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


Guest

#1

2016-02-07 08:17

I agree with all the points made. I believe for Washington state to have a pliable market the creators of these companies need to have a strong voice in the rule making process as we want to keep our state prosperous and the companies involved prosperous.

Guest

#2

2016-02-07 13:13

The destruction of property provision for small administrative infractions is outrageous. Cannabis cultivation is now a legal, state-sanctioned, highly taxed enterprise in Washington. The State shouldn't develop a framework for encouraging legal cultivation and then massively punish people who attempt to participate simply because they might misunderstand the application of one or more of these vague and confusing rules.

Guest

#3

2016-02-07 17:13

I agree with the items presented here. The are real problems which are unfair and and unwieldy I also agree with the remedies suggested

Guest

#4

2016-02-07 17:48

I believe that the LCB has been charged with the extremely difficult task of establishing rules and regulations to govern an industry which has never existed before in our State's history. I think they have been mandated to perform this task with inadequate funding and less than clear direction from the Legislature.

I further believe that to date the process to develop these rules and regulations has been seriously flawed as it does not include the input from ALL stakeholders. What may seem like a logical approach from a Legislator's, Retailer's or Laboratory's perspective, may and does in fact create undue hardship on the Farmer. What may seem like a good idea to a large Farmer, may not work so well for the small operation. What may work for Farmers, may not work for one of the other groups.

In closing, I would urge the Board to reconsider the proposed rule changes and to do so with input from an industry advisory
group(s) representing all stakeholders.

Guest

#5

2016-02-07 19:09

I would also like to see the canopy limits lifted with out of state money entering the industry as a teir 1 I'll now have access to more capital which I'll need more canopy to be able to compete


Guest

#6

2016-02-07 20:03

While I am sure the LCB was good intentioned, these are incredibly important issues raised as some of the proposed rules create more problems than they are solving. I am sure that by the licensed producers and processors working with the LCB, we can help avoid issues before they are raised.

Guest

#7

2016-02-07 22:57

Im struggling to the point of it effecting the roof over me head and the toll on my health. Everytime I find a way to make ends meet to be 100 compliant all I spent and the hard work was for nothing. I have to try and beat myself up all over again. I did this 502 to be legal not to be treated in such a criminal manner and work my fingers to the bone making nothing at 59 yrs old with ms and glucoma. I spend most days unable to walk from the physical labor and stress the constant rule changes for a small farmer placed upon me. This was to help me take care of my kids and let me retire in my old age. It has aged me 20 yrs.

Guest

#8

2016-02-08 00:43

Over regulation kills more business opportunities at a very high rate.

Guest

#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.


Guest

#10

2016-02-08 02:10

Oh, and some other laws need to be fixed which currently say "Cannabis is not an agricultural product", "Cannabis farmers aren't farmers", "Medical cannabis isn't medicine"


Guest

#11 Self-Serving Objectives

2016-02-08 02:18

My personal self-serving Objectives for the members of the newly appointed WSLCB Cannabis taskforce:

  1. Pinpoint advantageous features and detrimental challenges, Washington industry stakeholders face
  2. Encourage transparent critical decision making with the best interests of Washington's industry at the forefront
  3. Mentor all industry stakeholders, fairly, equitably, and in good faith encourage each and every cannabis farmer to experiment, research and develop state of the art equipment, standard operating procedures and best practice management practices with tax exemption for any expenditure, labor, purchases or design of equipment, method, and practices that utilize emerging technology or advances common industry goals
  4. Present new WSLCB strategies for increasing preciseness of records and accurately regulation of the emerging industry, with anonymous informative reports to our residents, tourists, and potential investors and businesses considering relocation to Washington State; while maintaining the protection of trade secrets, trade names, and personal confidentiality while in exemplary compliance with the DOJ eight priorities of 2013 Cole memo
  5. Adopt cutting edge global information tracking and accounting technology for agency monitoring of production, sales, transportation, QC/AC, and genetics to ensure unbiased and accurate statewide transparent, yet anonymous reporting thereof
  6. Induce intrastate capitalization by encouraging with grants, interest income tax exemption, and regulatory assistance for all main stem banking institutions serving the I-502 industry in Washington State
  7. Induce intrastate capitalization of the I-502 Industry with Washington State issued low or exempt interest rates for entities participating in research, on the job training, genetic footprinting, and value added project *development* revenue bonds
  8. Forge Strategic Alliances with Independent and University Education and Research departments worldwide
  9. Keep all WSLCB regulations simple and costs to produce I-502 governed cannabis cheap,
  10. Encourage state of the art quality control, organic, quantatative experiential growth, and objective unbiased education for consumers and to educate industry stakeholders; while maintaining the integrity of a highly regulated and closely monitored industry for the purpose of statewide economic high return on investment.
  11. Ensure highly regulated and steady production of natural unadulterated, QA/QC internally and independently tested, taxed cannabis, with provisions for WSLCB agency scaling up production as needed or desired, based on recreational and medical demand, for the protection and preservation of genetic diversity of Washington State strains and universally at risk landrace strains, or any other desirable traits of the cannabis plant genome known today, or which in the future is becomes desirable or contains any desirable trait to serve the diverse and various needs of tourists, residents of Washington State, and researchers at all corners and locations on this green earth.

Guest

#12 Wish list

2016-02-08 04:32

We need the following to comply with current LCB requirements:
1. High-speed internet (e.g. 1Gbps fiber) to our rural farms to provide internet accessible IP camera systems. The private sector can't or won't provide adequate bandwidth to rural WA. Of course the elementary school nearby has fiber and lots of dark fiber but they're not sharing thanks to exclusive licensing agreements with private companies. Of course there's more fiber a few hundred feet away from the farm but screw you farmers you ain't getting connected because we won't make enough money off you.
2. 5TB USB 3.0 or eSATA external hard drives provided by the LCB any time they request 45 days of video from our 1080p cameras. One hard drive per camera they are requesting data for.
3. Compensation for time working for the LCB (e.g. copying data for several days, 2 hrs of being inspected, data entry into biotrack, etc).

Guest

#13

2016-02-08 04:43

LCB is out of control!

Guest

#14 Re: Self-Serving Objectives

2016-02-08 04:49

#11: - Self-Serving Objectives 

 

Dude wtf are you talking about? You sound silly when you talk like that.
OB1

#15 Re:

2016-02-08 04:58

#13: - LCB is out of control!  

Yes, lots of people are reporting difficulty with their agents and compliance. I'd like to see us change from being adversaries to being friends and working together to stop bad practices and shut down the black market. That is all, young padawan. MTFBWY

Guest

#16

2016-02-08 16:43

The Liquor and Cannabis Board needs guidance from the cannabis community of small business people. We are birthing a new industry based upon a extremely wide-spread and prolific plant that has been cultivated since the dawn of time and we need to step thoughtfully into the regulated future. Making regulation favorable to small business in WA will set our state up for a unique identity that helps to build up our middle class and employ our citizens locally. We, the producers and processors need to lead this effort as informed professionals to ensure the future of not only a prosperous business climate but a healthy industry for many to thrive and benefit from.

Guest

#17

2016-02-08 17:15

Support of small and medium size growers.

Guest

#18

2016-02-08 17:51

I am in strong favor of points made in this petition. There are of course many other issues impacting the farmers across the state, but this is a great start in getting some dialogue started between the LCB and the growers.  I don't feel the LCB is our enemey here, we just need them to hear the voices of the average farmers. We undeniably do the most work for this industry yet make the least for our work. Overregulation and too few access points have created an almost impossible environment for small and medium business. 


Guest

#19

2016-02-08 18:45

This petition is legally solid and aims to prevent some irresponsible regulatory practices. We can't let our new industry be open to corruption or monopolization. Please check this out and sign, for the responsible and safe development of our 502 system. Thank You!

Guest

#20

2016-02-08 20:11

I agree with everything except F,G,H, and J.

Guest

#21

2016-02-08 20:45

to protect my business rights and support the state budget
Cannabis Farmer Tier 2

#22 Re:

2016-02-08 21:32

#4: -  

 I second this statement


Guest

#23

2016-02-08 21:47

The sample sizes should increase, not decrease. With multiple harvests per month, more samples are needed due to new tested lots and new products available. Also there are different types of products i.e. hash, pre-rolls, flower, edbles, etc.
Employee information and records are to remain confidential. It is not needed information.

Guest

#24

2016-02-08 23:31

I agree with most points but feel it would be better heard if we stick to the most important ones.

Guest

#25

2016-02-08 23:33

yes, I agree we should be sending samples to each puchasing vender with each test lot. but how much is really needed by the vender?