Reply To: What Are Your Thoughts on the USDA Rules

[Erik]

I confused on the testing requirements. From what I understood, the delta 9 reading isn’t necessarily considered on its own anymore I’m under the impression that they will either decarboxylate the THCa or use a formula to generate a total THC figure which will be determinative. I don’t like that at all, since there’s no way to determine how much THCa would be converted to delta 9 THC as opposed to delta 8 or THCV. I would think that’s strain dependent and can vary. I’m no geneticist, but given the wide cannabinoid differences in a myriad of strains, I would think that the THCa conversion may not be uniform across the board. Also, the .3% ceiling seems to have been a randomly selected number. I’m not aware of any data that says .3% delta 9 is functionally different than .4% or .5%. There’s simply no data. If the USDA wants to move off the delta 9 standard (decarboxylated with moisture content factored in) and move to a total Potential THC standard, then they need to raise the ceiling to 1% or so or at least allow a farmer to remediate. For a small farmer to grow even 2-5 acres of hemp, only to have to destroy it b/c the potential THC exceeds .5% – even though delta 9 THC is undetectable – is overly harsh. It will destroy the little guy.