need the ability to make changes as quickly as the science warrants it. The� last thing we all want is to work this much and end up opening a market � pathway and then having to close that market channel until the Legislature� reconvenes.

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