The Week Ahead
(December 6, 2021)

CCRS Groundhog Day

The Cannabis Central Reporting System (CCRS) was scheduled for launch on Monday amidst a week of important rulemaking at WSLCB and WSDA.

Here’s a look at cannabis-related policymaking events on the calendar in the week ahead.

Monday December 6th

WSLCB - CCRS Launch

On Monday, the Washington State Liquor and Cannabis Board (WSLCB) planned to launch the Cannabis Central Reporting System (CCRS).

  • Some unknown proportion of cannabis licensees, third-party software providers, testing laboratories, WSLCB staff, and board members could be said to be collectively holding their breaths in the hopes that the highly anticipated launch of the CCRS reporting platform on Monday morning---along with corresponding revisions to software platforms used by most licensees and labs---were executed smoothly enough for business to continue into the holidays without significant disruption or modification of processes. After months of preparation and communication, WSLCB staff planned to open their production CCRS server for one-way reporting sometime on Monday morning.
  • See the CCRS FAQ and CCRS resources screen for help documents including:
  • The first public mention of the intention of WSLCB staff to end the contract with MJ Freeway/Akerna for the provision of Leaf Data Systems occurred during the August 11th Executive Management Team (EMT) meeting when the executive sponsor of the project, Chief Financial Officer (CFO) Jim Morgan, provided a briefing on the communications plan staff planned to follow in the months ahead.
  • WSLCB staff published their most recent guidance on Friday December 3rd regarding the “Leaf Decommission and CCRS Expectations,” indicating, “Beginning Dec. 6, all licensees will be expected to begin reporting through CCRS. Reporting in Leaf data systems will not meet the reporting requirement for licensees beginning Dec. 6.” The announcement went on to clarify that, “Leaf will be shut off and no longer available to licensees after 8 a.m. on Dec. 18.”
    • While WSLCB staff negotiated terms with MJ Freeway which granted the agency the option to extend their contract with the vendor through June 2022---an option which an informal alliance of software integrators encouraged the agency to exercise---agency staff steadfastly and without explanation opted to end the contract in December.
  • WSLCB Policy and Rules Staff also published more formal guidance on Friday December 3rd in the form of a policy statement on “Security and Traceability Requirements for Marijuana [Cannabis] Licensees.” This published statement of agency policy indicated:
    • “Under the CCRS system, ‘up-to-date’ means a weekly report of the required information if there have been updates, changes or actions to any of the information described in WAC 314- 55-083(4)(a) through (p).”
    • “The CCRS system will not be generating unique identifiers; these will have to be generated by licensees. Under the CCRS system, all marijuana, usable marijuana, marijuana infused products, marijuana concentrates, seeds, plant tissue, clone lots, and marijuana waste must be physically tagged with the unique identifier reported to the traceability system.”
    • “All other traceability reporting requirements such as manifests, lab results, and co-ops remain the same consistent with existing rule.”
  • Finally, WSLCB staff sent a follow up “Clarification” regarding a “Known CCRS Bug” detailed in the message broadcast on Friday. The clarification can be interpreted to encompass many of the concerns various parties had going into this new era of compliance reporting.
    • The clarification, sent by WSLCB Communications staff a little more than an hour after the initial broadcast, recast the “Bug” as a “Known CCRS Issue.” It’s Cannabis Observer’s understanding that all communications to the ccrs@lcb.wa.gov account have first been handled by the agency public relations team.
    • The “Issue” explanation detailed how a workaround would be necessary for all clients interacting with the CCRS to upload required comma-separated value (CSV) files. The guidance instructed, “Licensees and integrators should not use commas and quotations in their .csv file submissions,” indicating that WSLCB staff had not utilized a standard library for CSV processing and had instead implemented their own non-standard approach to a protocol defined in 2005.
    • The clarification went on to say, “A Change Request will be drafted and presented to the Steering Committee for discussion and decision for inclusion in a future release.” It’s Cannabis Observer’s understanding that the referenced Steering Committee was composed of WSLCB staff and offered no voluntary transparency into its deliberations. The committee made the decision to proceed with the launch on November 16th.
  • While there will always be things to criticize about the history of seed-to-sale traceability in Washington state, we here at Cannabis Observer have done what we can to help mitigate the worst potential outcomes and have witnessed many software integrators collaborating together to make things work. While the general sentiment in the cannabis sector can be said to resemble the mood that pervades the film “Groundhog Day,” we remain hopeful that we’ll muddle through like we always do. As any incipient crises are abated, the sector can then turn to deciding what the future of cannabis data sharing and automation between businesses will be given the diminished role of the State in facilitating those transactions.

Tuesday December 7th

WSLCB - Board Caucus

On Tuesday at 10am PT, the weekly WSLCB Board Caucus was scheduled to recur.

WSDA - Public Hearing - Hemp Processor Registration

On Tuesday at 10am PT, the Washington State Department of Agriculture (WSDA) planned to host a public hearing on the Hemp Processor Registration rulemaking project.

  • [ Event Details, Rulemaking Project ]
  • On July 20th, WSDA staff initiated rulemaking on Hemp Extract Certification following the passage and signing of SB 5372 (“Concerning hemp processor registration and a hemp extract certification"). The initial rulemaking project was undertaken by the WSDA Food Safety Division.
  • On September 15th, WSDA Hemp Program staff initiated a separate rulemaking project to support voluntary registration of hemp processors more generally. On November 2nd, a CR-102 was filed which proposed amendments to hemp rules in WAC 16-306 to outline “the process for hemp processors to voluntarily register with the department, including specifying the information required on the registration application as well as the registration fee.”
    • The registration fee in the proposed rules was $1200 and good for three years.
  • Following the public hearing, WSDA staff anticipated filing a CR-103 on December 14th, and the new rules would become effective on January 14th, 2022.

DOE - Cannabis Science Task Force Steering Committee

On Tuesday at 1pm PT, the Washington State Department of Ecology (DOE) Cannabis Science Task Force (CSTF) Steering Committee planned to convene.

  • [ Event Details ]
  • The CSTF Steering Committee last convened on October 25th.
  • On Tuesday, the committee was scheduled to hear work group updates and motions; check on the status of their next legislative report; and review preparations to sunset the task force.

Wednesday December 8th

WSLCB - Board Meeting

On Wednesday at 10am PT, the bi-weekly WSLCB Board Meeting was scheduled to recur.

  • [ Event Details ]
  • The board last met to undertake formal rulemaking on November 10th. Members cancelled their last board meeting scheduled for November 24th, and would likely cancel their subsequent meeting scheduled for December 22nd.
  • On Wednesday, board members were scheduled to approve filing proposed rules on the Quality Control (QC) Testing and Product Requirements rulemaking project. The proposal should incorporate findings from and include a small business economic impact statement (SBEIS) undertaken by agency contractor Industrial Economics, Incorporated (IEc).
  • Board members were also scheduled to host a public hearing on the Tetrahydrocannabinol (THC) rulemaking project. The proposed rules would add definitions and “establish a procedure for the board to evaluate additives, solvents, ingredients or compounds used in the production of marijuana products, as those products are defined in chapter 69.50 RCW.” Elaborating on authorities granted by the Washington State Legislature in 2020 via HB 2826 following the E-VALI health scare and initially implemented that fall, the board would consider additional rules to “prohibit the use of any additive, solvent, ingredient or compound in the production of marijuana products that may pose a risk to public health or youth access.”
  • In addition to the public hearing, all board meetings provide an opportunity for general public comment at the end via Microsoft Teams. If you wish to speak to the Board during a public hearing or general public comments, please e-mail dustin.dickson@lcb.wa.gov before that agenda item on the day of the meeting, but preferably by close-of-business on Tuesday December 7th. Mr. Dickson will provide additional instructions including a link to connect to Teams through your computer or device. Comments are limited to four minutes per person.

WSLCB - Executive Management Team

On Wednesday at 1:30pm PT, the three-member Board and agency leadership were scheduled to convene their monthly WSLCB Executive Management Team (EMT) meeting.

Thursday December 9th

At publication time, no cannabis-related policymaking events were scheduled.

Friday December 10th

At publication time, no cannabis-related policymaking events were scheduled.