Events were wrapping up for the holidays, but the transition to CCRS would keep the cannabis sector busier than usual checking lists twice before the shutdown of MJ Freeway on Saturday.
Here’s a look at cannabis-related policymaking events on the calendar in the week ahead.
Monday December 13th
At publication time, no cannabis-related policymaking events were scheduled.
Tuesday December 14th
WSDA - Work Group - Pesticide Penalties
On Tuesday at 9am PT, the Washington State Department of Agriculture (WSDA) Pesticide Penalties Work Group was scheduled to convene.
- [ Event Details, Rulemaking Project ]
- The work group first convened on November 23rd and had originally planned to convene again on November 30th. Following the initial meeting, participants requested more time to provide substantive feedback.
- During the first meeting, participants introduced themselves; heard background on the rulemaking effort; reviewed “other state’s rules and matrices, for a comparison”; and considered a “WSDA proposal for a ‘Base’ penalty concept for human exposure & other violations.”
- On Tuesday, participants would discuss “changes/edits on the proposed draft rule language.”
WSLCB - Board Caucus
On Tuesday at 10am PT, the weekly Washington State Liquor and Cannabis Board (WSLCB) Board Caucus was scheduled to recur.
- [ Event Details ]
- This would be the last scheduled public meeting of the WSLCB board in 2021. The board would next convene in caucus on January 4th, 2022.
Wednesday December 15th
At publication time, no cannabis-related policymaking events were scheduled.
Thursday December 16th
At publication time, no cannabis-related policymaking events were scheduled.
Friday December 17th
DOH - RFI 26607 - Answers Due
On Friday, responses from staff at the Washington State Department of Health (DOH) about efforts to re-procure a medical cannabis patient registration system were expected.
- [ RFI 26607 ]
- Shortly after the October 21st presentation by DOH to Washington State House Commerce and Gaming Committee (WA House COG) members which featured some information derived from the registered patient database, agency staff published a new request for information (RFI) to begin the process of re-procuring the medical cannabis patient registration system.
- Following receipt and “To the extent possible, answers will be consolidated and answered in an Amendment to this RFI that is published on the Department’s website and on WEBS on or about December 17, 2021.”
Saturday December 18th
Decommissioning of MJ Freeway Leaf Data Systems
On Saturday at 8am PT, MJ Freeway Leaf Data Systems was scheduled to be shut down in Washington state.
- In the late morning last Monday, December 6th, WSLCB staff launched the Cannabis Central Reporting System (CCRS) heralding the beginning of a new era of cannabis data reporting for compliance purposes. At publication time, the CCRS remained operational.
- Licensees were responsible for uploading an initial inventory snapshot by Sunday December 13th followed by weekly reporting (with some exceptions), where weekly was subsequently defined as “no later than Sunday for the previous week.”
- WAC 314-55-102(2)(a)(ii) states that cannabis testing labs “must report quality assurance test results directly to the WSLCB traceability system when quality assurance tests for the field of testing are required within twenty-four hours of completion of the test(s).” The necessity of this rule in a post-realtime traceability regime was unclear, as the failure of required tests had been previously regarded as an opportunity for regulators to halt product from further movement within the cannabis sector via a realtime traceability system.
- The CCRS appears to implicitly require the prior upload of record dependencies, though perhaps not consistently. For example, a lab test result is associated with a particular product - but if the maker of that product has not uploaded their data to CCRS before the lab attempts to do so, the lab result upload may fail. As the labs are under a time constraint to perform many of their uploads, this arrangement may force efforts to coordinate reporting within the sector.
- If other inter-record dependencies are enforced with no attempts at post-upload reconciliation, the Sunday reporting deadline would likely result in many failed uploads if licensees or their software integrators wait until Sunday to report.
- On Wednesday December 8th, Chief Financial Officer (CFO) and executive project sponsor Jim Morgan provided an update on the CCRS rollout to agency leadership during the monthly Executive Management Team (EMT) meeting.
- Morgan said although the system “is performing as designed...it’s not time for a victory lap,” acknowledging that a more meaningful measure of success could be taken once “the industry is fully engaged, and fully involved, and successfully using the system.” He reported that 612 licensees had logged into CCRS “as of this morning,” or “about a third,” many of whom were authorizing their software providers.
- In addition to temporarily assigning more staff to the project to help with support requests, Director of Licensing Becky Smith mentioned that “we certainly couldn’t have expected the number of phone calls that we’re getting” and Director of Communications Brian Smith said collaborating with other divisions on the reporting system was “my number one priority at the moment.”
- Morgan hadn’t seen any “show stoppers...putting the brakes on the entire industry,” but noted that, “as expected, the manifest issue, going from completely automated to a more manual system is one of the issues that we’re hearing about.” He indicated that the requirement to use a wholly separate interface to generate manifests for transfer of cannabis products was one of the “hot topics” they aimed to solve “as soon as the dust settles from the initial go live.”
- WAC 314-55-085 specifies transportation rules which create reporting deadlines “Upon transporting any marijuana or marijuana product” requiring that “a producer, processor, retailer, or certified third-party testing lab shall notify the WSLCB of the type and amount and/or weight of marijuana and/or marijuana products being transported, the name of transporter, information about the transporting vehicle, times of departure and expected delivery.”
- At publication time, the Washington Cannabis Integrators Alliance (WCIA) was developing a proposal which would mitigate the manual manifesting issue by enabling reporting of this information in the same manner and using the same CCRS infrastructure as the other comma-separated value (CSV) files asked for by the agency.
- On Saturday at 8am, agency staff intended to ask MJ Freeway to decommission the Washington-specific version of Leaf Data Systems, drawing a contentious vendor relationship to a close.
- The CCRS Quick Start Guide indicated, “When Leaf is decommissioned, the state will receive the system’s final output.”
- At publication time, stock in the parent company of MJ Freeway, Akerna Corporation ($KERN), was trading at an all-time low slightly above $2 per share.