Cannabis Traceability �Program Design

Cannabis Traceability Program Design

Objectives:

• Understand stakeholder and operational impacts of current and proposed program designs
• Select a program design to move forward for Board consideration and public comment
• Design an updated program that provides the highest value to public safety efforts with the lowest possible impact to the industry

Why Now:

• Changes in the market and environment/lessons learned
• Technology requires updates, which necessitates clear program requirements
• Operational inefficiencies and challenges

Assumptions Used:

• Scope includes only cannabis reporting and reporting-related regulations
• Long-term technology will not be discussed until program framework is set
• Contingency technology needs will leverage current rule and law
• A change management program will be established to support the development and rollout of program modifications, if any;
• Program modifications will be organized, funded, resources, and scheduled as a project with dedicated resources

Cannabis Traceability Program Design

Process used

• Elicit program objectives from agency leadership
• Identify internal and external stakeholder groups
• Identify three most commonly cited program design options:
1. Current / highly regulated
2. Decreased reporting requirements as recommended by the majority of Traceability 2.0 participants
3. Eliminate reporting requirement in an “Audit-only” model
• Review rule and law against current reporting practices
• Review previous research, bills, and submitted stakeholder requests for changes
• Obtain limited external stakeholder feedback to inform internal direction
• Present findings and recommendations to leadership [We are here]

Cannabis Traceability Program Design

Initial Recommendation

After analyzing statutory intent, program objectives, as well as operational and industry risks, our initial program redesign would consider feasibility and approach of the following changes:

• Modify lot and batch size constraints
• Licensees would designate and report on the weight and/or piece count of lots and batches
• Specific parameters will need to be defined outside of strain, product type and harvest/production timeframe
• Representative sample will need to be redefined
• Modify unique identifier and tagging requirements
• GUIDS would only change at creation and conversion
• GUIDs for lots and batches, but not individual plants or products; tags for all
• Decentralize GUID creation using a ULID format suggested by workgroup
• WSLCB will need to determine if it will provide GUIDs to licensees that choose not to use a third-party commercial software

Cannabis Traceability Program Design

Initial Recommendation, continued

• Modify QA test reporting requirements
• Testing only required at end product state before retail
• Agency will need to determine impact of failing test at end product, define representative sample, and refine licensee recall procedures
• Modify technology controls
• Decouple reporting software from market dynamics
• Movement of product within the market would no longer be constrained by technology
• Producers, processors, labs, transporters and retailers would develop mechanisms to communicate transfers and product returns amongst themselves
• Reporting requirements would be modified slightly; however, reporting could remain within current statutory and regulatory timeframes

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Cannabis Traceability Program Design

Initial Recommendation, continued

• Modified transportation controls
• Manifests could be created from any source using state-designated required information
• WSLCB will need to determine pre-trip and mid-trip reporting requirements
• Reporting ownership would be enforced
• Those reporting on behalf of licensees, including third-party integrators and labs, must be authorized representatives of the licensee
• Reduction of licensee services
• Business and/or inventory management software would not be provided; however, licensees can report data to WSLCB directly if they so choose
• Manifests will no longer be provided
• GUIDs may not be provided

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Cannabis Traceability Program Design

What’s Next (subject to resource levels)

• Finalize proposed approach, resources and schedule
• Appoint program manager and project manager
• Proposed rule, policy and operational development effort
• Recommending new WAC that consolidates all reporting requirements
• Estimate twelve (12) month effort for rules to be amended
• Must include internal and external change management
• Once program requirements are clear and almost codified, begin technology planning

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Cannabis Traceability Program Design

Program feedback and/or questions?

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Cannabis Traceability �Technology Management

Cannabis Traceability Technology Management

Objectives (In order):

• Replace Leaf with interim central reporting system
• Procure or build long-term technology using industry standard processes
• Take time to develop program framework so that clear and consistent functional requirements can be

Why Interim System:

• Leaf is not sustainable
• Previous rushed and unfocused replacements were not successful
• New program requirements need to be firmly established before technology strategy is developed
• Central reporting solution previously built and shelved for contingency purposes can be used until long-term solution is in place

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What does the interim system look like:

• Architecture and details will be released once board approval is obtained

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Cannabis Traceability Technology Management

Effort Sequence

• Program redevelopment
• Interim solution (CRS) modification and implementation
• Long-term technology solution

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Factors Driving Effort

• Program redevelopment
• Rulemaking process
• Industry change management
• Interim solution
• Operational planning
• Budget
• Development of interfaces and reports
• Industry and integrator change management

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• Long-term technology solution
• Program development
• Authority
• Budget
• Procurement
• Internal, industry, and integrator change management

Cannabis Traceability Technology Management

Feedback and/or questions?

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