502 Producers & Processors: ACT NOW! Sign this Petition to the LCB!


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/ #9

2016-02-08 02:00

Need to add this stuff(see the pdf version for cleaner reading):

I would just add the following:
Inventory destruction should be carried out on case-by-case basis and only when the Department of Agriculture has confirmed that the products are contaminated and can't be cleaned.
Plant growth regulators are an essential element in our industry. We need rooting hormones to make clones.
Labeling very small 1g products with everything required by the LCB is impossible. Instead, all we need is the lot number and UBI in combination with a handout for the customer. This is what you see pharmacies do with medications, pesticide manufacturers do it, and many other industries use this method.
Selling below market price needs to be defined mathematically. The exact equation should be
P_M= (1+R_T)(P_W+P_R)
P_M=Market Price  P_W=Wholesale Price
R_T= Tax rate     P_R= Retail Markup

A real world example is as follows:
P_M=$12⁣ ⁣ and R_T= 0.37
Substituting the values in (2) in to Eq​(1) we get
$12 = (1+0.37)(P_W+P_R)
$12 = (1.37)(P_W+P_R)
($12)/1.37=P_W+P_R
$8.76=P_W+P_R
And in order to provide a living wage to farmers, we'll set P_W=P_R and we get P_W=$4.38. This will allow the LCB to look at sales records and come up with a numerical value that is determined by the market and take action to deal with illegal dumping, price gouging, etc. Currently, almost all producers are selling below market price and going out of business or else not making any profit while retailers are marking up 500% in some cases and 300% in most cases and consumers are left paying $22/g instead of $12/g.
The definition of "Licensed Premises" being extended is so vague that it would include my home where I do my paperwork, my salesman's home where he does remote work, my intern's home where he does remote learning, etc. I think the only places that we should be concerned with are the places where cannabis is located; be that a barn or car or shop.
Lab testing should be conducted by the state and paid for with cannabis tax dollars. The samples should be pulled randomly whenever a producer registers a transport manifest for an untested lot(or similar type of event like placing it in quarantine). These samples should be no more than 2g per lot. Under the current system, producers can modify samples to get any THC level they want, any CBD level they want, kill off all mold, etc.
Producers and processors should not have quarantines for anything other than bringing in new live plants. The waiting period ensures the LCB has time to come inspect and the quarantine is not needed. Instead, the retail stores should have an incoming quarantine in which the state can go take a random sample and then release the product from quarantine if it passes all the lab tests.
Lot sizes need to be increased to 100lbs, especially for outdoor tier 3 producers.
The fines and fees need to be reduced by a factor of 10. It doesn't cost $1,064 to print a business license and review an application. Fining someone $2500 because their employee forgot their badge is just a slap on the wrist for Phat Panda but could put a small grower out of business, especially during their first 3 years when they are most likely to have a lot of violations as they learn all the laws, come into compliance and when their income is very low.
The microbial analysis should distinguish between beneficial organisms and pathogens, rather than just a blanket test for all microorganisms. We use these pro-biotic organisms to out-compete pathogens.
Producers need to be allowed to sell directly to consumers either at their farm or at a nearby location in order to ensure that there is not a monopoly of retailers artificially inflating prices for consumers while low-balling farmers.
Producers need to be allowed to create payment terms such as net 30/60/90 in order to move large quantities of fresh product onto shelves rather than sitting in warehouses collecting dust.
Traceability needs to be open source so we can fix it. I'm tired of entering 16 digit barcodes in for 2500 plants every year. I can't believe they disabled the browser's ability to copy/paste. The only other option is to print the barcode onto paper and then scan it with a barcode reader or else pay Biotrack for their in-house proprietary software. I suppose one could become a software company and develop their own system with an API backend but that's a pretty unreasonable requirement.
Producers need an annual window to introduce new genetics.
Taxes should be 7 percent instead of 37 if we want to drive out the black market.
Stop using Imperial units like lbs. Nobody else is using it. We are all using Standard International measuring units like grams and ml. I'm sick and tired of converting units to satisfy the traceability's shortcomings.
We need a bank. This should be created by the state of WA and be a public resource so that all the people of WA can open accounts and do business without the instability created by the federal gov't through prohibition, depressions caused by credit default swaps, onerous fees, etc.
Samples should be done away with all together. If a store wants to let their 20 employees have a free sample, then they need to buy it and give it to them. It's a cost of doing business and it shouldn't be passed along to farmers.
All bans and moratoriums need to be repealed immediately. Medical patients can't drive 100 miles to get cannabis while they're dying of cancer. These people have a right to access cannabis under I-502 and their rights are not being honored. It will get much worse once the medical dispensaries shut down.
We need our own insurance. Right now we're being price-gouged out of business by insurance companies and being asked to store hundreds of pounds of cannabis in safes the size of what a bank would have. Why do we even need insurance on cannabis in a fire-proof safe protected by surveillance, alarms, and 8ft fences? Answer: we don't. Everyone knows cannabis is the safest product on the planet. It's safer than peanuts. Let's get real here and stop acting like we're carrying nuclear bombs around when in reality we're carrying plants.
We need the ability to take our kids to work with us on our farms. There should be an exemption for the children of licensees. It's impossible for a child to get high from a cannabis plant unless they know how to use a lighter, have a pipe, and know how to inhale. For people with edibles or concentrates, they should have it locked where the child can't encounter it.