James Moe: Hemp policy must protect consumers

I am writing to express my to state — Senate Bill 235 (Allen) and Assembly Bill 45 (Aguiar-Curry) — unless amended.

I believe it is critical that any prospective hemp legislation protects the integrity of both hemp and cannabis products, and where they intersect. hemp policy must protect consumer health and safety, and accurately delineate the ways in which hemp is both similar to and distinct from THC cannabis.

As written, SB 235 and AB 45 pose substantial risks to public health and the integrity of the legal cannabis framework. I believe the following amendments are essential to addressing major gaps within the current hemp framework:

1) Prohibit all hemp derived THC and its analogs such as Delta 8, Delta 10. Explicitly prohibit Delta-9 THC and its psychoactive analogs (such as Delta 8, Delta 10) in final form hemp products beyond trace amounts. Additional authority should be given to regulators to determine and restrict other intoxicating cannabinoids with properties similar to Delta-9 THC.

2) Limit THC to 0.1mg and clarify that the practice of marketing the permissible THC content in hemp products should be banned to avoid opportunistic and misleading product claims.

3) Hemp and cannabis should be tested in full parity: final form product level rather than the raw extract level. Hemp and cannabis products should be subject to the same contaminant thresholds in perpetuity. Parity in batch size limitations and representative sampling requirements.

4) Allow hemp-derived cannabinoid products to be distributed and sold by cannabis operators.

5) Cannabinoid content must be listed in milligrams directly on the product label.

Respectfully, I will continue to oppose until all of these amendments are addressed.

James Moe

Grass Valley

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