WSLCB - Webinar - CCRS
(September 8, 2021) - Summary

WSLCB - Cannabis Central Reporting System (CCRS) - Pile of Files
[ Event Details ]

Staff provided more specifics on processes and standards for compliance reporting under the Cannabis Central Reporting System (CCRS) and responded to 50 pre-submitted questions.

Here are some observations from the Wednesday September 8th Washington State Liquor and Cannabis Board (WSLCB) Webinar on the Cannabis Central Reporting System (CCRS).

My top 3 takeaways:

  • After years of trouble with MJ Freeway, the state’s seed-to-sale traceability vendor, agency leaders proposed replacing Leaf Data Systems with an in-house Cannabis Central Reporting System (CCRS).
    • Near the end of 2017, a transition from traceability vendor BioTrackTHC to MJ Freeway---which would later become a subsidiary of Akerna---resulted in an interim period where agency staff were responsible for gathering data on transactions within the state cannabis marketplace using a so-called “Contingency Reporting System” (CRS). That system, later modified to incorporate feedback, was the basis on which the CCRS was built.
    • Chief Information Officer (CIO) Mary Mueller---who left WSLCB at the end of March 2021---led implementation of traceability and other technology projects at the agency. She co-led the Traceability 2.0 work group, organized to help the agency chart a new course away from MJ Freeway towards an approach that would be more rational and less onerous at ensuring compliance and public safety. At the most recent meeting on March 2nd, participants reviewed the agency’s findings and explored a minimal Cannabis Traceability Requirement Repository.
    • In May 2021, Mueller was succeeded as CIO by George Williams, previously the Senior Information Technology (IT) Manager. Prior to departing, Mueller secured board approval on a road map towards ending the contractual relationship with MJ Freeway by June 2022. In June 2021, staff announced the cancellation of the Integrator Work Sessions which brought together third-party software providers, WSLCB officials, and occasionally MJ Freeway representatives. The last work session was hosted in February, prior to the agency’s commitment to transition away from MJ Freeway.
    • The CCRS and an associated “communications plan” were first presented to the board on August 11th, with Board Chair David Postman stating he was “really curious what you’re hearing out there and whether it gives us any new tasks between now and December.” On August 27th, an announcement from WSLCB outlined the project and its next steps for licensees and stakeholders, including a webinar to “provide technical details for the new CCRS system, detailed information to prepare you for the launch of CCRS, and contact information for technical support.”
  • Staff introduced the system to attendees, sharing new information on the system, its operations, the testing plan, and support details.
    • Chief Financial Officer Jim Morgan said the agency was “simplifying the state’s traceability to reflect the growth and maturation of the cannabis industry” as a way to prepare “for the future.” By the end of 2021, he said the agency and the entire cannabis sector “will transition off the current Leaf Data Systems platform to a revamped, simplified, data reporting platform developed and maintained in-house” (audio - 4m).
      • Over the preceding year, Morgan explained that the traceability platform used by WSLCB had been “on a service-only contract that will terminate no later than June 30, 2022.” He said that after “careful deliberation of a variety of program models, LCB intends to simplify” cannabis licensee reporting to “key elements” covered by CCRS. Asserting that agency staff had “worked closely and collaboratively with stakeholders including producers, processors, retailers, integrators, labs, and others to identify the future state of traceability,” Morgan told attendees by the end of 2021 WSLCB staff would “deploy a simplified reporting solution” inclusive of “ideas and concepts” from stakeholders.
        • Board Chair David Postman mentioned the contribution of the  Traceability 2.0 work group to the development of CCRS during the September 1st board meeting. At the work group’s last meeting on March 2nd, staff shared their conclusion that they did not believe a revised traceability system could be achieved prior to the end of the MJ Freeway subscription services contract in June 2022 without an interim system.
      • Morgan stated definitively that CCRS constituted “a reporting system, not a traceability system, per se" to get information to the agency via uploaded comma-separated value (CSV) files. Judging by “the history of traceability in any state, system disruptions could stop business. That will no longer be the case with CCRS.” Being a "reporting system only," it would "not be integral to completing business transactions, it will merely be a...solution for reporting them."
      • The benefits of the new arrangement, Morgan offered, were:
        • Less reporting “reduces margin for error”
        • Licensees may “perceive the framework to be more flexible for operational efficiencies” and “lower costs of compliance”
        • “Select stakeholder groups” learned about “the process and CCRS concepts” in the spring of 2021, and “in general...appreciated the collaborative approach and the simplified requirements.”
        • “Users will have the opportunity along the way to ask questions and provide input” as licensees and integrators would be “needed to help with system testing set to begin later this month.”
    • Cannabis Examiner Manager Kendra Hodgson went over “why we have a reporting system,” acknowledging a continuing prohibition on cannabis under U.S. law meant “specific challenges at the federal level” for legal cannabis jurisdictions like Washington state (audio - 6m).
      • Washington law and rule gave WSLCB “expectations and authority” over “large portions of the market” like production, transportation, and product standards “connected to test results,” she established. Reporting would meet these needs for regulators and licensees, Hodgson commented, as well as “other organizations...the Economic and Revenue Forecast Council, Washington state law enforcement agencies, public health departments, and other state agencies”
      • CCRS was “being deployed” so that “LCB, licensees, and labs are still meeting the requirements to gather information and to report,” she said, and “reduce the complexities of the software and inheritance rules that were problematic in our previous solutions.” Hodgson agreed with Morgan that the CCRS would be more versatile “in accommodating different operational models” while keeping “the detail that is required,” building on “CSV file uploads” to CRS during the “contingency period” of late 2017 and early 2018. The CCRS would have “nine CSV reports that have been created,” a “Drupal webform manifest,” and was designed to enable licensees to “directly report, to assign reporting permissions to a third-party integrator, and provide their own, external, identification numbers.”
      • The webinar was not intended to “address the nuts and bolts” of reporting, Hodgson relayed. Information would be added to the CCRS webpage and support options would also be centralized there “as we prepare for the transition.” Staff planned to address some “general questions” and subsequent webinars would respond to “technical details.” She recommended that stakeholders continue submitting questions via CCRS@lcb.wa.gov.
      • In describing how CCRS would be a “reporting solution” and not  “a traceability system in the manner that’s been experienced to date,” Hodgson noted it would “not create IDs for products, and it will not have the same types of inheritance or data dependencies of previous systems.” However, CCRS would not alter requirements for on-site records retention, accurate test results, as well as plant and product tagging.
    • Jeremy Wissing, Captain of the Marijuana Unit of the Education and Enforcement Division, provided WSLCB staff expectations for licensees transitioning to CCRS. He asked licensees to continue their normal reporting methods and frequency, adding that they would be “expected to do an initial upload of records into CCRS” from either their traceability integrator or a “request can be made directly to the LCB” (audio - 3m).
      • Following that upload, Wissing stated that licensees and labs would be responsible for following “the expectations for CCRS...a much simpler process than our current reporting system.”
      • Wissing said staff “highly recommend” that labs and licensees “use this timeframe...to reconcile records so that way there is as clean of a...start as we can get to” during deployment of CCRS. A weekly reporting schedule was mandated, he observed, “but primarily what we’re looking for is reporting” whenever there were “updates and changes.” Reporting could be submitted to CCRS “on a more frequent basis” to reflect “plants, or inventory, or sales data.”
    • Wissing turned to testing which would be open to “integrators, labs, and licensees” volunteering during a pilot period focused on finding “two or three integrators...or previous labs” that had utilized an application programming interface (API) “and also have some experience testing graphical user interfaces, or GUI.” Volunteers would begin testing “on September 20th,” he said, mostly occurring “October 4th to November 4th.” Prospective volunteers should sign up at testcannabisreport@lcb.wa.gov by September 15th (audio - 2m). 
    • Wissing also reviewed ways to get support during the transition or send questions regarding compliance and regulations (audio - 2m).
  • Agency staff responded to 50 pre-submitted questions on the system during the non-interactive webinar, which evinced concerns about reasoning for the change; preparation steps; basic operations; legality and risk; support for integrators and cannabis testing labs; and transparency.
    • Hodgson claimed “a handful of questions” had been submitted, and though not all were addressed, she said “we will be working through” them via direct responses or inclusion in education resources (audio - 1m). Cannabis Observer reorganized these questions by theme.
    • Reasoning. Several respondents sought to better understand the reasoning and due diligence of agency staff in undertaking such a significant change.
      • “Why is LCB switching to CCRS?” (audio - <1m) 
        • “This has been addressed earlier in Jim’s remarks, and messaging to date” and officials would continue to “encourage a review of those communications.”
      • “Was METRC/Biotrack considered for state traceability? Is there a possibility of LCB doing [a Request for Proposals] and switching to one of those, or other systems in the future?” (audio - 1m) 
        • “The agency did consider many options and focused on keeping the solution as simple as possible while meeting our needs for regulating the system,” but staff considered any traceability solution would be “very complicated to implement and would have required securing additional funding.”
      • “Does the LCB anticipate CCRS being a long-term solution?” (audio - <1m) 
        • “Whether or not this becomes a long-term solution will depend on how well it meets the needs of the state. A potential replacement of this system would only come after careful consideration of LCB and stakeholder needs.”
    • Preparation. Questioners inquired about steps licensees should take in advance of the transition.
      • “What does the transition period between LEAF and CCRS look like? Will there be a transition period where both LEAF and CCRS are operational, how long will that period be? Will licensees be permitted to dual-report for any period of time to manage the transition?” (audio - 1m)  
        • “There likely will be a period of short overlap. Reporting functions in LEAF will likely be available but they will not replace the requirement to report in CCRS.”
      • “What support will be available for...licensees using CCRS prior to launch and post-launch?” (audio - <1m) 
      • “How can I get involved in the testing process?” (audio - <1m)
    • Operations. Quite a few questioners sought answers about the configuration and operation of the CCRS.
      • “How will licensees authenticate with the new system?” (audio - <1m)
        • “The SecureAccess Washington login will operate as the licensees’ authentication.”
      • “What [are] the expectations of licensees using CCRS?” (audio - <1m) 
      • “Does CCRS apply to all licensees including retailer[s]?” (audio - <1m) 
        • “Yes, this applies to all license types and certified marijuana labs.”
      • “The LCB had a survey of licensees, how many were using the LEAF data web interface only without a third-party software, how will they report?” (audio - <1m) 
        • They would “report directly to LCB via their SecureAccess Washington login.”
      • “Will there be a direct entry web interface as well, or will this specifically be manual, one-off drop box type submission?” (audio - <1m)
      • “Will price data be included for wholesale and retail sales activity?” (audio - <1m) 
        • “Yes, the user guide will explain which of the CSV reports are required to be filled out by different license types and where sales data is to be reported.”
      • “Will the LCB be providing any cloud storage to facilitate digital transfer of data between licensees?” (audio - <1m) 
        • “At this time there’s no intention of providing this service.”
      • “How will folks who are not using a third-party software create or update manifests?” (audio - <1m) 
        • “The Drupal webform manifest will send an email with a detail that can be printed and used for the required physical transportation manifest.”
      • “When can we expect the updated transport manifest form?” (audio - <1m)
        • “The Drupal webform manifest, the specific system and reporting, will launch at the same time the CCRS reports launch. The combination of the two are the requirements for reporting.”
        • Problems producing manifest reports was a significant issue in the last traceability transition.
      • “Will there be a fixed list of inventory types or a broad equivalence in categories?” (audio - <1m) 
        • “The information for this particular question can be found in the resources that will be available later on the CCRS landing page and on the specific reporting submittals in the detail on the data fields.”
      • “Will LCB require usage of globally unique identifiers, GUIDs, to identify products and if so can we utilize the ULID standard as recommended by the Traceability 2.0 group?” (audio - 2m) 
        • “The CCRS reports and LCB will not be generating the IDs. Licensees will need to utilize a solid inventory tracking methodology to assign IDs to their inventory and provide the ID, titled the external identifier, when reporting via the CCRS reports. It is recommended that, where possible, to continue utilizing the existing ID structures for simplicity in transition.”
        • The submitted question notes: “The Traceability 2.0 work group recommended that GUIDs not be used or issued by a central service, but generated dynamically using an approved algorithm by a third-party software providers. Agency staff reviewed the universally unique lexicographically...sortable identifier (ULID) algorithm and specification suggested by the work group subcommittee which convened in November 2019.”
      • “Will partial batches require unique identifiers, example: sublotting multiple companies, or will batch identifiers be permitted to exist at multiple locations?” (audio - <1m)  
        • “Batches are not part of the CCRS data model. Unique identifiers will be required for each inventory and plant record being reported” and were “specific to the licensee reporting them.”
    • Legality and Risk. Several questioners expressed concerns about how the RCW and WAC encode traceability requirements, and whether usage of the CCRS would meet those requirements.
      • “Will LCB staff undertake rulemaking to update the WAC prior to CCRS launch?” (audio - <1m) 
        • “The core of the reporting requirements do not change in the CCRS model. There might be some minor clarifications made to how current WAC applies to CCRS but significant rule changes are not planned for this project.”
      • “In the absence of intent to update the WAC, please explain how shifting to the CCRS will not place licensees in jeopardy of violation of Washington State law and administrative law.” (audio - 1m) 
        • “The core of the reporting requirements, the existing WAC requirements for record retention, and requirements to report to LCB cover the WAC language that already exists. Every system used to date by LCB has had the same inherent requirement for licensees to report to be in compliance. The underlying concepts of reporting remain the same.”
      • “Will there be a redefinition of the concept of ‘failure to maintain traceability,’ or what it means to maintain compliance given these significant change[s]?” (audio - <1m)  
        • The move to CCRS “did not change the underlying concept that reporting is required and that accurate reporting and records maintenance is expected.”
      • “Currently, imported [cannabidiol] CBD materials are required to be entered into the system. Will that still be the case?” (audio - <1m) 
        • “Yes, imported CBD is required to have all the necessary tests to allow it to be added to marijuana and it retains the records and reporting requirements required currently.”
        • During rulemaking implementing HB 2334, the imported CBD law from 2018, the requirement to document imported CBD in Leaf Data Systems was never achieved. That requirement was suspended by the board in 2019 via an interim policy which remained in effect at publication time.
      • “In WAC 314-55-089, it states that the act of keeping data completely up-to-date in the state traceability system fulfills the monthly reporting requirement regarding taxes, will that still be the case, or will there be a new process?” (audio - 2m) 
        • “Reporting requirements have not changed...the statement regarding” the cited rule “specially sub[sections] (2) and sub (3) are specific to marijuana producers and processors” as they did not “have a tax obligation to LCB and the finance, tax, and fee group is not collecting reports from this group of licensees. Producers and processors should contact their enforcement officer if they have any questions regarding how to report on this particular information. To be fully compliant with the LCB, licensed marijuana retailers are required to report using the form that is already available….And pay by the tax due date, their monthly sales tax and information. The retail licensee is required to submit a report to the LCB each month even if they did not have sales completed. Per WAC 314-55-092(2), failure to make a report and/or pay will be sufficient grounds for the LCB to suspend or revoke a license.”
      • “Will there be explicit rules on what can be transported between licensees?” (audio - <1m)  
        • “There are no changes to licensee permissions by licensee type, and no changes in the types of products that can be transported between licensees.”
      • “Will there be explicit rules on conversion from one type to another? How will these be enforced?” (audio - <1m) 
        • “Rules on valid conversions have not changed, CCRS however will not enforce conversions by the system architecture. The enforcement of said conversions will be based on the detail reported to LCB and follow up conversations between licensees and their Enforcement Officer or Compliance Consultant.”
      • “Will the agency support a legislative change to eliminate the application and renewal fee added to fund the switch to traceability when we moved to MJ Freeway as the vendor?” (audio - 1m) 
        • In October 2020, Traceability 2.0 work group members were told “lawmakers passed Senate Bill 5130 in 2017 to add a nonrefundable additional fee of $480 assessed by LCB during...license renewals through June 2018, and that was to be used for the replacement of the board's traceability system...The bill also stipulated that beginning in July 2018 a general purpose $300 fee was added to all cannabis license renewals, raising their cost from $1000 to $1300 per year.”
        • This was the last of the pre-submitted questions by Traceability 2.0 Work Group members, and was worded a bit differently than Hodgson relayed. Members asked if agency staff would “support industry legislation to ask legislators to rescind” the fee. Hodgson’s answer seemed clear that the agency wouldn’t pursue rescinding the fee, but remained vague on how staff would respond to a change pushed by sector representatives.
    • Data Migration. Several respondents sought to better understand the scope of data required in the CCRS, and the mechanics of migrating that information to the agency.
      • “What will happen to data currently in LEAF? Will data be converted and retained in CCRS?” (audio - <1m)
        • “No, the user guide...will have information on how to do the initial upload,” with WSLCB staff getting “a final backup provided before the final decommission.”
      • “Is there any expectations for license holders to submit historical data to CCRS?” (audio - <1m)
        • Following the initial upload, “required reports” would be “from the point of the upload forward.” 
      • “In preparing for transition, what data covering what time frame period should licensees retrieve?” (audio - <1m) 
        • “Licensees will have more than one report that will need to be completed at the initial upload. The reports themselves will dictate what information the licensee will be responsible for providing.”
      • “In preparing for the transition does reconciling data mean doing a full and accurate data correction in existing point of sale systems?” (audio - 1m)
        • “The agency does...recommend reconciling the data against what has already been reported to LEAF. For licensees that utilize a point of sale integration software, really, the level and the amount of reconciliation work would be dependent on the amount of records already currently on file.”
    • Integrators. Many questions were specific to the concerns of third-party software providers.
      • “When will messaging go out with technical details to integrators?” (audio - <1m) and “When will integrators get technical documentation?” (audio - <1m)  
        • “The error messages and data model specification guides will be available on the CCRS webpage later today and additional communications will be determined on an as-needed basis.”
      • “Is three months enough time for all integrators to transition their systems and migrate all their clients to the new system?” (audio - <1m) 
        • “With the simplicity of the process being developed we believe that three months is sufficient for integrators to prepare their systems.”
      • “How will an integrator access the system to send or review data?” (audio - <1m)
        • A user guide “will have instructions on how an integrator would access” CCRS but such access was predicated upon “a licensee providing permissions to a specific integrator to report on their behalf.”
      • “Will CCRS allow integrators to use an API?” (audio - <1m) 
        • “No, there is no API involved with this particular solution.”
      • “Will there be [a] public comment period for the technical specification of CCRS? Will the LCB incorporate suggestions from experienced Washington state technology vendors?” (audio - 1m) 
        • “The technical specifications have already been determined...your feedback is always welcome, but unless there are items in our solution that would prevent reports from being submitted there will not be major changes on feedback before the release.”
      • “Is there technology powering CCRS? Is there a technical consulting company building it that integrators can work with to ensure a smooth experience for licensees?” (audio - <1m) 
        • “No, there is not an external vendor working on” CCRS.
      • “Does CCRS provide an integration sandbox for integrators to develop against? If so, is the sandbox data shared by all integrators or can they use it independently?” (audio - <1m) 
        • “No, there is not an API for this solution. The SecureAccess Washington will be the authentication to the portal for the CSV report uploads.”
      • “Will integrators have access to a CCRS database, on a per-license basis, for the purpose of activating accounts, restoring data, viewing historical data, reconciling and fixing reports?” (audio - 1m) 
        • “Integrators will not have direct database access, licensees will need to assign permissions to integrators to assist on reporting on their behalf...if the licensee has assigned permissions” to an integrator, they would “be able to insert, update, and delete information, as allowed, for individual data fields. Integrators will be assigned a specific ID and will need to utilize SecureAccess Washington to authenticate and report on behalf of a licensee.”
      • “CSV is a known antipattern in the data...interchange interoperability realm, since the LCB is defining data specification, can we use modern, circa 2001, structured format?” (audio - <1m) 
        • “At this time, submissions are only for the CSV format.”
        • A Traceability 2.0 Work Group member suggested usage of JavaScript Object Notation (JSON) for this purpose.
      • “Will LCB staff restart regularly scheduled integrator work sessions?” (audio - <1m)  
        • “Reoccurring integrator work meetings will not be scheduled but occasional technical work sessions may be set up for labs, licensees, and integrators.”
    • Cannabis Testing Laboratories. Several questions addressed the needs of lab staff and the future of testing data encoded as certificates of analysis (COAs).
      • “Will labs still be required to report their information to this system within 24 hours?” (audio - <1m) 
        • “Reporting requirements have not changed. It is recommended that labs utilize the CSV report as a per certificate of analysis submittal for reporting” but this was “a recommendation only, not a requirement.”
      • “Will the labs need to provide certificate of analysis (COA) documents to the LCB? Physical? In a digital form? Provided as links?” (audio - <1m) 
        • “Labs are required to provide the test results to LCB via the reports established for that purpose. Record maintenance and access remain the same for both the labs and licensees. No changes have been made on the requirement to produce the records if...requested by LCB.”
      • “Will there be a GUI for labs using the portal?” (audio - <1m)
        • “Labs will be assigned a lab ID and will have information that is specific to their function to report.” These reports would “also be through the SecureAccess Washington CSV upload.”
      • “How will...lab results be tracked for retail products?” (audio - <1m) 
        • “Record requirements have not changed, licensees are still required to provide the supporting documentation for all products sold at retail. Reports are being built against the CCRS data submitted for LCB’s use in reviewing test results.”
    • Transparency. Questions about licensee and public visibility into traceability and compliance data were raised.
      • “Will CCRS allow medical consumers to find medically compliant product as the original traceability system allowed?” (audio - <1m)  
        • “No, this is a reporting system, not an inventory management system.”
      • “Will licensees be able to access analytics from CCRS?” (audio - <1m)
        • “Licensees will still be able to request information via public records, and if there’s a third-party integrator who’s built analytics, that may be available to them, but there will not be analytics published at the launch of CCRS.”
      • “Can the LCB make a copy of the entire LEAF database available once it is turned off, similar to public records request, but with the full export?” (audio - <1m) 
        • “Public records requests will be managed as normal, a full publish of the entire backup is not in alignment with certain types of data restrictions, but there will be a final backup that will be available, as is currently, for data requests and public records requests.”
      • “Can we get access to all the CCRS data, including products sold, in order to assess trends, or will that data at least be public for sales figures by license, similar to what we can access currently?” (audio - <1m) 
        • “Public records requests and reports will follow the standard process that is already in place and there will be some information that is not disclosable, depending on the type of data itself.”
      • “The [Traceability 2.0 Work Group] has not met since early 2021 and this proposal did not include their feedback, is the traceability work group no longer being consulted?” (audio - 1m) 
        • “The group...was convened to discuss concepts about the future of traceability. Those concepts may find their way into future discussions and are still at play. For the purposes of the CCRS project, the timeline involved, and the model being implemented, not all of those concepts...fall within the project’s scope.”
      • “The proposed CCRS system does not appear that it will be able to catch anomalies that had been previously identified in regards to the conversation on both delta-8[-tetrahydrocannabinol (THC)], delta-9, and the abundance of facilities producing massive amounts of those items. Will this...still allow industry or the public to identify that those exploits, the loophole in both the federal and state laws that paved the way for the practice of created THCs from unregulated sources?” (audio - 1m)  
        • “The content response answer is that LCB reports will be built to assist the agency in its work related to the regulation. The system will not be the same as the previous, but meets the requirements for reporting that have been identified” in law and rule. “Audit-based work will likely be a tool that will be applied by the agency in new ways going forward.”

Information Set